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Articles by David B. McClintock, CPA

Understanding Your Composite Score: 3 Key Drivers

Understanding Your Composite Score: 3 Key Drivers

By David B. McClintock, CPA 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 Triggers can cause ED to require a school to recalculate its Composite Score making it more important than ever to really understand how it is...

Why is ED Requiring Fiscal Year to Match Tax Year?

Why is ED Requiring Fiscal Year to Match Tax Year?

By David B. McClintock, CPA 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 Ability to Benefit (ATB) | Knowledge Center), reinforces the proposed requirement by ED to align postsecondary institutions’ fiscal year end (FYE) with the institution’s tax...

The Updated 90/10 Rule: What’s New and What’s the Same

The Updated 90/10 Rule: What’s New and What’s the Same

By David B. McClintock, CPA May 4, 2022

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...

HEERF Annual Reporting Primer

HEERF Annual Reporting Primer

By David B. McClintock, CPA January 20, 2021

During 2020, the Higher Education Emergency Relief Fund (HEERF), included as part of the wide-ranging CARES Act, provided a lifeline to institutions of higher education and their students. As the policy and requirements for both the student and institutional grants evolved over the year, schools were required to post regular...

A Primer on Institutional HEERF Grant Reporting

A Primer on Institutional HEERF Grant Reporting

By David B. McClintock, CPA October 20, 2020

No tricks, a major deadline looms for postsecondary educational institutions just before Halloween. The first round of quarterly reporting for the institutional portion of the Higher Education Emergency Relief (HEERF) Grant is due October 30, meaning institutions cannot delay in preparing and posting their reports. Check out this rundown concerning the...

The 13 Major Provisions of Title IX’s Final Rule

The 13 Major Provisions of Title IX’s Final Rule

By David B. McClintock, CPA August 31, 2020

After years of debate, the U.S. Department of Education’s (ED) new Title IX regulations took effect in August. ED’s final rule details the responsibilities of schools that receive federal funds in responding to allegations of sexual assault and harassment. Along with Title IX coordinators, all leaders at postsecondary education institutions should...

How to Submit for Higher Education Emergency Relief Funds

How to Submit for Higher Education Emergency Relief Funds

By David B. McClintock, CPA April 13, 2020

Following last week’s announcement of the $6 billion Higher Education Emergency Relief Fund to aid students amid the COVID-19 pandemic, the Department of Education (ED) has provided a set of resources as it prepares to disburse funds to institutions. We recommend visiting ED’s relief fund web page here. It includes: A...

CARES Act Analysis Summary

By David B. McClintock, CPA March 31, 2020

  Higher Ed Colleagues: As we continue to work to understand the impact that the stimulus bills will have on Title IV and businesses, we want to help you do the same. In an effort to keep you informed, we’ve compiled a list of resources that expound on the CARES Act’s impact on...

ED’s COVID-19 Guidance and FAQ

By David B. McClintock, CPA March 24, 2020

  Hello friends, As we begin another week, we hope you are all doing well and successfully transitioning to new circumstances. We also would like to direct your attention to the Department of Education’s (ED) updated guidance related to Title IV compliance and interruptions of study caused by the COVID-19 outbreak. The update...

Allowance Accounting and the Biggest Issues Institutions Face

Allowance Accounting and the Biggest Issues Institutions Face

By David B. McClintock, CPA February 7, 2020

The allowance for doubtful accounts related to student receivables is often the least precise measurement on a school’s balance sheet.  Few items on a financial statement can have a greater influence on profitability. As an estimate of an institution’s expectation of what it will not collect from students’ accounts receivable,...

How to Avoid a Letter of Credit After a Change in Ownership

How to Avoid a Letter of Credit After a Change in Ownership

By David B. McClintock, CPA April 10, 2019

Making an acquisition in a highly regulated industry like postsecondary education means following required procedures and obtaining approvals from multiple agencies. Often, the most significant approval comes from the U.S. Department of Education (ED) because the approval can include a requirement to post a letter of credit with ED as...