Introduction by Barbara K. Mistick

Dear Colleagues,

Due to the July 4 holiday, we're publishing this week's Washington Update on Thursday rather than Friday to make sure you have the latest news before Congress begins its recess.

This week witnessed two significant regulatory developments within the Department of Education. First, the Department released final AHEAD regulations implementing the new program-level accountability framework, often referred to as “Do No Harm” or “Gainful Employment for All,” which will determine whether programs remain eligible for federal Direct Loan participation. The regulations include several important changes from the proposed rule, particularly around implementation timing, cohort aggregation, earnings thresholds, appeals, and exemptions, reflecting the impact of sustained advocacy by NAICU and the higher education community. See story below. 

The Department also released interim guidance responding to a federal court order staying part of the RISE final rule’s definition of “professional” programs, adding several health sciences programs to the professional loan category while making clear that other programs will not be treated as professional during the stay. NAICU will continue to analyze both developments, provide members with additional guidance, and press for implementation that is workable, legally sound, and responsive to the needs of students and institutions. See story below.

NAICU continues to closely monitor the proposed changes to the OMB Uniform Guidance and its potential implications for independent colleges and universities. NAICU will participate in a higher education community response letter, due July 13, and we strongly encourage institutions to submit their own comments to ensure that OMB understands the practical impact these proposed changes would have on campus operations, federal student aid administration, and institutional compliance. In addition to the community letter, NAICU will submit a shorter letter of its own highlighting several key concerns with the proposed guidance at a high level. A template outlining those issues is available here: [LINK].

To help NAICU members understand the two policies announced this week, as well as a better understanding of the OMB Uniform Guidance policy, we hope you will join us for the three webinars outlined below:

• Tuesday, July 7 | 3:00 p.m. ET 
  OMB Uniform Guidance: How It Can Impact Your Campus 
  Learn what OMB's proposed changes to the Uniform Guidance could mean for federal grants and private, nonprofit colleges and universities.
  

• Wednesday, July 8 | 12:00 p.m. ET 
  RISE Regulations and Graduate Loan Reporting 
  Hear from attorneys at Duane Morris on the Department of Education's interim guidance following the recent federal court ruling on the RISE regulations and what it means for Title IV compliance and graduate loan reporting. 

• Tuesday, July 14 | 12:00 p.m. ET
  Do No Harm Final Rule
  NAICU’s policy experts will provide a detailed overview of the final “Do No Harm” regulations issued through the AHEAD negotiated rulemaking process, including key changes from the proposed rule and implications for independent colleges and universities.

We also encourage institutions to review NAICU's Your Vote, Your Voice resources as campuses begin preparing for the 2026 midterm elections. 

I hope you have a safe, relaxing, and enjoyable Fourth of July weekend as we celebrate America's 250th birthday.

Regards,  

Barbrara

Barbara K. Mistick

President, NAICU

For more information, please contact:
Barbara K. Mistick