Recent guidance from the U.S. Department of Education (ED) brings both relief and important clarification for institutions navigating financial responsibility requirements and the 90/10 rule. While some regulatory pressure has eased, the updates introduce new considerations that institutions should evaluate carefully. This article breaks down what has changed, what it means...
The U.S. Department of Education has issued new interpretive guidance that significantly impacts how proprietary institutions calculate revenue under the 90/10 rule. This change represents a major victory for schools offering non-Title IV programs via distance education. What Changed? In a reversal of its 2022 position, the Department now confirms that proprietary...
For those of us invested in the future of higher education, the past few years have been anything but predictable. From shifting federal policies to mounting student loan concerns, institutions are navigating a landscape that’s constantly evolving. That’s why gathering in Washington, D.C., for CSPEN’s 7th Annual Higher Education Policy Meeting...
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...
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 90/10 rule near the end of 2022 that includes significant changes beyond just redefining what funds should be included in both sides of that equation. This makes it crucial that institutions understand the nuanced changes, update their processes to calculate 90/10, and undergo...
As a parent, sending a child to school seems so far off when they are born. However, eventually the day comes, whether they (or you) are ready or not. Most parents spent multiple years preparing their child for school to make the transition a great experience for everyone: themselves, teachers,...
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...
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...
Practice makes perfect, right? With year two of the Higher Education Emergency Relief Funding (HEERF) audits in process, we want to share some best practice points before the next HEERF Annual Performance Report (APR) submission period opens. As a reminder the HEERF APR for the January 1, 2021, to December 31,...
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...
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...
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...
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...
Institutions have one last chance to comment on the Department of Education’s (ED) proposed changes to the annual reporting form for Higher Education Emergency Relief Fund (HEERF) grants. ED released its response to the first round of public comments earlier this month, adopting some changes after commenters’ input and declining others....
From discussions with various clients, for-profit institutions are receiving the following email in regard to future audits of their Higher Education Emergency Relief Funding (HEERF) grants and these emails are causing confusion: To: Department of Education Grant Recipients From: Phillip Juengst, Deputy Assistant Secretary, Office of Acquisition and Grants Administration Subject: Single Audit...
Institutions that have yet to post reporting to their website regarding their first quarter utilization of the student portion of Higher Educations Emergency Relief Fund (HEERF) grants may need to do so immediately. In addition, there is an upcoming deadline for institutional reporting. The due date for the use of student...
This article was published in the May 2021 issue of Career Education Review and reproduced here with permission. Article originally posted at careereducationreview.net. As we frequently say in our office, “Don’t ask questions that you don’t want the answer to” — and the issuance of the Guide for Compliance Attestation Engagements...
On March 19, 2021, the U.S. Department of Education (ED) released long awaited guidance on the uses of the Higher Education Emergency Relief Funding (HEERF) grants included in the various coronavirus relief legislation passed over the previous year: the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which created the...
This article was originally published in the March 2021 issue of Career Education Review and reproduced here with permission. Article originally posted at careereducationreview.net. If you’re getting a sense of déjà vu, you’re probably not alone, as more coronavirus relief programs with some familiar names are top of mind for higher...
On December 27, 2020, the Consolidated Appropriation Act, 2021 (Act) was signed into law which includes relief funds for the COVID-19 pandemic. This Act is hopefully going to provide continued relief to individuals and our economy. The Act’s relief provisions included $81.88 billion for the Education Stabilization Fund and $23...
Just in time for the holidays, Congress passed a new $900 billion stimulus bill in response to the ongoing COVID-19 pandemic. Of particular note is the $284 billion set aside for a second round of funding for the popular Paycheck Protection Program (PPP), which provided forgivable Small Business Administration (SBA)...
On December 11, the U.S. Department of Education (ED) issued a Federal Register notice updating waivers and modifications of statutory and regulatory provisions governing the Federal student financial aid programs. We have reviewed these provisions and identified the items that will have the greatest impact on our audit procedures. Read on...
On October 2, 2020, the U.S. Department of Education (ED) published “Round 3” for Frequently Asked Questions related to the Higher Education Emergency Relief Fund (HEERF) grants. This document addressed questions related to the usage of the HEERF grants for institutional and student purposes. McClintock & Associates (M&A) has reviewed and...
The Department of Education (ED) on September 28 announced the implementation of the quarterly public reporting requirement for the institutional portion of the Higher Education Emergency Relief Fund (HEERF), as well as a new reporting form. The form includes sections for institutional dollars provided for emergency financial aid grants or tuition...
We have been fielding questions from several clients in regard to the guidance surrounding when a student who withdraws can be treated as a COVID-19 drop and be eligible for the R2T4 relief provided as part of the CARES Act. Thus, we felt a reminder was in order of the...
Based upon the electronic announcements issued by the U.S. Department of Education (ED) and the relief provisions in the CARES Act, we have been receiving numerous questions from institutions on implementing and interpreting this guidance. As a result, we have compiled this Questions and Answer for institutions to utilize as...
This article was original published in the May 2020 Career Education Review and reproduced here with permission. Article originally posted at careereducationreview.net. Co-authored by Dave McClintock, CPA. The American political satirist P.J. O’Rourke once opined, “giving government power and money is like giving a 16-year old keys to the car and...
On June 23, 2020, the U.S. Department of Education’s Office of Postsecondary Education provided a technical assistance webinar related to the Higher Education Emergency Relief Funding (HEERF) provided by the Coronavirus Aid, Relief and Economic Security (CARES) Act. This webinar provided guidance to institutions which mainly focused on the institutional...
