Has ED Extended OIG Audit Guide Deadlines and Site Visit Alternatives Due To COVID-19?

This AskRegs Knowledgebase Q&A was updated on December 18, 2020 to note that the December 11, 2020 Federal Register reaffirms the six-month extension provided under earlier guidance, as well as provides additional clarification.

Yes.

Submission Deadlines: As described in the May 15, 2020 Electronic Announcement, the U.S. Department of Education (ED) has exercised its authority under the Higher Education Relief Opportunities for Students (HEROES) Act to extend by six months the deadlines for submission of financial statements and compliance audits under the September 2016 Audit Guide, Guide for Audits of Proprietary Schools and For Compliance Attestation Engagements of Third-Party Servicers Administering Title IV Programs (OIG Audit Guide). The December 11, 2020 Federal Register reaffirms that this six-month extension applies to "any such audits that are due to be submitted to the Department no later than March 1, 2020, through December 31, 2020, or other periods specified by the Secretary."

The Federal Register adds the following clarification:

"For IHEs and other entities choosing to submit their audits after the normal due date, the Department will consider the audits to be submitted timely if they are submitted to eZ-audit or as directed by the Department no later than 30 calendar days after the date of the audit report. If the date of the audit report is prior to the date of this notice, IHEs and other entities have 30 calendar days from the date of this notice to submit their required audits."

Site Visits: According to an updated Electronic Announcement, on July 14, 2020, ED Revised the March 10, 2020 Dear CPA Letter CPA-20-01 to extend the timeframes for the site visit exemption to audits of fiscal years ending through December 31, 2020. The limited exemption in CPA-20-01 allows alternatives to in-person site visits and applies to proprietary school audits of fiscal years ending between September 30, 2019 and December 31, 2020, that are conducted using the OIG Audit Guide. See CPA-20-01 for more information.

Be sure to regularly monitor the OIG Non-Federal Audit website for updates. Also, see the Frequently Asked Questions for the Guide for Audits of Proprietary Schools and For Compliance Attestation Engagements of Third-Party Servicers Administering Title IV Programs for additional guidance and contact [email protected] with any questions.

Notes:

• This AskRegs Q&A was updated on July 30, 2020 to reflect an extension to the site visit exemption in Dear CPA Letter CPA-20-01 for audits conducted using the OIG Audit Guide.
• This AskRegs Q&A was previously updated on May 21, 2020 to reflect the deadline for submission of OIG Audit Guide audits in the May 15, 2020 Electronic Announcement.