In his recent article on accreditation reform (Accreditation-Reform Hopes for the Second Trump Administration, January 31, 2025),Sam Negus raises an interesting question in what may be the most radical (and the least likely) proposal ever — “Why not cut out the middleman [the accrediting agencies] and have institutions file [their certified financial] audits with the U.S. Treasury Department to qualify as Title IV recipients?” he asks.
The problem is that the metrics used differ greatly; they measure different things, and are not compatible.
Single Audits (2 CFR 200 Subpart F) under GAAP, for example, are financial reviews conducted annually by professional CPAs. Once completed, the Single Audit report is filed through the Federal Audit Clearinghouse (FAC) to the Office of Management and Budget (OMB), not the U.S. Treasury. Ironically, the audits are monitored for financial compliance by the US Department of Education, which administers Title IV.
Accreditation reviews, on the other hand, provide the “demonstration of compliance” required under the Title IV provisions of the Higher Education Act (HEA). GAAP audits determine if a college’s financial statements are accurate and complete, but accreditation reviews Title IV requirements in regard to the rules and regulations for the disbursement of federal loans and grants. They are not interchangeable.
I have been eagerly waiting for someone to propose viable alternatives to the current system of Title IV accreditation, but unfortunately, “cutting out the middleman” is not worth considering.
Glen McGhee, Dir.
Florida Higher Education Accountability Project (FHEAP)
Author
Letters to the Editor
