The Results Act: Observations on the Department of Education's June 1997
Draft Strategic Plan (Correspondence, 07/18/97, GAO/HEHS-97-176R).

Pursuant to a congressional request, GAO reviewed the Department of
Education's draft strategic plan required by the Government Performance
and Results Act of 1993 (the Results Act).

GAO noted that: (1) overall, the Department's draft plan is a useful
document and includes almost all the elements required by the Results
Act; (2) the plan's long-term goals and objectives are succinct and
logically linked to its mission statement; (3) the quality of the goals
and objectives reflects the Department's thoughtful deliberation in its
efforts to comply with the Results Act; (4) the department's draft
strategic plan includes information that the agency will use to develop
its annual performance plan; (5) although this information was not
required, it illustrates the Department's preliminary thinking on
performance measures and targets; (6) the draft strategic plan addresses
in some form all of the Department's major statutory responsibilities;
(7) GAO's review of the department's draft plan indicates, however, that
the plan could benefit from more information, clarity, and context in
some of is components; (8) specifically, the plan should include an
explanation of the relationship between its long-term goals and
objectives and its annual performance goals as well as a complete
description and schedule of program evaluations in accordance with the
Results Act; (9) the plan could also better address the Department's
major statutory responsibilities; (10) for example, the plan's long-term
goals and objectives do not address the Department's responsibilities
for enforcing and monitoring civil rights related to education, an
activity identified by the Department as a key agency function; (11) in
addition, the narrative supporting the department's mission statement
does not address the Department's major statutory responsibilities for
basic education for adults, vocational rehabilitation, education of
individuals with disabilities, or school-to-work opportunities; (12) the
Department's plan would be improved if it provided a context for
stakeholders by discussing in more detail the management challenges the
Department faces, since such problems could affect its ability to
fulfill certain goals; and (13) on the basis of GAO's past work, GAO
believes that the Department does not have the data systems necessary to
complement two of its objectives related to ensuring sound information
technology investments and financial integrity.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  HEHS-97-176R
     TITLE:  The Results Act: Observations on the Department of 
             Education's June 1997 Draft Strategic Plan
      DATE:  07/18/97
   SUBJECT:  Agency missions
             Strategic planning
             Congressional/executive relations
             Interagency relations
             Program evaluation
             Special education
             Civil rights
             Adult education
             Management information systems
             Vocational rehabilitation
IDENTIFIER:  Dept. of Education Central Automated Processing System
             Dept. of Education Easy Access for Students and 
             Institutions Project
             Dept. of Education National Student Loan Data System
             Federal Family Education Loan Program
             William D. Ford Federal Direct Loan Program
             
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Cover
================================================================ COVER



September 1997


GAO/HEHS-97-176R

Education's Draft Strategic Plan

(104895)


Abbreviations
=============================================================== ABBREV

  BOP - Federal Bureau of Prisons
  CFO - Chief Financial Officers
  DEA - Drug Enforcement Administration
  DOJ - Department of Justice
  EASI - Easy Access for Students and Institutions
  EDCAPS - ABC
  FBI - Federal Bureau of Investigation
  FDLP - Federal Direct Loan Program
  FFELP - Federal Family Education Loan Program
  GMRA - Government Management Reform Act of 1994
  HEA - Higher Education Act
  HHS - Department of Health and Human Services
  INS - Immigration and Naturalization Service
  IPOS - Institutional Participation and Oversight Service
  NPR - National Performance Review
  NSLDS - National Student Loan Data System
  OIG - Office of the Inspector General
  OMB - Office of Management and Budget

Letter
=============================================================== LETTER


B-277444

July 18, 1997

The Honorable Richard K.  Armey
Majority Leader
House of Representatives

The Honorable John R.  Kasich
Chairman, Committee on the Budget
House of Representatives

The Honorable Dan Burton
Chairman, Committee on
 Government Reform and Oversight
House of Representatives

The Honorable Bob Livingston
Chairman, Committee on Appropriations
House of Representatives

Subject:  The Results Act:  Observations on the Department of
Education's June 1997 Draft Strategic Plan

On June 12, 1997, you asked us to review the draft strategic plans
submitted by the cabinet departments and selected major agencies for
consultation with the Congress as required by the Government
Performance and Results Act of 1993 (the Results Act).  This letter
is our response to that request concerning the Department of
Education. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :1

Our overall objective was to review and evaluate the latest available
version of the Department's draft strategic plan for fiscal years
1998-2002.  As you requested, we (1) reviewed the draft plan to
determine whether it complies with the Results Act's requirements and
assessed its strengths and weaknesses; (2) described the Department's
key statutory authorities and how they are related to the mission and
goals in the strategic plan; (3) identified the Department's
programs, activities, and functions that are crosscutting in that
they are similar to or related to goals, activities, or functions of
other agencies and the extent to which the plan reflects interagency
coordination; (4) discussed the extent to which the Department
addresses major management challenges in the plan; and (5) discussed
the Department's capacity to provide reliable information about
performance. 

We obtained the June 17, 1997, draft strategic plan that the
Department provided the House of Representatives congressional staff
team working with the agency.  As agreed with your offices, our
assessment of the Department's draft plan was generally based on our
knowledge of the Department's operations and programs, our numerous
reviews of the Department, and other existing information available
at the time of our assessment.  Specifically, the criterion we used
to determine whether the Department's draft strategic plan complies
with the requirements of the Results Act was the Results Act itself,
supplemented by the Office of Management and Budget's (OMB) guidance
on developing the plans (Circular A-11, part 2).  To make judgments
about the overall quality of the plan and its components, we used our
May 1997 guidance for congressional review of the plans
(GAO/GGD-10.1.16) as a tool.  To determine whether the plan contains
information on interagency coordination, and to address management
problems we had previously identified, we relied on our general
knowledge of the Department's operations and programs and the results
of our previous reports.  A list of our major products related to
Department operations and programs appears at the end of this letter. 

