McClintock Minute


Recent Title IV Compliance Articles


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…


Amid COVID-19, ED Provides Regulatory Flexibility

By Catherine Demchak, M. Ed, CFAA July 14, 2020

As the coronavirus crisis continues and an uncertain new school year approaches, the U.S. Department of Education (ED) recently announced some leniency on certain regulatory reporting and disclosures. ED extended the deadlines for the following: Campus and Fire Safety: Institutions must distribute their Annual Security Reports (ASRs) and Annual Fire…


Does Your Institution “Act CAREfully” When it Comes to Accounting, Recording Keeping and Documentation of Federal Funds?

By Michael T. Wherry, CPA June 24, 2020

This article was original published in the May 2020 Career Education Review and reproduced here with permission.  Article originally posted at  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…


Institutional Portion of the CARES Act – ED Webinar Guidance

By Michael T. Wherry, CPA June 24, 2020

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…


Year-End Financial Responsibility Planning

By Michael T. Wherry, CPA June 23, 2020

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…


Updated Covid-19 Return to Title IV Funds Relief

By Michael T. Wherry, CPA June 19, 2020

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…