The Software & Information Industry Association (SIIA) has sent the following letter to Secretary Cardona in response to the Dear Colleague Letter issued by the Department of Education (the Department) on February 15, 2023, “Requirements and Responsibilities for Third-Party Servicers (TPS) and Institutions.”
Key takeaways:
- Due to the widespread consensus of lack of clarity around the scope and significant impact this guidance could have on the education community, we strongly recommend the Department rescind the “effective immediately” nature of the letter, and extend the May 1 reporting deadline and comment period by a minimum of 30 days.
- The guidance creates a litany of issues and will be extremely burdensome on the education community.
- Based on our early analysis of the new guidance, the Department’s definition of TPS goes far beyond the commonly understood scope of the term
Read the full letter here
