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BRIEFING: Third Party Servicers and Online Program Management

On February 15, 2023, the U.S. Department of Education Office of Federal Student Aid issued a Dear Colleague Letter that greatly expanded the definition of third-party servicers (TPS) to include “entities performing the function 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.” The guidance also prohibits colleges and universities from contracting with third-party servicers located outside of the United States or entities “owned or operated by an individual who is not a U.S. Citizen or national or a lawful U.S. permanent resident.” The guidance will take effect on September 1, 2023. On that same day, colleges and universities must report all TPS arrangements to the Department. Join us for a 30-minute NACUA briefing to learn about the guidance, associated regulatory requirements, and institutional compliance efforts.