ED’s New Audit Guide Mandates Greater Scrutiny of Compensation Practices under the “Incentive Compensation” Rule
The second post of our Audit Guide series focuses on the incentive compensation rule. The new Audit Guide requirements significantly expand the review required by auditors to assure compliance with the incentive compensation rule.
The new Audit Guide for Title IV compliance audits includes numerous, expanded requirements for accounting firms to use in conducting required annual audits. The Audit Guide applies to Title IV compliance audits for fiscal years ending June 30, 2017 or later for for-profit higher education institutions and for third-party servicers that administer any aspect of the Title IV programs on behalf of any postsecondary institutions.
The 2017 NASFAA National Conference is June 26-29 in San Diego, California. The annual NASFAA conference brings together 2,500+ student aid professionals from across the nation. Members of the Cooley team will be presenting throughout the conference.
BDTR is likely to be one of the final major regulatory initiatives under the Obama administration, and one that will be in pre-effective date status on January 20th when Donald Trump becomes President.
Before the end of this month, the U.S. Department of Education (ED) is expected to issue a new set of regulations to provide students and former students with expanded rights to avoid having to repay their federal loans based on certain acts or omissions of the institutions they attended.
Almost four months after the marathon negotiated rulemaking ended in March without consensus, the US Department of Education (ED) has released a massive Notice of Proposed Rulemaking describing how it plans to refocus the rules governing the Borrower Defense to Repayment (BDTR) provision of the Higher Education Act (HEA).
This memo discusses the proposed process for students to file claims to have their federal loans forgiven, as well as the role of institutions in that process, under the Final Draft of the BDTR Rule.
Following a highly charged, often contentious three days of debate, the third session of the Negotiated Rulemaking on Borrower Defense to Repayment (DTR) ended as it started, without consensus. The Department of Education (ED) is now free to promulgate the regulations it wants, entirely independent of the DTR negotiations.
The US Department of Education and appointed negotiators representing higher education and legal groups are preparing for the second round of negotiations to expand the “Borrower Defense to Repayment” regulations, with the next session to run from Wednesday, February 17 through Friday, February 19.
At the end of November, the US Department of Education (ED) issued important new guidance regarding its incentive compensation regulations, which ED says “clarifies and provides additional information” about part of the rules.
On October 15, 2015, the US Department of Education (ED) issued a long-awaited notice announcing an “Experimental Sites Initiative” (ESI) to permit limited access to federal loan and grant programs for students enrolled in certain kinds of short, non-institutional educational programs.