The OMB has released the Compliance Supplement for 2022.  Some notable items related to Student Financial Aid (SFA) and the HEERF program that will be evaluated by your auditors are as follows:

SFA Cluster:

1. The R2T4 special test includes the updated guidance on modules and expands the recommended sampling to include students who withdrew from modular programs.
2. Last year the header “Short-Term Programs at Postsecondary Vocational Institutions” was found under the Program Eligibility special test. This year it has been expanded back to its own special test. There are now 14 special tests again, instead of 13 as there were last year.

HEERF:

1. HEERF is still a “higher-risk” program.
2. Cash Management has been identified as applicable for FY22, whereas it was not applicable last year for FY21. Testing that drawdowns were made within 15 days of student portion disbursements or 3 days of institutional portion will be likely.
3. The requirement of HEERF III institutional funds to be used in some amount for (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines and (b) to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment (PJ) was added to the earmarking section.
4. They have clarified that for procurement the public exigency flexibility should be unlikely in FY22 due to the distance of FY22 from the beginning of the pandemic.

    

   ^{Readers should not act upon information presented without individual professional consultation.}

   ^{Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.}