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NSF Foreign Financial Disclosure Reports due September 3 for higher education institutions

The U.S. National Science Foundation (NSF) has implemented new rules requiring institutions of higher education (IHEs) to submit annual reports regarding financial support of $50,000 or more received directly or indirectly...more

THIS WEEK: ED hosts listening sessions on bundled services exception to incentive compensation rule

On March 8 and 9, the U.S. Department of Education (ED) will host virtual listening sessions to receive public comment on the incentive compensation rule. ED will accept written comments through March 16, per the Federal...more

Updated U.S. Department of Education guidance on Section 117 Foreign Gift and Contract requirements

This advisory summarizes Section 117 requirements and enforcement, highlights key aspects of the updated guidance, and identifies considerations for higher education institutions given the U.S Department of Education’s...more

Department of Education releases long-awaited Title IX proposal

On June 23, 2022, the U.S. Department of Education (ED) released its long-awaited proposal to amend ED's regulations implementing Title IX of the Education Amendments of 1972 (Title IX). ED’s proposed regulations include...more

New veterans education law reinstates foreign student recruitment carve-out to incentive payment ban

After nearly one year of advocacy efforts and watchful waiting by education associations and other stakeholders, Congress has now confirmed via legislation that institutions may approach incentive payment requirements for...more

Department of Education embarks on negotiated rulemaking

On October 4, 2021, the U.S. Department of Education (ED) commenced the first of five negotiated rulemaking sessions. The five sessions are focused on the federal student financial aid programs authorized under Title IV of...more

Reminder: New Department of Education rules regarding Professional Licensure Programs are in effect July 1, 2020

As we’ve previously reported in detail, on November 1, 2019, the U.S. Department of Education (ED) published final rules concerning state authorization of distance education programs and other topics. Notably, the new rules...more

U.S. Department of Education releases first set of materials related to the CARES Act's Higher Education Emergency Relief Fund

On April 9, the U.S. Department of Education (ED) released information and guidance related to the Higher Education Emergency Relief Fund (HEERF), the approximately US$14 billion fund created under the Coronavirus Aid, Relief...more

U.S. Department of Education provides COVID-19 guidance for colleges and universities

On 5 March 2020, the U.S. Department of Education (ED) published an electronic announcement to provide guidance on compliance with federal student financial aid (Title IV) requirements in connection with students for whom...more

U.S. Department of Education withdraws proposed Section 117 foreign gift and contract information collection request; plans to...

On 4 February 2020, the Office of Management and Budget (OMB) announced that OMB and the U.S. Department of Education (ED) have decided to withdraw the emergency information collection request that ED had submitted to OCR on...more

U.S. Department of Education provides notice of new, expanded Section 117 foreign gift and contract reporting requirements for...

On 17 December 2019, the U.S. Department of Education (ED) published in the Federal Register notice of a new information collection request (ICR) related to reporting requirements under Section 117 of the Higher Education Act...more

U.S. Department of Education finalizes "borrower defense to repayment" rules effective 1 July 2020

On 23 September 2019 the U.S. Department of Education (ED) published final regulations concerning, among other things, "borrower defense to repayment" claims for federal student loans first disbursed on or after 1 July 2020,...more

Third time's the charm? – U.S. Department of Education issues additional Q&A on implementation of 2016 "borrower defense to...

The U.S. Department of Education (ED) has issued additional guidance in the form of several supplemental "questions and answers" related to implementation of ED's 2016 "borrower defense to repayment" regulations (BDTR...more

Gainful employment whiplash: 2014 regulations rescinded

Although in the past few weeks the U.S. Department of Education (ED) had encouraged institutions to prepare for additional compliance requirements related to gainful employment (GE) that were scheduled to take effect on...more

Additional gainful employment program disclosure requirements take effect 1 July 2019

After granting institutions several extensions to comply with certain disclosure requirements of the U.S. Department of Education's (ED) "gainful employment" (GE) regulations, ED announced that beginning on 1 July 2019,...more

U.S. Department of Education provides additional, albeit limited, guidance on implementation of 2016 "borrower defense to...

On 3 June 2019 the U.S. Department of Education (ED) published a two-page Questions and Answers (Q&A) document to provide additional guidance to colleges and universities about aspects of the final regulations often referred...more

State authorization redux: New rules would retain disclosure requirements for professional licensure programs

The U.S. Department of Education's (ED) 2019 negotiated rule-making process recently ended with the negotiators somewhat unexpectedly reaching consensus on proposed regulatory language on a variety of topics, including the...more

Spring brings promises of change in federal higher education policy

Like the cherry blossoms now emerging in Washington, D.C., there are signs that after recent years rife with partisan congressional gridlock, 2019 may bring changes to the Higher Education Act of 1965 (HEA), the sweeping law...more

U.S. regulation of "foreign schools": Selected considerations for institutions participating in the U.S. Student Assistance...

Under U.S. federal law, known as the Higher Education Act (HEA), eligible U.S. students may receive federal student aid to help pay for education expenses incurred to attend approved higher education institutions, including...more

Department of Education convenes "Accreditation and Innovation" negotiated rulemaking committee

The U.S. Department of Education (ED) will convene a negotiated rulemaking committee in Washington, D.C. 14-16 January 2019 to begin discussions about proposals to revise the ED regulations related to the Title IV federal...more

ED proposes two-year delay of state authorization rule

The U.S. Department of Education (ED) now has published its proposed rule to delay by two years the state authorization final regulations that were set to become effective July 1, 2018.? In this alert, we summarize what this...more

Foreign location authorization rule appears on schedule for July 1 effective date

In the waning days of the Obama Administration, the U.S. Department of Education (ED) released final regulations regarding state authorization for distance education and foreign country authorization for certain locations...more

Distance education rule appears on schedule for July 1 effective date

In the waning days of the Obama Administration, the U.S. Department of Education (ED) released final regulations regarding state authorization for distance education and foreign country authorization for certain locations...more

U.S. Department of Education Announces Further Delays to Borrower Defense to Repayment Regulations

On October 24, the U.S. Department of Education (“ED”) published an interim final rule to delay until July 1, 2018 the effective date of selected provisions of what have become known as the borrower defense to repayment...more

Department of Education Rescinds Obama-Era Title IX Guidance Documents, Introduces New Q&A on Campus Sexual Misconduct

On September 22, the U.S. Department of Education Office for Civil Rights issued a Dear Colleague Letter withdrawing the statements of policy and guidance reflected in two key documents about Title IX and sexual violence...more

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