Dennis Cariello

Dennis Cariello

DLA Piper

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Congress and the Higher Education Act: what’s on the table? What’s to come? Our look at the major proposals

Congress is well into the process of passing a reauthorization of the Higher Education Act (HEA), and many members of Congress have introduced bills addressing many aspects of higher education that concern the public....more

9/19/2014 - Financial Aid Financial Education Initiatives Higher Education Act Legislative Agendas Legislative Committees Proposed Legislation Transparency

Very Few Changes Between Draft Gainful Employment Rule And One Published In The NPRM

As we reported yesterday, the Department of Education (Department) released the Notice of Proposed Rule Making (NPRM) for the gainful employment rule this morning. The NPRM is long – 841 pages in the pre-publication format. ...more

3/17/2014 - Department of Education Gainful Employment

Department Of Education To Release Gainful Employment Rule Tomorrow Morning

Politico has just reported that the Department of Education will be releasing the gainful employment rule tomorrow morning. From the reports, it appears that the rule is substantially similar to the one discussed at the...more


Department of Education Sends Proposed Gainful Employment Rule to the Office of Management and Budget

As reported on the website for the Office of Management and Budget (OMB), on January 30, the Department of Education (Department) sent its version of the gainful employment (GE) rule to OMB (specifically, the Office of...more

2/3/2014 - Department of Education Executive Orders Gainful Employment OIRA OMB

Department of Education’s Office for Civil Rights Issues Controversial Guidance On Rights of Disabled Students to Participate in...

On Jan. 25, 2013, the U.S. Department of Education’s Office for Civil Rights (‘‘OCR’’) released a Dear Colleague Letter (‘‘DCL’’) providing guidance on the obligations under Section 504 of the Rehabilitation Act of 1973...more

12/6/2013 - ADA Department of Education OCR Rehabilitation Act Section 504 Students

According to New NCES Study, Proprietary Higher Education Reduces Costs for Students by Over 10% Since 2007-08

On December 3rd, the National Center for Education Statistics released the 2011-2012 National Postsecondary Student Aid Study. This report focuses on the average price of attendance paid by students to attend institutions of...more

12/5/2013 - Colleges Students Tuition Universities

Primer on Negotiated Rulemaking

Given all the current and future negotiated rulemaking sessions for the U.S. Department of Education (Department), it might be helpful to take a look at the Department’s FAQs on the Negotiated Rulemaking Process. ...more

12/4/2013 - Negotiations Rulemaking Process

On December 3rd, House Subcommittee to Discuss Proposals to Strengthen Pell Grant Program

On Tuesday, December 3rd at 10:00 a.m. in room 2175 of the Rayburn House Office Building, the Subcommittee on Higher Education and Workforce Training, chaired by Rep. Virginia Foxx (R-NC), will hold a hearing entitled,...more

12/3/2013 - Colleges Financial Aid Pell Grants Students Tuition Universities

Supreme Court Declines to Hear Liberty University’s Challenge to Affordable Care Act Suit

As reported by multiple sources on Monday, the U.S. Supreme Court declined to wade into the constitutionality of the Affordable Care Act’s (ACA) employer mandate. Liberty University, a Christian university in in Lynchburg,...more

12/3/2013 - Affordable Care Act Contraceptive Coverage Mandate Employer Mandates Individual Mandate Religious Institutions Religious Schools SCOTUS

Department of Education Announces Negotiators for Rulemaking Concerning the Violence Against Women Reauthorization Act of 2013

Following up on our prior coverage of this rulemaking session, late last week, the U.S. Department of Education (Department) announced the negotiators for the rulemaking session seeking to “prepare proposed regulations to...more

12/3/2013 - Department of Education Domestic Violence VAWA

Final Gainful Employment Rulemaking Session Scheduled for Friday, December 13

Politico’s Libby Nelson, in yesterday’s “Morning Education” email (and in a tweet on Black Friday) reports that the U.S. Department of Education “has scheduled its third session of negotiated rule-making on the ‘gainful...more

12/3/2013 - Department of Education Gainful Employment

Some Thoughts on the Latest Round of Gainful Employment Negotiatied Rulemaking Part 2

