On January 16, 2026, the U.S. Department of Education issued an Electronic Announcement, “Program Participation Agreement Signature Requirements” (GEN-26-04), addressing the general circumstances under which an owner-entity of a Title IV-eligible institution may be required to sign a program participation agreement (PPA) under Section 498 of the Higher Education Act (HEA), codified at 20 U.S.C. § 1099c. The announcement was issued in connection with the Department’s settlement of litigation in Hannibal-LaGrange University v. U.S. Department of Education, 2:25-cv-00042 (E.D. Mo. 2025), which challenged the legality of the Department’s 2023 amendment to 34 C.F.R. § 668.14(a)(3)(ii).
Read the full Alert on the Duane Morris LLP website.
