Education Response

8/4/2019 Education Response

1/17

UNITED STATES DEPARTMENT OF EDUCATIONOFFICE OF THE CHIEF FINANCIAL OFFICER

Honorable Darrell IssaChairmanCommittee on Oversight andGovernment ReformHouse ofRepresentativesWashington, DC 20515Dear Mr. Chairman:

March 31,2011

I am responding to your March 8, 2011, letter requesting information about electronic systems inuse at the Department ofEducation (Department). The specific responses to the questions youposed are enclosed.In addition, we recommend you review the Department's Fiscal Year 2010 Agency FinancialReport available at http://www2.ed.gov/about/reports/annual/201 0reportlindex.html .Please do not hesitate to contact Assistant Secretary Gabriella Gomez, Office ofLegislation andCongressional Affairs, at 202-401-0020, if you have any questions or require additionalinformation.

Enclosure

Sincerely,

Thomas P. SkellyDelegated to Perform the Duties and Functionsof the Chief Financial Officer

400 Maryland Avenue, SW, 4th Floor, Washington, DC 20202-4447Our Mission is to promote student achievement and preparation/or global competitiveness by fosteringeducational excellence and ensuring equal access


2/17


March 31,2011

Honorable Todd R. PlattsChairmanSubcommittee on Government Organization,Efficiency and Financial ManagementHouse ofRepresentativesWashington, DC 20515Dear Mr. Chairman:I am responding to your March 8, 2011, letter requesting information about electronic systems inuse at the Department ofEducation (Department). The specific responses to the questions youposed are enclosed.In addition, we recommend you review the Department's Fiscal Year 2010 Agency FinancialReport available at http://www2.ed.gov/aboutirepOJts/annuall2 010report/index.html.Please do not hesitate to contact Assistant Secretary Gabriella Gomez, Office ofLegislation andCongressional Affairs, at 202-401-0020, if you have any questions or require additionalinformation.

Enclosure

Sincerely,~ l ~ Thomas P. SkellyDelegated to Perform the Duties and Functionsof the Chief Financial Officer

400 Maryland Avenue, SW, 41b Floor, Washington , DC 20202-4447Our Mission is to promote student achievement and preparaJionfor global competitiveness by fosteringeducational exceUence and ensuring equal access


3/17


March 31, 2011

Honorable James LankfordChainnanSubcommittee on Technology, InfonnationPolicy, Intergovernmental Relations andProcurement RefonnHouse of RepresentativesWashington, DC 20515Dear Mr. Chainnan:I am responding to your March 8, 2011, letter requesting infonnation about electronic systems inuse at the Department of Education (Department). The specific responses to the questions youposed are enclosed.In addition, we recommend you review the Department's Fiscal Year 2010 Agency FinancialReport available at http://www2.ed.gov/aboutireports/annual/2010reportJindex.html.Please do not hesitate to contact Assistant Secretary Gabriella Gomez, Office of Legislation andCongressional Affairs, at 202-401-0020, if you have any questions or require additionalinfonnation.

Enclosure

Sincerely,' ~ R A A j _ Thomas P. S k e l l v - ..... 7Delegated to Perfonn the Duties and Functions

of the Chief Financial Officer

400 Mary land Avenue, SW, 4111 Floor, Washington, DC 20202-4447Our Mission is to promote student achievement and preparation for global competitiveness by fosteringeducational excellence and ensuring equal access


4/17

Honorable Jim JordanChairman


March 31, 2011

Subcommittee on Regulatory Affairs,Stimulus Oversight and Government SpendingHouse ofRepresentativesWashington, DC 20515Dear Mr. Chairman:I am responding to your March 8, 2011, letter requesting information about electronic systems inuse at the Department ofEducation (Department). The specific responses to the questions youposed are enclosed. 'In addition, we recommend you review the Department's Fiscal Year 2010 Agency FinancialReport available at http://www2.ed.gov/aboutireports/annua1J201 Oreportlindex.html.Please do not hesitate to contact Assistant Secretary Gabriella Gomez, Office ofLegislation andCongressional Affairs, at 202-401-0020, if you have any questions or require additionalinformation.

