Morrison Cohen Provides Pro Bono Legal Support on Department of Education STATS Final Rule

Morrison Cohen's Government Strategies & Controversies Group advised an entity in the higher education sector in a pro bono engagement involving the Department of Education’s new Student Tuition and Transparency System (STATS) and Earnings Accountability final rule, published in the Federal Register on July 1, 2026.

The team provided legal and regulatory analysis concerning the evolving framework and its potential impact on institutions that do not participate in the federal Direct Loan program.

Partner Y. David Scharf, with assistance from intern Shayna Altschuller, coordinated the firm’s efforts in support of a broad coalition of religious organizations and trade schools across the country. The GS&C team presented information and perspectives through the negotiated rulemaking and notice-and-comment process, helping the client understand proposed regulatory changes and evaluating potential legal and operational implications.

The final rule exempts institutions that have not participated in the Direct Loan program during the preceding five award years from certain Title IV eligibility consequences and provides an opt-out mechanism for institutions that choose to discontinue participation. These provisions address concerns raised by diverse religious institutions and professional programs while furthering the Department’s higher-education reform objectives.