It is important to recognize that the Department's final strategic
plan is not due to the Congress and OMB until September 30, 1997. 
Furthermore, in passing the Results Act, the Congress anticipated
that several planning cycles might be needed to perfect the process
of developing a strategic plan and that the plan would continually be
refined.  Thus, our comments reflect a "snapshot" of the status of
the plan at this time.  We recognize that developing a strategic plan
is a dynamic process and that the Department is continuing work to
revise the draft with input from OMB, congressional staff, and other
stakeholders. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Created in 1980, the Department administers approximately 200
programs and supports activities that involve two major kinds of
educational institutions:  (1) elementary and secondary schools and
(2) postsecondary institutions.  With a staff of about 4,600 in
fiscal year 1997 and a budget of about $29 billion, the
Department--in partnership with other federal, state, and local
entities--manages the federal investment in education and leads the
nation's long-term effort to improve the quality of education. 
Specifically, the Department awards grants to education agencies and
institutions to strengthen teaching and learning; makes student loans
and grants available to students and their families to help pay the
costs of postsecondary education; monitors and enforces civil rights
to ensure that the nation's education system is accessible and fair
for all students; supports education research, development,
evaluation, and information dissemination; and provides leadership in
support of national educational priorities. 

The Department prepared a strategic plan in 1994 and, on the basis of
its discussions with many internal and several external parties, has
revised this plan to reflect the requirements of the Results Act. 
The Results Act requires agency strategic plans to include the
following six key elements: 

  -- a comprehensive mission statement covering the major functions
     and operations of the agency,

  -- a description of general goals and objectives for the major
     functions and operations of the agency,

  -- a discussion of how these goals and objectives will be achieved
     and the resources needed,

  -- a description of the relationship between performance goals in
     the annual performance plan and general goals and objectives in
     the strategic plan,

  -- a discussion of key factors external to the agency that could
     affect significantly the achievement of the general goals and
     objectives, and

  -- a description of program evaluations used to develop the plan
     and a schedule for future evaluations. 

The Results Act is aimed at improving program performance.  It
requires that federal agencies consult with the Congress and other
stakeholders in developing their strategic plans.  It also requires
that agencies establish long-term strategic goals as well as annual
goals that are linked to them.  These annual goals are to appear in a
performance plan that the agencies must prepare each year and submit
to the Congress beginning in February 1998.  Agencies must then
measure their performance against the goals they have set and report
publicly, in subsequent years, on how well they are doing.  In
addition to ongoing performance monitoring, agencies are expected to
perform discrete evaluation studies of their programs and to use
information obtained from these evaluations to improve their
programs. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :3

Overall, the Department's draft plan is a useful document and
includes almost all the elements required by the Results Act.  The
plan's long-term goals and objectives are succinct and logically
linked to its mission statement.  Further, the quality of the goals
and objectives reflects the Department's thoughtful deliberation in
its efforts to comply with the Results Act.  Moreover, the
Department's draft strategic plan includes information that the
agency will use to develop its annual performance plan.  Although
this information was not required, it illustrates the Department's
preliminary thinking on performance measures and targets.  In
addition, the draft strategic plan addresses in some form all of the
Department's major statutory responsibilities.  (See encl.  I.)

Our review of the Department's draft plan indicates, however, that
the plan could benefit from more information, clarity, and context in
some of its components.  Specifically, the plan should include an
explanation of the relationship between its long-term goals and
objectives and its annual performance goals as well as a complete
description and schedule of program evaluations in accordance with
the Results Act.  The plan could also better address the Department's
major statutory responsibilities.  For example, the plan's long-term
goals and objectives do not address the Department's responsibilities
for enforcing and monitoring civil rights related to education--an
activity identified by the Department as a key agency function.  In
addition, the narrative supporting the Department's mission statement
does not address the Department's major statutory responsibilities
for basic education for adults, vocational rehabilitation, education
of individuals with disabilities, or school-to-work opportunities. 
The Department's plan would be improved if it provided a context for
stakeholders by discussing in more detail the management challenges
the Department faces, since such problems could affect its ability to
fulfill certain goals.  On the basis of our past work, we believe
that the Department does not have the data systems necessary to
implement two of its objectives related to ensuring sound information
technology investments and financial integrity. 


   THE DEPARTMENT'S DRAFT
   STRATEGIC PLAN CONTAINS MOST
   ELEMENTS REQUIRED BY THE
   RESULTS ACT
------------------------------------------------------------ Letter :4

Overall, the Department's draft plan generally complies with the
Results Act.  The plan includes all but one of the six elements
required by the Results Act--it does not discuss how the agency's
long-term goals and objectives will be related to its annual
performance goals.  Although the plan presents a logical and fairly
complete description of how the Department intends to achieve its
mission, a few areas in the draft plan could be improved. 

The basic framework for the Department's strategic plan is provided
by its mission, goals, and objectives as shown in figure 1. 
Following is our analysis of each of the plan's major components. 

   Figure 1:  U.S.  Department of
   Education Framework for
   Strategic Plan Goals and
   Objectives as of June 17, 1997

   (See figure in printed
   edition.)


      MISSION STATEMENT
---------------------------------------------------------- Letter :4.1

According to OMB Circular A-11, the mission statement in a strategic
plan should be brief, defining the basic purpose of the agency, with
particular focus on its core programs and activities.  We have found
that high-quality mission statements often explain why the agency
exists, what it does, and how it performs its work. 

The Department's stated mission in its strategic plan is "to ensure
equal access to education and to promote educational excellence
throughout the nation." The Department's mission statement clearly
and briefly explains why the agency exists and, in conjunction with
supporting narrative, explains what the agency does and how it
performs its work.  For example, the plan states that the
Department's key functions include providing education leadership,
financing, and information as well as access to a fair education
system through the enforcement and monitoring of civil rights.  The
supporting narrative also emphasizes the Department's partnerships
with individuals and public and private entities to fulfill its
mission.  However, the mission statement with its supporting
narrative does not address all of the Department's major statutory
responsibilities as required by the Results Act.  A more complete
discussion of this issue appears later in this letter. 


      GOALS AND OBJECTIVES
---------------------------------------------------------- Letter :4.2

The Department's draft strategic plan contains the following four
goals: 

1.  Help all students reach challenging academic standards. 

2.  Build a solid foundation for learning. 

3.  Ensure access to postsecondary education and lifelong learning. 

4.  Make the Department a high-performance organization by focusing
on results, service quality, and customer satisfaction. 

