October 1 Compliance Deadlines Are Approaching. Is Your Institution Ready? 

October 1 is an important date on many higher education compliance calendars. This year, institutions may be preparing for several federal reporting and disclosure obligations, including: 

• Annual FISAP submission
• Annual Security Report (ASR) distribution
• New hazing-related reporting requirements within the ASR
• Gainful Employment (GE) and Financial Value Transparency (FVT) reporting  

Because these requirements often involve multiple offices across campus, institutions may benefit from revisiting submissions, disclosures, and supporting documentation in advance of the deadline. 

FISAP: Time for the Initial Submission 

Institutions participating in federal campus-based aid programs are required to submit the Fiscal Operations Report and Application to Participate (FISAP) by October 1. 

As institutions put the finishing touches on their initial FISAP submissions, a few last-minute checks may be worthwhile: 

• Confirm campus-based expenditures reconcile to institutional records.
• Review key data elements for completeness and accuracy. 
• Ensure any unusual transactions, adjustments, or manual calculations are appropriately documented.
• Save the reports, reconciliations, calculations, and other supporting documentation used to prepare the FISAP in a centralized or shared location. 

Institutions should also remember that the October 1 deadline is not necessarily the end of the process. Corrections to the FISAP may be submitted through December 15, 2026. As a result, institutions that identify errors or omissions after the initial October submission still have an opportunity to update their reporting during the correction period.   

Maintaining a complete FISAP support file that includes the reports, reconciliations, calculations, and other documentation used to prepare the submission is necessary.  Having a clear record of how amounts were derived will help streamline future audits, support corrections submitted during the correction period, and reduce the effort required to respond to questions months after the report is filed. 

Annual Security Report: New Hazing Reporting Requirements Join Existing Obligations 

By October 1, institutions are required to make their Annual Security Report (ASR) available to current and prospective students and employees. The report must include campus crime statistics and required safety and security disclosures under the Clery Act. 

The 2026 ASR cycle will also be the first year institutions are required to include hazing statistics under the Stop Campus Hazing Act. Hazing statistics collection began in 2025 and are required to be disclosed in the October 1, 2026 ASR. 

Before finalizing the ASR, institutions must ensure: 

• Reportable hazing incidents have been identified and documented. 
• Required hazing-related policies and prevention disclosures are included in the ASR. 
• A Campus Hazing Transparency Report has been published and maintained in accordance with applicable requirements. 
• Hazing statistics collected under the Stop Campus Hazing Act are incorporated into the October 1, 2026 Annual Security Report. 
• Internal reporting processes support accurate and consistent disclosure of hazing-related information. 

We recommend that institutions use the 2026 ASR preparation process as an opportunity to review the report in its entirety, not solely the new hazing requirements. Institutions should confirm that all required Clery Act statistics, policy statements, emergency procedures, and VAWA-related disclosures are complete and current, and retain the documentation used to support reported statistics and disclosures for audit and compliance purposes. 

Gainful Employment and Financial Value Transparency Reporting 

Gainful Employment and Financial Value Transparency reporting remains a significant October 1 compliance obligation for almost all institutions. 

As discussed in our recent article, Earnings Accountability: Understanding the Framework, the Department has provided institutions with an opportunity to participate in early implementation of the STATS and Earnings Accountability regulations. As institutions prepare for the October 1 reporting deadline, they may wish to understand how current reporting data could be used in future accountability calculations and ensure their underlying data is accurate and well documented. 

As part of that preparation, considerations may include: 

• Validating source data and reported outcomes. 
• Reviewing internal approval and quality-control processes. 
• Retaining documentation that supports reported data and calculations. 
• Reviewing the institution’s approach to any available Earnings Accountability early implementation opportunities. 

We recommend using the reporting process as an opportunity to evaluate data governance, documentation practices, and program-level reporting controls. Similar to our other sections, maintaining clear support for reported data may help institutions respond to future reporting, compliance, or accountability requirements as additional guidance becomes available. 

Final Thoughts 

October 1 brings together several significant compliance obligations, each with its own reporting requirements and operational considerations. For many institutions, the challenge is not simply understanding the requirements, but coordinating the people, systems, and documentation necessary to support accurate reporting. 

While some of this year’s requirements are new, much of the work remains the same: understanding the rules, compiling accurate information, meeting deadlines, and maintaining support for what was reported. 

And yes, as auditors, we are intentionally repeating the importance of documentation. There is a reason for that. Good documentation not only helps demonstrate compliance, but also helps institutions reconstruct how decisions were made and how figures were compiled months or even years later. The same records that help an auditor or program reviewer understand what happened often help the institution answer its own questions when staff change, systems evolve, or reporting assumptions are revisited. 

As October 1 approaches, a final review of submissions, supporting documentation, and internal processes may help reduce surprises and make future compliance, audit, and reporting activities a little easier for everyone involved. 

For other important reminders, check out our Dates to Know Calendar. 

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Kimberly Cravotta, FAAC®, is a leader within the Compliance Department at McClintock & Associates and has extensive experience in Title IV compliance and financial aid administration. She provides guidance to institutions on regulatory requirements, compliance considerations, and operational best practices.