[wactc-san] {Disarmed} Ed Department Shakes-Up OPMs and Third-Party Servicers

[McBurney, Melissa]

In case you haven’t heard about these new requirements from the Department of Education, please read this email.

The Department of Education released a press release<https://www.ed.gov/news/press-releases/us-department-education-launches-review-prohibition-incentive-compensation-college-recruiters> along with this Dear Colleague letter<https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2023-02-15/requirements-and-responsibilities-third-party-servicers-and-institutions> that clarifies Requirements and Responsibilities for Third-Party Servicers and Institutions. The definition of what needs to be reported to the Department of Education has been expanded so please look at the letter as soon as possible and open the categories to see the definitions. If there are contracts you have that fit those definitions you need to report these by May 1st.

WCET also published this today: Ed Department Shakes-Up OPMs and Third-Party Servicers:  This is Huge<https://wcet.wiche.edu/frontiers/2023/02/22/stronged-department-shakes-up-opms-and-third-party-servicersnbsp-this-is-huge-strongnbsp/>.

Please share any information that you come across with this mailing list.

Melissa

From: Cheryl Dowd via WCET <Mail at ConnectedCommunity.org>
Sent: Wednesday, February 15, 2023 8:35 AM
To: McBurney, Melissa <mmcburney at columbiabasin.edu>
Subject: SAN Network : SAN Breaking News - OPM Guidance by ED

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Good morning, SAN colleagues! Earlier this morning the Department of Education issued an important announcement for institutions using Online... -posted to the "SAN Network*" community
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[Cheryl Dowd]<https://wcetmix.wiche.edu/people/cheryl-dowd1>
Feb 15, 2023 11:34 AM
Cheryl Dowd<https://wcetmix.wiche.edu/people/cheryl-dowd1>
Good morning, SAN colleagues!
Earlier this morning the Department of Education issued an important announcement for institutions using Online Program Management (OPM) services for programs that involve the disbursement of Title IV Federal financial aid.
You can find:

  *   The press release "Requirements and Responsibilities for Third-Party Servicers and Institutions<https://www.ed.gov/news/press-releases/us-department-education-launches-review-prohibition-incentive-compensation-college-recruiters>" released this morning.
  *   The new Department of Education third-party services guidance<https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2023-02-15/requirements-and-responsibilities-third-party-servicers-and-institutions> that goes beyond just regulating incentive compensation or the percentage of a program that can be offered. A quote: "We therefore issue this guidance to clarify that entities performing the functions 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 are defined as third-party servicers. As such, the institutions that contract with these entities are subject to reporting requirements with respect to the entities, and the entities themselves are subject to annual non-federal audits of the Title IV-relevant functions they perform, if such functions are covered by the audit guide."
Note that there is a deadline of May 1 for reporting to the Department any third-party services that you have not reported to them. Since what is included as a "third-party service" is expanded, your institution may need to report.
There are also opportunities to participate in a "listening session" in early March or to submit comments about the guidance. If you have or suspect you have a contract that might be subject to this guidance, it might be good to notify your leadership (financial aid office, legal counsel, provost, or president) about this change.
We just received this notice. We will examine it further and give you more interpretation of what we see as new and significant.
Thank you,
Cheryl & Russ


------------------------------
Cheryl Dowd
Senior Director, State Authorization Network & WCET Policy Innovations
WICHE Cooperative for Educational Technologies (WCET)
Boulder CO
(303) 541-0210
cdowd at wiche.edu<mailto:cdowd at wiche.edu>
https://wcetsan.wiche.edu/
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