Something that seems clear after two rounds of negotiated rulemaking is the lack of trust those aligned with consumer advocates have for proprietary schools. As I recall, one negotiator suggested they needed to think...more

11/25/2013 - Gainful Employment Student Loans Students

Some Thoughts on the Latest Round of Gainful Employment Negotiatied Rulemaking Part 1

I will apologize upfront for the length of this post. Or that there will be multiple posts on this. There’s just a lot to say after this latest session of gainful employment negotiated rulemaking. For those of you...more

11/23/2013 - Colleges Department of Education Gainful Employment Higher Education Act Rulemaking Process Student Loans Universities

Senate Forms Task Force to Review Higher Ed Regulations and Reporting Requirements

In a statement yesterday, Senate education committee Ranking Member Senator Lamar Alexander (R-Tenn.), and members Barbara Mikulski (D-Md.), Richard Burr (R-N.C.), and Michael Bennet (D-Colo.) “announced the formation of a...more

11/19/2013 - Colleges Reporting Requirements Universities

Department of Education Publishes Change to NACIQI Schedule

Earlier today, the Department of Education published a notice in the Federal Register (78 FR 68832) announcing revisions to the agenda for the December 12-13, 2013 meeting of the National Advisory Committee on Institutional...more

11/15/2013 - Accreditation Department of Education Nurses

Additional Information on the Government Shut Down from Federal Student Aid

In our report on the budget showdown, I neglected to link to the letter from James Runcie, the COO of the Department of Education’s Office of Federal Student Aid (FSA) about the budget shutdown. ...more

10/2/2013 - Department of Education Financial Aid Government Shutdown Student Loans

What the Budget Showdown Means for Higher Education

Well, it’s September 30th and that means is the end of the Federal Government’s fiscal year. Before anyone bites into the cake, however, Congress still needs to pass a new budget (or continuing resolution. Otherwise, the...more

9/30/2013 - Colleges Department of Education Furloughs Government Shutdown Universities

New CRS Report: Banning the Use of Racial Preferences in Higher Education

An interesting new report from the Congressional Research Service reviews Schuette v. Coalition to Defend Affirmative Action, a case heading to the Supreme Court this upcoming 2013-2014 Term that will consider “whether it is...more

9/26/2013 - Affirmative Action College Admissions Colleges Equal Protection SCOTUS Students Universities

Compliance Focus: New FSA Handbook Prohibits Discounts to Students Who Pay in Cash or Who Pay Before the Start of Class

As many of you know, the new Federal Student Aid Handbook were released this summer. There are a number of new items in the handbook and I encourage you all to review it. We will be discussing these new items in future...more

9/26/2013 - Compliance Discounts Flexible Spending Accounts Handbooks Student Loans Students

New College Scorecard to Have Salary Information for Institutions

According to Libby Nelson at Politico, on Tuesday September 17, deputy director of the White House Domestic Policy Council James Kvaal announced at a National Press Club that the administration is revising the College...more

9/19/2013 - Colleges Students Transparency Universities Wages

Department of Education Publishes Court-Mandated Changes to Misrepresentation Rule

Earlier today, the Department of Education (Department) published a Federal Register notice (the official publication will likely be tomorrow) amending the misrepresentation rule that was published on October 29, 2010 as part...more

9/19/2013 - Department of Education Misrepresentation New Regulations Public Schools

Department of Education Announces New Negotiated Rulemaking – With More to Follow

Yesterday, the Department of Education (Department) announced the intention to establish a negotiated rulemaking (neg reg) committee to “prepare proposed regulations to address the changes to the campus safety and security...more

9/19/2013 - Clery Act Department of Education New Regulations Safety Precautions VAWA

Some Thoughts on the Gainful Employment Negotiated Rulemaking Session – Part 1

I attended the negotiated rulemaking sessions hosted by the U.S. Department of Education to discuss the Department’s proposed “gainful employment” rule. As we reported previously, these sessions are a second attempt at...more

9/12/2013 - Department of Education Gainful Employment Proposed Regulation Students

Department of Education Publishes Gainful Employment Proposal for Negotiated Rulemaking

On August 30, the U.S. Department of Education published a new web page containing ”information about our rulemaking efforts to establish standards for programs that prepare students for gainful employment in a recognized...more


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