Glenn Bogart Compliance

Title IV compliance assistance and administrative litigation since 1992

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Glenn Bogart, J.D., started his consulting business in the area of higher education compliance and administrative litigation in 1992.  Services provided include:

  • On-site Title IV compliance reviews
  • Acquisition due diligence in compliance
  • On-site investigations
  • Responses to program reviews, audits
  • Appeals of Final Determinations
  • Appeals of Emergency Actions
  • Accreditation responses and appeals
  • Expert testimony

Mr. Bogart's impressive qualifications in the compliance field provide assurance to clients that they are hiring the best:

  • Independent consultant since 1992
  • Former financial aid executive and director of financial aid
  • Former program review officer, U.S. Dept. of Education
  • Juris Doctor, Western New England College, 1986
  • 25 years' experience in Title IV

If you are a college executive, you will probably find some things of interest on this site.  Look around, and come back soon -- the site will change from time to time. 

Please feel free to contact Mr. Bogart by calling
205 249-5453

or, send e-mail to:

OK, what do other people have to say about this guy?

"When you need him, you really won't care how he's dressed."  Kenneth C. Horne, Jr., founder, Virginia College, Birmingham, Alabama.

"If you aren't completely satisfied with the services Glenn Bogart provides, I'll pay his fee myself."  Guy Euliano, former president, Tri-State Business Institute, Erie, Pennsylvania.  (He actually said this to a prospective client who called for a recommendation -- but don't hold him to it, please.)

". . . a known expert in student financial aid . . ."  Administrative Judge Richard F. O'Hair, Office of Hearings and Appeals, U.S. Department of Education, Washington, D.C.

Due Process, ED-Style

Can you say, "Reimbursement?"

My editor at "Career Education Review" said my website might be better if I would lose the attitude.  Then he said, if I did that, I wouldn't be me, so, never mind.  As you will see, I took his advice.  That is, the "never mind" advice.

I do have an attitude where the US Department of Education is concerned.  That attitude is as follows:  Just enforce the regulations the way you wrote them, and stop acting as if your second-guesses (Dear Colleague Letters and program reviewer biases) are the law.

That said, let me assure you all that I am exquisitely sensitive to those Dear Colleague Letters and program reviewer biases, and I do my best to help my compliance review clients understand them.  I would never advise anyone to ignore stuff like that.  More than once I have said, "You can't die in every ditch, and this is not one in which you should make your stand."

In my compliance reviewer role, my job is to let you know what you're doing, or not doing, that could get you into difficulties with ED, whether ED's position has any merit or not. 

In my administrative litigation role, my job is to make mincemeat of any and all Dear Colleague Letters, unless there is something in them that works to your advantage -- in which case, I will embrace the DCL to the death in order to defend you.  That is one thing that is to your advantage in an adversarial situation -- the DCL provides you with safe harbor, but you are not bound by it.  And I will take advantage of this advantage shamelessly, to your benefit.

The main thing I bring to your table is that I know the reality of school operations, and I also know the administrative case law.  I have been a regulator, and I have been a defender of schools against regulators.  If you can find find somebody who is in a better position to help you, then hire that person.  If not, then consider hiring me.  If I am available, I probably will accept.