News & Analysis as of

Title IV Reporting Requirements

Holland & Knight LLP

New Guidance Issued on Financial Value Transparency and Gainful Employment Regulations

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The U.S. Department of Education (Department) released an important update and reminder regarding new Financial Value Transparency (FVT) and Gainful Employment (GE) regulations that take effect on July 1, 2024. The...more

Husch Blackwell LLP

The Long and Winding Road to the New Financial Value Transparency and Gainful Employment Rules

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Effective July 1, 2024, institutions of higher education participating in Title IV Federal Student Aid programs must comply with the U.S. Department of Education’s (Department) Financial Value Transparency and Gainful...more

Pillsbury Winthrop Shaw Pittman LLP

U.S. Education Department’s New Accountability and Transparency Rules for Postsecondary Institutions to Take Effect in July 2024

The rules impose new extensive reporting requirements on postsecondary institutions and could cause 1,700 programs to lose Title IV eligibility as early as 2026. The Education Department will begin collecting information...more

Husch Blackwell LLP

Update: U.S. Department of Education Third-Party Servicer Guidance - 4/14/2023

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UPDATE: On April 11, the Department of Education (Department) published a blog post updating the latest Third-Party Services (TPS) Dear Colleague Letter (DCL) which was published on February 15, 2023 (updated February 28,...more

Husch Blackwell LLP

Update: U.S. Department of Education Third-Party Servicer Guidance

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UPDATE: On February 28, 2023, the Department updated the Dear Colleague Letter issued February 15, 2023 to establish a future effective date for the guidance, extend the public comment period, and extend the reporting...more

Husch Blackwell LLP

Department of Education Expands Interpretation of "Third-Party Servicer" Definition (and Announces Incentive Compensation Review)

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Wednesday’s U.S. Department of Education Dear Colleague Letter announces an expanded Department interpretation of the definition of Third-Party Servicer to include a new array of vendors providing student recruiting and...more

Cooley LLP

Blog: ED Announces New System for Institutions to Report Foreign Ownership, Contracts and Gifts

Cooley LLP on

On June 22, the United States Department of Education announced its new information collection system for postsecondary institutions that participate in the Title IV programs to comply with the foreign owner, contract and...more

Ballard Spahr LLP

DOE Signals Renewed Commitment to Enforcement of Foreign Gift Reporting Requirements

Ballard Spahr LLP on

The U.S. Department of Education (DOE) recently announced that it is launching an investigation into the foreign gifts reporting practices of two higher education institutions. ...more

Faegre Drinker Biddle & Reath LLP

Foreign Contract and Gift Reporting Deadline Approaches for Higher Education Institutions, As Does a Revised Reporting Process

As discussed in a previous alert dated June 18, 2019, the U.S. Department of Education (the “Department”) over the last year increased its scrutiny of postsecondary institutions’ contracts with, and gifts from, foreign...more

Cooley LLP

Blog: New ED Audit Guide Now Requires Extensive Gainful Employment Compliance Testing

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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

Cooley LLP

Alert: No 11th Hour Reprieve: GE Rules Upheld

Cooley LLP on

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

Cooley LLP

Alert: Gainful Employment Regulations: Recent Updates from the Department of Education

Cooley LLP on

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

Katten Muchin Rosenman LLP

LEGAL UPDATE: Final Medicare Medical Staff Conditions of Participation: What Should be in your Bylaws

In This Presentation: - Hospital Governing Board - Do physicians have to serve on boards? - How must board consult with the organized medical staff if physicians are not on the board? - Hospital Medical...more

Smith Anderson

JOBS Act Update: SEC Proposes New Rules to Update Regulation A Offerings

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In mid-December, the Securities and Exchange Commission (SEC) voted to propose rules updating the framework to the existing Regulation A offering. The rules would implement new Section 3(b)(2) of the Securities Act of 1933,...more

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