Enclosure

SincerelyJ

Thomas P. SkellyDelegated to Perform the Duties and Functionsof the ChiefFinancial Officer

400 Maryland Avenue, SW, 4th Floor, Washington, DC 20202-4447Our Mission is to promote student achievement and preparation/or global competitiveness by fosteringeducational exceUence and ensuring equal access


5/17

Responses to Committee on Oversight and Government ReformUS Department ofEducation

March 31, 20111. Identify and briefly describe each ofyour agency's business and accounting systems. If

separate divisions, bureaus, or offices ofyour agency use separate systems, identify whichdivisions, bureaus, or offices use each system.The Department ofEducation's department-wide accounting and business systems are allcaptured under an umbrella system named the Education Centralized AutomatedProcessing System (EDCAPS). A brief description of hese systems follows. Please seeAttachment 1 for a flowchart of the EDCAPS component systems.The Financial Management Support System (FMSS) is the Department ofEducation'sdepartment-wide core financial management (accounting) system. The services it providesinclude: funds control, budget planning, general ledger, accounts payable, accountsreceivable, administrative payments, and financial reporting.The Government-wide E2 Travel System is a department-wide system and manages allemployee and invitational travel authorizations and vouchers with an automated interfaceto the FMSS.The Nortridge Loan System manages the Department's portfolio ofpromissory notes andhas an automated interface to the FMSS.The Contracts and Purchasing Support System (CPSS) is a department-wide system forcontracts management and processes procurement and contract data with an automatedinterface to the FMSS.The G5 Grants Management System is a department-wide system for grants managementand processes grants data with an automated interface to the FMSS.The CheckFree system is a cash reconciliation and SF224 reporting system to theDepartment of the Treasury.The Unbilled Lockbox processes electronic refunds via P A Y.gov and check refundsthrough US Bank for the Department with an automated interface to the FMSS.The Accounts Receivable Reporting Database is a database of accounts receivableinformation used to generate reports specific to accounts receivable functions.The Hyperion Budget Planning System is a department-wide system used to input annualbudget plans.The Department of Interior processes all payroll for the Department ofEducation.


6/17


The Department of the Treasury processes payments for the Department ofEducation.The Federal Student Aid Financial Management System (FSA FMS) processes student loanand grant accounting data from the Federal Student Aid systems with an automatedinterface to the FMSS. Please see Attachment #2 for a diagram of the FSA componentsystems and their descriptions.

2. Explain how the business and accounting systems identified in response to Request No. 1interact with one another.All Education systems identified in Response No.1 above interact via automatedprocesses. These processes are controlled through scheduled predefined procedures thateither interface via online, real-time or via batch mode depending upon the businessrequirement.

3. For each system identified in response to Request No.1, state whether information found inthat system is regularly or periodically submitted to any of the government-wideaccounting systems maintained by the Department of the Treasury, e.g., GFRS, FACTS I,FACTS II, IFCS, etc., ,and explain how and at what intervals those submissions occur,including descriptions ofboth manual and automated processes.The FMSS regularly submits information to the government-wide accounting systemsmaintained by the Department of the Treasury. All submissions are automated. Thefrequency of the submissions is: GFRS--annually; FACTS I and FACTS II--quarterly; andIFCS--quarterly.

4. For each system identified in response to Request No.1, state whether information found inthat system is regularly or periodically submitted to the Office ofManagement andBudget's ("OMB") MAX Information System, and explain how and at what intervals thosesubmissions occur, including descriptions ofboth automated and manual processes.FMSS data is submitted to Treasury's FACTS II system quarterly for budget executionreporting. From the FACTS II system, MAX is automatically populated with the agencyfinancial data.Department staff uses FMSS data in preparing SF-132 apportionment requests, which aremanually entered into the MAX Apportionment module, as needed. Department staffusually processes several requests each month.Department staff also manually enter prior-year budget execution data from FMSS intoMAX in budget presentation format during the annual budget formulation process, whichnormally occurs between November and January.

2


7/17


Finally, Department staff periodically responds to OMB Budget Data Requests (BDR' s),which may require FMSS budget execution and financial data to be manually entered into aMAX application module.

