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Aaron Lacey


St. Louis
314 552 6405 314 552 6405 direct

The Chair of Thompson Coburn's Higher Education Practice, Aaron assists institutions to navigate a wide range of complex legal and regulatory matters.

Aaron has substantive experience in federal, state, and accrediting agency laws and standards that govern postsecondary institutions, and regularly advises on issues involving students, faculty and staff, facilities, academics, governance, and operations. He also leads the Firm's extremely active higher education transactional practice. He and his colleagues have experience negotiating, documenting, and implementing merger, asset acquisition, stock acquisition, joint venture, and religious sponsorship and affiliation transactions for both nonprofit and proprietary higher education clients. In recent years, the practice has managed numerous non-traditional arrangements, as well, including for-profit to non-profit conversions and the acquisition of distressed institutions.

Aaron and his colleagues are valued for their deep understanding of the postsecondary regulatory framework, including requirements relating to the federal financial aid programs, incentive compensation, distance education, the Clery Act, FERPA, and Title IX, among others. In October 2017, Aaron was selected by the U.S. Department of Education to serve as one of 17 negotiators charged with overhauling the Department's complex and controversial "borrower defense" rule. The Department appointed him to negotiate on behalf of general counsels, attorneys, and compliance officers at postsecondary institutions nationwide.

Aaron routinely represents institutions in administrative proceedings before state licensing entities, accrediting agencies, and the U.S. Department of Education, including matters arising from audits, program reviews, and investigations of the Office of Inspector General. He assists with the management of regulatory and government agency relationships, policy creation and implementation, strategic planning, and compliance systems design. In support of institutional initiatives, Aaron drafts and negotiates a wide variety of agreements, including domestic and international articulation, consortium, licensing, marketing, and bundled service provider (OPM) contracts.

The host of the Firm's popular Higher Education Webinar Series, and editorial director of REGucation, the Firm's higher education law and policy blog, Aaron is a frequent writer and speaker on topics relating to higher education policy and regulation. He is a member of the National Association of College and University Attorneys and of the American Bar Association.


Postsecondary Institutions: Business Considerations

Examining ED’s Incentive Compensation Rule

Higher Education Transactions: Valuation & Structure

The Regulatory Outlook for Higher Education

Analyzing ED’s New Distance Education Rule

Title IX Module 6: Title IX Appeals

Title IX Module 5: Title IX Determinations

Title IX Module 4: Title IX Hearings

Title IX Module 3: Title IX Investigations & Informal Resolutions

Title IX Module 2: Formal Complaints of Title IX Sexual Harassment

Title IX Module 1: An Introduction to Managing Title IX Sexual Harassment on Campus

Getting Ready for USED’s New Student Disclosure Requirements

USED’s New Title IX Rule: A Detailed Examination

The CARES Act for Higher Education: Strategy and Implementation

Contingency Planning for Distressed Institutions of Higher Education

Recent Court Decisions in Student Disputes That You Should Know About

A Year-End Roundup of USED Rulemaking Activity

Merging Institutions of Higher Education: Corporate and Tax Considerations

An Examination of ED's New Borrower Defense Rule: Financial Responsibility and Related Reporting Requirements

An Examination of ED's New Borrower Defense Rule: The Borrower Defense Claim Process

Examining the USED Approval Process for Higher Ed Mergers and Acquisitions

A Midsummer Update on USED Rulemaking Activity

Charitable Giving for Institutions of Higher Education

Advertising and Communications for Institutions of Higher Education

Guidance on Borrower Defense Regulations

USED’s Proposed Title IX Rules: A Detailed Examination

Notice of Proposed Rulemaking on Borrower Defense

Disclosure Requirements for Online and Distance Professional Licensure Programs

Borrower Defense Rule: Negotiated Rulemaking Session 3

Borrower Defense Rule: Negotiated Rulemaking Session 2

Borrower Defense Rule: Negotiated Rulemaking Session 1

Gainful Employment Disclosures and Student Warnings

New Audit Guidelines for Higher Educational Institutions

Final Borrower Defense Rule Webinar Series

Borrower Defense Rule Webinar Series

Gainful Employment Webinar Series

Competency-Based Education

The Clery Act


Higher Education Emergency Relief Funds reporting requirements

COVID IV legislation: A summary of provisions most impacting higher education

Free Title IX compliance checklist for institutions of higher education

Thompson Coburn releases free Title IX training series for institutions of Higher Education

