On February 15 the Department of Education provided guidance via a Dear Colleague letter which expands its interpretation of the definition of “third-party servicers”. Institutions will have until September 1, 2023 to provide the requested details on their relationships with third-party servicers. The deadline to provide comments to the Department is March 30, 2023. According to ACE: “Based on our review of the DCL, it appears that the following entities may be considered TPSs: an institution that provides courses and instruction to another institution as part of an inter-college consortia; an online extension campus providing services to another campus of the same university; an institution in a state system providing services to other institutions in the system; a hospital providing clinical experiences and the related educational programing for nurses and other medical professionals; a local police department helping to compile and analyze campus crime statistics; a non-profit organization providing student engagement and 1 This letter does not attempt to detail our substantive input on the Department’s proposal, which we are in the process of developing and will provide to the Department in a separate submission. 2 retention services or tools to improve student outcomes for at-risk students; publishers providing online materials and study guides, or technology providers developing adaptive courseware solutions.”

Details and the opportunity to comment may be accessed here. A letter from ACE to the Department of Education is available here.