5. For each system identified in response to Request No.1, describe recent, current, andplanned migration or modernization projects.The FMSS resides on an Oracle database and uses the Oracle Federal Financials 11.5.10release of the application. A new version of the software has been released (Version 12)and the Department is currently in the initial stages of analyzing the business need, effort,and resources necessary to implement this new version.The E2 Travel system contract with GSA expires in 2013. If a new vendor is chosen,Education will migrate to a new system in 2014.The Nortridge Loan System has no recent, current, or planned modernization projects atthis time.The Contracts and Purchasing System--The Department ofEducation has initiated a projectto integrate a new Commercial-Off-The-Shelf (COTS) product into the enterprise,replacing or significantly enhancing the current contract writing system.The G5 Grants Management System--The final component of the G5 implementation wascompleted March 14, 2011, and the system is now operational.The CheckFree system has no recent, current, or planned modernization projects at thistime.The Unbilled Lockbox was recently migrated from US Bank to PAY.gov for electronicrefunds.The Accounts Receivable Reporting Database has no recent, current, or plannedmodernization projects at this time.The Hyperion Budget Planning System has no recent, current, or planned modernizationprojects at this time.The Federal Student Aid Financial Management System has no recent, current, or plannedmodernization projects at this time.

6. In addition to your agency's submissions to government-wide accounting systemsmaintained by the Department of the Treasury and OMB, as described in response to

3


8/17


Requests Nos. 3 and 4, does your agency publish any of the same infonnation online forpublic viewing? If so, describe how and in what fonnat that information is published.The Department does not publish any of the same information online for public viewing.

7. Identify and briefly describe each system that your agency uses to manage grants, directloans, and/or loan guarantees. If separate divisions, bureaus, or offices of your agency useseparate systems, identify which divisions, bureaus, or offices use each system.The Department uses the G5 Grants Management System to manage grants and direct loandisbursements. The G5 investment has been selected and approved by OMB as a ConsortiaLead for the Grants Management Line ofBusiness (GMLoB). The shared service modelenables ED to provide services to client agencies that will migrate to the Department ofEducation's end-to-end grant management system. The G5 solution supports the Agency'sgrant-making business process and is a full life cycle, end-to-end grants managementsystem (intake of applications, peer review, award, payment, perfonnance monitoring, andfinal closeout of the grant award). Also, please see Attachment 2 for a description oftheFederal Student Aid office systems that support grant, direct loan, and/or loan guaranteeactivity.

8. For each system identified in response to Request No.7, explain how it interacts with anybusiness or accounting system identified in response to Request No.1.G5 interacts with the FMSS accounting system in both a real-time mode for funds controlon awards and a batch mode for drawdowns.The FSA-FMS system interfaces with the FMSS accounting system and G5 grants systemin a batch mode. Please see Attachment 2 for a description of grant systems with theFederal Student Aid office.

9. For each system identified in response to Request No.7, state whether information found inthat system is regularly or periodically submitted to the Catalog ofFederal DomesticAssistance (CFDA), and describe how and at what intervals those submissions occur,including descriptions ofboth automated and manual processes.New programs are entered into the G5 system as pending, manually placed into the CatalogofFederal Domestic Assistance (CFDA), and updated in the Department's Grants System(G5) once approved within the CFDA. The existing CFDA program information is alsoreviewed and updated on an annual basis.

10. For each system identified in response to Request No.7, state whether infonnation found inthat system is regularly or periodically submitted to any of the government-wide grants

4


9/17


management and reporting systems, e.g., FAADS, FAADS PLUS, etc., and describe howand at what intervals those submissions occur, including descriptions ofboth automatedand manual processes.Data from the G5 application is submitted to F AADS quarterly (prior to the F AADSdiscontinuance) and to USASpending.gov (using the FAADS Plus format) bimonthly. TheF AADS submission process includes running reports from G5 and manually submittingthem to the F AADS system. For USASpending.gov, submissions are run from the G5database and manually uploaded to USASpending.gov.

11. For each system identified in response to Request No.7, describe recent, current, andplanned migration or modernization projects.The final component of the G5 implementation was completed March 14,2011, and thesystem is now operational.See Attachment 2-The Direct Loan Servicing System and the Conditional DisabilityDischarge Tracking System are migrating to the Title IV Additional Servicers model andbeing decommissioned. The Debt Management and Collection System (DMCS) is beingreplaced by DMCS2.