Making Clery Act notifications during COVID-19

CARES Act funds: Significant new USED guidance includes surprises

ED issues instructions to Higher Ed to obtain CARES Act funds

The CARES Act: More options for higher education

The CARES Act: Summary of provisions impacting higher education institutions and borrowers

COVID-19: Is there a silver lining for higher education?


"The Latest in Federal Policy," University Professional & Continuing Education Association – Annual Conference March 2018

"Managing ADA Accommodations in the Clinical Setting," National Conference on Allied Health Education March 2018

"An Update on the Rewrite of the Federal ‘Borrower Defense’ Rule," National Association of State Administrators and Supervisors of Private Schools – Webinar March 2018

"Consumer Information Boot Camp and What’s Next for USED’s Borrower Defense Rule," Missouri Association of Student Financial Aid Personnel - Annual Conference November 2017

"How to Project Gainful Employment Rates,"
Thompson Coburn Desk Guide, March 2016

Co-Author, "The Nuts and Bolts of Reauthorization,"
Career Education Review, October 2015

Co-Author, "Rethinking the Regulatory Environment of Competency-Based Education,"
American Enterprise Institute's Center on Higher Education Reform, May 2015


Presenter, “The State of Gainful Employment: Current and Future Challenges for Schools”;
National Association of State Administrators and Supervisors of Private Schools – Annual Conference, April 2017

Panelist, “Regulatory and Compliance Aspects of International Online and Continuing Education”;
University Professional & Continuing Education Association, February 2017

Co-Presenter, “FSA: The New Audit Guide”;
New York State Financial Aid Administrators Association, January 2017

Presenter, “Hot Topics in Higher Education”;
Louisiana Association of Private Colleges and Schools Executive Management Meeting, January 2017

Presenter, “USED Program Review Preparation and Unwrapping the Borrower Defense Rule”;
Missouri Association of Student Financial Aid Personnel - Annual Conference, December 2016

Presenter, “The Borrower Defense Final Rules”;
New York State Financial Aid Administrators Association – 48th Annual Conference, November 2016

Presenter, “Gainful Employment: Preparing for the Next Six Months”;
Kansas Board of Regents – Annual State Meeting, October 2016

Presenter, “Structuring International Recruiting and Marketing Arrangements and Gainful Employment: Effectively Challenging Debt-to-Earnings Rates”;
Association of Private Sector Colleges and Universities - Annual Conference, June 2016

Co-Presenter, “Federal Perspectives in Higher Education”;
United States Distance Learning Association National Conference, May 2016

Presenter, "ADA Title III Fundamentals";
Commercial Vehicle Trade Association - Fall Conference, October 2015

Panelist, "The Promise (and Perils) of Competency-Based Education";
Roundtable Webinar Series Presented by University Professional & Continuing Education Association and Penn State University, September 2015

Presenter, "Paper Nirvana: Crafting Enrollment Documentation that's Great for Students and Schools Alike";
Association of Private Sector Colleges and Universities - Webinar, August 2015

Co-Presenter, "Competency-Based Education: The Path to Program Approval";
Association of Private Sector Colleges and Universities - Annual Conference, June 2015

Presenter, "Managing Crime, Security, and Allegations of Sexual Misconduct on the Christian Campus";
Council for Christian Colleges and Universities - 39th Annual President's Conference, January 2015

Co-Presenter, "Rightsizing the Right Way Restructuring and Realignment in Higher Education";
Webinar, September 2014