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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
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
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
As part of the “America First” Investment Policy Memorandum, released on February 21, the Trump administration signaled that it may increase restrictions on investments made by American university endowments relating to...more
The Stop Hazing Act, passed on December 23, 2024, amended the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (the “Clery Act”). The Clery Act requires colleges and universities that receive...more
In December, we informed you that the Stop Campus Hazing Act (the Act) was sent to the President after it was passed by both the House and Senate. President Biden signed the Act on December 23, 2024. ...more
On Dec. 23, 2024, President Biden signed the Stop Campus Hazing Act (SCHA), amending the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). The SCHA requires recipients of federal...more
The Biden administration's Department of Education has finally released the much-anticipated final rule (the "Final Rule") amending the regulations for Title IX, which prohibits sex discrimination and harassment in education...more
Today, the U.S. Department of Education (“Department”) issued significant changes to its Title IX regulations (“Final Rule”) governing how schools respond to complaints of sexual misconduct. The Final Rule takes effect on...more
On March 5, 2024, the U.S. Department of Education (the “Department”) announced that Liberty University (“Liberty”) has agreed to pay a fine of $14 million for material and ongoing violations of the federal Clery Act. This...more
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
The U.S. Department of Education (Department) issued new Gainful Employment (GE) regulations in September 2023 for the first time since 2014. These program-specific regulations impose important compliance obligations on...more
Congressional Republicans are increasingly focused on ensuring that U.S. colleges and universities are properly disclosing gifts and contracts from foreign sources under Section 117 of the Higher Education Act of 1965, 20...more
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
The Clery Act sits at the heart of higher education compliance obligations and is often the vehicle through which the Department of Education issues its most significant fines. Clery compliance requires year-round, team...more
This advisory summarizes Section 117 requirements and enforcement, highlights key aspects of the updated guidance, and identifies considerations for higher education institutions given the U.S Department of Education’s...more
Colleges and universities that receive federal funding will soon be required to administer campus climate surveys every two years on issues related to dating and domestic violence, sexual assault, sexual harassment, and...more
President Biden signed the American Rescue Plan Act of 2021 into law on March 11, 2021. The Act includes around $1.9 trillion dollars in funding for coronavirus recovery, $39.6 billion of which is appropriated to institutions...more
Last week the U.S. Department of Education (ED) announced the rescission and replacement of the 2016 Clery Handbook with a new “Clery Act Appendix for the Federal Student Aid (FSA) Handbook.” ED determined that much of the...more
On August 31, 2020, the U.S. Department of Education (ED) published a Federal Register notice revising its May 6, 2020, electronic announcement requiring higher education institutions to publish on their websites certain...more
The Clery Act requires colleges and universities that receive federal funding to issue annual security and fire safety reports and to provide timely notifications to students and staff of certain emergency situations....more
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
Update: On August 30, 2019, the U.S. Department of Education released extensive final regulations addressing, among other topics, Borrower Defense to Repayment reporting requirements. The new final regulations, effective July...more
Update on June 22, 2020: On June 22, ED unveiled its new online portal for college and university reports of foreign gifts and contracts. Original post on May 5, 2020: Mid-pandemic, the U.S. Department of Education...more
Institutions of higher education (IHEs) that received emergency relief funds from the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) must report certain designated information to the U.S. Secretary of...more