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Disclosure Requirements Department of Education

Morrison & Foerster LLP

New Executive Order Adds Scrutiny to Universities’ and Other Higher Education Institutions’ Foreign Sources of Funding

As a part of the new administration’s broader effort to add regulatory requirements and scrutiny to institutions of higher education, on April 23, 2025, President Trump issued an Executive Order (EO) on Transparency Regarding...more

Holland & Knight LLP

Education Dept. Prioritizes Foreign Gifts and Contracts Enforcement for Colleges, Universities

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The Trump Administration stated last week that it will prioritize compliance and enforcement against colleges and universities with respect to the U.S. Department of Education (ED)'s foreign gift, contract and ownership...more

McGuireWoods LLP

Colleges and Universities Face New Scrutiny Over Foreign Gifts

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On April 23, 2025, President Donald Trump signed an executive order titled Transparency Regarding Foreign Influence at American Universities, aimed at reinforcing and expanding the enforcement of Section 117 of the Higher...more

Akin Gump Strauss Hauer & Feld LLP

Transparency Regarding Foreign Influence at American Universities (Trump EO Tracker)

The Order requires the Secretary of Education to take all appropriate actions to ensure complete and timely disclosure by higher education institutions of foreign funding. The Secretary will take appropriate steps to reverse...more

Holland & Knight LLP

Colleges and Universities Must Report Certain Foreign Gifts and Contracts

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In light of recent enforcement activity, institutions of higher education should review their reporting and disclosure obligations related to foreign entities and individuals under Section 117 of the Higher Education Act (20...more

McGuireWoods LLP

Department of Education Issues Guidance on Student Privacy and Parental Rights, Imposes Reporting Requirements for State...

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On March 28, 2025, the U.S. Department of Education issued a Dear Colleague Letter addressed to the chief officers of state educational agencies (SEAs) and local educational agencies (LEAs), reminding them that the Family...more

Marshall Dennehey

Federal ‘Stop Campus Hazing Act’ Signed into Law

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The federal bipartisan Stop Campus Hazing Act, an amendment to the Jeanne Clery Act, was signed into law by President Joe Biden on December 24, 2024....more

Fox Rothschild LLP

Stop Campus Hazing Act: First Federal Anti-Hazing Law Creates New Reporting Requirements for Higher Ed Institutions

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The Stop Campus Hazing Act, which went into effect on Jan. 1, 2025, now requires higher education institutions to collect hazing statistics to include in their 2026 Annual Security Report, among other new reporting and...more

Proskauer - Labor Relations Update

NLRB GC Abruzzo Issues Guidance to Academic Institutions Addressing Conflicting Obligations under Labor and Student Privacy Laws

Earlier this week, the National Labor Relations Board General Counsel Jennifer Abruzzo issued Memorandum GC 24-06 seeking to clarify the obligations imposed by the National Labor Relations Act (NLRA) on academic institutions...more

Kohrman Jackson & Krantz LLP

FERPA Faux Pas: Avoiding Missteps as Your Child Steps into College

Can you believe it? Summer isn’t over yet, but it’s already time to start thinking about the upcoming school year. For parents of younger children, this means shopping for school supplies and new clothes, reestablishing...more

Holland & Knight LLP

New Financial Responsibility Requirements from U.S. Department of Education

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The U.S. Department of Education (Department) has identified college closures and institutional financial instability as creating significant costs for students and taxpayers. From 2013 to 2022, the Department sought more...more

Bass, Berry & Sims PLC

NIH Begins Implementation of OSTP Foreign Influence Recommendations for Research Institutions

Bass, Berry & Sims PLC on

As part of the government’s broader efforts to combat foreign threats to U.S.-funded scientific research, the National Institutes of Health (NIH) and White House Office of Science and Technology Policy (OSTP) have announced...more

Ballard Spahr LLP

Third Circuit rules CFPB lawsuit against federal student loan servicer did not preclude PA AG’s parallel lawsuit, federal law did...

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The U.S. Court of Appeals for the Third Circuit ruled last week in Commonwealth of Pennsylvania v. Navient Corp. that the PA Attorney General could bring a parallel enforcement action against Navient, a servicer of federal...more

Hogan Lovells

COVID-19: Daily Report for Life Sciences and Health Care Companies (UPDATED)

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The Daily Report is a compilation of COVID-19 (coronavirus) news briefs from around the world to help life sciences and health care companies stay current in this challenging time....more

Bradley Arant Boult Cummings LLP

Misrepresentation Claims Not Preempted: Eleventh Circuit Rules Against Preemption in Student Loan Case

As we’ve been tracking for over a year now, courts across the country have addressed the significant question of whether the federal laws governing federally owned or guaranteed student loans preempt state laws placing...more

Perkins Coie

US Department of Education Scrutinizes Foreign Investment Into Higher Education

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The U.S. Department of Education (DOE) recently launched investigations into at least a half dozen top research institutions for failing to disclose foreign-sourced gifts or contracts. Under section 117 of the Higher...more

Hogan Lovells

U.S. Department of Education withdraws proposed Section 117 foreign gift and contract information collection request; plans to...

Hogan Lovells on

On 4 February 2020, the Office of Management and Budget (OMB) announced that OMB and the U.S. Department of Education (ED) have decided to withdraw the emergency information collection request that ED had submitted to OCR on...more

Bricker Graydon LLP

Disclosing foreign gifts and contracts: An expanding area of compliance for higher education institutions

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The Higher Education Act was passed by Congress in 1986. Since then, higher education institutions have been required by Section 117 of the act to biannually report to the U.S. Department of Education (ED) gifts from or...more

Hogan Lovells

U.S. Department of Education provides notice of new, expanded Section 117 foreign gift and contract reporting requirements for...

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On 17 December 2019, the U.S. Department of Education (ED) published in the Federal Register notice of a new information collection request (ICR) related to reporting requirements under Section 117 of the Higher Education Act...more

Faegre Drinker Biddle & Reath LLP

U.S. Department of Education Issues Final Rule to Revise Accreditation and State Authorization Regulations

On November 1, 2019, the U.S. Department of Education (the “Department”) published in the Federal Register final regulations (the “Final Rule”) governing the recognition of accrediting agencies for postsecondary education and...more

Cooley LLP

Blog: ED Publishes Final State Authorization for Distance Education Rule

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On Friday, November 1, the Department of Education published its final state authorization for distance education regulations in the Federal Register, available here. The rule draws on the 2016 version of the state...more

Hogan Lovells

Gainful employment whiplash: 2014 regulations rescinded

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Although in the past few weeks the U.S. Department of Education (ED) had encouraged institutions to prepare for additional compliance requirements related to gainful employment (GE) that were scheduled to take effect on...more

Faegre Drinker Biddle & Reath LLP

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

Hogan Lovells

Additional gainful employment program disclosure requirements take effect 1 July 2019

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After granting institutions several extensions to comply with certain disclosure requirements of the U.S. Department of Education's (ED) "gainful employment" (GE) regulations, ED announced that beginning on 1 July 2019,...more

Faegre Drinker Biddle & Reath LLP

New Gainful Employment Program Disclosure Requirements Take Effect July 1, 2019

After earlier delays in implementation, the U.S. Department of Education (the Department) has instructed postsecondary education institutions that more extensive distribution requirements for Gainful Employment (GE) program...more

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