Requests may involve data that must be reconciled across multiple systems and departments. Building ongoing readiness for a Program Review can help institutions avoid scrambling after a notice arrives.
In today’s higher education environment, Program Reviews are more than routine compliance exercises. As federal oversight and enforcement activity continues to evolve, institutions should understand what may prompt a review, what information may be requested and how to prepare before a notice arrives.
That trajectory came into sharper focus on July 7, 2026, when the U.S. Department of Education and its Office of Inspector General held the first Higher Education Fraud Summit. The event drew more than 800 attendees, including institutional leaders, financial aid administrators, compliance officers, and federal and state law enforcement officials. Panel discussions covered aid program vulnerabilities, identity and enrollment fraud, institutional controls and enforcement pathways.
A review may be triggered by a range of factors, including data anomalies, compliance concerns, borrower complaints, audit findings or information identified through federal monitoring. A review can also be triggered by referrals from accrediting or state licensing agencies, unusually rapid enrollment growth or elevated cohort default rates. In some cases, a review may focus on a specific program, issue or period rather than an institution’s entire operation. The presence of a trigger does not necessarily mean a violation has occurred, but it does mean the institution should be prepared to explain its practices and support its conclusions with documentation.
The law specifies that the Department of Education gives priority in Program Reviews to institutions that meet any of the following criteria:
- A high cohort default rate or dollar volume of default
- Significant fluctuation in Pell Grant awards or FSA loan volume that is not accounted for by changes in the programs
- Are reported to have deficiencies or financial aid problems by the appropriate state agency or accrediting agency
- High annual dropout rates
- The Department determines a school may pose a significant risk of failing to comply with administrative capability or financial responsibility requirements
– Source: Vol 2, Chapter 8 of the FSA Handbook on Program Reviews
Once a review begins, requests may extend beyond a single report or policy. Institutions may be asked to provide student records, enrollment and attendance information, academic calendars, program documentation, institutional policies, consumer disclosures, financial aid records or evidence supporting how requirements were applied. Requests may also involve data that must be reconciled across multiple systems and departments.
Preparation starts well before a review notice arrives. Institutions should regularly assess whether policies reflect current requirements, confirm that procedures are being followed consistently and maintain organized, accessible records. Cross-functional teams should understand their roles, establish a clear process for responding to requests and identify who is responsible for reviewing information before it’s submitted.
The strongest preparation is ongoing, not reactive. By monitoring potential risk areas, validating data and maintaining clear documentation, institutions can approach a Program Review with greater confidence and respond in a timely, coordinated and accurate manner.
The Fraud Summit’s message was direct: enforcement isn’t slowing down, and readiness is not simply about responding when questions arise – it’s about building the operational discipline to answer them. For compliance leaders and institution presidents, the relevant question isn’t whether a review could happen. It’s whether your institution could produce a complete, defensible record today.
September 17, 2026
All information is subject to change.