Public Comment Letter Regarding the Requirements and Responsibilities of Third-Party Servicers (TPS)
March 30, 2023
CHEPP submitted the following public comment to the U.S. Department of Education on the requirements and responsibilities of third-party servicers (TPS). In February 2023, the Department released updated guidance on TPS that greatly expanded the number of higher education institution contracts that are considered a TPS entity. TPS previously only applied to contractors directly administering Title IV dollars, not the administration of Title-IV eligible programs. CHEPP’s letter outlines considerations the Department should make in implementing this expansion, such as whether this gives more contractors heightened access to student data and how to handle when current contractors do not comply with the new guidance.