The Department of Education (ED) released Dear Colleague Letter (DCL) GEN-23-03 earlier this year to ensure proper oversight of Third-Party Services that perform various functions related to institutions’ participation in Title IV aid programs.
The effective date of the DCL was initially set for May 1, 2023, but it was extended to September 1, 2023. ED received over 1,000 comments during the 30-day comment period, providing valuable feedback. Acknowledging the concerns and efforts made by institutions and companies to comply with reporting and compliance deadlines, ED is granting additional time for compliance.
On a blog post published April 11th, ED announced that institutions will have additional time to comply with the guidance and removed the September 1st deadline.
The new DCL GEN-23-08 officially removes the effective date of third-party servicer guidance in DCL GEN-23-03, which will not go into effect, and also removes the prohibition on contracts between institutions and foreign-owned or operated third-party servicers.
ED further stated that they plan to “issue a final revised DCL with an effective date at least six months after its publication to allow institutions and third-party servicers covered by the final guidance to meet any reporting requirements. Deadlines for audit and contractual requirements will follow, starting with the institution’s first fiscal year that begins after the effective date for the reporting requirements.”
College Aid Services is an audited U.S.-based third-party servicer with over 20+ years of experience and knowledge. If your institution needs help with these or other guidelines, interim staffing, technology support or enrollment modeling and marketing, contact us here. We look forward to connecting with you.
Source: (GEN-23-08) Update to Third-Party Servicer Guidance in GEN-23-03