These four broad goals are a positive attempt to define results that
the Department expects to achieve from most of its major activities. 
The first three goals generally address the Department's
mission-related functions, the last one indicates a desire to
institutionalize good management practices, and all four appear to be
logically related to the Department's mission. 

Overall, the objectives developed to support the goals are generally
linked to the goals and are results oriented.  Some of the objectives
supporting these goals seem to be ambitious, given the Department's
limited sphere of control in the education arena.  However, the plan
explains that through leadership and leverage the Department works
with a host of partners, such as states, schools, and financial
institutions, to carry out its mission and effect changes intended to
improve the nation's educational system.  Thus, even though the
Department has little direct control over the conditions that would
ensure attainment of its goals, it seems appropriate for the
Department to base its performance on achieving broad objectives,
such as the four listed below that relate to its first goal--"help
all students reach challenging academic standards": 

1.3 Schools are safe, disciplined, and drug-free. 

1.4 A talented and dedicated teacher is in every classroom in
America. 

1.5 Families and communities are fully involved with schools and
education. 

1.7 Schools use advanced technology for all students and teachers to
improve education. 


      STRATEGIES TO ACHIEVE GOALS
      AND OBJECTIVES
---------------------------------------------------------- Letter :4.3

Under the Results Act, the plan should include the strategies an
agency will use to achieve its goals and objectives.  The strategies
should briefly describe the operational processes, staff skills, and
technologies, as well as the human, capital, information, and other
resources needed.  OMB Circular A-11 states that this section of an
agency's strategic plan should also outline the process for
communicating goals and objectives throughout the agency and
assigning accountability to managers and staff for the achievement of
objectives. 

Overall, the Department's draft strategic plan outlines the various
strategies needed to achieve its goals and the links between goals
and objectives.  In the core strategies section following the
explanation of each of the Department's objectives, the Department
explains how it plans to achieve these objectives and at several
points indicates resource needs as required by the Results Act.  For
example, the Department's draft strategic plan lists five core
strategies for ensuring access to postsecondary education (goal 3)
through information dissemination and support services (objective
3.2).  One of these strategies is providing information on the
benefits, academic requirements, and financial costs of higher
education to middle-school students, especially those from low-income
families.  Another strategy involves the Department's providing
incentives and guidance for increased coordination between elementary
and secondary schools and postsecondary institutions to ensure that
students are ready for college. 

The Department identifies some of its resource requirements
throughout the plan.  Narrative describing the core strategies for
several different objectives indicates that, to implement some of its
goals and objectives, the Department will need to

  -- provide employees with the technology to respond effectively to
     customer requests for information and better manage agency
     programs,

  -- redesign Department computer systems,

  -- develop benchmarks and performance standards in certain program
     areas to measure performance, and

  -- train staff in financial management and performance measurement. 

The Department's draft strategic plan also does a good job of
describing how plan goals will be communicated throughout the agency. 
At the end of the plan's introduction, the Department states that the
draft plan will be a discussion topic at an upcoming Labor/Management
Partnership conference.  In addition, the Acting Deputy Secretary and
Acting Under Secretary will hold meetings with headquarters staff at
each of the Department's five buildings in Washington, D.C., and make
special arrangements with regional staff to discuss the draft plan. 
This information and the narrative supporting objective 4.7--to
become fully a performance-driven agency--further indicate that the
Department intends to involve all levels of the agency (senior
leadership, program managers, and line staff) in the development or
achievement of plan goals and objectives, which will ensure that the
goals and objectives are known and understood within the agency. 

In addition, the Department's draft plan outlines the following three
strategies for holding managers accountable for achieving objectives: 
(1) provide a report card on overall agency performance as well as on
individual program offices, (2) redesign the agency's performance
appraisal system to align employee goals with the overall mission of
the Department, and (3) assess whether the redesigned appraisal
system is effective in promoting desired employee performance and
development. 


      RELATING LONG-TERM GOALS AND
      OBJECTIVES TO ANNUAL
      PERFORMANCE GOALS
---------------------------------------------------------- Letter :4.4

The Results Act requires agencies to prepare performance plans each
fiscal year beginning with plans for the fiscal year 1999 budget. 
Performance goals and performance indicators in an annual performance
plan should be linked to the long-term goals and objectives in the
agency's strategic plan.  According to OMB Circular A-11, the
strategic plan should briefly outline (1) the type, nature, and scope
of the performance goals in the annual plan; (2) the relationship
between the annual performance goals and the strategic goals; and (3)
the relevance and use of annual goals in helping to determine the
achievement of the strategic goals. 

The Department did not discuss in its draft strategic plan the
relationship between its strategic plan goals and those to be
included in its annual performance plan but indicated in the draft
that this section would be completed once its annual plan has been
prepared. 

The Department did, however, provide a preview of its annual plan by
means of a matrix of performance indicators, data sources, and
baseline data for each strategic plan objective supporting its
long-term strategic goals.  According to the Department, these
indicators and data sources will become the basis for its annual
performance plan.  Although this type of information is not required,
it is a positive step toward articulating how the Department will
measure its progress. 

We recognize that the Department is in the process of developing its
annual plan and that the performance indicators listed in its current
strategic plan may change.  However, we did identify several areas in
which we believe the Department could improve its conceptualization
and presentation of this information.  First, what the Department
described as "indicators" were in some instances more like targets,
performance objectives, or strategies.  For example, indicator 55 is
stated in the draft plan as follows: 

     "Bilingual education and special education resources focus on
     improving the skills of school staff working with special
     populations."

This indicator appears to be more a strategy than a performance
measure.  Further refinement of the Department's indicators could
ensure that they are understandable measures of progress toward
specific performance goals.  Second, the set of indicators related to
certain objectives does not seem to fully address the objective, thus
making achievement of an objective difficult to determine.  For
example, to ensure that every state has a school-to-work system that
increases student achievement and broadens career opportunities
(objective 1.2), the Department cited only one results-oriented
(rather than process-oriented) indicator.  This indicator--an
increase each year in the percentage of students involved in
school-to-work programs who complete high school and begin
postsecondary education--does not encompass other desired outcomes,
such as employment for those not entering postsecondary education. 


