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June 7, 2023

On May 19, 2023, the U.S. Department of Education (ED) published in the Federal Register the official version of its latest notice of proposed rulemaking (NPRM), which reintroduces the “gainful employment” or “GE” framework. Understanding that this is of particular significance, we are distributing the recording of our June 6, 2023 webinar and summary of the proposed GE rule: 

Proposed GE Rule Webinar Recording
Summary of Proposed GE Rule

This webinar led by Aaron Lacey, the Chair of Thompson Coburn’s Higher Education Practice, pays particular attention to the expanded application of the rule to non-GE programs (degree programs offered by public and private non-profit institutions), including the proposed D/E rate and earnings premium calculations, the consequences of failure, and the associated data reporting requirements.

We strongly encourage institutional counsel, compliance officers, and federal financial aid professionals to communicate with campus leadership, professional colleagues, and appropriate trade organizations regarding this proposed rule, and to consider commenting.