Where’s the Financial Responsibility Pendulum Now? Perspectives on the Current State of ED’s Fiscal Oversight and Related Title IV Compliance Matters

The past several years have seen significant swings not only with the explicit financial responsibility regulations, but also in the manner that the Department of Education (ED), accreditors, and states have interpreted and applied their regulations and standards at a given time. Grounded in the most recent ED regulatory framework concerning financial responsibility and related matters, this session will explore how ED’s downsizing has affected its fiscal oversight of institutions, as well as changes to composite score and 90/10 interpretations, eZ-Audit requirements, changes in fiscal year end, and fiscal assessments related to changes in ownership. The presenters will focus particular attention on revised regulatory interpretations by ED, whether via formal guidance or enforcement actions and routine reviews, and similar developments under related accrediting body and state agency requirements, including NC-SARA.