Culture Eats Process for Breakfast

I’m giving the keynote at 10ET / 9CT along with a follow up discussion at tomorrow’s Digital Education Summit #DES24 for Sam Houston State University’s Online Campus. Registration is free. My topic is “The opportunity for innovation in practice despite a challenging time frame.”

The aphorism attributed to Peter Drucker, but more likely a combination of his concepts mashed up with those of Edgar Schein, describes how culture will nearly always be a more important determination of an organization’s success than defined strategy. Human factors including how people react in stressful situations matter much more than if strategies are well-defined. The same could be said of culture eating process for breakfast. It’s the people in the organization and their patterns of behavior that matter much more than having defined procedures.

This, in my mind, is the missing piece from the GAO interim audit findings on the US Department of Education (ED), the Federal Student Aid (FSA) office within ED, and its FAFSA Fiasco that were released along with congressional testimony on Tuesday. The GAO did a great job describing what went wrong and how significant the errors were, but when it came time for recommendations the reports only talked about procedures with minimal discussion of leadership and decision-making.

The Coverage

I don’t want to reiterate the primary coverage of the GAO reports. You can find that by reading one or more of the following sources.

• Inside Higher Ed: “The Long-Awaited FAFSA Autopsy Is Here” - The initial reporting with a good summary of findings, with examples, came from IHE. The article had enough detail that either Liam Knox has very fast fingers or was provided with a scoop.

• Education Dive: “Scathing GAO reports blame Education Department leaders for FAFSA mess” - This article focuses more than others on ED obstruction of the process along with a summary of findings.

• Chronicle of Higher Education: “Congressional Watchdog Digs Into FAFSA Fiasco, Revealing Oversights, Call-Center Failures, and Unresolved Glitches” - Eric Hoover’s reporting (and let’s admit that he has been the hero of this coverage in the trade press) combines the reports along with congressional testimony.

• NPR: “Watchdog sheds light on FAFSA fiasco, from a birthday bug to call center failures” - This article is written for a broader audience with a good categorization of problems found in the GAO reports.

All of these articles capture that there was not one or even two major errors causing the FAFSA Fiasco. There were multiple, persistent errors, and we are not out of the woods yet. Next year’s FAFSA is at risk.

It’s the People, Stupid

If you read GAO’s two reports and watch the congressional testimony, it becomes more and more obvious that the core issue is that ED leaders consistently made bad decisions regardless of process.

• FSA knew in August 2022 that the scheduled completion of October 1st, 2023 was unlikely - and the internal project schedule was changed to December - yet there was no public notice of the delay for seven months.

• As of December 23, 2023 there were 19 identified functionality and performance defects remaining from testing, including six “urgent” defects - but FSA executives “accepted the risk of reduced testing” and claimed all major items were addressed by December 30th and released the new FAFSA anyway. Immediately after launch, 55 defects were found.

• FSA had guidance on tracing requirements to ensure needed functionality but did not follow this guidance until after December 2023. FSA execs noted that the guidance is outdated, but FSA did nothing to replace the guidance and actually test requirements.

• FSA had guidance on testing but did not follow all of its own guidance and approved milestone reviews despite testing not being completed. And there was no end user testing before deployment.

• FSA’s CIO “did not follow the department’s risk rating process and update the rating for FPS on a monthly basis.” There was no CIO risk assessment between September 2021 and June 2024.

• FSA guidance “instructed call center representatives to advise some students facing technical problems to just ‘try again later’ rather than proactively notifying them when the problem was resolved, which sometimes took months.”

• FSA “did not give colleges any advanced warning that it would not meet promised deadlines for delivering the student records colleges needed to develop aid offers.”

The common theme in these and numerous other examples is that FSA leadership made the wrong decisions (i.e., harmful to students and institutions), whether there was guidance or a set of procedures identified or not. Furthermore, FSA and ED at large continues to view any pushback or oversight as misguided and unnecessary. It’s the culture, it’s the pattern of human behavior.

The Monday Missive

Throughout the process, ED’s communications have emphasized the we’re working hard message and highlighting numerical triumphs rather than giving clear, complete information. Read any one of the FAFSA update posts started on April 1, 2024 and try to find any direct admission of mistakes made or a real heads up that there would be no batch correction process available. Read Education Secretary Miguel Cardona’s statements at a conference at the end of May that “we recognized early on that it needed to be delayed and we continue to find ways to move it along.”

Prior to the GAO release and congressional testimony, ED released a 10-page self-congratulatory memo outlining all the improvements they are making. Hiring more staff, adding more testing plans, etc. And most of those are welcome improvements.

There were plenty of descriptions of “we have been working tirelessly” and "taken bold steps” and “making key improvements” in the document. What there is not is any acknowledgement of the human factor. Nothing about FSA understanding that leaders made bad decisions with faulty assumptions and that this problem needs to be fixed. Nothing expressing remorse or acknowledgement of the numerous mistakes. The closest I can find is one mention of being “accountable,” but that was in terms of holding vendors accountable.

There were some real improvements outlined in the Monday document about testing plans for next year’s cycle, but the overall the document was defensive in nature. For example, the call center “received an unprecedented number of contacts” [passive in nature, no acknowledgement of poor planning] and “callers were often not reliably able to reach an agent for support” [GAO reported that 4.0 out of 5.4 million calls went unanswered - seems more than a reliability issue]. The call center “added more than 700 new agents—an 80% increase—to handle projected call volumes” [not acknowledging that this only gets back to the levels available in the 2023-24 cycle].

ED’s View of Oversight

Back in the spring, when congressional Republicans asked for the GAO investigation, the ED reaction was telling, as reported by Education Dive.

In May and June, ED finally made some changes. FSA’s Chief Operating Officer (COO) Richard Cordray reportedly resigned, but in reality he finished out his three-year term and even extended it by a month. ED then brought in several executives from the College Board and appointed an acting COO to reorganize FSA. So perhaps this obstruction and defensiveness were a thing of the past? Well, it doesn’t appear to be the case, even with revised FSA management.

To this day, the Department of Education and its Federal Student Aid office are showing a disdain for oversight.

Several media outlets highlighted that FSA had six CIOs in the past four years, but I would note that there was a CIO in place from May 2022 through June 2024, who provided no oversight and made no progress in reforming FSA risk management, and she has been promoted in effect to the number two position (acting deputy COO) in FSA.

Accountability is not a strenth for the Department.

The GAO Limitation

And this gets to my main criticism of the GAO findings. Despite all the evidence of poor human decision-making (culture), the GAO recommends a bunch of policies and plans (i.e., process).

And the list goes on. No one seems to be talking about the elephant in the room. The toxic culture of no accountability and poor decision-making at the Department of Education. I truly hope that the current reorganization under Denise Carter’s leadership and with Jeremy Singer’s FAFSA interim leadership will lead to real cultural changes. But I have to note:

1. The GAO recommendations which will provide the foundation for change ignored the culture issues; and

2. The ongoing ED reactions of making oversight difficult and avoiding direct culpability are not encouraging.

Unless the FSA culture gets fixed soon, next year’s 2025-26 FAFSA cycle is going to have problems that go beyond the initial two-month delay.

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