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  • Date:

    U.S. Dep’t of Education Financial Value Transparency and Gainful Employment Supplemental Training Resource (Nov. 6, 2024)

    The U.S. Department of Education created supplemental training resources for the Financial Value Transparency and Gainful Employment (FVT/GE) process in response to feedback and commonly asked questions from schools. The resources offer additional assistance and guidance for complying with the reporting requirements and a review of the FVT/GE Completers List via the National Student Loan Data System (NSLDS).  

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Higher Education Act (HEA) | Program Integrity & Gainful Employment | Students

  • Date:

    U.S. Dep’t of Education Update regarding Proposed Rules to Authorize Debt Relief Based on Hardship (Oct. 31, 2024)

    The U.S. Department of Education proposes to amend the regulations related to the Higher Education Act of 1965 to provide the waiver of certain student loan debts. The proposed regulations would clarify the use of the Secretary’s authority to waive all, or part of any student loan debts owed to the Department based on the Secretary’s determination that a borrower has experienced or is experiencing hardship related to such a loan. Comments regarding the proposed rule impact the William D. Ford Federal Direct Loan Program (Direct Loans), the Federal Family Education Loan (FFEL) Program, the Federal Perkins Loan (Perkins) Program, and the Health Education Assistance Loan (HEAL). Comments regarding the proposed rule must be made on or before Dec. 2, 2024, and via the Federal eRulemaking Portal at www.regulations.gov

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Higher Education Act (HEA) | Students

  • Date:

    U.S. Dep’t of Education Notice of Information Collection Request on Student Aid Internet Gateway (SAIG) Enrollment Document (Oct. 30, 2024)

    The U.S. Department of Education Notice of New Information Collection Request and Invitation to Comment. The Department is soliciting public comment related to the already approved information collection request, The Student Aid Internet Gateway (SAIG). Specifically, the Department wants to know: (1) is the collection necessary to the proper functions of the Department; (2) will the information be processed in a timely manner; (3) is the estimate of burden accurate; (4) how might the Department enhance the quality, utility, and clarity of the information to be collected; and (5) how might the Department minimize the burden of this collection on the respondents. Written comments and recommendations should be submitted on or before November 29, 2024, via www.reginfo.gov/public/do/PRAMain

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Students

  • Date:

    U.S. Dep’t of Education (GE-24-09) Revised Draft NSLFS FVT GE Completers List Available (Oct. 25, 2024)

    U.S. Department of Education Office of Federal Student Aid (FSA) electronic announcement regarding transmission of the revised draft Financial Value Transparency and Gainful Employment (FVT/GE) Completers List to schools. FSA announced that it planned to remit the List over the weekend of Oct. 26-27, 2024, through GEFVCMOP to each school’s Student Aid Internet Gateway (SAIG) TG mailbox, for all institutions enrolled for NSLDS FVT/GE reporting. The GE/FVT is used to calculate debt-to-earnings (D/E) and earnings premium (EP) measures, which will factor into GE determinations. Schools have until Jan. 15, 2025, to review and correct student information on the revised draft FVT/GE Completers List. 

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Higher Education Act (HEA) | Program Integrity & Gainful Employment | Students

  • Date:

    U.S Dep’t of Education Disclosure of Related Party Transactions in Financial Statements (Oct. 31, 2024)

    The U.S. Department of Education Office of Federal Student Aid published a reminder to institutions regarding the requirement to disclose all related party transactions in audited financial statements and further explanation as to how institutions can comply with the requirements given recent guidance provided by the American Institute of Certified Public Accountants (AICPA). While new regulatory requirements concerning the related party transaction requirements went into effect July 1, 2024, the new regulations do not change the requirements for reporting the transactions, which have been in place since 1997. Instead, the new regulations require specific information on related party disclosures to clearly identify the related party being disclosed. Further, the new regulations require institutions to provide an affirmative disclosure that an institution had no related party relationships and transactions to disclose.  

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Students

  • Date:

    2U, LLC v. Miguel Cardona, Secretary of Education (D.D.C. Oct. 21, 2024)

    Joint Status Report. Plaintiff, an online program management firm, brought claims against the U.S. Department of Education (the Department) regarding its February 2023 Dear Colleague Letter regarding Requirements and Responsibilities for Third-Party Services and Institutions (the DLC). Plaintiff alleged that the Department’s use of the sub-regulatory DCL to (1) expand the definition of third-party servicers (TPS) to include “entities performing the function of student recruiting and retention, the provision of software products and services involving Title IV administration activities, and the provision of educational content and instruction,” and (2) prohibit colleges and universities from contracting with third-party servicers located outside of the united States or entities “owned or operated by any individual who is not a U.S. Citizen or national or a lawful U.S. permanent resident,” exceeded its authority to make substantive changes without formally going through the federal rule-making process. The Joint Status Report states that the Department intends to rescind the DCL by November 18th.  

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Higher Education Act (HEA) | Students

  • Date:

    U.S. Dep’t of Education Proposed Rules to Authorize Debt Relief (Oct. 25, 2024)

    The U.S. Department of Education (the Department) issued a Notice of Proposed Rulemaking (NPRM) that would authorize student debt relief to borrowers who struggle with high medical costs, childcare costs, natural disasters, and other financial hardships. The NPRM on Hardship (Unofficial), if finalized, would impact approximately eight million borrowers, and sets forth two potential pathways for relief. Option one codifies authority for the Secretary of Education (the Secretary) to grant individualized, automatic relief without an application on a one-time basis. The Department would glean qualified borrowers by applying seventeen non-exclusive factors to existing borrower data and consider relief for those with an 80% or greater chance of being in default within the next two years. Option two proposes a primarily application-based pathway to debt relief for both current and future borrowers based on a holistic assessment of their personal hardship. The thirty-day comment period will commence once the NPRM publishes in the Federal Register. The Department expects to finalize the new regulation in 2025. 

    Topics:

    Financial Aid, Scholarships, & Student Loans | Students

  • Date:

    Office of Federal Student Aid Announcement re Active Confirmation of TG/FT Numbers (SAIG Mailboxes) and Electronic Services User Accounts (Oct. 21, 2024)

    The U.S. Department of Education Office of Federal Student issued a new requirement for every organization enrolled in a Student Aid Internet Gateway (SAIG) account. Organizations must review and validate their TG/FT numbers and Electronic Services user accounts, including TG numbers with access to the National Student Loan Data System (NSLDS), Professional Access website, the Common Organization and Disbursement (COD) System, and all FAFSA Partner Portal and EDconnect user accounts. Third party servicers are also required to validate their organization’s SAIG mailboxes and Electronic Services accounts. Failure to accurately complete the process can result in loss of access to Federal Student Aid data systems, including services such as Institutional Student Information Record (ISIR) deliveries, ISIR requests, FAFSA corrections, and NSLDS enrollment reporting and updates. The deadline to complete the process is December 10th

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Higher Education Act (HEA) | Students

  • Date:

    Choh v. Brown Univ. (D. Conn. Oct. 9, 2024)

    Opinion granting Defendants’ Motion to Dismiss. Plaintiffs, current and former student athletes, filed a putative class action, claiming a violation of Section 1 of the Sherman Act, 15 U.S.C. § 1 against Brown University, the Trustees of Columbia University in the City of New York, Cornell University, the Trustees of Dartmouth College, Harvard University, the Trustees of the University of Pennsylvania, Princeton University, Yale University, and the Ivy League Council of Presidents. Plaintiffs allege the Universities formed a price-fixing agreement, referred to by the Universities as “the Ivy League Agreement,” “not to provide athletic scholarships to their Division I Athletes and not to pay Ivy League Athletes any compensation (or reimbursement of education-related expenses).” Plaintiffs further allege the Agreement is per se illegal because the Universities are “horizontal competitors in the commercial activities in the Relevant service markets.” The Universities argued that they hold authority in setting rules for financial aid and compensation, and the ban on sports scholarship is meant to “foster campus cultures that do not prioritize athletics.” In finding that plaintiffs do not allege a cognizable antitrust violation, a restraint that violates the Rule of Reason, or the requirements for defining a plausible relevant market, the court wrote “at best, the plaintiffs’ allegations of anticompetitive effects relate to just some market participants, not effects in the market as a whole.”  

    Topics:

    Antitrust | Athletics & Sports | Financial Aid, Scholarships, & Student Loans | Students | Taxes & Finances

  • Date:

    U.S. Department of Education Announces Successful Beta 1 Testing for the 2025–26 FAFSA form as Beta 2 Testing Begins (Oct. 16, 2024)

    The U.S. Department of Education announced the launch of the second stage of testing (Beta 2), for the 2025-26 Free Application for Federal Student Aid (FAFSA). During the first stage of testing, (Beta 1) over 650 students successfully submitted applications; 586 institutions received 6,266 Institutional Student Information Records (ISIRs) generated by applications; and dozens of student corrections were successfully completed. During Beta 2, participating institutions will ask students to submit the FAFSA form as returning students for the 2025-26 cycle and begin downloading and testing ISIRs to the extent their financial aid systems are able to do so. Beta 1 testing results can be found at www.FAFSA.gov/beta.  

    Topics:

    Financial Aid, Scholarships, & Student Loans | Students