Vanderbilt University Law School,
J.D. and Certificate in Law and Business, 2002
Duke University,
B.A., 1999
District of Columbia
Missouri
Virginia
Virginia USDC, Eastern District
National Association of College and University Attorneys
American Bar Association
Thompson Coburn LLP
Partner, 2014-Present
Vatterott Educational Centers, Inc.
Senior Vice President of Regulatory Affairs and Strategic Development, 2010-2014
Dow Lohnes PLLC (now Cooley LLP)
Attorney, Postsecondary Education Practice Group, 2002-2010
Aaron's practice is dedicated entirely to helping institutions of higher education navigate complex legal and regulatory matters.
With time served both as outside and in-house counsel, Aaron has substantive experience in the array of federal, state, and accrediting agency laws and standards that govern postsecondary institutions, and is a frequent writer and speaker on topics relating to higher education policy and the federal financial aid programs. He also is the editorial director of REGucation, the firm's higher education law and policy blog, and host of the firm's Higher Education Webinar Series.
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 selected Aaron to represent and negotiate on behalf of general counsels, attorneys and compliance officers at postsecondary institutions nationwide.
Aaron regularly 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.
In support of institutional initiatives, he assists clients in drafting and negotiating a wide variety of agreements, including domestic and international articulation, consortium, licensing, marketing, and agency contracts, and in the case of postsecondary mergers and acquisitions, stock and asset purchase agreements. Aaron also assists with the management of regulatory and government agency relationships, policy creation and implementation, strategic planning, and compliance systems design.
Aaron previously served for four years as Senior Vice President of Regulatory Affairs and Strategic Development for a multi-campus, postsecondary institution, where he managed regulatory and government affairs for the institution's 24 campus locations and its online division, as well as aspects of the institution's public relations and strategic development efforts. Prior to going in-house, Aaron served for nearly eight years in the higher education practice of a prominent Washington, D.C., law firm.
Aaron is a member of the National Association of College and University Attorneys and of the American Bar Association.
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: 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
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?
Panelist,
"The Latest in Federal Policy," University Professional & Continuing Education Association – Annual Conference March 2018
Presenter,
"Managing ADA Accommodations in the Clinical Setting," National Conference on Allied Health Education March 2018
Presenter,
"An Update on the Rewrite of the Federal ‘Borrower Defense’ Rule," National Association of State Administrators and Supervisors of Private Schools – Webinar March 2018
Presenter,
"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
Back to school: Thompson Coburn kicks off higher education webinar series
Higher ed webinar series provides insider’s look at borrower defense rulemaking
Webinar series to help higher ed navigate gainful employment regulations
Aaron Lacey, Chris Murray author paper on regulatory hurdles for competency-based education
Rightsizing the Right Way: Restructuring and Realignment in Higher Education
Higher education attorney Aaron D. Lacey joins Thompson Coburn
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