[Webinar] Examining ED’s Incentive Compensation Rule

May 6th, 2:00 pm - 3:30 pm CDT
Thompson Coburn LLP

Thompson Coburn LLP

May 6th, 2021
2:00 PM - 3:30 PM CDT

Since 1992, institutions of higher education participating in the federal student aid programs have been required to comply with the U.S Department of Education’s prohibition on incentive compensation. In simple terms, the rule prohibits institutions from providing any form of commission or bonus to individuals based on their success in covered recruiting activities or the awarding of financial aid. But as is the case with many federal regulations, interpreting and complying with the incentive compensation rule is anything but simple. Indeed, complexities rapidly arise when the rule is applied to multi-tiered organizations with varied compensation plans, bundled services agreements with third-party providers (e.g., online program managers), non-Title IV programs, or referral initiatives, to name a few. And the consequence of non-compliance can be severe.

Thompson Coburn’s Higher Education Practice is pleased to announce that the next entry in its 2020-21 Higher Education Webinar Series will explore the intricacy, and nuance, of the Department’s incentive compensation rule. On May 6, the Practice will offer a 90-minute presentation that will begin by discussing the scope, interpretation, and enforcement of the rule, how each has changed over time, and what the future may bring. The webinar then will turn to a discussion of the rule’s application to various compensation programs, bundled service agreements, and referral initiatives.

The upcoming webinar will be presented by Aaron Lacey, Chair of the Firm’s Higher Education Practice. This is an advanced topics webinar. Individuals planning to participate may wish to review the following articles prior to attendance:

Can colleges reward students and alumni for referring new students?
Can colleges compensate recruiters based on graduation rates?

This presentation is approved for 1.8 hours of general CLE credit in Missouri and 1.5 hours of general CLE credit in California and Illinois. 1.5 hours of general CLE credit in Texas is pending.


Aaron Lacey

Aaron Lacey
Thompson Coburn LLP

Aaron’s practice is dedicated entirely to helping institutions of higher education navigate complex legal and regulatory matters. He has significant experience in the array of federal, state, and accrediting agency laws and standards that govern postsecondary institutions, and is a frequent writer and speaker on topics relating to higher education policy and the federal financial aid programs.

In 2018, Aaron served the U.S. Department of Education as one of 17 negotiators charged with overhauling the Department's complex and controversial "borrower defense" rule. The Department selected Aaron to represent and negotiate on behalf of general counsels, attorneys and compliance officers at postsecondary institutions nationwide.

Aaron regularly represents institutions in administrative proceedings before state licensing entities, accrediting agencies, and the U.S. Department of Education, including matters arising from audits, program reviews, and investigations of the Office of Inspector General.

In support of institutional initiatives, he assists clients in drafting and negotiating a wide variety of agreements, including domestic and international articulation, consortium, licensing, marketing, and agency contracts, and in the case of postsecondary mergers and acquisitions, stock and asset purchase agreements. Aaron also assists with the management of regulatory and government agency relationships, policy creation and implementation, strategic planning, and compliance systems design.

Aaron is a member of the National Association of College and University Attorneys and of the American Bar Association.


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