The Department of Education’s Office of Inspector General issued the Guide for Compliance Attestations Engagements for Proprietary Schools Expending Higher Education Emergency Relief Fund Grants on March 31.
The Guide is effective immediately for the first fiscal year during which a school has expended HEERF funds, which for most institutions will be any fiscal year starting after April 1, 2020. Any proprietary school that expended more than $500,000 in HEERF funds during the fiscal year, or expended HEERF funds in any amount while also on HCM1 or HCM2 status, will be subject to audit under this new Guide.
The audit must be completed and submitted to the Department through the eZ-Audit portal the later of 120 days of issuance of the Guide (which would be roughly July 30, 2021) or the submission deadline for the school’s Title IV Audit (including any extensions granted by ED). Obviously, for institutions with a calendar based fiscal year, the timing on this additional audit is a bit challenging, since most have already started and, in some cases, completed their Title IV audit. This new audit will have some overlap with that process, but the HEERF funds audit is a different type of examination that cannot be added as another component of the annual Title IV compliance audit. There must be a separate engagement letter, testing and report issued by the auditor.