The U.S. Department of Education (ED) has sought to establish a definition of Gainful Employment (GE) for over a decade, and in more recent years, we’ve seen regulatory whiplash as priorities and opinions change. An initial attempt to establish a rule by the Obama administration was thrown out in a legal...
The last thing an institution wants to hear while undergoing an audit is, “We’ve identified some processes that aren’t compliant with Title IV rules.” In a perfect world, a compliance audit comes and goes swiftly and without any findings. But in the real world, one where regulations change regularly and it’s...
Chances are you haven’t seen your auditor around the office for quite a while — and some people might be just fine with that. After all, audits normally don’t rank highly on a financial aid professional’s list of favorite annual activities. However, the past two-plus years of pandemic gave rise to...
If we’re playing a word association game, then when a postsecondary education institution participating in Title IV aid programs hears the word “audit,” it’s likely to prompt a response of “confusion,” “anxiety” or even “fear.” It’s understandable, but frequently unfounded. In fact, a compliance audit can be a good thing for...
If your institution is still utilizing Higher Education Emergency Relief Fund (HEERF) grants, take note: the Department of Education (ED) just released a new Quarterly Reporting Form (QRF) that includes some substantial changes from previous versions. The new form is to be used beginning with Q2 2022 reports and is due...
In March 2022, the Department of Education (ED) reached consensus with non-federal negotiators on a crucial regulation for proprietary institutions: the 90/10 rule. Broadly, the 90/10 rule requires proprietary institutions to receive at least 10% of their revenue from nonfederal educational assistance sources every fiscal year. Because consensus was reached, the...
Is your school having trouble drawing down federal student aid for any of its locations? Earlier this month, the General Services Administration (GSA) as well as the U.S. Department of Education (ED) officially discontinued the use of the Data Universal Numbering System (DUNS) number and began recognizing the Unique Entity...
The latest negotiated rulemaking session featuring the Department of Education’s (ED) Institutional and Programmatic Eligibility Committee concluded March 18 — and I appreciated the chance to be a part of it. As a committee advisor representing compliance auditors who work with institutions that participate in Title IV, I was able to...