Tag: Title IV
Department of Education Updates 90/10 Guidance
On March 10, 2026, the Department of Education (ED) quietly updated its 90/10 Questions and Answers guidance that complements the 90/10 regulations at 34 CFR § 668.28. This rule mandates that proprietary institutions participating in the Federal Student Aid programs (FSA or Title IV) must generate at least 10% of […]
From Degrees to Dollars: How Wages, Not Graduates or Colleges, Will Determine Federal Student Loan Access Across All Institutions
Earlier this month, the Department of Education (ED), in coordination with the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) committee, concluded its negotiated rulemaking session and reached the elusive “consensus” to implement the new Earnings Premium (EP) framework as established by the One Big Beautiful Bill […]
ED Revises Its Interpretation of 90/10 Rule
The US Department of Education (ED) will now allow proprietary institutions to include revenue generated through distance programs in their calculations for federal student aid eligibility. On July 7, 2025, ED published an interpretive rule significantly revising its position on how for-profit institutions calculate compliance under the Title IV regulations, […]
Big Beautiful Bill – Earnings Premium for Nonprofit and Public Universities
Jay Vaughan and Vanessa Agudelo
On July 4, President Donald Trump signed “The Act,” commonly referred to as the “One Big Beautiful Bill,” as part of the budget reconciliation process and, among other changes, amended the Higher Education Act of 1965. While the law includes a number of elements impacting higher education (such as endowment taxes and loan limits), one key change was the creation of the “earnings premium” (EP) metric to assess the effectiveness of degree programs at all universities receiving Title IV funds.
90/10 Provisions of American Rescue Plan Act of 2021 Brings Major Change
Kate Lee Carey and Vince Sampson
President Joe Biden signed the American Rescue Plan Act of 2021 on March 11. The ARPA includes a major change in the 90/10 revenue test that provides for-profit institutions and their students access to the FSA programs.
Managing COVID-19 Disruption: Title IV Processing
Nancy Anderson and Rebecca Flake
The Department of Education has issued guidance on Title IV processing in response to COVID-19.