Thompson Coburn partner Aaron Lacey, co-chair of the firm’s nationally recognized Higher Education Practice, has been appointed by the U.S. Department of Education as a primary negotiator to the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) rulemaking committee.
The committee is charged with negotiating several critical topics, including the revision of the existing Financial Value Transparency and Gainful Employment accountability framework, the integration of the new Do No Harm accountability framework created by the One Big Beautiful Bill Act (OB3), and the implementation of the new Workforce Pell Grant program, also created by OB3.
During the negotiations, Aaron has been selected to represent the interests of private nonprofit institutions of higher education (including institutions eligible under Title III and Title V of the HEA, Tribal Colleges and Universities, and Historically Black Colleges and Universities).
“I’m deeply grateful for the opportunity to participate in the upcoming rulemaking, and, in particular, to provide insight regarding the revision and reconciliation of the various accountability frameworks currently in play,” Aaron said. “It’s a critically important issue, and one I’ve worked on for the past 15 years.”
The proceedings, which will be live-streamed, are scheduled to take place in December and January. Understanding that many institutions will not be able to tune in for the weeklong sessions, Aaron will host two debriefings for the higher education community. During these webinars, Aaron will summarize the main topics discussed during the prior week and the status of each. Interested parties are invited to register using the links below:
- 2-3 p.m. CT December 16: December 2025 AHEAD Negotiated Rulemaking Committee Debrief
- 2-3 p.m. CT January 13: January 2026 AHEAD Negotiated Rulemaking Committee Meeting Debrief
This is Aaron’s second time to serve as a negotiator. In 2017, he was selected by the Department of Education to serve as a negotiator in overhauling the complex and controversial “borrower defense” rule. In that instance, the Department appointed him to negotiate on behalf of general counsels, attorneys, and compliance officers at postsecondary institutions nationwide.
