In March 2021, 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,…
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Recent Title IV Compliance Articles
The Trouble With SAM
Is your school having trouble drawing down federal student aid for any of its locations? Earlier this month, the General Services Administration (GSA) as well as the U.S. Department of Education (ED) officially discontinued the use of the Data Universal Numbering System (DUNS) number and began recognizing the Unique Entity…
The latest negotiated rulemaking session featuring the Department of Education’s (ED) Institutional and Programmatic Eligibility Committee concluded March 18 — and I appreciated the chance to be a part of it. As a committee advisor representing compliance auditors who work with institutions that participate in Title IV, I was able…
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…
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,…
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…
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…
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…