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...more
Last week, the US Department of Education (ED) Office for Civil Rights (OCR) issued a Dear Colleague Letter (DCL) outlining the obligations of educational institutions pursuant to Title VI of the Civil Rights Act of 1964 and...more
For proprietary institutions subject to the 90/10 rule, President Joe Biden’s signing of the American Rescue Plan Act of 2021 on March 11 reflects a major change in this revenue test that provides for-profit institutions and...more
Important note: These rules – except as described below – are applicable to All institutions participating in the Title IV programs.
The deadline for affected institutions to file reports with the Department of Education...more
With the perceived loosening of regulatory controls at the federal level, many states are stepping in with aggressive legislative and regulatory action. Leading the charge is California, where a legislative package of seven...more
As noted in our previous blog post on ED’s new Audit Guide, for the first time ED is requiring that independent audit firms conduct extensive testing relating to Gainful Employment (GE) data reporting and mandated disclosures...more
In this, the first in a series of client alerts that will explain the workings of the new Borrower Defense to Repayment Rule (BDTR), we explore what promises to be a series of rules, procedures and interpretations to be...more
The US Department of Education just announced its intent to issue the first set of official Debt to Earnings Rates ("D/E Rates") under the Gainful Employment Rule ("GE Rule") in January 2017. That timing would be consistent...more
The US Department of Education has announced another delay in the distribution of the Completer Lists for Gainful Employment programs until Spring 2016, which is bound to push back the date for ED to issue the first set of...more
Governor Jerry Brown has now signed into law Senate Bill 81, which included language amending the California Private Postsecondary Education Act of 2009 (the "Act") to permit "independent institutions of higher education"...more
7/10/2015
/ Accreditation ,
Commerce Clause ,
Complaint Procedures ,
Department of Education ,
Educational Institutions ,
Exempt Organizations ,
Financial Aid ,
Governor Brown ,
Jerry Brown ,
Nonprofits ,
Students ,
Title IV
With a second court ruling in late June in favor of the U.S. Department of Education, the Gainful Employment Rules ("GE Rules") took effect on July 1, 2015. The GE Rules will, ultimately, provide new challenges to the...more
7/8/2015
/ Accreditation ,
Certifications ,
Colleges ,
Deadlines ,
Disclosure Requirements ,
Filing Deadlines ,
Gainful Employment ,
Reporting Requirements ,
Student Loans ,
Students ,
Title IV ,
Universities
The Department of Education published another announcement in its series of Electronic Announcements ("EAs") last week, as it prepares to implement the new Gainful Employment ("GE") regulations. Those regulations are...more
The US Department of Education ("ED" or "the Department") has decided against an earlier plan to send letters to every institution believed to be out-of-compliance (or rather, located in a state that is considered...more
6/11/2015
/ Colleges ,
Complaint Procedures ,
Department of Education ,
Distance Learning ,
Educational Institutions ,
Exemptions ,
Federal Student Aid ,
Financial Aid ,
Nonprofits ,
Private Schools ,
Proposed Regulation ,
Students ,
Title IV ,
Universities