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Preparing students for the workforce is a key part of the value of higher education and a major reason the public supports continued government investment in federal student aid. Increasingly, however, bad actors have found ways to game the system, accessing billions of dollars of federal aid for poor quality or fraudulent programs that leave students saddled with debt they can never repay. In addition to harming students, these bad actors erode public trust in the value of higher education as a whole.

NACUBO is committed to preserving the public's confidence in federal student aid programs and protecting students from fraud and abuse, without placing an undue regulatory burden on institutions that offer a legitimate, quality education. NACUBO's expertise and advocacy efforts have focused on ED regulations related to program integrity, particularly borrower defense, gainful employment, and state authorization.


Borrower Defense

Borrower defense rules relieve student borrowers of their federal debt if their schools have closed or misled them. Notably, the rules also include financial responsibility adjustments in response to several newly defined triggering events that might call an institution’s financial responsibility into question. After a court battle, the Obama-era borrower defense regulations went into effect on October 17, 2018. To learn more about borrower defense rules, visit NACUBO's Borrower Defense page.


Gainful Employment

Gainful employment rules disqualify programs from receiving Title IV aid if their graduates consistently have high levels of student debt relative to their incomes.


State Authorization

This addresses the requirement that an institution have state authorization before it can offer study abroad programs or provide distance education to students residing in other states.


General Program Integrity

These broad rulemaking efforts fall outside of borrower defense, gainful employment, or state authorization.


Related Pages

ED Regulations   ED Archives   Borrower Defense


Liz Clark

Vice President, Policy and Research


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