Advocacy Alert: USDE Third-party Service Provider Guidance Comment Period Extended

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

MSCHE joined nearly 50 signers from higher education in a letter sent by the American Council on Education (ACE) urging USDE to extend both the period for institutions to submit comments and the institutional reporting deadline contained in the guidance.

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. The letter was updated to extend the public comment period.

USDE also released a Dear Colleague Letter providing guidance to institutions that contract with a third-party servicer (TPS) to administer any aspect of the institution’s participation in the student assistance programs authorized under Title IV of the Higher Education Act of 1965, as amended (HEA). The guidance will become effective on September 1, 2023, on which date the reporting requirements will also go into effect.

Read the Dear Colleague Letter regarding Requirements and Responsibilities for Third-Party Servicers and Institutions.

Submitting Public Comments

Institutions should submit written comments via the Federal Rulemaking Portal by March 30, 2023.