While much of the higher education sector’s attention is understandably focused on the sweeping changes of the “One Big Beautiful Bill Act,” it’s important not to lose sight of other regulatory updates and approaching deadlines that also demand attention. The Department of Education’s (ED) Federal Update session on June 26, 2025 at the 2025 NASFAA National Conference provided critical information on regulatory changes and reminders that will significantly impact institutions in the coming months and years. Below is a summary of key updates—organized chronologically by effective date—to help schools prepare for upcoming compliance requirements.
1. Campus Crime Reporting & Hazing
Various Effective Dates January through December 2025
The Stop Campus Hazing Act introduces new requirements that institutions should be preparing for now:
- Statistics Collection – Institutions were required to begin collecting statistics on hazing incidents reported to campus security authorities or local law enforcement as of January 1, 2025. These statistics from 2025 will be due by October 1, 2026, when included for the first time in the 2026 Annual Security Report (ASR).
- Policy & Prevention Programs – Anti-hazing policies and prevention programs were required to be in place by June 23, 2025.
- Documentation of Hazing Violations – As of July 1, 2025, Institutions were required to have a process for documenting hazing violations.
- Campus Hazing Transparency Report (CHTR) – Due December 23, 2025, institutions must publicly publish this new report, separate from the ASR, which includes the documented violations mentioned above. In addition, the CHTR must be updated at least twice per year.
These requirements are in addition to existing Clery Act obligations, and schools should begin reviewing current policies and reporting mechanisms now to ensure compliance. ED representatives stated that they anticipate publishing a Dear Colleague Letter (DCL) with official guidance on the Stop Campus Hazing Act “soon.” As of today, August 18, 2025, no such DCL has been issued. While ED’s forthcoming DCL may provide additional clarification, institutions should move forward with implementation based on the statutory requirements and Clery Act best practices to avoid delays in meeting the 2025 compliance deadlines.
2. V4/V5 Identity Verification Changes
Effective June 6, 2025
ED clarified significant changes to verification requirements for students selected for V4 or V5 tracking groups:
- Statement of Educational Purpose Flexibility – Institutions are no longer required to collect the Statement of Educational Purpose, although it remains an option.
- Remote Identity Verification – Institutions may view a student’s ID over a live video call. Institutions may either take a screenshot of the student’s ID or, alternatively, have the student send an electronic copy of the same ID.
- Vendor Options – Schools may continue using their existing in-house verification procedures. However, they may also choose to use a third-party vendor for identity verification if the vendor complies with NIST Level 2 standards. Institutions that wish to use an optional third-party vendor should obtain and retain documentation from the vendor verifying compliance with NIST Level 2. Likewise, notaries may still be used but are not mandatory.
- Students Selected for Verification After Disbursement – If Title IV funds were disbursed before the student was selected for verification and the student is unable to complete identity verification, ED reminds schools that this must be treated as a student overpayment. One exception applies: if the student was selected for verification after ceasing enrollment and does not intend to return to the school during the applicable award year, the school is not required to complete verification.
ED updated published FAQs to clarify vendor compliance expectations which can be found here. McClintock is also working on a Verification Q&A based on questions we’ve received over the last few weeks.
3. Financial Value Transparency (FVT) & Gainful Employment (GE) Reporting
Reporting Deadlines: September 30 & October 1, 2025
There are two back-to-back deadlines for FVT and GE reporting that are due this fall:
- 2024 Reporting Cycle – Extended to September 30, 2025.
- 2025 Reporting Cycle – Due just one day later, on October 1, 2025.
During ED’s NASFAA session on June 26, 2025, officials urged schools to submit 2024 cycle data as early as possible (ideally in the summer) to allow adequate time to prepare for the 2025 Reporting Cycle deadline on October 1. ED also stated that no further extensions for the 2025 cycle are anticipated.
However, we must acknowledge that much has changed since that session. The “One Big Beautiful Bill Act”, signed into law just one week after the NASFAA conference, introduces an Accountability Measure that is conceptually similar to current FVT and GE earnings premium measure. Additionally, FVT and GE are now on the agenda for Fall 2025 Negotiated Rulemaking.
Given these developments, it is reasonable to question whether the current reporting deadlines will remain unchanged. For now, institutions should continue to prepare as though the deadlines will hold but stay alert for possible changes as new regulations are developed.
4. Distance Education Definition & Reporting
Effective July 1, 2026 and July 1, 2027
ED finalized the definition of a distance education course which will amend 34 CFR §600.2. Starting July 1, 2026, a course will be considered distance education if instruction occurs exclusively as described in the definition of distance education, even if there are in-person non-instructional requirements (e.g., orientation, testing, or academic support).
In addition, effective July 1, 2027, institutions will be required to report student enrollment by modality (fully in-person, distance, hybrid) and correspondence courses through the National Student Loan Data System (NSLDS). ED has not yet released detailed reporting procedures.
5. Perkins Loan Oversight
Schools continuing to service Perkins Loans should be aware of several compliance risks:
- Many institutions are experiencing Fiscal Operations Report and Application to Participate (FISAP) errors related to general ledger reconciliations. If your school does not understand where the errors are occurring and how to resolve them, ED urged schools to reach out to the Perkins team for assistance.
- Administrative Capability Risk – Unresolved reconciliation issues and continued FISAP errors may be considered when evaluating an institution’s administrative capability.
- Third-Party Servicing Reminder – Even if Perkins loans are serviced by a third-party, the school remains responsible for ensuring accurate reporting.
- A new Perkins Loan Portfolio Report (PRKPF1) will soon be available in NSLDS to help schools with oversight.
6. Accrediting Agency Changes / School Oversight
Two important oversight reminders were highlighted:
- Expedited Accrediting Agency Changes (GEN-25-03) – ED will expedite review of applications to change accrediting agencies, except in rare cases where an institution lacks reasonable cause. To begin the change process, institutions should submit a Reasonable Cause Request Certification form to CaseTeams@ed.gov, along with the required materials under 34 CFR §600.11(a)(1) and (b).
- Reasonable cause will not be found if the institution had accreditation withdrawn, revoked, or terminated for cause within the last 24 months, or has been on probation, show cause, or suspension—except in cases where due process was denied, standards were inconsistently applied, or the prior agency failed to respect the institution’s stated mission.
- This guidance supersedes GEN-22-10 and GEN-22-11.
- Case Team Communications – ED strongly urged institutions to email: CaseTeams@ed.gov rather than individual staff for faster processing of oversight-related requests and questions. This applies broadly to matters such as E-App submissions, recertification, program reviews, etc.
Conclusion
The Federal Update session at NASFAA underscored ED’s increased emphasis on accountability, transparency, and timely data reporting. With several key requirements becoming effective in 2025, schools should evaluate their current policies, data systems, and vendor relationships now to ensure compliance.
McClintock & Associates will continue to monitor additional guidance as it becomes available and provide updates to help institutions navigate these evolving requirements. If you have questions or need assistance preparing for these changes, please contact us.
______________________________
At McClintock & Associates, we’re committed to keeping you informed—even when the rules are still being written. Sign-up for our newsletter to stay up to date.
