AACOM and AAMC Comment on ED Third-Party Servicer Guidance
Published April 03, 2023
By AACOM Government Relations
Advocacy Federal Policy Financial Aid Higher Education OME Advocate
On March 29, 2023, AACOM and the Association of American Medical Colleges (AAMC) submitted a joint comment letter in response to the U.S. Department of Education (ED)’s expanded guidance for third-party servicers (TPS). Our organizations urged ED to withdraw the guidance or modify it to explicitly exclude its application to medical schools or the services we provide.
Under the guidance, vendors providing student recruiting and retention services, certain software products and services linked to Title IV Federal Student Aid administration activities and educational content and instruction would have to register and comply with TPS rules. Hospitals, clinics and doctors’ offices that host rotations for osteopathic medical students may fall within this expanded TPS definition. This could harm their willingness to host clinical opportunities for medical students during the third and fourth years of medical school. Many other routine services could also be captured under the new guidance. AACOM will continue to keep our COMs informed of ED’s actions on this issue.