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Title IV Audits

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Graduation cap, book, and money

Proprietary schools and foreign schools are required to have annual financial statement audits and compliance audits of their Title IV programs performed in accordance with the applicable OIG audit guide. Third-party servicers are required to have annual compliance audits of their administration of the Title IV programs, performed in accordance with the applicable audit guide. Audit requirements of proprietary schools and third-party servicers are combined into one audit guide, referred to as the Title IV Audit Guide, while audit requirements of foreign schools are contained in a separate audit guide, referred to as the Foreign School Audit Guide.

All proprietary school, foreign school, and third-party servicer audits are submitted to the Department of Education’s eZ-Audit System.

Audit Guides and Dear CPA Letters

See below for links to the most recent audit guides and amendments communicated through Dear CPA Letters. For copies of superseded audit guides, send a request to OIGNon-FederalAudit@ed.gov.

2023 Title IV Audit Guide 

Guide for Financial Statement Audits of Proprietary Schools and For Compliance Attestation Examination Engagements of Proprietary Schools and Third-Party Servicers Administering Title IV Programs  (March 2023) and Transmittal Letter.

The 2023 Title IV Audit Guide is effective for fiscal years beginning on or after January 1, 2023 (December 31, 2023 fiscal year ends), and supersedes the 2016 Title IV Audit Guide and associated Dear CPA Letters and FAQs.

The OIG Non-Federal Audit Team is responsible for assessing the quality of Title IV audits and does so through Desk Reviews of report packages and Quality Control Reviews of audit documentation. To provide the auditee and auditor community with greater transparency around our work, we are making the guides we use for these reviews publicly available. Auditors may use these review guides as a tool to perform their own quality assurance checks. Along with the fully functioning Excel files, we are also posting accessible PDFs that are 508 compliant.

2016 Title IV Audit Guide

Guide For Audits of Proprietary Schools and For Compliance Attestation Engagements of Third-Party Servicers Administering Title IV Programs (September 2016) and Transmittal Letter. The 2016 Title IV Audit Guide and associated Dear CPA Letters and FAQs remain in effect for fiscal years beginning prior to January 1, 2023.

  • Dear CPA Letter CPA-23-01: Modified Enrollment Reporting Testing Due to National Student Loan Data System Issues (Issued January 26, 2023)
  • Dear CPA Letter CPA-22-02: Identifying School’s Unique Entity Identifier in Report Packages (Issued May 13, 2022)
  • Dear CPA Letter CPA-21-02: Proprietary School Example Auditor’s Reports Reflecting Changes for 2018 Government Auditing Standards revision and SAS Nos. 134 140 (Issued October 26, 2021 and reposted February 7, 2022)
  • Dear CPA Letter CPA-21-01: Extension of Site Visit Exemption During COVID-19 National Emergency (Issued January 20, 2021)
  • Dear CPA Letter CPA-20-01: Site Visit Exemption During COVID-19 Outbreak (Issued March 10, 2020, Revised July 14, 2020, Expired January 20, 2021 with issuance of CPA-21-01)
  • Dear CPA Letter CPA-19-01: Amendments to September 2016 Audit Guide – Student Information Security (Issued October 30, 2019)
  • Frequently Asked Questions for the Guide for Audits of Proprietary Schools and For Compliance Attestation Engagements of Third-Party Servicers Administering Title IV Programs (Revised July 31, 2019)

2020 Foreign School Audit Guide

Guide for Financial Statement Audits and Compliance Attestation Engagements of Foreign Schools (March 2020) and Transmittal Letter. The 2020 Foreign School Audit Guide is effective for fiscal years ending on or after December 31, 2020.

  • Dear CPA Letter CPA-23-01: Modified Enrollment Reporting Testing Due to National Student Loan Data System Issues (Issued January 26, 2023)
  • Dear CPA Letter CPA-22-02: Identifying School’s Unique Entity Identifier in Report Packages (Issued May 13, 2022)
  • Dear CPA Letter CPA-21-03: Foreign School Example Auditor’s and Practitioner’s Reports Reflecting Changes for 2018 Government Auditing Standards revision, SAS Nos. 134-140, and SSAE Nos. 19 and 21 (Issued October 26, 2021)
  • Dear CPA Letter CPA-21-01: Extension of Site Visit Exemption During COVID-19 National Emergency (Issued January 20, 2021)

Other Important Information

Federal Student Aid Asks Proprietary Schools to Postpone Submitting Their Annual Audits 

FSA issued electronic announcement GENERAL-24-30 in April 2024 to outline annual audit submission guidance for proprietary schools with fiscal years that begin on or after January 1, 2023, with completed audits ready for submission. The 90/10 regulatory updates required that FSA make extensive updates to the eZ-Audit reporting system to accommodate the regulatory changes, and these updates remain in progress. FSA asked that proprietary schools postpone submitting their annual audits until these eZ-Audit updates are complete.  FSA also said they will purge any annual proprietary school audits for fiscal years ending on or after December 31, 2023, that were already submitted or that are submitted before the update is complete. Schools will need to resubmit the purged audits when the update is released.

Additional 90/10 Footnote Requirements for Institutions Seeking Enforcement Relief Due to Tuition Assistance Payments Delayed by the ArmyIgniteED System Issues 

FSA issued electronic announcement GENERAL-23-117 in December 2023 to provide instructions to proprietary institutions on how they should report tuition assistance payments delayed as a result of the U.S. Army’s ArmyIgnitED system issues and ED’s treatment of such delayed payments for purposes of 90/10 enforcement. In order for a proprietary institution that fails the 90/10 due solely to this issue to receive enforcement relief, the institution must disclose an additional 90/10 footnote that excludes the late ArmyIgnitED payments and certain additional information about those excluded payments. An auditor performing the financial statement audit of a proprietary school that includes this additional 90/10 footnote will be expected to evaluate both the original 90/10 calculation and the revised 90/10 calculation.

Available Resources

The following resources are available to assist auditors that perform Title IV audits.