Open Program Reviews: How the Department Is Reducing Delays and Burdens
The U.S. Department of Education’s office of Federal Student Aid (FSA) has released a communication to institutions currently undergoing a program review, reaffirming both the continuity of the review process and the Department’s efforts to reduce institutional burden amid a period of workforce restructuring.
This announcement signals a positive shift in how FSA intends to engage with institutions going forward. While the statutory responsibility to complete Title IV compliance reviews remains unchanged, the Department is taking tangible steps to make the process more efficient and transparent.
What Institutions Need to Know
1. Streamlined Case Management:
FSA has confirmed that despite recent internal changes, program reviews are continuing without disruption. A designated analyst will be assigned to assess each institution’s case, review submitted materials, and coordinate a collaborative meeting to work toward resolution. This one-on-one engagement model represents a more personalized approach that is likely to enhance clarity and efficiency.
2. Standardization of Document Submission:
Institutions are now directed to submit all responses and supporting documentation through the Common Origination and Disbursement (COD) Document Center, even if those materials were previously submitted via email or SharePoint. This consolidation of submission channels aims to reduce confusion and ensure all documentation is tracked consistently. If documents have already been submitted through COD, no further action is required.
3. Backlog Acknowledgment and Acceleration:
The Department has openly acknowledged the existing backlog and is prioritizing the completion of reviews. By focusing on process improvements and targeted communication, the agency is working to close cases more efficiently—an important development for institutions waiting on resolution.
4. Emphasis on Record Retention Compliance:
FSA also reminds institutions of their obligations under 34 C.F.R. § 668.24(e)(1), (2) to retain program records for the required period. This reminder underscores the importance of maintaining strong administrative processes to support compliance throughout and beyond the review period.
Why This Matters
In recent years, many institutions have expressed concerns about the administrative burden tied to program reviews and the lack of clarity around timelines and expectations. FSA’s communication is a promising signal that the agency is listening and taking action. By simplifying documentation procedures and increasing transparency, the Department is offering institutions a more navigable path through an often complex process.
Institutions with active program reviews should take this opportunity to reassess their documentation practices and ensure all relevant materials have been uploaded to COD. Doing so will help accelerate review timelines and support the Department’s efforts to close cases efficiently.
Final Thoughts
The Department’s renewed focus on streamlining the program review process is a welcome development, but navigating the details and ensuring full compliance still requires time, expertise, and proactive planning. Institutions often face challenges not only in gathering and submitting documentation, but also in understanding the broader implications of findings, maintaining internal controls, and responding strategically.
This is where JH Strategic Group can provide critical support. Our retainer services are specifically designed to help institutions with quick questions on demand with one-on-one support from former Federal Student Aid employees. With our deep subject matter expertise in Title IV regulations and hands-on experience supporting institutions through audits and reviews, we can serve as an extension of your compliance team.
Whether your institution is in the early stages of a review, awaiting resolution, or simply wants to ensure future readiness, partnering with JH Strategic Group offers the peace of mind that comes with having a trusted advisor on call.
Reach out to discuss how our ongoing support services can help your institution meet regulatory expectations while reducing internal strain, so your team can stay focused on serving students.
