NASACT recently joined the American Institute of Certified Public Accountants, the Council of Governmental Relations and National Association of College and University Business Officers to sign a letter outlining concerns over the U.S. Department of Education’s (ED) audit requirements pertaining to Title IV funds.
 
Specifically, the groups are concerned about ED’s announcement that it will be requiring a separate annual compliance audit of Title IV Student Aid Programs, including the Student Financial Assistance (SFA) Cluster. The letter co-signers believe that ED’s requirement for a separate annual compliance audit is in direct conflict with the underlying principles of the Single Audit Act Amendments of 1996 and the recently issued Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (UG). Both the act and the UG are premised on effective and efficient use of scarce audit resources by focusing on a single audit that targets higher-risk programs.
 
The letter requests that OMB review ED’s position and consider the broader implications to federal single audit policy. Further, the letter asks OMB to work with ED and the groups to develop clear audit guidance to ensure a consistent understanding of how the audits of these programs are to be conducted and the criteria the programs are to be audited against. Lastly, the letter request a meeting with appropriate OMB senior-level staff and ED to review next steps; as this topic will likely be addressed in the 2017 OMB Compliance Supplement, the letter proposes that this meeting take place in a timely manner so as not to interfere with its development. 

NASACT will keep members apprised. Questions may be directed to Kinney Poynter or Cornelia Chebinou.