The AAMC and the American Association of Colleges of Osteopathic Medicine (AACOM) sent a March 30 joint letter in response to updated Department of Education (ED) guidance on “third-party servicers” (TPS). In the letter, the associations state, “we urge ED to withdraw the guidance or modify it to explicitly exclude its application to medical schools or the services we describe below and to better target the guidance to match ED’s stated intention pertaining to online program managers.”
On Feb. 28, ED updated guidance via a Dear Colleague Letter, “Requirements and Responsibilities for Third-Party Servicers and Institutions” (GEN-23-03), to better regulate online program managers and for other purposes. TPS are individuals or entities that assist institutions of higher education in meeting their Title IV requirements under the Higher Education Act. TPS must comply with specific ED contracting, auditing, liability, and reporting requirements. The new ED definition for TPS includes activities related to recruiting or retaining students, providing software products and services involving Title IV administration activities, and providing educational content and instruction.
Of particular concern to academic medicine, hospitals and preceptors participating in student clinical rotations would fall under the definition of TPS. In response, the joint letter noted, “As described, the proposed TPS framework does not take into consideration the unique aspects of U.S. medical education and risks worsening the healthcare workforce shortage.”
The updated guidance and corresponding reporting requirements are scheduled to go into effect on Sept. 1, but on March 23, ED announced “third party servicers and related issues” as a potential topic in upcoming negotiated rulemaking. ED public hearings to discuss those potential topics will be held April 11-13.