News & Analysis as of

Department of Education Financial Aid Title IV

Cooley LLP

ED Revises Its Interpretation of 90/10 Rule

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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

Bond Schoeneck & King PLLC

Student Financial Aid Regulations May Require Additional Reporting of Transactions Involving Trustees and Employees

On July 1, 2024, revised regulations governing federal student financial assistance programs became effective. The regulations, which can be found at 34 C.F.R. 668.23(d), require institutions that participate in the federal...more

Holland & Knight LLP

U.S. Department of Education Issues New Certification Procedures for Federal Financial Aid

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The U.S. Department of Education (Department) issued final rules on Oct. 24, 2023, imposing new conditions that higher education institutions must satisfy to participate in federal student aid programs under Title IV of the...more

Holland & Knight LLP

New Administrative Capability Requirements Announced for Colleges and Universities

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The Biden-Harris Administration on Oct. 24, 2023, issued final rules detailing important obligations for higher education institutions that receive federal funding. (Codified at 34 C.F.R. § 668 et seq.) The final regulations...more

Troutman Pepper Locke

Biden-Harris Administration Amends Higher Education Act to Address College Closures and Withholding Transcripts

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On October 24, the Biden-Harris administration announced amendments to the regulations implementing title IV of the Higher Education Act of 1965 (HEA). According to the fact sheet, the amendments are intended to allow the...more

Alston & Bird

New Regulations Proposed by the Department of Education Will Impact Proprietary and Nonproprietary Schools Alike

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Our Education Team delves into new proposed regulations that would bring a substantial change to the way Title IV is administered. New gainful employment regulations are more complex than Obama-era versions....more

Holland & Knight LLP

U.S. Department of Education Issues New Guidance on Third-Party Servicers

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The U.S. Department of Education (Department) published its newest "Dear Colleague Letter" (DCL ID: GEN-23-03) on Feb. 15, 2023, making sweeping changes to the regulation of agreements between institutions of higher education...more

Hogan Lovells

Department of Education embarks on negotiated rulemaking

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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

Lathrop GPM

DOE Issues Additional Guidance and Interim Final Rule Regarding CARES Act Grants

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On June 17, 2020, the U.S. Department of Education issued an interim final rule (IFR) aligning student eligibility for CARES Act funds with eligibility requirements for Title IV student aid. Effective immediately, higher...more

Ballard Spahr LLP

Dept. of Ed close to releasing proposal that would facilitate income share agreement programs at selected Title IV schools

Ballard Spahr LLP on

My colleagues and I have the privilege of advising numerous clients on income share agreements (ISAs), including universities, service providers, and institutional investors. So we were excited by reports that the U.S....more

Hogan Lovells

U.S. Department of Education and state of California attempt to reach accord to restore Title IV eligibility to California...

Hogan Lovells on

As widely reported in the news and as discussed in our recent webinar, on 22 July 2019 the U.S. Department of Education (ED) notified institutions that, as a result of the U.S. District Court ruling in NEA v. DeVos, ED's 2016...more

Saul Ewing LLP

Strategies for Dealing with the Title IV Ineligibility of CA-Resident Students Under the Retroactive Distance Education Rule

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On Monday, July 22, 2019, the Federal Student Aid Office of the U.S. Department of Education (ED) announced that the Distance Education Rules that were originally scheduled to go into effect on July 1, 2018, and were then...more

Cooley LLP

Blog: Department Announces California Residents at Out-of-State Public and Nonprofit Institutions Ineligible for Federal Student...

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The Department of Education issued guidance yesterday that ED’s regulations prohibit California residents enrolled in distance education programs at out-of-state public and nonprofit institutions from receiving federal...more

Cooley LLP

Blog: California Jumps in With Sweeping Regulatory, Statutory Proposals Affecting VA Benefits, Other Issues

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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

Carlton Fields

Professional Services Exclusion Precludes Coverage for False Claims Act Suit

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It is not unusual for a directors and officers liability policy to have an exclusion for professional services. A such, a question often arises regarding whether the claimed wrongful conduct involved the rendering or failure...more

Ballard Spahr LLP

NY bars use of mandatory arbitration agreements by career training schools

Ballard Spahr LLP on

The New York Education Department (NYED) has issued a ruling which states that the Bureau of Proprietary School Supervision (BPSS) will not permit an enrollment agreement, including an arbitration clause, to infringe on the...more

Hogan Lovells

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

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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

Cooley LLP

Blog: New ED Audit Guide Updates Requirements Concerning Third-Party Servicers

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As discussed in our previous posts, the Department of Education’s new Audit Guide establishes new audit requirements applicable to for-profit schools and to compliance audits of third-party servicers that administer “any...more

Bond Schoeneck & King PLLC

Education Department Reverses Course on Prohibition Against Incentive Compensation Based on Retention and Graduation; Clears Way...

On November 27, 2015, the United States Department of Education announced a reversal of its previously existing prohibition against the payment of incentive compensation based on students’ program completion or graduation...more

Cooley LLP

Alert: New Proposal Offers Limited Access to Federal Student Aid for Alternative Providers

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On October 15, 2015, the US Department of Education ("ED") issued a long-awaited notice announcing an "Experimental Sites Initiative" ("ESI") to permit limited access to federal loan and grant programs for students enrolled...more

Cooley LLP

Alert: California Approves Pathway for Non-Profit Institutions to Maintain Exemption from State Oversight

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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

Cooley LLP

Alert: Recent Developments on State Authorization at Department of Education and in California

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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

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