USDE Third Party Servicer (TPS) Update

The JRCERT has been apprised of an update from the United States Department of Education (USDE) regarding the Dear Colleague Letter (GN-23-03) with the proposed revisions to the definition of Third-Party Servicer (TPS). As proposed, this definition would have encompassed clinical settings as third-party servicers with contracts required between sponsoring institutions and clinical settings as well as joint liability for any violation of Title IV requirements between the two.

The gravity of the situation was critical and required immediate attention, to which the profession responded swiftly. Over 1,000 letters of concern were submitted to the USDE, many from our accredited programs. In addition to the JRCERT, the ARRT and ASRT also provided letters of concern. These efforts showed tremendous merit and the USDE responded accordingly. We are pleased to announce that the USDE provided clarification and clinical settings and externships are not considered TPS. If you are interested, the entire USDE update on guidance for third party servicers can be located HERE.  

Again, thank you for all your efforts and support of programmatic accreditation. It is exciting to see the results we can achieve through a unified profession! If you have any questions, please do not hesitate to contact CEO Leslie Winter at