Glenn Bogart Compliance

Title IV compliance assistance and administrative litigation since 1992

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Services available:

On-site Title IV compliance reviews

          How would your college fare in a program review?  If you want to find out, call Glenn Bogart.  I use judgmental sampling to find the students who are most likely to have compliance failures and potential liabilities, and will help you fix those failures.  Generally this can be done in three days, regardless of the size of the school, at a modest cost.  On top of that, it is not unusual for me to find money on the table that more than pays for the cost of the visit.  For more information on that, please see the "Why Hire Me" page elsewhere on this site.  If you want to know my fees, please contact me at 205 249-5453 or for a quote.

Acquisition due diligence

        When you buy a school, you're jointly and severally responsible for any Title IV liabilities incurred under the old ownership.  Before you take that on, you'd better get the operation reviewed by the best expert you can find.  'Nuff said!

Program review responses

          If they were always right, they wouldn't give you an opportunity to respond -- not to mention, a right to appeal!  Program reviewers are just people, and they can be wrong, just like anybody else.  Sometimes they are wrong in pretty spectacular fashion -- but that may not be obvious even to an experienced financial aid director.  In this, as in other important business matters, having an expert on hand can make all the difference. 

          I will come to your college, if necessary, to oversee any necessary file reviews and to write a professional response.  If it looks like I can write the response at home, I'll do that, and save you the travel expenses.  At this point, we want to try to keep it collegial, if possible -- ED doesn't need to know a hired gun is involved.  I'll write it, and you sign it.  Of course, ED may be a little surprised at "your" expertise!

          The initial response to a program review report is your first chance to try to talk them out of some of those findings -- don't blow it!  If you treat this as a do-it-yourself project, there's about a 95 percent chance you are not going to be happy with the results -- the same as if you were to build your own house without expert help.

          It's worthwhile to spend some money and bring in an expert right from the start -- even during the on-site visit, if you have enough notice and someone is available. 

Your business office after a program review?

Program review and audit final determination appeals; fees

          A Final Program Review Determination or Final Audit Determination isn't really final.  The law and regulations give you an opportunity to appeal -- but this definitely isn't a do-it-yourself job.  The case will be decided by an administrative judge in the Department's Office of Hearings and Appeals.  He's going to be a real judge, and he's going to want to hear real argument and real case law that supports your position.  If you go in there and just tell him what a good school you have, ED's lawyer will squash you like a bug.  

          I can write your appeal, write your brief(s), and present your oral argument if that becomes necessary.   No guaranteed win, of course -- but you could do a whole lot worse in picking a representative for your school.  Since I operate as a consultant, and not as an attorney, I can afford to charge my clients a lot less than an attorney would. Contact me for a quote.

Accrediting agency responses and appeals

          My role here varies, depending on the nature of the problems alleged.  The first step, of course, is to see if a finding is correct, according to the exact language of the criterion or standard your college supposedly violated.  After that, you either grovel or fight, depending on what you find.  At the very least, I can help you figure out your strategy and help you put together a response or appeal that will be as professional as any the agency has ever seen.

Attorney assistance and expert testimony

Do you have a lawyer you trust, but who really doesn't know a whole lot about Title IV?  No problem -- hire me to help.

Need an expert to testify about Title IV rules, regulations, ED policies, and school practices?  I can do that, too. 

And in conclusion

Glenn Bogart is the man to call if you have a higher education compliance problem -- or if you don't, and you want to keep it that way.  Law degree, ex-Fed, ex-corporate financial aid executive, and independent consultant for over 30 years.

Call Glenn Bogart at 205 249-5453 or email  Do it now!