Glenn Bogart Compliance

Title IV compliance assistance and administrative litigation since 1992

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Articles & Advice

Financial Aid "Criminal" Exonerated

Glenn Bogart, J.D.

I’ve been working on this certain program review appeal case forever, it seems.

It was a sad case if I’ve ever seen one.  I’m going to leave out the name of my client to protect his privacy – but I think the story needs to be told.

This client, Mr. X we’ll call him, i…

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Top 10 Things Owners Must Not Do

1. Don't buy a school without having expert due diligence done. Otherwise, you could end up buying a lot of liabilities that will bite you later - and your nice new school might end up being terminated.

2. Don't hire someone with no Title IV experience to run your financial aid operation.

3. D…

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Why You Should Follow Dear Colleague Letters

This is why administrative law defense can really stink sometimes.  This is the original, unexpurgated, no-holds-barred version of my article.

Secretary’s Decision in CollegeAmerica-Denver Case

We don’t need no stinkin’ regulations:  If we say it, it’s a rule.

Glenn Bogart, J.D.

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Conflicting information and “unlikely scenarios”

Glenn Bogart, J.D.
published in "Career Education Review"
October, 2008

Conflicting information or documentation with respect to a student’s application for federal student aid is a rich source of expensive file review requirements and institutional liabilities in many U.S. Department of Educat…

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Welcome to the DMV!

copyright 2007 Glenn Bogart, J.D.

In my work with (and against) the U.S. Department of Education, I have run across a fair amount of bureaucratic nonsense and bullying.  Remember the day of the Financial Aid Transcript?  Granny applies for a Pell Grant, indicates that she attended Miss Brown's Sc…

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Decisions, Decisions . . .

As 2007 began, we found ourselves awaiting two decisions from the administrative judges in ED's Office of Hearings and Appeals that we believed would have a big impact on program reviews and enforcement actions for years to come.  One of them came through as hoped.  The other case, described immedia…

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Cases in Which I Participated

Over the years, I have been involved in a lot of cases that were appealed to the Office of Higher Education Appeals, U.S. Department of Education. 

Most cases end up being settled.  The ones listed below went all the way. 

In some of these cases,  I represented the school in the administrat…

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Why 100% verification is a bad idea

1.  Because it's a pain in the butt.  Well, it is!  By all means, you should have the student bring the tax returns in if you are helping fill out the FAFSA -- but when you're done, give them back.  Tell the student you might need them again if he or she is selected for verification, so he needs t…

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Top Ten Reasons You Might Be a Little Concerned About Your Financial Aid Director

10.  She drives a brand new Lexus, but makes only $30,000 a year, has three kids, no husband, and gets no child support.
9.  She asks for three months off to visit her chateau in the south of France.
8.  He wears a pinkie ring with a diamond the size of a Buick.
7.  Since he's b…

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Financial Aid Director Interview Questions

Interview questions for Financial Aid Director applicants . . .

Have to interview applicants who want to be your school's next Director of Financial Aid?  Here are some questions you can use to test their knowledge.

Q.1.  What's IFAP?
A.1.  It's ED's website, Information for Financ…

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