AACS Submits Recommendations on GE, BDR, and Audit Guidelines to the Department of Education

Last Wednesday, July 12th, 2017, in response to the U.S. Department of Education’s June 16th Federal Register Notice announcing their intention to establish two Federal Negotiated Rulemaking Committees, AACS submitted written testimony applauding the Department’s decision to revisit both the Gainful Employment and Borrower Defense to Repayment Regulations and offering comments and recommendations related to not only needed changes to these two harmful and overly restrictive regulations, but also the urgent need for immediate postponement and revision to the Proprietary School/Servicer Audit Guidelines (letter attached).  AACS GRC Committee Chairman Neal Heller also presented these concerns at the first of two regional field hearings held by the Department last week in Washington, D.C.

With this submission behind us, AACS now turns our attention to two additional opportunities to submit additional sets of comments and recommendations to Secretary DeVos and the Department.  First, in response to the July 5, 2017 Federal Register Notice announcing additional time to comply with the GE Alternate Earnings Appeals deadlines – which were published in no small measure thanks to the Court’s Order in response to our lawsuit, AACS will be responding to requests for comment on the decision to delay implementation of the GE Disclosure Template requirements related to the inclusion of such information in institutions’ promotional materials and the presentation of GE program data to prospective students prior to any enrollment related actions on the part of the student.  AACS is currently drafting our favorable response to the Department’s decision and will be providing additional comments to the Department prior to the August 4th, 2017 deadline. 

Second, in response to Secretary Devos June 22nd, 2017 request seeking any and all recommendations on how to streamline the current regulations and over 1,000 Office of Postsecondary Education, AACS will be providing a comprehensive list of proposals to revise or repeal overly prescriptive, duplicative, and redundant regulations and sub-regulatory guidance and interpretation prior to the August 21st, 2017 deadline.  Please be advised that next week AACS will be putting forth a Call to Action seeking your input in the development of a comprehensive list of proposals to submit to the Department.

All of this while we await the Department’s publication of new revised GE guidance in response to the AACS lawsuit which the Department has indicated would be forthcoming in early August.