Gainful Employment Redux – Not Just for For-Profits Anymore
Kate Lee Carey and Shannon Noonan
The Department of Education released the final and official Gainful Employment rule on October 10, 2023. The final rule is substantially similar to the proposed rule released in May 2023, with a few exceptions outlined within this post.
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)
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.