Less than two weeks before it was set to end, the COVID-19 national emergency was extended by President Joe Biden. Citing ongoing public health and safety risks presented by the pandemic, the declaration published in the Federal Register on February 18, 2022, continues the emergency beyond its March 1, 2022,...
McClintock Minute
Recent Title IV Compliance Articles
ED Opens Application Periods for Additional HEERF III and SSARP Funds
As postsecondary institutions nationwide continue to contend with hardships caused by the COVID-19 pandemic and seek to assist their students, the Department of Education (ED) is reopening the application period for Higher Education Emergency Relief Funds, as well as a supplementary program. According to an ED notice, eligible institutions have until...
New opinions: What to know about the latest auditor report changes
It’s a fact: auditor reports continue to change — even the opinions. For entities with a December 31, 2021, year-end or later, there are notable changes to reports’ “Opinion” section and other areas that must be implemented. Read on for why and what the changes look like. In May of 2019, the...
Even half a year after new rules for Return to Title IV (R2T4) exemptions went into effect — and as we consider specific scenarios stemming from the changes — we continue to learn more and fill in the gaps in knowledge to assist institutions. Recently, we contacted the Department of Education...
Analyzing the Revised HEERF Annual Performance Reporting Form
As initially proposed in June of 2021 and subject to two comment periods, the U.S. Department of Education (ED) has released the revised Annual Performance Reporting (APR) form to capture the use and application of the Higher Education Emergency Relief Fund (HEERF) grants. As a reminder, the APR filing is based upon...
Key Points from the OIG’s Annual Plan: M&A’s Analysis
The chief responsibility of the Department of Education’s (ED) Office of the Inspector General (OIG) is to detect waste, fraud and abuse — intentional or not — within ED and the institutions under its purview. Its recently released 2022 Annual Plan provides a roadmap and points of emphasis regarding that...
Ready for 2022? Mark Up Your Calendars with These Dates to Know
Got a fresh 2022 daily planner? As nice as it is to see the blank pages, it’s time to start filling them. With the new year comes a new set of financial reporting due dates and notable milestones to mark. Each month brings different challenges, and we know how difficult it...
Financial Student Aid Regulation Changes: Determining the R2T4 Denominator (Updated)
Update (10/19/21): The department of Education (ED) has issued additional guidance effective 10/6/21 for Institutions not using an R2T4 Freeze Date: If the student is only eligible for Pell Grant, Iraq-Afghanistan Service Grant, and/or TEACH Grant funds during the period and the institution does NOT use an R2T4 Freeze Date, the...