EDUCAUSE Comments: Federal Student Aid’s Safeguards Rule Audit Requirement

Abstract

On March 29, 2017, EDUCAUSE joined the National Association of College and University Business Officers (NACUBO), the Council on Governmental Relations (COGR), and the National Association of Student Financial Aid Administrators (NASFAA) in asking the federal Office of Management and Budget (OMB) to delay and/or rewrite a “federal single audit” requirement proposed by the Federal Student Aid (FSA) division of the U.S. Department of Education. The requirement as written would introduce Gramm-Leach-Bliley Act (GLBA) Safeguards Rule compliance into the single audit process, but in a potentially expensive and ineffective way. EDUCAUSE and its partner associations asked OMB to delay introducing the requirement until FY 18 to allow time for FSA to work with affected stakeholders on improving it. Absent that, the associations asked OMB to use the alternative version of the requirement proposed by the National State Auditors Association instead of the text originally put forward by FSA.

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