Comments submitted on behalf of the low-income clients of the Legal Aid Foundation of Los Angeles (LAFLA) and the National Consumer Law Center (NCLC) in response to the Department’s announcement of its intent to form a negotiated rulemaking committee to address program participation in federal student aid programs under Title IV of the HEA, including institutional eligibility under 34 C.F.R. § 600.2; the definition of state authorization reciprocity agreement under 34 C.F.R. § 600.9; third-party servicers and related issues; the definition of “distance education” under 34 C.F.R. § 600.2 as it pertains to clock hour programs and reporting for students who enroll primarily online; and the return of title IV funds.
Our comments are informed by our work as legal aid practitioners. NCLC and LAFLA strive to
meet the legal needs of individuals and families with limited economic means, who otherwise
would be without professional legal assistance.
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