      KEY EXTERNAL FACTORS
---------------------------------------------------------- Letter :4.5

In its draft strategic plan, the Department describes in general the
factors outside the agency's program scope and responsibilities that
could negatively affect its ability to achieve its strategic goals as
required by the Results Act.  Although these factors were not
explicitly linked to a particular goal in accordance with OMB
Circular A-11, the draft plan does describe how certain external
factors could affect the various entities and individuals involved in
the nation's education system which, in turn, could affect the
Department's programs, activities, and resources.  For example, the
Department's efforts to improve the quality of teachers will,
according to its draft plan, depend on the willingness of school
systems to invest in staff professional development over the long
term.  Similarly, a decline in state and local school tax revenue
could affect the ability of local school districts to serve growing
school enrollments and implement needed education reforms. 

This section of the Department's plan could be strengthened by
including a brief discussion of actions the Department could take to
mitigate the external factors that could possibly affect achievement
of its agency goals.  For example, the Department could describe how
it can use its leadership to encourage employers to participate in
school-to-work partnerships.  It could also outline any information
campaigns or program incentives that may help to change some of the
attitudes and behaviors the plan cites as external factors. 


      PROGRAM EVALUATIONS
---------------------------------------------------------- Letter :4.6

To comply with the Results Act, agencies are required to include in
their strategic plans a description of the program evaluations used
to establish or revise their long-term goals and objectives and a
schedule for future evaluations.  The Department's plan did not
completely address this element.  The Department states in the plan
that it will provide detailed descriptions of supporting evaluations
once it has consulted with the Congress, completed the strategic
plan, and agreed on performance indicators. 

The draft plan indicates the Department's commitment to using
evaluations as a basis for its results-based activities.  The draft
lists evaluations and strategies that the Department intends to use
to develop sound performance measures, such as the National
Evaluation of the School-to-Work Program and customer surveys
supporting an evaluation of one of the federal student loan programs. 
According to the draft, the Department's Planning and Evaluation
Service is coordinating agency evaluation activities, and the Office
of the Inspector General (OIG) plans to conduct reviews of the
quality and reliability of the Department's performance measures. 
All this information will be useful to the stakeholders and
congressional teams who will review the Department's plan.  However,
the Department's strategic plan does not describe the evaluations. 
To fulfill the Results Act requirements for this element, OMB
Circular A-11 requires the plan to (1) identify specifically
evaluations and studies that are ongoing and those that are being
planned, (2) describe each evaluation used to develop the plan, and
(3) provide a schedule for future program evaluations. 


   THE DEPARTMENT ADDRESSES ALL OF
   ITS MAJOR STATUTORY
   RESPONSIBILITIES IN ITS DRAFT
   STRATEGIC PLAN
------------------------------------------------------------ Letter :5

The Department's strategic plan addresses in some way all of its
major statutory responsibilities and is consistent with the relevant
statutes.  The Department's civil rights enforcement and monitoring
are reflected in the mission statement but not in the long-term goals
or objectives; several other major functions are reflected in the
objectives supporting the goals but are not clearly outlined in the
mission statement.  Three of the four goals in the draft strategic
plan reflect specific statutory responsibilities of the Department,
and the fourth goal reflects one of the purposes of the Results Act. 

We identified the following areas of major statutory responsibility
for the Department:  (1) strengthening and improvement of elementary
and secondary schools; (2) national education reform; (3)
school-to-work opportunities; (4) basic education for adults; (5)
higher education resources and student assistance; (6) vocational
education; (7) vocational rehabilitation and other rehabilitation
services; (8) education of individuals with disabilities; (9)
education research and improvement; (10) education statistics; and
(11) monitoring and enforcing civil rights.  (A list of the statutes
that authorize the Department's major responsibilities is included in
encl.  I.)

The Results Act requires that a strategic plan indicate an agency's
major functions in the mission statement and include goals and
objectives for the major functions of the agency.  Although the
Department's mission statement includes "monitoring and enforcement
of civil rights to ensure that the U.S.  education system is
accessible and fair for all students" as a major function, none of
the goals or objectives included in the draft plan focuses on this
function, and the Department does not elaborate on it further in any
other part of the plan. 

The mission statement (including its supporting narrative) does not
include several major functions that are addressed in the
Department's long-term goals and objectives.  The Department's
statutory responsibilities related to basic education for adults,
vocational rehabilitation, education of individuals with
disabilities, and school-to-work opportunities are addressed in the
Department's long-term strategic goals and objectives but are not
included in the mission statement. 

The Department should address specifically its civil rights
responsibility in the plan's goals and objectives and include the
omitted key functions with its mission statement.  This should help
stakeholders better understand the full scope of the Department's
mission and its performance goals and objectives. 

Three of the four goals in the Department's strategic plan reflect
statutory responsibilities.  Goal 1--to "help all students reach
challenging academic standards"--reflects a declared goal of the
Goals 2000:  Educate America Act (20 U.S.C.  ï¿½ 5812(3)(A)).  Goals 2
and 3--to "build a solid foundation for learning" and "ensure access
to postsecondary education and lifelong learning"--reflect the
overall purpose of several of the Department's major statutory
authorities.  The fourth goal--to "make (the Department) a
high-performance organization"--is not based on a specific statutory
responsibility of the Department but, rather, reflects one of the
purposes of the Results Act itself. 


   THE DEPARTMENT'S DRAFT
   STRATEGIC PLAN IDENTIFIES KEY
   INTERAGENCY ACTIVITIES EXCEPT
   THOSE AFFECTING POSTSECONDARY
   PROGRAMS
------------------------------------------------------------ Letter :6

Although the Department has the primary responsibility for
implementing federal education policy and programs, several other
federal agencies also provide education-related programs and
services.  For example, the Departments of Labor and Veterans'
Affairs administer employment training programs and award student aid
to finance postsecondary study, respectively.  We have identified in
our past work opportunities for consolidating programs in certain
areas, such as job training and early childhood education, to
eliminate inappropriate duplication.\1 Specifically, we identified 90
early childhood programs being administered by 11 federal agencies
and 20 offices in fiscal years 1992 and 1993.  In addition, we found
that the federal government administered 163 employment training
programs, spread over 15 agencies, in fiscal year 1995.  However,
until such programs are consolidated, coordination will be key to
ensure that similar programs administered by different agencies work
in tandem to provide needed services. 

