Category: Higher Ed

ED’s New Audit Guide Mandates Greater Scrutiny of Compensation Practices under the “Incentive Compensation” Rule

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 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.

Reminder: July 1 Deadline for Out-of-State Schools to Register to Enroll Distance Learning Students in California

Kate Lee Carey

Effective July 1, private postsecondary institutions outside of California that enroll California students are generally subject to new “Out-of-State Institution Registration” regulations.

Cooley Team at CECU Annual Convention & Exposition

Blain Butner, Jonathon Glass, Kate Lee Carey, David Mills, Vince Sampson and Jay Vaughan

The 2017 Career Education Colleges and Universities (CECU) Annual Convention & Exposition is June 6-8 in Las Vegas, Nevada. The CECU Annual Convention brings together nearly 300 organizations and approximately 1,500 attendees. Members of the Cooley team will be speaking throughout the conference.

California Assembly Recommends Eliminating For-Profit Institutions from Cal Grant Program

Kate Lee Carey and Vince Sampson

While there are indications that Washington has lessened its antipathy towards for-profit institutions, states continue to go in their own directions. This post focuses on the California Assembly’s recommendation to eliminate for-profit institutions from the Cal Grant program.

State Authorization and Licensing: Recent Developments and Trends to Watch

Nancy Anderson

State authorization requirements, particularly for online education programs, remain in flux even as more states join the state reciprocity compact, known as SARA, which applies to accredited institutions.

Assessing Kaplan-Purdue – Revolution or Evolution??

Mike Goldstein

The announcement that Purdue University, a Big Ten public institution, has agreed to acquire Kaplan University, a 30,000-student for-profit online institution, has sent shock waves across the entire higher education community.