Summary: This letter advises institutions of the potential impact of the Year 2000 problem and the importance of an aggressive approach to ensuring that Title IV Student Financial Assistance (SFA) Programs will continue unimpaired. It also encloses a brief definition of the Year 2000 problem and compliance requirements, and it highlights the functions where postsecondary institutions and Department of Education SFA data systems interface.
SUMMARY: This letter advises institutions of the potential impact of the Year 2000 problem and the importance of an aggressive approach to ensuring that Title IV Student Financial Assistance (SFA) Programs will continue unimpaired. It also encloses a brief definition of the Year 2000 problem and compliance requirements, and it highlights the functions where postsecondary institutions and Department of Education SFA data systems interface.
The purpose of this letter is to reinforce the importance of your efforts to address data systems issues pertaining to the year 2000. We encourage you to make certain that your school has taken appropriate steps to ensure the continued functioning of Title IV Student Financial Assistance (SFA) Programs in light of Year 2000 information systems challenges. It is vitally important that all of your institutions data systems and procedures be fully Year 2000 Compliant. Year 2000 Compliant is defined as: "Year 2000 applications are capable of correct identification, manipulation and calculation using dates, including leap years, outside of the 1900-1999 year range and have been tested as such." Few systems currently in use were designed with the ability to process dates later than 1999. A more comprehensive discussion of the Year 2000 issue as it relates to SFA programs is provided as an enclosure to this letter. Serious processing errors and disruptions to student aid delivery and accountability may result from the failure of systems to provide for the upcoming change to Year 2000 and beyond. If you have not already done so, we strongly encourage your institution to develop an aggressive strategy and action plan for addressing this issue.
Within ED, we have taken the Year 2000 issue very seriously. Assessment of our critical computer systems has revealed fundamental changes to be made, and we are in the process of making these changes. Our process for ensuring that our internal systems will be Year 2000 Compliant, and one which we recommend your institution follow, includes the following general steps:
Awareness - Understanding the problem and developing a detailed project or business plan for addressing the issue.
Assessment - Completing an inventory of all systems, processes, files, etc. that are affected and conducting a thorough review of all of the application code to identify every occurrence of non-compliant date processing.
Renovation - Making necessary changes to ensure that each system is compliant.
Validation - Testing, contingency planning, and risk analysis to ensure compliance.
Implementation - Moving renovated and validated systems into production.
Year 2000 Compliance - page 2
We understand that at most institutions the responsibility for ensuring that systems are Year 2000 Compliant, including those that help administer student aid programs, rests outside of the financial aid office. However, we strongly urge you to contact your Chief Information Officer or information technology personnel to request information regarding the Year 2000 compliance plan and progress to date. In addition, you should seek information regarding the Year 2000 compliance plan of any third party vendors or servicers that provide you with software or other SFA services. As you review this information, please make certain that the plan includes the proper procedures and time frames for ensuring that your institution will be able to meet the January 1, 1999, deadline for Year 2000 compliance as provided in 1998-99 Action Letter #2 (GEN-97-11).
As you work to make certain that your institution will be Year 2000 Compliant, you should refer to the enclosed table that highlights the functions of systems used to exchange data between institutions and ED for SFA purposes. Institutions must also make certain that other interfaces they utilize in the administration of Title IV aid, such as those with Federal Family Education Loan (FFEL) lenders and guaranty agencies, are also Year 2000 Compliant.
In order to provide additional information on this important topic, we are in the process of creating a "Year 2000 Compliance Information and Best Practices" Web site. In the meantime, if you have questions regarding the Year 2000 compliance requirement, you may e-mail an inquiry to our Program Systems Service staff at:
Thank you for your efforts in this matter and for all of your work to help ensure the viability and integrity of our student aid programs.
Elizabeth M. Hicks
Deputy Assistant Secretary
Student Financial Assistance Programs