The Department's draft strategic plan has done a good job of
identifying crosscutting program activities in elementary and
secondary programs.  For example, it clearly identifies the need to
work with (1) the Departments of Health and Human Services (HHS),
Housing and Urban Development, Justice, and Transportation; the
President's Crime Prevention Council; and the Office of National Drug
Control Policy for the Safe and Drug-Free Schools program; (2) the
Department of Labor for the School-to-Work program; and (3) the
Department of Agriculture and HHS for preschool programs. 

However, the plan does not identify or discuss activities for
postsecondary programs that require coordination.  The Higher
Education Act (HEA) of 1965, as amended, requires the Department to
coordinate with the Social Security Administration to verify the
social security numbers of students who apply for federal student aid
(20 U.S.C.  1091(p)).  The act also requires or authorizes a number
of activities that call for the Department to coordinate with several
other federal entities for specific purposes (see table 1). 



                                Table 1
                
                  Selected Requirements in the Higher
                   Education Act of 1965, as Amended,
                Providing for Interaction Among Agencies

                                                Purpose for
                        Higher Education Act    interagency
Agency                  of 1965, as amended     coordination
----------------------  ----------------------  ----------------------
Department of the       20 U.S.C. 1077a         To consult on setting
Treasury                                        student loan interest
                                                rates

Internal Revenue        20 U.S.C. 1087e         To obtain adjusted
Service                                         gross income and other
                                                tax information on
                                                borrowers for
                                                repayment of federal
                                                direct student loans

Immigration and         20 U.S.C. 1091(g)       To perform data
Naturalization Service                          matches verifying
                                                immigration status to
                                                help ensure student
                                                aid applicants are
                                                eligible for federal
                                                aid

Selective Service       20 U.S.C. 1091(n)       To perform data
                                                matches that help
                                                ensure student aid
                                                applicants are
                                                registered for
                                                military service

Advisory Committee on   20 U.S.C. 1098          To advise the
Student Financial                               Secretary of Education
Assistance                                      on student financial
                                                aid matters
----------------------------------------------------------------------
By discussing these agencies and activities involved with the
Department's higher education programs in its strategic plan, the
Department can provide the Congress a more complete picture of the
scope of the agency's coordination activities. 


--------------------
\1 Early Childhood Programs:  Multiple Programs and Overlapping
Target Groups (GAO/HEHS-95-4FS, Oct.  31, 1994); Multiple Teacher
Training Programs:  Information on Budgets, Services, and Target
Groups (GAO/HEHS-95-71FS, Feb.  22, 1995); Multiple Employment
Training Programs:  Information Crosswalk on 163 Employment Training
Programs (GAO/HEHS-95-85FS, Feb.  14, 1995); and Department of
Education:  Information on Consolidation Opportunities and Student
Aid (GAO/T-HEHS-95-130, Apr.  6, 1995). 


   THE DEPARTMENT'S DRAFT
   STRATEGIC PLAN IDENTIFIES
   SEVERAL MANAGEMENT CHALLENGES
------------------------------------------------------------ Letter :7

In its discussion of core strategies for achieving its strategic
goals and objectives and in appendix B of the strategic plan (which
outlines performance indicators, baseline data, and data sources),
the Department identifies several management challenges it will face
in the coming years, but it provides little detail about these
challenges and how it will meet them.  This type of information could
help the Department and its stakeholders identify major management
problems that could impede the Department's efforts to achieve its
goals and objectives.  Further, stakeholders could benefit from
knowing what the Department has done, is doing, or plans to do to
address such problems. 

These challenges generally fall into three categories:  (1) ensuring
that qualified staff and high-quality information systems are
available to manage programs and provide information and technical
assistance, (2) improving Department processes to ensure agencywide
and program-specific financial accountability, and (3) improving
oversight of postsecondary institutions. 

Over the past 5 years, we have reported on major management
challenges that the Department faces in carrying out its mission.  In
response to our work and the work of others--including the
Department's OIG--the Department has undertaken efforts to
reorganize, reform, and reengineer its overall mission-related
management approach.  The Department's draft strategic plan suggests,
however, that more remains to be done. 


      ENSURING THAT QUALIFIED
      STAFF AND HIGH-QUALITY
      INFORMATION SYSTEMS ARE
      AVAILABLE TO MANAGE PROGRAMS
      AND PROVIDE INFORMATION AND
      TECHNICAL ASSISTANCE
---------------------------------------------------------- Letter :7.1

The Department's draft strategic plan indicates that the agency views
as a significant challenge having the appropriate systems, processes,
and staff it needs to support managerial decision-making and assist
its customers.  Objectives supporting goal 4--to make the Department
a high-performance organization--relate to the agency's emphasis on
addressing this challenge.  In a 1993 report in which we examined
management problems at the Department, we identified shortages of
technically qualified staff as a major problem with the agency that
contributed to management problems in the financial and information
areas.\2 According to the Department's draft strategic plan, some of
these problems still exist today.  The draft plan indicates that
Department managers lack the necessary knowledge, skills, and
abilities in financial management and performance measure development
that will allow the agency to manage its finances appropriately and
with a minimum amount of waste identify clearly what it intends to
accomplish.  The plan states that additional training is needed in
these areas.  The Department also cites improvements needed in its
internal research and audit resolution dissemination processes that
we believe will help the agency ensure that taxpayer dollars
appropriated to the Department are being managed and spent
responsibly. 

According to the plan, the Department has already taken steps to
improve its systems and processes agencywide.  For example, the
strategic plan states that the Department is developing a central
automated processing system known as EDCAPS to provide reliable and
timely information to agency managers about their programs. 
According to the plan, EDCAPS should also better control program
funds to prevent unlawful expenditures. 


--------------------
\2 Department of Education:  Long-Standing Management Problems Hamper
Reforms (GAO/HRD-93-47, May 28, 1993). 


