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
The U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) have issued proposed regulations interpreting the Inflation Reduction Act’s (IRA) prevailing wage and apprenticeship requirements (Labor...more
On March 1, 2023, the Department of Education (“DOE”) released guidance related to the instances in which it will require assumption of personal liability for an institution’s continued participation in Title IV programs....more
Although the sweeping changes to the Medicare Shared Savings Program (MSSP) were only finalized on December 21, 2018, just before the holiday season and government shutdown, aspiring and currently participating accountable...more
Financing energy projects that have entered into PPAs with CCAs presents unique challenges for lenders and investors. Key Points: ..In recent years, CCAs have begun supplying energy to a growing number of consumers in...more
The U.S. Department of Education has issued a final rule that broadly addresses the ability of a student to assert a school's misconduct as a defense to repayment of a federal student loan. The final rule includes a ban on...more
On July 1, 2016 the U.S. Department of Education issued a follow-up Dear Colleague Letter to the Dear Colleague Letter of July 29, 2015. This most recent letter reminds institutions of their legal obligation to protect...more
Public Citizen, Inc. has sent a petition to the Department of Education requesting the Department to adopt a rule that requires schools to agree, as a condition of receiving Title IV assistance under the Higher Education Act...more
Deepening a circuit split, the Seventh Circuit has joined the Fifth Circuit in rejecting the implied false certification theory of liability under the FCA. United States v. Sanford-Brown, Ltd., No. 14-2506 (7th Cir., June 8,...more