Audit Requirements Update

By Rick Cox

Popular topics at this year's virtual Federal Student Aid conference included updates on audit requirements for financial aid offices. Here are a few updates to keep an eye out for:

• Cash Management for HEERF (Higher Education Emergency Relief Fund) will be tested for the first time in fiscal year 2022.
• Automatic Extension of Performance Period was issued on April 4, 2022.
• The U.S. Department of Education should issue some type of guidance for auditors due to NSLDS issues. Keep an eye out for this.
• Auditors also need to be mindful of the COVID waivers that might affect compliance testing.

Dear Colleague Letter GEN-21-07 provides guidance on an auditor’s responsibility for evaluating and reporting on the Financial Responsibility Supplemental Schedule.

New changes to the audit guide are coming and will be effective for fiscal year 2023 audits (the current plan).

New: Auditors will be testing on state authorization for out-of-state institutions offering distance education, as well as testing changes to the Safeguards Rule of the Gramm-Leach-Bliley Act.

Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance