On February 15th, the Department released updated guidance to clarify when organizations that contract with institutions of higher education are considered third-party servicers and, thereby, subjected to disclosure, audit, and liability requirements. In the guidance, the Department added recruitment and retention services, software services used to administer Title IV programs, and the provision of educational content and instruction to those entities that are subject to  these requirements and codified the prohibition on foreign-owned providers.

The effective date for this guidance is September 1, 2023 and the Department is accepting written comments through March 30, 2023. Interested parties have raised concerns about the impact of the expansion of the definition of third-party servicers and how many entities will now fall under the definition.  During the webinar, speakers from Thompson Coburn LLP will discuss the Dear Colleague Letter and the potential implications for those industry participants that are current or potential third-party servicers. A question-and-answer session will follow the discussion. Members can register for the webinar on the NCHER website.

Online registration is now closed. 

Please email James Bergeron directly if you need to register for the webinar.