The U.S. Department of Education, Office of Inspector General has published the 2022 version of the Guide for Compliance Attestation Engagements of Proprietary Schools Expending Higher Education Emergency Relief Fund Grants (Guide). The Guide applies to and provides requirements and guidance for compliance attestation engagements of proprietary schools, as defined in Title 34 of the Code of Federal Regulations § 600.5, receiving Higher Education Emergency Relief Fund (HEERF) grants through the Coronavirus Aid, Relief, and Economic Security Act; the Coronavirus Response and Relief Supplemental Appropriations Act, 2021; the American Rescue Plan; or any future acts passed by Congress that include HEERF (collectively, HEERF grant programs).
As a condition of the HEERF awards, a proprietary school must have a compliance audit conducted of its administration of the HEERF grant for any fiscal year during which the eligible school expends $500,000 or more in total HEERF grant program funds, is on Federal Student Aid’s Heightened Cash Monitoring 1 or 2 list in a fiscal year in which it expended any HEERF grant program funds, or has closed or is in the process of closing. The HEERF compliance audit must be conducted in accordance with Generally Accepted Government Auditing Standards, issued by the Comptroller General of the United States, and the Guide. To satisfy the HEERF compliance audit requirement, the Guide requires an examination-level attestation engagement.
The Guide is effective for fiscal years beginning after June 30, 2021, and thereafter (with early implementation allowed and encouraged). This Guide supersedes the March 2021 version and the associated Dear CPA Letters.
If you are a proprietary school subject to audit in accordance with the Guide, please ensure that your auditor is using the correct version of the Guide, based on your fiscal year end. The Guide and the related transmittal letter, which includes a summary of major changes, are available on the OIG Non-Federal Audit website at https://www2.ed.gov/about/offices/list/oig/nonfed/proprietary.html.
Contact Information
Questions pertaining to the Guide may be directed to the Office of Inspector General’s Non Federal Audit Team via email to OIGNon-FederalAudit@ed.gov.