The Education Department is on track to release the 2026–27 Free Application for Federal Student Aid by Oct. 1, but a government watchdog warned this week that future forms are at risk of technical issues.

The Government Accountability Office, in its second report on the botched launch of the 2024–25 FAFSA, found that the department has yet to implement a number of its recommendations from the first report released in September 2024. Additionally, the agency needs to improve its oversight of contractors. The GAO also noted that the department doesn’t have a plan for testing future FAFSAs and that staff overseeing the application lack key experience and training.

“Until [the Office of Federal Student Aid] makes progress in these important areas, [the FAFSA Processing System] is at risk of not functioning as intended in future releases, leading to students having trouble in obtaining timely aid,” the report states. “Further, the FPS contract is at risk of overexpenditure and potentially wasting taxpayer dollars. These risks are compounded by reductions in staff that likely impact the agency’s ability to carry out its mission to manage and oversee student financial assistance programs.”

FSA officials took issue with parts of the report and recommendations in a response to the agency.

“We believe that GAO’s analysis teaches the wrong lessons and, as an unintended consequence, reinforces the exact practices that led to the FAFSA’s initial challenges,” wrote Aaron Lemon-Strauss, executive director of the FAFSA program.

Lemon-Strauss said GAO is applying a “more traditional, and somewhat outdated, project-based model that does not support modern technology development for scaled systems like the FAFSA.” He went on to outline a number of changes that the department made to improve the system, as well as the key challenges they faced.

Among other things, he noted that FSA had no internal engineering expertise until last year and that contractors working on different pieces of the process used different tools that didn’t integrate with each other.

“The team is still working to unwind these parallel environments and the technical debt created by these decisions today,” he wrote.

GAO officials disagreed with some of the department’s statements and proposed changes to their recommendations, countering that the review was based on both federal and department guidelines and that ED needs a way to hold its contractors accountable.

“As our report notes, FSA was not appropriately overseeing the work of its contractor and did not adequately ensure rigorous testing of the system,” officials wrote. “By not doing so, FSA put the FAFSA modernization effort at risk of failure, which their letter points out.”