Understanding Your Composite Score: 3 Key Drivers
August 22, 2024
The U.S. Department of Education (ED) has been calculating an institution’s Composite Score as part of its annual assessment of Financial Responsibility. However, new Financial...
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Why is ED Requiring Fiscal Year to Match Tax Year?
May 29, 2024
The U.S. Department of Education’s (ED) Dear Colleague Letter issued May 16, 2024 (Implementation of Regulations Related to Financial Responsibility, Administrative Capability, Certification Procedures, and...
Recent Articles
While exhibiting at NASFAA’s 2024 Leadership & Legislative Conference & Expo, Parker Charlton, FAAC® and I had the opportunity to attend sessions featuring both the Secretary of Education, Miguel Cardona, and a panel of Department of Education (ED) officials. They acknowledged the challenges posed by the 2024-2025 FAFSA and subsequent...
New Financial Responsibility Standards
February 8, 2024
Introduction Financial Responsibility, as defined by the U.S. Department of Education, is a condition of eligibility for a school participating in FSA programs, requiring that schools submit an audited financial statement to ED each year. Recently, the conditions for meeting these important requirements changed in ways that may add complexity to...
Audit Guide Updates
January 19, 2024
Looking back, 2023 was a dynamic year marked by growth and new challenges facing institutions. With the national emergency coming to an end, FAFSA simplification rolling out, and an updated audit guide, institutions have a unique opportunity to make 2024 a season of growth and a refresher on best practices. Out...
What to Expect from the Updated CECL Accounting Standard
January 11, 2024
In response to the financial crisis in 2008, the Financial Accounting Standards Board (FASB) took action for revisiting the methodology for recognizing credit losses as the existing approach to estimating credit losses was determining whether such losses met the threshold of being “probable”, regardless of whether or not they were...
GLBA Safeguards: Protecting Your School Against Cyber Threats
November 15, 2023
The 2023 updates to the Gramm-Leach-Bliley Act introduce several new requirements for schools when it comes to protecting student financial records from cyber threats. Here are key recommendations for safeguarding your data, which fall under three overarching strategies. When implemented properly, these can help higher education institutions address systemic cybersecurity...
GLBA Compliance Issues to Watch
November 2, 2023
On June 9, 2023, the Federal Trade Commission (FTC) rolled out significant updates to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule, requiring financial institutions and organizations to take immediate action to ensure compliance. Since this summer update, the team at McClintock has been working with institutions to review compliance risks and recommend...
Financial Responsibility Standards Proposed Regulations — How Stable Is Your Institution?
June 16, 2023
The U.S. Department of Education (ED) recently released proposed rule changes for strengthening monitoring and oversight of colleges and universities. These changes cover general standards of financial responsibility, and add new reporting requirements, among other updates reviewed below. We recommend that institutions review these changes to identify any potential issues. That...
The U.S. Department of Education (ED) published the change in ownership (CIO) rule in the fourth quarter of 2022. The rule goes into effect July 1, 2023, and impacts every step of this process. It includes new notifications that are required before any CIO, an updated approval process, and requirements...