12. In addition to your agency's submissions to government-wide grants management andreporting systems, described in response to Requests Nos. 9 and 10, does your agencypublish any of the same information online for public viewing? If so, describe how and inwhat format that information is published.Forecast ofFunding Opportunities under the Department ofEducation Discretionary GrantPrograms for the fiscal year is posted biweekly to the Department's Web site athttp://www2.ed.gov/fundlgrantlfindledlite-forecast.html. The Forecast lists virtually allprograms and competitions under which the Department has invited or expects to inviteapplications for new awards and provides actual or estimated deadline dates for thetransmittal of applications under these programs. The lists are in the form of charts-organized according to the Department's principal program offices--and include programsand competitions previously announced, as well as those planned to be announced. Theinformation is advisory only and is not an official application notice. The Departmentprovides updates to this document starting in the first week ofNovember in a fiscal yearand continuing through the following July.Education also publishes a Discretionary and Formula Grants Award database on theDepartment's Web site at http://wdcrobcolpOl.ed.gov/CFAPPS/grantaward/start.cfin. The

5


10/17


database contains information on discretionary and formula grants made in the last severalyears. It has multiple methods for searching, viewing, and downloading data about awards.

13. Identify and briefly describe each system that your agency uses to manage contracts. Ifseparate divisions, bureaus, or offices ofyour agency use separate systems, identify whichdivisions, bureaus, or offices use each system.The Department ofEducation uses a contract writing system, CPSS. It supports theacquisition process from pre-award planning activities (e.g., initiating, fund obligation andcommitment, contract assembly, and issuance) through contract close out.

14. For each system identified in response to Request No. 13, explain how it interacts with anybusiness or accounting system identified in response to Request No.1.CPSS has a near real-time two-way interface to the FMSS. Financial data in support ofcommitments, adjustments to commitments, obligations, adjustments to obligations andvendor data are passed from CPSS to the FMSS. Account classification codes are sentfrom the FMSS to CPSS. Status messages regarding posting status are sent to CPSS fromtheFMSS.

15. For each system identified in response to Request No. 13, state whether information foundin that system is regularly or periodically submitted to any of the government-wide contractmanagement and reporting systems, e.g., FPDS, FPDS-NG, FAPIIS, etc., and describe howand at what intervals those submissions occur, including descriptions of both automatedand manual processes.Contract data is submitted to USASpending on behalfofEducation from the FederalProcurement Data System - Next Generation (FPDS-NG). To ensure that contract actionsget entered into FPDS-NG, the Department's CPSS automatically requires FPDS-NGreporting be completed before a contract obligation can be made. To address timeliness,Education ensures that all new grant and loan transactions are submitted twice monthly.This ensures that we meet the 3D-day reporting requirement. We also enter contract datanear real-time, which exceeds the requirement for posting in the Federal Procurement DataSystem within 3 days of award.

16. For each system identified in response to Request No. 13, describe recent, current, andplanned migration or modernization projects.The Department ofEducation has initiated a project to integrate a new Commercial-OffThe-Shelf (COTS) product into the enterprise, replacing, or significantly enhancing thecurrent contract writing system.

6


11/17


17. In addition to your agency's submissions to government-wide contract management andreporting systems, described in response to Request No. 15, does your agency publish anyof the same information online for public viewing? If so, describe how and in what formatthat information is published.Department contracting personnel manually post contract opportunities and awards toFedBizOps and also pos t a list of active contracts and the annual forecast of contractopportunities to the Department's Web site in html, .doc, .docx, andlor PDF format.

18. Briefly describe your agency's efforts to comply with OMB's memorandum on the OpenGovernment Directive - Federal Spending Transparency, dated April 6, 2010. Inparticular, describe whether and how your agency has begun to collect and report subawards data, as required by the memorandum, and describe how your agency 's reports onOMB's data quality metrics, as required by the memorandum, are generated.The Department complies with the guidance ofOMB's Memorandum ofApril 6, 2010, byissuing new grant policies around "Sub-award and Executive Compensation ReportingRequirements under the Federal Funding Accountability and Transparency Act." Thepolicy disseminated information about sub-award and executive compensation reportingrequirements set forth in the Federal Funding Accountability and Transparency Act(FFATA), and to establish guidance and policy regarding the inclusion of the relatedspecial grant award conditions established by OMB for the purpose of ensuring compliancewith FFATA. The policy further requires all prime awardees to report sub-awards by theend of the month following the month the award or obligation was made. Prime awardeesand sub-awardees information is reported to the Federal Sub-award Reporting System(FSRS) and is made available to the public via USASpending.gov. Department programstaffensure grantee compliance with FFATA reporting requirements, by including theapplicable Grant Award Notification (GAN) attachment with GANs that are to be issued toprime awardees that must comply with FFATA reporting requirements. Program staff alsoremind these grantees of their reporting requirements during monitoring.

