NASFAA Calls on FSA to Delay Change in Audit Sampling Method

By Owen Daugherty, NASFAA Staff Reporter

NASFAA joined the National Association of College and University Business Officers (NACUBO) in a letter to Federal Student Aid (FSA) Chief Operating Officer Richard Cordray regarding FSA’s proposed changes to the 2021 Office of Management and Budget (OMB) Compliance Supplement. Pointing to the disruptions colleges and universities experienced due to the coronavirus pandemic, the letter urges Cordray to delay new requests for the single audit cycle until 2022.

The letter comes as a proposed change is in the works in which FSA would use colleges’ and universities’ single audit as a way to demonstrate improvement in reducing improper payments in the Direct Loan program by requesting a change in audit sampling protocol in the 2021 OMB Compliance Supplement.

At issue is the proposed change in audit sampling from standard unbiased sampling approaches — which the letter notes has been used for decades by external auditors to test for program compliance — to random sampling. The letter adds that the timing of the change would place an “enormous burden” on schools and an immediate implementation would mean financial aid offices will “be inundated with new and unplanned audit requests” this summer and fall, just as aid offices are at their busiest. 

“The unanticipated and sizeable burdens this change will place on our institutions now will negatively impact how effectively our institutions can serve their students at a time when heightened care for their entire campus communities is most in need,” the letter to Cordray concludes.


Publication Date: 6/15/2021

Jeff A | 6/15/2021 11:12:40 AM

Some institutions are not afforded the use of the single audit, and are subject to an audit guide that was revised recently that increased the audit burden greatly. Sample sizes became a very large percentage of all students for some schools, and greatly expanded the scope of these audits. The changes to the single audit are minimal in comparison.

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