Advocacy Alert: Institutions are Encouraged to Comment on the USDE Updated Third-party Service Provider Guidance

As part of the Middle States Commission on Higher Education’s (MSCHE) strategic priority to promote advocacy initiatives for its members and others, we encourage institutions to submit feedback during the comment period for the United States Department of Education (USDE) Updated Third-party Service Provider Guidance. Read USDE’s Announcement.

Updated Third-party Service Providers Guidance

On February 15, 2023, USDE released updated guidance regarding third-party servicers providers and offering clarification on organizations providing recruitment services. According to the release,

Institutions will have until May 1, 2023, to report any arrangements with third-party servicers that have not been reported to the Department, detail the services the entity performs on behalf of the institution, and disclose the timeframe of the agreement. Entities or individuals that meet the definition of a third-party servicer as a result of this Dear Colleague Letter are required to submit the Third-Party Servicer Data Form to the Department or update their existing form by May 1, 2023. Any audits required of third-party servicers would not be needed for at least six months, with most servicers having significantly longer than that.

Submitting Public Comments

Institutions should submit written comments via the Federal Rulemaking Portal by March 17, 2023.