GAO urges Education to set formal early coordination criteria for loan servicers

The Government Accountability Office recommends that the Department of Education adopt formal criteria for determining when to conduct early coordination with its federal student loan servicers. The recommendation follows a GAO review of 68 change requests issued between the start of the COVID-19 payment pause in March 2020 and December 2024.

Servicers reported that unclear upfront instructions often required extensive clarification. One change request generated six rounds of questions and answers over a two-month period. All four contracted servicers said early coordination would enable quicker, more accurate implementation of new requirements.

Education officials acknowledge the value of early coordination but note that it is currently performed at staff discretion, based on factors such as request complexity. In June 2025 officials said early coordination was not common, citing insufficient time, while in December 2025 they reported recent improvements, including proactive solicitation of servicer input on draft repayment-plan requirements.

GAO's recommendation directs the Secretary of Education to ensure Federal Student Aid develops and implements the formal criteria. The department has disagreed, arguing that such criteria would hinder timely implementation and responsiveness to administration priorities. The recommendation remains open.

GAO argues that formal criteria would help Education provide servicers with the information needed to implement changes efficiently, while preserving flexibility to respond to changing circumstances.