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In August, NACUBO reported that the Department of Education would pursue an annual audit mandate of Student Financial Assistance programs for FY17 as part of the Office of Management and Budget's (OMB) 2017 Compliance Supplement to federal audit requirements. On November 4, NACUBO, the Council on Governmental Relations, the National Association of State Auditors, Comptrollers and Treasurers, and the American Institute of Certified Public Accountants outlined mutual concerns over such a requirement in a letter submitted to OMB.

In the letter, the groups explained 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 Single Audit 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 associations asked OMB to intervene by providing further legal analysis of the Higher Education Act in relation to the Single Audit Act, participating in a meeting with stakeholders to review ED’s position, and assisting in the development of clearer audit guidance.


Sue Menditto

Senior Director, Accounting Policy


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