Glenn Bogart Compliance

Title IV compliance assistance and administrative litigation since 1992

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Glenn Bogart, J.D.
3292A Warringwood Dr.
Hoover, AL  35216

Phone: 205 249-5453



1992 – present             

Independent consultant, Birmingham, Alabama.  A nationwide consulting practice specializing in compliance with Title IV of the Higher Education Act.  Representing higher education institutions in program review and Office of Inspector General audit and inspection matters, writing responses and appealing final program review and final audit determination letters.  Less frequently, representing schools in emergency action and termination matters, and accrediting agency adverse actions.  Performing on-site Title IV compliance and management reviews at colleges throughout the U.S. 

Frequent contributor to Career Education Review on Title IV, student financial aid management and administrative litigation.  Speaker at Career College Association annual convention, Las Vegas, 2003, as well as several state private career school organization meetings.


Director, Internal Audit and Compliance, Phillips Colleges, Inc., Gulfport, Mississippi.  Supervised staff of four internal audit/compliance officers.  Wrote responses to about 30 Office of Inspector General audit and inspection reports and U.S. Department of Education program review reports, working closely with the company’s outside attorneys, Dow, Lohnes & Albertson of Washington, D.C.  Designed and implemented special-purpose internal audits.  Served on corporate committee formed to analyze and implement massive changes in federal student aid requirements brought about by the Higher Education Amendments of 1992.

1987 – 1991

Vice President for Student Financial Aid, HCTIA, Inc., Birmingham, Alabama.  In charge of financial aid operations and policy for chain of 24 proprietary colleges, and policy only for another 30 or so schools under partially the same ownership.  Wrote and implemented “Appendix D” student loan default management plan which was later used by many school clients of the Postsecondary Education Assistance Corporation (PEAC).  That plan helped reduce default rates at dozens of colleges, and was found to be in compliance with regulatory requirements in administrative litigation with the Department of Education.  Also in this position, developed expertise in admissions and ability-to-benefit testing and general administration of proprietary schools.

1979 – 1982

Institutional Review Specialist, U.S. Department of Education, Atlanta and San Francisco Regional Offices.  Performed on-site Title IV program reviews at all types of postsecondary institutions, and also served as Title IV training specialist for the Atlanta office.  Supervised all other program review officers in audit review project.  Received several cash awards for sustained superior performance.


Juris Doctor, Western New England College School of Law, Springfield, Massachusetts, 1982

Bachelor of Arts, Government, Southern Illinois University, Carbondale, Illinois, 1974