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ED Proposes Significant Revisions to Title IV Certification, Financial Responsibility and Administrative Capability Requirements

On May 19, 2023, the U.S. Department of Education (ED) published in the Federal Register a Notice of Proposed Rulemaking (the Proposed Rule) to substantially change or expand a host of regulatory requirements concerning...more

U.S. Department of Education Announces Personal Liability Requirements for Postsecondary Institutions Participating in Title IV...

On March 1, 2023, the U.S. Department of Education (ED) published Electronic Announcement GENERAL-23-11 (EA) notifying institutions that participate in the Title IV federal student aid programs (Title IV) that it is...more

Proposed Rule From U.S. Department of Education Affects Changes of Ownership and Control, 90/10 Rule and Other Title IV...

On July 28, 2022, the U.S. Department of Education (the Department) published in the Federal Register a Notice of Proposed Rulemaking (the Proposed Rule) to amend its regulations concerning changes in institutional ownership...more

Education Department Unveils New Portal for Foreign Contract and Gift Reporting

As described in previous alerts dated June 18, 2019 and January 17, 2020, the U.S. Department of Education (ED) has been increasing its scrutiny of higher education institutions’ contracts with, and gifts from, foreign...more

CARES Act Provides Aid And Regulatory Relief To Students And Educational Institutions

On Friday, March 27, 2020, the President signed into law a $2 trillion stimulus package to combat the coronavirus pandemic and its systemic effects. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) is the...more

U.S. Department of Education Releases Guidance for Title IV Participating Institutions Regarding Coronavirus

On March 5, 2020, the U.S. Department of Education (ED) released formal guidance for institutions regarding their compliance with the Title IV federal student aid program requirements in the context of the coronavirus...more

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

Gainful Employment Regulations Rescinded as of July 1, 2020, with Institutional Option for Early Implementation

On July 1, 2019, the U.S. Department of Education (the Department) published final regulations (the “Final Rule”) rescinding requirements for programs that are eligible for Title IV federal student financial aid based on...more

Higher Education Institutions under Increased Scrutiny for Foreign Contracts and Gifts

The U.S. Department of Education (the Department) in recent months has undertaken increased scrutiny of postsecondary institutions’ contracts with, and gifts from, foreign entities and individuals. Although long-required to...more

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