19. If your agency interacts directly with USASpending.gov, in addition to submittinginformation to the systems that feed USASending.gov, describe the nature, frequency, andpurposes of that interaction.The Department interacts with USASpending.gov for bimonthly data submissions. Outsideofthis, the Department works with the USASpending.gov technical teams to answer datasubmission and display questions. The Department has contacted the USASpending.govteam approximately five times over the past year.

7


12/17


20. Describe the data quality controls and procedures that your agency has implemented forinformation that is submitted to USASpending.gov, including information submitteddirectly and information submitted to one of the systems that feeds USASpending.gov.For grant and loan data, Education staff conducts a 3-way validation ofthe data betweenthe G5 grant system, the file submitted, and USASpending. The Office of the ChiefFinancial Officer extracts information from the 05 grant system and validates it against theFMSS general ledger in order to generate monthly department-wide financial spendingreports. For contract data, the Education staff compares the FPDS-NO accounting dataagainst the accounting data in the Department's CPSS contract system. In addition, theagency Senior Procurement Executive certifies annually in writing the accuracy of the datathe Department submits to FPDS-NO.

21. State whether all of your agency' s current grants, contracts, and loans are accuratelyreflected on USASpending.gov, and, ifnot, estimate the percentage of current grants,contracts, and loans that are not accurately reflected, using both the number of transactionsand the dollar figures.99 percent of the Department's current grant data represented on USASpending.gov isaccurately reflected. 100 percent of the Department's current contract data represented onUSASpending.gov is accurately reflected.

22. State whether your agency incurs any reporting burdens or costs as a result of itsobligations under the Federal Financial Assistance Transparency Act ("FFATA") that itdoes not incur as a result ofother reporting obligations, and estimate those burdens andcosts in worker-hours and dollars.Approximately 1 FTE is required to support the FFATA reporting requirements.

8


13/17

Responses to Committee on Oversight and Government RefonnUS Department ofEducation

23. Identify the individual(s) who serve(s) as Senior Accountable Official(s) ("SAO") overfederal spending data quality for your agency, as defined by OMB.Danny A. Harris, Ph.D.Chief Information OfficerOffice of he Chief Information OfficerUS Department ofEducation

9


14/17

G5/GAPS

AR Bal, Unapplied Refunds, and AC

Treasury

GL - General LedgerAR - Accounts ReceivableFed Admin - FederalAdministratorPO - Purchase OrdersAP - Accounts PayableGAPS/G5 - Grants Management

Attachment 1EDCAPS System Flowchart

FSA FMS

0 -l :J],," ;, ; ~ ~ ,, ; ',Fed Admin I ,

Unbilledlockbox

FMSSOracle Financials

O , , ~ AP"I:

Nortridge

.; ;0. _ ~ _ ~ ~ ~ " - =" - " - : " 'i i : ' -. . . , . . , I " " k : " ,~ : ' ~ n ' - " ' ' ' ' ' ' ' '

CPSS

EOCAPSFunctionalArc h itectu re

HyperlonBudgetPlanning

e2TravelSystem

001


15/17

Attachment 2Federal Student Aid

Grant and Loan Financial Overview ChartExternal Partnars/Services I Department 01 Educltion Systems I other Government Systems

Common Services for Borrowers (CSa)

, ....(DLSS) 4.0 CentralProcessingSystemI , , , ~ ~ I .... dc..:! '"ac':::':6 O i t d l < u~ - r n { D M C S } T r ~ ~ ~ ( D U : ' ) 6.0 Commonf f 01iglnaUon &DisbursemenlI ! (COO)!

