Category: Higher Ed
Increased Student Samples, Student Confirmations and Site Visits Mean Expanded Audits Under ED’s New Audit Guide
Blain Butner and Rebecca Flake
In the fourth post of our Audit Guide series, we focus on three significant process expansions: the size and composition of the required student sample, the student confirmations auditors are required to perform and how site visits are conducted.
Department Seeks Public Comment on Regulations to Repeal
Vince Sampson and Nancy Anderson
As part of the Administration’s regulatory reform directive, the Office of the Secretary of the Department of Education is seeking public comments on regulations and guidance that may be appropriate for repeal, replacement or modification. The Department of Education has extended the deadline. Comments will now be due Friday, September 20.
New ED Audit Guide Now Requires Extensive Gainful Employment Compliance Testing
Kate Lee Carey, Jonathon Glass and Joseph Mensah
Gainful Employment data reporting is the topic for the third post in our Audit Guide series. For the first time ED is requiring that independent audit firms conduct extensive testing relating to Gainful Employment data reporting and mandated disclosures as part of their annual Title IV compliance audits.
The Post-9/11 GI Bill Is One Step Closer to a Major Overhaul
Lisa Bureau, Matt Johnson and Joseph Mensah
The President has signed the Harry W. Colmery Veterans Educational Assistance Act of 2017 – the “Forever GI Bill” into law – which amends the Post-9/11 Veterans Educational Assistance Act of 2008 and enhance education benefits provided to eligible military veterans.
ED’s New Audit Guide Mandates Greater Scrutiny of Compensation Practices under the “Incentive Compensation” Rule
Greg Ferenbach and Blain Butner
The second post of our Audit Guide series focuses on the incentive compensation rule. The new Audit Guide requirements significantly expand the review required by auditors to assure compliance with the incentive compensation rule.
New ED Audit Guide Means Compliance Audits Will Be More Expansive, More Expensive
Blain Butner and Rebecca Flake
The new Audit Guide for Title IV compliance audits includes numerous, expanded requirements for accounting firms to use in conducting required annual audits. The Audit Guide applies to Title IV compliance audits for fiscal years ending June 30, 2017 or later for for-profit higher education institutions and for third-party servicers that administer any aspect of the Title IV programs on behalf of any postsecondary institutions.
Department Holds Hearings and Comment Period on Neg Reg Agenda
Vince Sampson and Nancy Anderson
The Department of Education holds hearing to hear comments regarding the agenda for the upcoming negotiated rulemaking.
Last Minute Reprieve in GE Rule
Kate Lee Carey and Jonathon Glass
Faced with court decision, continuing data problems and new negotiated rulemaking, the Department of Education issues last minute reprieve on Gainful Employment appeals and certain disclosure requirements.
Cooley Team at NACUA
Greg Ferenbach and Paul Thompson
The 2017 NACUA Annual Conference is June 25-28 in Chicago, Illinois. The annual NACUA conference attracts hundreds of higher education attorneys each year to learn and discuss current issues and legal developments in the field of higher education law.
Cooley Team at NASFAA
Blain Butner, Marjorie Arrington, Rebecca Flake, Pat Dickerson, Kate Lee Carey, Naomi Harralson May and Joseph Mensah
The 2017 NASFAA National Conference is June 26-29 in San Diego, California. The annual NASFAA conference brings together 2,500+ student aid professionals from across the nation. Members of the Cooley team will be presenting throughout the conference.
Department of Education’s Announcement Leaves Unanswered Questions Regarding Coming Gainful Employment Rule Deadline
Jonathon Glass, Kate Lee Carey and Vince Sampson
The Department of Education announced it will engage in a new negotiated rulemaking to revise the Gainful Employment Rule, but questions remain.
Department of Education Delays Borrower Defense Rules and Proposes Reset on Gainful Employment
Vince Sampson and Nancy Anderson
The Department announced today that it will delay Borrower Defense and will convene a new “Mega Neg Reg,” which will include Borrower Defense and Gainful Employment.
