The Middle States Commission on Higher Education, a regional accreditor that has historically been responsible for accreditation in states between D.C. and New York, recently unveiled a proposed new policy on Third-Party Providers. 

  • The proposed policy which can be commented on through October 20th, is the latest attempt by regulators to hone in the vast number of entities partnering with colleges and universities.
  • If implemented, the policy would set parameters around contracts and what information needs to be included and addressed. It also requires institutions to have a formal process for the review and approval of these contracts to ensure they are meeting Middle States requirements. 

Middle States’ policy would have an incredibly broad definition of Third-Party Providers: “​​an entity, institution or organization that has a contract or written arrangement to provide services to the institution.”

  • The policy, while broad, does sharpen in the context of providers that provide recruiting and marketing outsource contracts, including some OPMs, noting the institution is responsible for promotional materials and noting that contracts “that outsource marketing, recruitment, and advertising to third-party providers will receive intense scrutiny.”

The policy comes as the U.S. Department of Education’s (ED) Third-Party Servicer Dear Colleague Letter remains on pause, with ED still expected to share an updated letter addressing a number of concerns submitted through comment.