7.0 Trtle IV 3.0 Federal studenlAdditionsl Aid FinancialSe1Vi


16/17

Attachment 2to lenders (3.1) and guaranty agencies (3.2). It also performs validations and reasonabilitychecks to minimize erroneous payments.FMS is currently in "operations and maintenance" (O&M) mode.4.0 Central Processing System (CPS)Central Processing System (CPS) provides a centralized system for processing the FAFSA formand determining aid eligibility. CPS processes each submitted FAFSA through a series of datachecks, formula calculations, and data matching/verifications with other Federal agencydatabases. CPS also sends eligibility notifications to applicants, schools, service providers, andState agencies.5.0 eCampus-BasedThe eCampus-Based system addresses the Congressionally mandated activities of providingCampus-Based funds to eligible Title IV institutions. The Federal Perkins Loan, Federal WorkStudy, and Federal Supplemental Educational Opportunity Grant Programs are referred to asCampus-Based programs because the Department allocates these funds to participatinginstitutions for students who need financial aid to meet the costs of postsecondary education.The eCampus-Based system uses Web-based technologies that improve service, reduceimproper payment of student aid, and strengthen financial management and internal controls byproviding relevant and timely information in the management of day-to-day operations.6.0 Common Origination and Disbursement (COD)The COD system enables approximately 6,200 eligible institutions of higher education tooriginate and disburse approximately $41 billion of Title IV funds. These funds are disbursed toapproximately 9.6 million eligible students/recipients each award year under the Federal DirectLoan program, Federal PELL, ACG/SMART, IASG, and TEACH grant programs. The CODsystem processes, stores, and reconciles data from several FSA programs. The CODcontractor provides operation and maintenance, a call center, and customer service to assistinstitutions with processing data and managing their administration of Federal Direct Loans andgrants. The COD system began servicing Foreign School operations during the 2010/2011award year. In addition, COD serves as FSA's loan distribution vehicle across the Title IVAdditional Servicers (TIVAS).7.0 Title IV Additional Servicers (TIVAS)TIVAS provide a full range of serviCing functions for student loans such as processing ofpayments, debt collection, and loan consolidation. Customer services range from call centers tosystem maintenance and enhancements. The performance-based deliverable pricing structureof the contracts encourages the contractor to avert borrower delinquency and move delinquentborrowers to repayment status. Servicing costs are associated with three main drivers: 1) loanvolume, specifically unique borrowers; 2) timing of loan servicing, when unique borrowers beginreceiving loans; and 3) distribution of total volume among loan statuses: In-School, Grace orCurrent Repayment, Delinquency, and Default.These are not government-owned systems, but service contracts only with ACS EducationSolutions, LLC.

2


17/17

Attachment 2

Common Services fo r Borrowers (CSB)8.0 Direct Loan Servicing System (DLSS)The Direct Loan Servicing System (DLSS) services Direct Loans while borrowers are in school,in deferment status, or in repayment. DLSS, like the TIVAS, provides a full range of servicingfunctions for student loans such as processing of payments, debt collection, and loanconsolidation. In support of the 100% Direct Lending model, DLSS is in the process oftransferring its loan portfolio to the TIVAS model. DLSS will then be decommissioned.This is not a government-owned system, but part of a service contract with ACS EducationSolutions, LLC.9.0 Direct Loan Consolidation System (DLCS)The Direct Loan Consolidation System (DLCS) serves to simplify loan repayment by allowingthe borrower (Le., students) to combine several types of federal student loans with variousrepayment schedules into a single loan. The consolidated loans are then sent to the Title IVServicers (TIVAS) through the Common Origination and Disbursement (COD) system.This is not a government-owned system, but part of a service contract with ACS EducationSolutions, LLC.10.0 Debt Management & Collection System (DMCS)The Debt Management and Collection System (DMCS) is the repository and managementsystem for the Department's defaulted loan and grant overpayments that went to borrowersand/or schools. DMCS is responsible for the collection and servicing of these defaulted loansand grants.DMCS is in the process of being replaced by the new Debt Management & Collection System(DMCS2).DMCS and DMCS2 are not government-owned systems, but part of a service contract with ACSEducation Solutions, LLC.11.0 Conditional Disability Discharge Tracking System (CDDTS)The CDDT System supports financial servicing and tracks borrower claims for total andpermanent disability discharges. Final discharge of the loan and interest is made if the borrowermeets all eligibility requirements in an allotted period. If borrowers are determined to beineligible for disability based on program guidelines, they are returned to an active servicingstatus.In support of the 100% Direct Lending model, CDDTS is in the process of transferring its loanportfolio to the TIVAS model. CDDTS will then be decommissioned.This is not a government-owned system, but part of a service contract with ACS EducationSolutions, LLC.

3

Education Response

Documents

Transcript of Education Response