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Articles by Michael T. Wherry, CPA

New Financial Responsibility Standards

New Financial Responsibility Standards

By Michael T. Wherry, CPA February 8, 2024

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…

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…

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…

ED Releases New HEERF Quarterly Reporting Form

ED Releases New HEERF Quarterly Reporting Form

By Michael T. Wherry, CPA July 6, 2022

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…