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Updated U.S. Department of Education guidance on Section 117 Foreign Gift and Contract requirements

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

New veterans education law reinstates foreign student recruitment carve-out to incentive payment ban

After nearly one year of advocacy efforts and watchful waiting by education associations and other stakeholders, Congress has now confirmed via legislation that institutions may approach incentive payment requirements for...more

Department of Education embarks on negotiated rulemaking

On October 4, 2021, the U.S. Department of Education (ED) commenced the first of five negotiated rulemaking sessions. The five sessions are focused on the federal student financial aid programs authorized under Title IV of...more

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

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

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

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

Spring brings promises of change in federal higher education policy

Like the cherry blossoms now emerging in Washington, D.C., there are signs that after recent years rife with partisan congressional gridlock, 2019 may bring changes to the Higher Education Act of 1965 (HEA), the sweeping law...more

U.S. regulation of "foreign schools": Selected considerations for institutions participating in the U.S. Student Assistance...

Under U.S. federal law, known as the Higher Education Act (HEA), eligible U.S. students may receive federal student aid to help pay for education expenses incurred to attend approved higher education institutions, including...more

International online programs: Know the pitfalls

Thanks to the rapid development and widespread acceptance of online programs over the last decade, American universities and their respective business partners now offer degree or non-degree programs entirely online around...more

U.S. Department of Education Announces Further Delays to Borrower Defense to Repayment Regulations

On October 24, the U.S. Department of Education (“ED”) published an interim final rule to delay until July 1, 2018 the effective date of selected provisions of what have become known as the borrower defense to repayment...more

U.S. Department of Education Issues Final Regulations Regarding Teacher Preparation Programs

On October 31, 2016, the U.S. Department of Education (ED) published final regulations regarding teacher preparation programs, implementing the accountability provisions of Title II of the Higher Education Act (HEA) and...more

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