      IMPROVING DEPARTMENT
      PROCESSES AND SYSTEMS TO
      ENSURE AGENCYWIDE AND
      PROGRAM-SPECIFIC FINANCIAL
      ACCOUNTABILITY
---------------------------------------------------------- Letter :7.2

To ensure that its programs and services are financially sound
(objective 4.6), the Department acknowledges in its draft plan a need
to improve its financial systems and processes and describes
strategies to achieve this objective.  Several factors mentioned in
the Department's plan or discussed in our past work or that of others
will make the Department's improvement efforts in this area
difficult.\3

  -- Significant financial management weaknesses.  The Department's
     strategic plan includes obtaining an unqualified audit opinion
     on its annual financial statement as a strategy for achieving
     financial integrity.  To provide decisionmakers with reliable,
     consistent financial data on the operations of federal agencies,
     the Government Management Reform Act of 1994 (GMRA) requires
     each department and major independent agency to submit to OMB an
     audited agencywide financial statement beginning with fiscal
     year 1996.  Our work has shown that the Department faces
     significant challenges in meeting GMRA requirements.  The
     Department's own audit efforts have identified significant
     financial management weaknesses that agency management must
     address.  According to the draft plan, poor data from the
     Federal Family Education Loan Program (FFELP) have prevented the
     Department from obtaining unqualified audit opinions on its
     annual financial statements for the past 4 years.  These audits
     indicated that data underlying the Department's $13 billion
     estimated liability for loan guarantees for FFELP were
     insufficient and unreliable.  Also, because guaranty agencies
     and lenders play a crucial role in the implementation and
     ultimate cost of FFELP, the auditors stressed the need for the
     Department to complete steps under way for improving oversight
     of guaranty agencies and lenders.  In an effort to prepare
     auditable fiscal year 1996 financial statements, the
     Department's Chief Financial Officer requested data from the top
     10 guaranty agencies to be used as a basis for computing the
     liability for loan guarantees.  In addition, an independent
     auditor under contract with the Department has developed agreed
     upon procedures to be applied by the guaranty agencies'
     independent auditors to test the reliability of the requested
     data.  Although the draft plan expresses concerns regarding the
     integrity of the data supporting the loan guaranty liability, it
     does not specify how the Department intends to resolve the data
     integrity issues or accurately estimate the government's
     liability.  The plan does, however, include a strategy for
     improving the oversight of guaranty agencies and lenders. 

  -- Ongoing problems with the management, structure, and processes
     related to the student financial aid programs.  According to the
     Department's draft plan, ensuring that taxpayer dollars are used
     effectively and are safeguarded against fraud, waste, and abuse
     will also help achieve the level of financial integrity the
     Department seeks.  Our work has shown that persistent problems
     with the individual student aid programs' processes, structure,
     and management are at the core of the Department's financial
     accountability difficulties.  These problems include (1) overly
     complex processes, (2) inadequate financial risk to lenders or
     state guaranty agencies for defaulted loans, and (3) management
     shortcomings.\4 Protecting the financial interests of the
     government will also be difficult because the student loan
     programs now serve more students from low-income families and
     those attending proprietary schools than in the past.  As the
     number of these higher risk borrowers increases, so does the
     potential for student loan defaults. 


--------------------
\3 Financial Audit:  Federal Family Education Loan Program's
Financial Statements for Fiscal Years 1993 and 1992 (GAO/AIMD-94-131,
June 30, 1994); Financial Audit:  Guaranteed Student Loan Program's
Internal Controls and Structure Need Improvement (GAO/AFMD-93-20,
Mar.  16, 1993); and Education Grants Management:  Actions Initiated
to Correct Material Weaknesses (GAO/HRD-91-72, June 26, 1991). 

\4 High-Risk Series:  Student Financial Aid (GAO/HR-97-11, Feb. 
1997); Higher Education:  Ensuring Quality Education From Proprietary
Institutions (GAO/T-HEHS-96-158, June 6, 1996); and Federal Family
Education Loan Information System:  Weak Computer Controls Increase
Risk of Unauthorized Access to Sensitive Data (GAO/AIMD-95-117, June
12, 1995). 


      IMPROVING THE DEPARTMENT'S
      OVERSIGHT OF POSTSECONDARY
      INSTITUTIONS
---------------------------------------------------------- Letter :7.3

In its discussion of core strategies to achieve goal 3--to ensure
access to postsecondary education and lifelong learning--the
Department indicates that it must improve its oversight of
postsecondary institutions, agencies, and lenders. 

Our past work has shown that the student aid programs have many
participants and involve complicated, cumbersome processes.  Three
principal participants--students, schools, and the Department of
Education--are involved in all the student financial assistance
programs.  Two additional participants--lenders and guaranty
agencies--also have roles in FFELP.  In general, each student aid
program has its own processes, which include procedures for student
applications, school verifications of eligibility, and lenders or
other servicing organizations that collect payments.  Further, the
introduction of the Ford Federal Direct Loan Program (FDLP),
originally viewed as a potential replacement for FFELP, has added a
new dimension of complexity.  Rather than replacing FFELP as
initially planned, FDLP now operates alongside it.  Essentially, this
means that the Department has two programs that are similar in
purpose but that operate differently. 

As we reported in one of our reports on high risk issues, several
weaknesses in the Department's oversight process continue to cause
concern.\5 For example, the Department's OIG identified problems with
the recertification process that could increase the likelihood that
schools not in compliance with eligibility requirements are able to
continue to participate in federal student assistance programs.\6 A
review of a sample of Department recertification actions showed that
27 percent of schools sampled had violations of eligibility
requirements such as unpaid debts or failure to meet financial
responsibility requirements.\7

The Department acknowledged that some recertifications should not
have been made and stated that it was taking action to make current
financial data available for future recertification reviews.  In its
draft strategic plan the Department states that it will address
problems like this through improved targeting and oversight.  The
Department also plans to implement a gatekeeping initiative designed
to focus resources on high-risk schools called the Institutional
Participation and Oversight Service (IPOS) Challenge.  This
initiative uses a computer model to identify schools for review on
the basis of their risk of noncompliance and is listed as a data
source in the Department's strategic plan for measuring agency
progress toward meeting goal 3. 


