Image of Painted Question Mark Symbolizing the five questions

US Department of Education Third-Party Servicer Changes: Resource Round-Up


Last updated October 23, 2023


**Update **


As of April 11, 2023, the US Department of Education has updated its guidance “Specifically, we will delay the effective date of the guidance letter, and the September 1, 2023, date will no longer be in effect. The effective date of the revised final guidance letter will be at least six months after its publication, to allow institutions and companies to meet any reporting requirements.”

Resources have also been added below.


On February 15, the US Department of Education issued a Dear Colleague Letter regarding significant expansion to what it considers a Third-Party Servicer. A set of FAQs was also provided. The Third-Party Servicer changes have widespread implications for nearly all institutions and many departments within the college or university — including departments involved with admissions, enrollment, retention, data analysis, technology, etc. The Government Accountability Office (GAO) released a report in May 2022 citing recommendations for OPMs based on their findings.

The following are links to resources that may be helpful to Third-Party Servicers as well as colleges and universities.

Attorney Reviews:

Image of Painted Question Mark Symbolizing the five questions

Duane Morris – Article – Article 5/26/23

Thompson Coburn – Article (4/12/23)

CooleyED – Article

Thompson Coburn – Article

Thompson Coburn – Webinar (3/27/23)

Hush Blackwell – Article

Duane Morris – Article

Holland & Knight – Article



Higher Education Organizations:

MSCHE – Policy Proposal (October 2023)

WICHE – Article

UPCEA – Article

ACE – Joint Group Letter

ACE – Call to Discuss in NegReg

NACUBO – Article

NAICU – Letter

NAICU – Issue Summary

NAICU – Letter to Abolish Guidance



Inside HigherEd – OpEd

Inside HigherEd – Debrief of the DOE Listening Sessions

Inside HigherEd – Article 2

Inside Higher Ed – Article 1

EdSurge – Article

Higher Ed Dive – Article 2

HigherEd Dive – Article 1


Higher Education Businesses

D2L – Not a Third-Party Statement



Whiteboard Advisors – Webinar Discussion

Forbes – Article

Phil on Ed Tech – Article

Phil on EdTech – Article – 10/23/23



Pearson Sells its OPM – Article

2U – Sues Federal Government


If you have additional free resources to be added, email the link for consideration.