This document is a formal letter from four leading professional organizations—AICPA, COGR, NACUBO, and NASACT—addressed to the U.S. Office of Management and Budget (OMB) in response to the U.S. Department of Education’s (ED) recent policy requiring a separate annual compliance audit for Title IV Student Aid Programs, regardless of the programs’ risk status under existing single audit regulations. The organizations express concern that ED’s new position diverges from longstanding federal audit policy, particularly the Single Audit Act, which aims for efficient oversight by focusing audit resources on higher-risk programs and has traditionally allowed single audits to satisfy program-specific audit requirements. The letter underscores that ED’s new directive increases both administrative burden and audit costs for institutions with proven compliance records and may establish a precedent prompting other federal agencies to impose similar requirements, undermining the unified and risk-based approach of the Single Audit framework.
The letter further emphasizes the need for OMB’s engagement to clarify the legal and procedural validity of ED’s position, to enforce adherence to federal requirements regarding audit notifications and cost provisions, and to develop clear, consistent guidance for auditors and institutions. The authors argue that ED’s legal interpretation does not align with the Higher Education Act’s allowance for single audits to fulfill audit requirements and that additional clarity is necessary to prevent confusion over audit procedures and program coverage. The organizations request a meeting with OMB and ED to discuss these issues ahead of the anticipated updates to the 2017 OMB Compliance Supplement, with the ultimate goal of ensuring audit policy that is both legally sound and administratively efficient, consistent with congressional intent and federal mandates to minimize unnecessary burden.