--------------------
\5 High-Risk Series:  Student Financial Aid (GAO/HR-97-11, Feb. 
1997) and Financial Management:  Education's Student Loan Program
Controls Over Lenders Need Improvement (GAO/AIMD-93-33, Sept.  9,
1993). 

\6 The Department periodically certifies the financial and
administrative capacity of all schools that participate in its
student financial assistance programs.  This certification process
ensures, among other things, that schools can pay their bills, are
financially sound, and have the personnel resources to administer the
student financial assistance programs. 

\7 U.S.  Department of Education, OIG, Subsequent Review to Follow-Up
Review on Selected Gatekeeping Operations, ACN:  11-60004
(Washington, D.C.:  Department of Education, June 7, 1996). 


   THE DEPARTMENT DOES NOT HAVE
   ADEQUATE DATA SYSTEMS AND
   INFORMATION TO ACHIEVE ALL ITS
   STRATEGIC GOALS
------------------------------------------------------------ Letter :8

Our work has shown that the Department generally lacks reliable data
sources and adequate accounting and information systems to achieve
the following two objectives supporting goal 4: 

  -- The Department's information technology investments are sound
     and used to improve impact and efficiency. 

  -- Management of Department programs and services ensures financial
     integrity. 

In 1992, we identified information resource management problems at
the Department, and in recent testimony before the Subcommittee on
Human Resources, House Government Reform and Oversight Committee, we
reported that the Department does not have a sound integrated
information technology strategy to manage its portfolio of
information systems.\8 The Department recognizes in its draft
strategic plan that improvements are needed in this area.  The plan
identifies several new agencywide initiatives as core strategies for
improving the efficiency and effectiveness of operations through the
use of information technology. 

  -- Assess current and proposed major information systems.  Recent
     information technology reform legislation, including the
     Paperwork Reduction Act of 1995 and the Clinger-Cohen Act of
     1996, set forth requirements that promote more effective use of
     information technology in support of agencies' missions and
     improved program performance.  Under the information technology
     reform laws, agencies are required to better link their
     technology plans and utilization to their programs' missions and
     goals.  In this regard, the Department's strategic plan states
     that the agency will assess current and proposed major
     information systems, such as the agency's financial systems, to
     ensure that they efficiently meet the needs and mission of the
     Department. 

  -- Utilize an Information Technology Board.  Among its activities,
     the Board will review new information technology investment
     proposals and conduct periodic reviews of ongoing systems. 

  -- Develop a data warehouse.  The Department intends to develop an
     agencywide information collection and dissemination system using
     a data warehouse to make Department data easily accessible
     internally and externally and to eliminate data duplication. 

  -- Model and develop an information architecture.  The Department
     plans to begin a modeling project to develop an architectural
     framework and uniform operating standards for all Department
     data systems to eliminate duplication in collection and data
     storage. 

The Department has also taken the important step of including in its
plans a major agencywide effort to address the "year 2000" date
conversion problem arising from the decades-old practice of recording
dates in computer programs using just the last two digits.  As a
result of this practice, systems or programs that use dates to
perform calculations, comparisons, or sorting may generate incorrect
results when working with years after 1999. 

We have identified the year 2000 problem as a high risk area in
recognition of the critical challenge faced by agencies that have to
address this issue.  Though this problem is not technically
challenging, it will be a massive and complex undertaking.  For many
agencies, the year 2000 conversion effort will be the largest project
ever to be managed and implemented by their information resource
management organizations.  Thus, the Department must ensure that its
information systems are fully "year 2000 compliant" before January
2000.  In its draft strategic plan, the Department has established
December 31, 1999, as the deadline for converting seven
mission-critical systems as part of its year 2000 conversion effort. 
Experts in the information technology industry, however, believe that
all systems should be converted by December 31, 1998, to allow a year
or more for validation and testing.  Considering the magnitude of the
task ahead, the Department would be well advised to establish a
target indicator date well before the current target date of December
31, 1999, shown in its draft strategic plan. 


--------------------
\8 Department of Education:  Management Commitment Needed to Improve
Information Resources Management (GAO/IMTEC-92-17, Apr.  20, 1992)
and Department of Education:  Challenges in Promoting Access and
Excellence in Education (GAO/T-HEHS-97-99, Mar.  20, 1997). 


      IMPROVING INFORMATION
      SYSTEMS SUPPORTING STUDENT
      AID PROGRAMS PRESENTS A
      SPECIAL CHALLENGE
---------------------------------------------------------- Letter :8.1

The Department faces a particularly difficult challenge in improving
its information systems for the student aid programs.  The
Department's student financial aid database, known as the National
Student Loan Data System (NSLDS), enables schools, guaranty agencies,
and others involved with administering student loans to transmit
updated loan status data to the Department.  However, the Department
has not yet integrated NSLDS with the numerous separate data systems
used to support individual student aid programs, often because the
various systems have incompatible data in nonstandard formats.  As a
result, program managers often lack accurate, complete, and timely
data to manage and oversee student aid programs.\9

The lack of an integrated student financial aid system also creates
several other problems: 

  -- unnecessary manual effort on the part of users;

  -- redundant data being submitted and stored in numerous databases,
     resulting in additional costs to the Department as well as the
     chance for errors in the data;

  -- lack of common identifiers for students and institutions, making
     tracking students and institutions across programs and systems
     difficult (the 1992 HEA amendments required the Department to
     establish common identifiers for students and institutions not
     later than July 1, 1993; the Department's draft strategic plan,
     however, does not address the development and implementation of
     common identifiers);

  -- inadequate program monitoring and data quality assurance.  For
     example, the current system cannot always identify where a
     student is enrolled, even after an award has been made and
     thousands of dollars in student aid have been disbursed. 

Although the Department has improved its student aid data systems
somewhat since 1992 and has recognized the use and development of
technology systems in this area in its strategic plan, major
improvements are still needed.  Both we and the Department's OIG
reported in 1996 that the Department had not adequately tested the
accuracy and validity of the loan data in the NSLDS.\10

During the past year, the Department has been developing a major
reengineering project, Easy Access for Students and Institutions
(EASI), to redesign the entire student assistance program delivery
systems to integrate the management and control functions for the
student assistance programs.  EASI is an important part of the
Department's core strategy for developing cost-effective major
systems that deliver for its customers and employees.  Although
activity on the EASI project, which had waned in previous months, has
recently been renewed, the project is expected to be a long-term
undertaking. 


