UPDATE (March 1, 2023): On February 28, 2023, the Department updated the Dear Colleague Letter regarding third-party servicers to expressly state: “the guidance in this Dear Colleague Letter will not become effective until September 1, 2023.” The Department also extended the public comment period on this Dear Colleague Letter to Thursday, March 30, 2023. Finally, the Department extended the reporting deadline for institutions and third-party servicers to September 1, 2023.

On Feb. 15, the U.S. Department of Education issued guidance that significantly expands the definition of “third-party servicer” to include services completed by many online program managers and entities providing other services that historically have not been considered third-party servicers. Institutions and entities considered third-party servicers under the new guidance are subject to mandatory reporting requirements by May 1, 2023.

Read on to learn more about the Department’s guidance.