All posts by Cooley

ED to Shut Down and Overhaul E-App System

Nancy Anderson and Rebecca Flake
The US Department of Education has announced that it will implement updates to its current E-App system.

Lurking Behind the Headline: Significant Regulatory Changes Beyond Gainful Employment in ED’s Latest NPRM

Nancy Anderson , Kate Lee Carey and Caitlyn Shelby

The Department of Education published a substantial NPRM on May 19, which includes a new iteration of the Gainful Employment rules.

California Legislature Updates Private Postsecondary Education Act … Again

Kate Lee Carey and Nancy Anderson

The BPPE posted a memo explaining the amendments to the California Private Postsecondary Education Act that took effect in January 2023.

Third-Party Servicer Guidance on Hold

Kate Lee Carey, Nancy Anderson and Vince Sampson
The Department of Education announced that it will modify and further delay the implementation of its controversial guidance on third-party servicer issues.

ED Updates Timeline for Third Party Servicer Guidance

Nancy Anderson and Kate Lee Carey

The Department of Education has extended the timeline for implementation of its February 15 Dear Colleague Letter.

ED Revisits Third-Party Servicer and Incentive Compensation Guidance

Nancy Anderson and Kate Lee Carey

The Department of Education announced two initiatives that expand oversight of third-party providers to institutions of higher education that participate in federal financial aid programs.

Borrower Defense to Repayment 4.0

Kate Lee Carey and Jasmine Lee

The US Department of Education published final regulations regarding the borrower defense to repayment rule in October 2022.

ED Proposes Significant Amendments to Change in Control and 90/10 Regulations

Nancy Anderson, Kate Lee Carey, Jasmine Lee and Shannon Noonan

The Department of Education is accepting comments until August 26 on the NPRM to amends its 90/10 and change of ownership and control regulations.

California BPPE Implements New Statutory Provisions

Kate Lee Carey and Shannon Noonan

California Senate bills became effective January 1, 2022 that impact the Bureau for Private Postsecondary Education and institutions subject to the BPPE’s oversight.

Department of Education Webinar and Website Updates Provide Additional HEERF Guidance

Rebecca Flake and Kate Lee Carey

The Department of Education’s webinar provided some helpful additional context and explanation regarding the October 30 HEERF institutional reporting requirements.

California Higher Education Bill AB70 Signed into Law by Governor Newsom (and Why it Matters)

Kate Lee Carey

Proposed changes to recognition of nonprofit and public institutions have been signed into law and will become effective January 1, 2022, just in time for the out-of-state registration process to become more complex.

ED Announces New System for Institutions to Report Foreign Ownership, Contracts and Gifts

Shannon Noonan, Paul Thompson and Nancy Anderson

On June 22, the United States Department of Education announced its new information collection system for postsecondary institutions that participate in the Title IV programs to comply with the foreign owner, contract and gift reporting obligations under the HEA.