The U.S. Department of Education, Office of Inspector General has published 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 grant program awards, a proprietary school must have a compliance audit conducted of its administration of the HEERF grant programs for any fiscal year during which the eligible school expends $500,000 or more in total HEERF grant program funds or 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. 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 March 31, 2021, for the first fiscal year during which a proprietary school expends HEERF award funds. Report packages for the compliance attestation engagements conducted in accordance with the Guide must be submitted within the later of 120 days after March 31, 2021 (July 29, 2021), or the submission deadline for the school’s Title IV audit, as established by Title 34 of the Code of Federal Regulations § 668.23(a)(4), including any extensions granted by the U.S. Department of Education for those audits.

If you are a proprietary school subject to audit in accordance with the Guide, please ensure that your auditor is using the Guide, starting with the first fiscal year during which your school expends HEERF award funds. The Guide and the related transmittal letter are available on the OIG Non-Federal Audit website at https://www2.ed.gov/about/offices/list/oig/nonfed/proprietary.html