This afternoon, the Department of Education provided an update on its Third-Party Servicer guidance. ASAHP joined ACE in submitting comments to the Department regarding concerns with the guidance on March 29. The Department said the September 1, 2023 effective date of the guidance letter will no longer be in effect, and that the effective date of the revised final guidance letter will be at least six months after its publication. In the update the Department included a list of activities it does not consider as constituting Third-Party Servicer relationships. Included in this list is “clinical or externship opportunities that meet requirements under existing regulations because they are closely monitored by qualified personnel at an institution”.

The update may be accessed here. The comments submitted by ASAHP, ACE, and others may be accessed here.