An institution with a June 30 year-end should ensure a check of their financial responsibility is performed before the month of June is over. Once an institution is past its year-end, very limited options are available. At this point in time, the Department of Education (ED) has not waived any financial...
On June 16, 2020, the U.S. Department of Education (ED) issued updated information related to their May 15, 2020 Guidance for interruptions of study related to Coronavirus (COVID-19). The revised guidance can be found here: The updated information was solely related to the Return to Title IV (R2T4) Relief and made...
The U.S. Department of Education (ED) decided April 9th was a good time to issue guidance on multiple items. ED released an electronic announcement responding to questions submitted in regard to the composite score ratio which becomes effective July 1, 2020 as part of the Borrower Defense to Repayment regulations...
The Department of Education (ED) on May 6 provided some clarification about the timing of reporting requirements for institutions that receive Higher Education Emergency Relief Fund (HEERF) grants for students. The same announcement also offered more detail about reporting on institutions’ websites. Section 18004(e) of the CARES Act originally required institutions...
Co-authored by Audrey Kaplan. Since the U.S. Department of Education’s April 9, 2020, announcement of the forthcoming release of the student emergency funds as noted in Section 18004(c) of the Coronavirus Aid, Relief and Economic Security Act (CARES Act), we have had numerous discussions with clients in regard to the awarding,...
McClintock & Associates has begun to review the Higher Education Emergency Relief Fund which was included in the CARES Act. Within the Act, under Section 18004(a)(1), the U.S. Department of Education (ED) will distribute these funds to all institutions based upon the relative share of full-time equivalent enrollment of Federal...
Note: The U.S. Department of Education (ED) has not issued any guidance related to provisions in the CARES Act. We anticipate ED will issue further guidance. This summary is for general guidance and informational purposes only, and should not be relied upon for regulatory compliance. Situations specific for your institution...
This article was original published in the February 2020 Career Education Review and reproduced here with permission. Article originally posted at careereducationreview.net. Remember the scene from the movie “2001: A Space Odyssey” in which it takes an astronaut what seems like forever to move across the scene? As a CPA, the...
After committing two years ago to making significant changes to the borrower defense to repayment regulations, the Department of Education (ED) released finalized office rules on Sept. 20, clarifying existing pieces and overhauling many other facets. While these changes affect the nature of claims, procedural steps and items related to...
The recent rescission of the Gainful Employment (GE) regulations is akin to watching a Stanley Cup hockey game going into overtime. With every shot, you are riding a wave of exultation or fear as the outcome of the game could occur at a moment’s notice. Similarly, regulatory whiplash occurred over much...
On March 5, 2019 ED published new guidance to address when books, supplies, etc. are considered to be institutional charges and how these charges should be properly recognized for Title IV purposes. ED defined clearly that an institutional charge must be recognized over the entire period for which the charge...
This article was original published in the May 2019 Career Education Review and reproduced here with permission. Article originally posted at careereducationreview.net. As Herb Brooks famously told the U.S. Olympic hockey team late in the 1980 game against the USSR – “Play Your Game” – these words ring true today. Herb...
The Department of Education (ED) simplified parts of the 2019 Gainful Employment Disclosure Template, with ED outlining the changes in a May announcement (Gainful Employment Electronic Announcement #119). In the weeks leading up to the July 1 deadline to comply with the changes, ED also gave institutions some important clarity...
On March 15, 2019, the U.S. Department of Education (ED) issued a long-awaited announcement providing guidance for the implementation of the Borrower Defense to Repayment (BDTR) regulations, which the U.S. District Court ruled was unlawful back in October. You might remember ED proposed a new set of regulations determining if...
Over the past couple of years, a handful of Accounting Standard Updates (ASU) issued by the Financial Accounting Standards Board (FASB) related to business combinations and consolidations have had an impact on our clients. Since increased merger and acquisition activity has been seen in 2018, a short summary of the...
Originally published in the October 2018 issue of Career Education Review, and reproduced here with permission. Article originally posted at careereducationreview.net Over the summer, I have been reflecting on the impact of the September 2016 Guide for Audits of Proprietary Schools and for Compliance Attestation Engagements of Third-Party Servicers Administering Title...
By Michael Wherry, CPA The old adage “what doesn’t kill you makes you stronger” is relevant to our clients who have gone through their first student financial aid compliance audit under the September 2016 Audit Guide (Guide). The Guide certainly caused an increase in the amount of work and posed some...
By Michael T. Wherry, CPA, Director/Shareholder and Ted Blendermann, CPA Director/Shareholder, McClintock & Associates, PC Originally published in the June 2017 issue of Career Education Review, and reproduced here with permission. Article originally posted at careereducationreview.net Remember in the movie the Perfect Storm, how three independent storms collided to create disaster for...
Originally published in the November 2016 issue of Career Education Review, and reproduced here with permission. Article originally posted at careereducationreview.net When the expression “all good things come to those who wait” was first used it probably didn’t have the student financial program regulations in mind. While postsecondary schools and auditors have been...
By Michael T. Wherry, CPA The Financial Reporting Framework for Small and Medium-Sized Entities (FRF for SME) is a self-contained financial reporting framework not based on accounting principles generally accepted in the United States of America (GAAP). Special purpose frameworks, with the exception of the contractual basis of accounting, are commonly...
By Michael T. Wherry, CPA With summer vacations on the horizon and with the 6/30 audit deadline now in the “rearview mirror”, it is a good time for schools to perform a mid-year check-up of financial and regulatory items as a form of preventive maintenance. Planning in advance of year end...