“‘Kafka-esque’ and ‘bureaucratic bungling’ were the words chosen by the U.S. Court of Federal Claims in describing the U.S. Department of Education’s determination that San Juan City College, a Title IV participant, had closed and its subsequent decision to withhold Title IV funds from the school. The ‘bungling’ involved the Department’s erroneous conclusion in February 1995 that San Juan City College had ceased operations and its failure to acknowledge its error until it had deprived the school of Title IV funding for a full six months.”