UK universities and other educational institutions that process loans to visiting United States students under the US Department for Education William D. Ford Federal Direct Loan Programme (known as the Direct Loan Programme) are required to have an annual audit. The audit is undertaken in accordance with the Foreign School Audit Guide and focuses on compliance with processes and procedures laid down by the US Department for Education, as well as ensuring that adequate internal controls are in place over the handling of the loans.
The extent of the audit required is dependent on the level of funds received in the relevant year ended 31 July. Standard compliance attestation engagements are required for universities in receipt of $500k or more, whilst an alternative compliance attestation engagement can be submitted if the total funding is below $500k.
Who can provide the audit report?
Audit reports must be carried out by an auditor that holds certifications equivalent to CPA in the US or work for the equivalent of a non-government licensed certified public accounting firm in the US.
Clive Owen LLP have a team of registered auditors approved to sign independent accountant’s reports and with the qualifications necessary to meet the requirements set by the US Dept of Education.
What are our credentials?
We work with universities to deliver an efficient, timely service, ensuring reporting deadlines are met but also offering value for money and pro-active advice should improvements be needed. Don’t take our word for it though, here is what Tuesday Sampson of the international support team at University of Sunderland had to say:
“We worked with Clive Owen LLP on our 2020/21 US student loan audit having previously worked with another supplier. We found the process to be extremely efficient and more cost effective, rapidly improving our reporting timeline and reducing the burden on our team. Carl and Eleanor were extremely professional but also very supportive, providing pragmatic advice throughout.”
What is the William D. Ford Federal Direct Loan programme and why is it relevant to UK universities?
The William D. Ford Federal Direct Loan programme, know as the Direct Loan Programme, is a federal loan programme operated by the US Department for Education. United States students studying at UK universities and other education establishments are often entitled to this loan funding. UK institutions are required to administer loan payments on behalf of the US Department for education. Under this arrangement Universities are subject to annual audits to confirm compliance with the rules of the Direct Loan Programme and the adequacy of internal financial controls in place respect of the programme.
What is an Alternative Compliance Attestation Engagement for Foreign Schools?
UK education providers who receive Direct Loan funding for foreign students as part of the United States Title IV program are subject to a compliance audit requirement set by the US Dept of Education.
Providers who received less than $500,000 per fiscal year must obtain an Alternative Compliance Attestation Engagement, designed to identify any non-compliance or internal control deficiencies.
Providers receiving greater than $500,000 per fiscal year will be required to complete a standard compliance attestation engagement.
Does my institution need a report?
All universities and other academic institutions administering loans to US students are likely to require an audit report. These audit reports, entitled Compliance Attestation Engagement for Foreign Schools, are required regardless of the level of total loan funding advanced to eligible students, with limited exceptions.
Providers who received less than $500,000 per fiscal year must obtain an Alternative Compliance Attestation Engagement, designed to identify any non-compliance or internal control deficiencies.
Providers receiving greater than $500,000 per fiscal year will be required to complete a standard compliance attestation engagement, which is more in-depth than the Alternative Compliance Attestation Engagement.
What is the reporting period for US Direct Loan Programme audits?
The US Direct Loan Programme is delivered over an academic year running from 1 August to 31 July of the following year. The auditing period for the compliance attestation engagement process mirrors this timeline. There is a six month window for audit reports to be prepared, with the submission deadline usually falling on 31 January of the following year.
