Image of Painted Question Mark Symbolizing the five questions

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

**Update ** As of February 28, 2023, the US Department of Education has updated its guidance “to extend the public comment period, establish a future effective date for the guidance, and extend the reporting deadline for institutions and third-party servicers.” The deadline is now September 1, 2023 (rather than May 1).

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

CooleyED – Article

Thompson Coburn – Article

Thompson Coburn – Webinar (3/27/23)

Hush Blackwell – Article

Duane Morris – Article

Holland & Knight – Article



Higher Education Organizations:

WICHE – Article

UPCEA – Article

ACE – Joint Group Letter

NACUBO – Article

NAICU – Letter

NAICU – Issue Summary



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



Pearson Sells its OPM – Article


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