Case Study

An Acquisition Management Success for the U.S. Department of Education Office of Federal Student Aid

Challenge: The U.S. Department of Education’s Office of Federal Student Aid (FSA) is responsible for processing the Free Application for Federal Student Aid (FAFSA) for approximately 20 million federal student aid applicants each year. For almost 50 years, FSA has relied on an increasingly expensive and outdated legacy system written in Common Business-Oriented Language, or COBOL, to process FAFSA applications. Additionally, in 2019 and 2020, Congress passed the Fostering Undergraduate Talent by Unlocking Resources for Education (FUTURE) Act and FAFSA Simplification Act, both of which mandated significant changes to the FAFSA award process with significant implications for the legacy system.

FSA made several attempts to procure a modernized system to enhance back-end FAFSA operations and implement congressional mandates. Unfortunately, these solicitations ended up being canceled after multiple vendor-filed protests before any modernization could take place.

Solution: FSA requested Summit’s support for the Award Eligibility Determination (AED) project in 2020—the revamped effort to modernize the legacy FAFSA back-end system. Our acquisition management team worked with the customer to implement an acquisition strategy focused on protest mitigation, including:

  • Maximizing communication with potential vendors during the market research phase to understand industry capabilities and ensure full understanding of FSA’s needs through:
      • a Request for Information;
      • a Rough Order of Magnitude request;
      • vendor clarification written requests;
      • vendor-FSA clarification meetings;
      • an Industry Day with interested vendors; and
      • a draft Request for Proposals.
  • Assembling a core integrated procurement team to shepherd development of the acquisition package and coordinate with stakeholders across the organization.
  • Facilitating requirements sessions with stakeholders to solicit as much detail as possible to allow vendors to understand and adequately price each task.

Result: The Summit team’s support resulted in the successful award of the AED Modernization contract in 2022 with no protests. For the first time, FSA is moving forward with modernizing the FAFSA back-end system and incorporating the changes mandated by Congress. The protest mitigation efforts enabled FSA to successfully communicate its needs to the vendor community and conduct a transparent acquisition process, which ultimately led to enhanced FAFSA operations for the millions of students who rely on timely application processing to access higher education.