Comment Request: Improper Payment Estimation Information Collection

FSA Partners Knowledge Center

Published March 16th, 2026

Detected March 17th, 2026

Summary

The Department of Education's Federal Student Aid (FSA) is requesting comments on a new information collection requirement for institutions of higher education. This new form will be used to collect data necessary for estimating improper payments annually, as mandated by the Payment Integrity Information Act of 2019.

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What changed

The Department of Education's Federal Student Aid (FSA) is initiating a request for public comment on a proposed new information collection activity. This activity aims to develop a form that institutions of higher education will use to report specific data related to their compliance audits. This data is crucial for FSA to execute its Sampling and Estimation Methodology Plan (S&EMP) and to fulfill the annual reporting requirements for payment integrity information under the Payment Integrity Information Act of 2019 (PIIA) and OMB Circular A-123, Appendix C.

Institutions of higher education will be required to provide sample, population, and audit finding information that is not currently reported with their compliance audits. This new reporting mechanism is necessary for the Department to carry out its oversight responsibilities concerning improper and unknown payments in federal student financial aid programs. The public comment period is open, and the Federal Register notice provides a link for viewing the full publication and submitting feedback.

What to do next

Review the Federal Register notice regarding the proposed information collection for improper payment estimation.
Submit comments to the Office of Management and Budget (OMB) if the proposed information collection impacts the institution.
Prepare for potential future reporting requirements related to improper payment estimation data.

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Publication Date March 16, 2026 Posted Date March 16, 2026 Subject Comment Request: Required Information for Annual Improper Payment Estimation FR Type Notice

Federal Student Aid (FSA) administers the Department of Education's Federal student financial aid programs authorized by Title IV of the Higher Education Act of 1965, as amended. Under these programs, institutions of higher education act as a fiduciary in receiving grant and loan funds from the Department for the sole purpose of allowing students to pay the costs of attendance at the institution. The Department executes a two-stage Sampling and Estimation Methodology Plan (S&EMP) that is based in part on the results of compliance audits to estimate its improper payments and unknown payments in accordance with the Public Law 116-117, Payment Integrity Information Act of 2019 (PIIA) and OMB Circular A-123, Appendix C (A-123C). The Department requires sample, population, and as applicable, finding information regarding testing performed by the auditors, however, this is not reported with the compliance audit. This information is necessary to execute FSA's S&EMP.

The legal and administrative requirements that necessitate the collection of this information are the audit access provisions in 2 CFR 200.517(b) and Title IV regulations at 34 CFR 668.23(e)(1)(ii), which the Department has concluded gives it the authority to collect certain information from the single audit in order for the Department to carry out its oversight responsibilities with regard to improper payments and unknown payments. PIIA section 3352 (31 U.S.C. 3352) requires federal agencies to review all programs and activities they administer that may be susceptible to significant improper payments and publish the payment integrity information annually.

This is a request for a new information collection to develop a form for institutions of higher education to have a mechanism to report to the Department information required to carry out the S&EMP and publish payment integrity information on an annual basis.

To view this Federal Register publication, click here.