The Department of Education's Office of Inspector General recently issued a limited exemption from the site-visit requirement in Chapter 3, Section B.9 of the 2016 Audit Guide.
The letter guidance is available here.
The 2016 Audit Guide, available here, requires auditors to perform site visits to each location at which at least 50% of an educational program is offered. The purpose of this requirement is to verify that the instructional location exists and assess whether the location supports the instruction provided.
Under the limited exemption OIG recently announced, which applies to proprietary school audits for fiscal years ending between Sept. 30, 2019 and Dec. 31, 2019, auditors may use alternative procedures to achieve the intent of the site-visit requirement.
Aside from noting that the alternative procedures must achieve the intent of the site visit, OIG does not describe the procedures auditors may use. The letter guidance does explain, however, that auditors who use alternative procedures must document their justification for departing from the site-visit requirement and how the alternative procedures achieved its intent. Auditors must also perform all offsite audit procedures in a secure manner.
“If an auditor performs an alternative procedure instead of a site visit, the alternative procedure will count as the site visit for purposes of determining site visit rotation in future years and the date of the alternative procedure should be noted on the Auditor Information Sheet as the ‘Date of auditor’s last visit to the location.’”
Questions about the site-visit exemption may be directed to the Office of Inspector General’s Non-Federal Audit Team by email at OIGNon-FederalAudit@ed.gov