The recent rescission of the Gainful Employment (GE) regulations is akin to watching a Stanley Cup hockey game going into overtime. With every shot, you are riding a wave of exultation or fear as the outcome of the game could occur at a moment’s notice. Similarly, regulatory whiplash occurred over much...
On March 5, 2019 ED published new guidance to address when books, supplies, etc. are considered to be institutional charges and how these charges should be properly recognized for Title IV purposes. ED defined clearly that an institutional charge must be recognized over the entire period for which the charge...
The Department of Education (ED) simplified parts of the 2019 Gainful Employment Disclosure Template, with ED outlining the changes in a May announcement (Gainful Employment Electronic Announcement #119). In the weeks leading up to the July 1 deadline to comply with the changes, ED also gave institutions some important clarity...
Schools are educating a variety of students these days. With the rise in non-traditional students – or students who go to school at different stages of their lives – and with various lifestyles to accommodate, colleges and universities are changing traditional school models to create more options and flexibility for...
On March 15, 2019, the U.S. Department of Education (ED) issued a long-awaited announcement providing guidance for the implementation of the Borrower Defense to Repayment (BDTR) regulations, which the U.S. District Court ruled was unlawful back in October. You might remember ED proposed a new set of regulations determining if...
Confusion as to whether charges for books, supplies, kits and other related goods and services should be prorated has been an ongoing issue for years in the post-secondary education industry. The Department of Education has provided the following wording in response to the confusion. “The determining factor in whether the...
Originally published in the October 2018 issue of Career Education Review, and reproduced here with permission. Article originally posted at careereducationreview.net Over the summer, I have been reflecting on the impact of the September 2016 Guide for Audits of Proprietary Schools and for Compliance Attestation Engagements of Third-Party Servicers Administering Title...
The new audit guidelines have brought about a multitude of obstacles for secondary education leaders and auditors alike. McClintock & Associates Director, Mike Wherry recently co-presented a webinar on the “Calculating Your Institution’s 90/10 Rate” alongside Dennis Cariello of Hogan Marren Babbo & Rose. The webinar provides the need to...