--------------------
\9 Department of Education:  Multiple, Nonintegrated Systems Hamper
Management of Student Financial Aid Programs (GAO/T-HEHS/AIMD-97-132,
May 15, 1997) and Student Financial Aid:  Data Not Fully Utilized to
Identify Inappropriately Awarded Loans and Grants (GAO/HEHS-95-89,
July 11, 1995). 

\10 Department of Education:  Status of Actions to Improve the
Management of Student Financial Aid (GAO/HEHS-96-143, July 12, 1996). 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :9

On July 15, 1997, Department officials provided comments on a draft
of this report (see encl.  II).  Department officials agree with our
observations about the Department's draft strategic plan and intend
to make several revisions in response to our review.  For example,
the officials said that the next version of the plan will better
address all agency activities in its mission statement and include an
additional objective focusing specifically on the management of
postsecondary programs.  In response to the comments on the draft, we
recognize that the Department's statutory responsibility for
vocational rehabilitation is included in the draft strategic plan;
Department officials said, however, that the plan would be revised to
strengthen its discussion of this program. 


---------------------------------------------------------- Letter :9.1

As arranged with your offices, unless you publicly announce its
contents earlier, we plan no further distribution of this letter for
30 days.  We will then send copies to the Ranking Minority Members of
your Committees and to the Chairman and Ranking Minority Members of
other committees that have jurisdiction over education activities,
the Secretary of Education, and the Director of the Office of
Management and Budget.  We will send copies to others on request. 

Please contact me at (202) 512-7014 if you or your staffs have any
questions concerning this letter.  Major contributors to this
correspondence include Harriet Ganson, Assistant Director; Karen
Whiten, Evaluator-in-Charge; Adam Vodraska, Senior Attorney; and
Cheryl Driscoll, Senior Auditor. 

Carlotta C.  Joyner
Director, Education and
 Employment Issues

Enclosures - 2


DEPARTMENT OF EDUCATION'S MAJOR
STATUTORY RESPONSIBILITIES
=========================================================== Appendix I

1.  Strengthening and improvement of elementary and secondary
schools-- The Elementary and Secondary Education Act of 1965, as
amended (20 U.S.C.  6301). 

2.  National education reform--Goals 2000:  Educate America Act (20
U.S.C.  5801). 

3.  School-to-work opportunities--School-to-Work Opportunities Act
(20 U.S.C.  6101). 

4.  Basic education for adults--Adult Education Act, as amended (20
U.S.C.  1201). 

5.  Higher education resources and student assistance--Higher
Education Act of 1965, as amended (20 U.S.C.  1001; 42 U.S.C.  2751). 

6.  Vocational education--Carl D.  Perkins Vocational and Applied
Technology Education Act, as amended (20 U.S.C.  2301). 

7.  Vocational rehabilitation and other rehabilitation
services--Rehabilitation Act of 1973, as amended (29 U.S.C.  701). 

8.  Education of individuals with disabilities--Individuals With
Disabilities Education Act, as amended (20 U.S.C.  1400). 

9.  Education research and improvement--Educational Research,
Development, Dissemination and Improvement Act of 1994 (20 U.S.C. 
6001). 

10.  Education statistics--National Educational Statistics Act (20
U.S.C.  9001). 

11.  Monitoring and enforcement of civil rights related to
education--Department of Education Organization Act, as amended (20
U.S.C.  3401, 3413).  (The Department's Office for Civil Rights
enforces the antidiscrimination provisions of Title VI of the Civil
Rights Act of 1964, Title IX of the Education Amendments of 1972,
Section 504 of the Rehabilitation Act of 1973, and the Age
Discrimination Act of 1975 and also has responsibilities relating to
the Americans With Disabilities Act of 1990.)




(See figure in printed edition.)Enclosure
COMMENTS FROM THE DEPARTMENT OF
EDUCATION
=========================================================== Appendix I



(See figure in printed edition.)


============================================================ Chapter 0


RELATED GAO PRODUCTS
============================================================ Chapter 1

The Government Performance and Results Act:  1997 Governmentwide
Implementation Will Be Uneven (GAO/GGD-97-109, June 2, 1997). 

Executive Guide:  Effectively Implementing the Government Performance
and Results Act (GAO/GGD-96-118, June 1996). 

School Facilities:  Condition of America's Schools (GAO/HEHS-95-61,
Feb.  1, 1995). 

Charter Schools:  New Model for Public Schools Provides Opportunities
and Challenges (GAO/HEHS-95-42, Jan.  18, 1995). 

Education Reform:  School-Based Management Results in Changes in
Instruction and Budgeting (GAO/HEHS-94-135, Aug.  23, 1994). 

Buyouts at the Department of Education (GAO/GGD-94-197R, Aug.  17,
1994). 

Regulatory Flexibility in Schools:  What Happens When Schools Are
Allowed to Change the Rules?  (GAO/HEHS-94-102, Apr.  29, 1994). 

Special Education Reform:  Districts Grapple With Inclusion Programs
(GAO/T-HEHS-94-160, Apr.  28, 1994). 

Immigrant Education:  Federal Funding Has Not Kept Pace With Student
Increases (GAO/T-HEHS-94-146, Apr.  14, 1994). 

Transition From School to Work:  States Are Developing New Strategies
to Prepare Students for Jobs (GAO/HRD-93-139, Sept.  7, 1993). 

Vocational Rehabilitation:  Evidence for Federal Program's
Effectiveness Is Mixed (GAO/PEMD-93-19, Aug.  27, 1993). 

Vocational Education:  Status in 2-Year Colleges in 1990-91 and Early
Signs of Change (GAO/HRD-93-89, Aug.  16, 1993). 

Transition Series:  Education Issues (GAO/OCG-93-18TR, Dec.  1992). 

Vocational Rehabilitation:  Clearer Guidance Could Help Focus
Services on Those With Severe Disabilities (GAO/HRD-92-12, Nov.  26,
1991). 


*** End of document. ***