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Recent Title IV Compliance Articles

Financial Responsibility Standards Proposed Regulations — How Stable Is Your Institution?

Financial Responsibility Standards Proposed Regulations — How Stable Is Your Institution?

By Michael T. Wherry, CPA 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….

2023 Changes to the 90/10 Rule Require Careful Analysis

2023 Changes to the 90/10 Rule Require Careful Analysis

By Michael T. Wherry, CPA March 13, 2023

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…

ED’s Fresh Start Initiative: What Institutions Need to Know

ED’s Fresh Start Initiative: What Institutions Need to Know

By James Ference September 15, 2022

It’s been a good time for student loan borrowers lately. Not only did the Biden administration just announce a partial loan forgiveness policy, but the Department of Education’s (ED) Fresh Start initiative is giving some borrowers who defaulted on their federal loans before or after the pandemic payment pause another…

What to Expect from the New Gainful Employment Rule

What to Expect from the New Gainful Employment Rule

By Michael T. Wherry, CPA August 1, 2022

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…

Facing Audit Phobia, Part III: Embrace Learning Opportunities

Facing Audit Phobia, Part III: Embrace Learning Opportunities

By Luke Hoey, FAAC® July 26, 2022

The last thing an institution wants to hear while undergoing an audit is, “We’ve identified some processes that aren’t compliant with Title IV rules.” In a perfect world, a compliance audit comes and goes swiftly and without any findings. But in the real world, one where regulations change regularly and…

Facing Audit Phobia, Part I: The Latest Trends

Facing Audit Phobia, Part I: The Latest Trends

By Parker Charlton, FAAC® July 12, 2022

If we’re playing a word association game, then when a postsecondary education institution participating in Title IV aid programs hears the word “audit,” it’s likely to prompt a response of “confusion,” “anxiety” or even “fear.” It’s understandable, but frequently unfounded. In fact, a compliance audit can be a good thing…