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So your probably holding this Civil Investigative Demand from DOJ or DOE about education fraud and your entire institution is collapsing. Maybe you had issues with the 90/10 rule. Maybe there’s problems with recruiter compensation. Or maybe your just caught up in there latest Title IV enforcement sweep. Look, we get it. Your ABSOLUTELY TERRIFIED. And you should be! Because for-profit colleges have paid $95.5 MILLION settlements and executives face federal prison for Title IV violations!
Let me explain the academic nightmare your facing. DOE discovered $90 MILLION in fraudulent disbursements and there desperate to destroy “bad actors” in higher education!
The False Claims Act applies to ANY false certification for Title IV funds! Every FAFSA certification, every 90/10 calculation, every enrollment report becomes a potential false claim! We’ve seen legitimate schools destroyed over technical violations of impossibly complex regulations!
Here’s what’s really scary – treble damages apply to the ENTIRE amount of federal aid received! Got $10 million in student loans last year? That’s $30 million in damages! Plus up to $28,000 per false claim! Each student is a separate claim!
Hold onto your accreditation because these numbers will bankrupt entire colleges!
EDMC paid $95.5 million for incentive compensation violations! American Commercial College paid $2.5 million for 90/10 manipulation! These aren’t fly-by-night schools – there established institutions destroyed by DOJ!
Criminal penalties are CATASTROPHIC – wire fraud carries 20 years prison! False statements to DOE adds 5 years! Conspiracy another 5 years! School officials are going to federal prison! One executive got 3 years for falsifying enrollment!
The 90/10 rule is a DEATH TRAP for schools! For-profit schools must get at least 10% revenue from non-federal sources!
But DOE interprets this impossibly strictly! Veterans benefits now count as federal! State grants might count as federal! Private loans guaranteed by school? FEDERAL! We’ve seen schools fail 90/10 because they helped students get private financing!
Prospect College got caught manipulating institutional payments – counting school money given to students as “private” revenue! Now there destroyed! One accounting trick triggers False Claims Act liability for YEARS of aid!
Your probably wondering “Who reported us?” Let me tell you what puts schools in DOJ’s crosshairs:
Whistleblowers get 15-30% of recoveries! Fired admissions rep? They’re calling lawyers! Former financial aid officer? Filing qui tam lawsuit! Even current employees report violations for million-dollar rewards!
Compliance audits trigger investigations! A-133 audit findings get referred! Program reviews find discrepancies! Change in ownership reviews expose past violations! We’ve seen routine audits explode into criminal prosecutions!
The incentive compensation ban DESTROYS schools! ANY bonus based on enrollment is illegal!
But DOE interprets this insanely broadly! Performance reviews mentioning enrollment? VIOLATION! Promoting successful recruiters? Violation! Team bonuses when campus hits goals? ILLEGAL! We’ve seen schools destroyed for standard HR practices every business uses!
The safe harbors are meaningless! “Salary adjustments” get scrutinized! “Merit increases” trigger investigations! Even firing underperforming recruiters becomes evidence of illegal compensation! Your damned if you incentivize, damned if you don’t!
ABSOLUTELY! And executives are personally targeted! School official pled guilty to $2.9 million veterans education fraud!
Recent prosecutions are terrifying! Jeffrey Williams got prison for fake employment letters! Admissions directors prosecuted for enrollment fraud! Financial aid directors imprisoned for false certifications! These aren’t criminals – there education professionals!
The Varsity Blues scandal showed DOJ’s appetite for education prosecutions! Parents, coaches, administrators all imprisoned! If they’ll prosecute parents for admissions fraud, imagine what they’ll do to schools taking federal money!
The scope is absolutely overwhelming! DOE demands EVERYTHING about Title IV participation:
Every enrollment agreement and transcript, all financial aid files and FAFSA forms, recruiter compensation records and bonus structures, marketing materials and scripts, graduation and job placement data, default rate calculations, even personal emails about admissions!
For 90/10 calculations its worse – revenue recognition policies, private loan arrangements, institutional scholarship records, military benefit processing, state grant documentation! How do you prove every dollar was properly categorized over 5 years? You can’t!
Prepare for YEARS of regulatory hell! Education fraud investigations are extraordinarily complex:
Initial CID response (60-90 days of massive production), DOE/DOJ review and analysis (6-12 months), student interviews and data verification (6-12 months), False Claims Act damages calculation (6-12 months), settlement or prosecution (12-24 months)!
Your looking at 3-5 years MINIMUM! During this time, Title IV suspended, can’t enroll new students, accreditor requires disclosure, and current students transfer out! Legal fees? Expect $1-3 million! We’ve seen colleges close before investigations conclude!
Title IV termination is INSTANT DEATH for schools! DOE can emergency suspend without hearing!
No federal student aid means no students! 90% of students need Title IV! Can’t operate without it! Even temporary suspension triggers mass exodus! We’ve seen 5,000-student schools close within months of suspension!
Provisional certification is almost as bad – heightened monitoring, letter of credit requirements, delayed disbursements! Students go elsewhere! Faculty flee! Death spiral begins! One compliance failure destroys decades of education!
Self-reporting is a TRAP with criminal exposure! DOJ uses self-disclosures as admissions!
Program Participation Agreement requires reporting “credible information” of fraud – but reporting triggers False Claims Act! Don’t report when required? Concealment charges! Report minor issue? Opens door to everything! We’ve seen schools self-report small violations only to face $50 million settlements!
The “voluntary” disclosure to DOE doesn’t prevent DOJ prosecution! Civil settlement doesn’t stop criminal charges! Cooperation credit is minimal! Your confessing to crimes hoping for mercy that rarely comes!
School officials face PERSONAL criminal liability! Responsible corporate officer doctrine applies!
CEO didn’t know about violations? Doesn’t matter! CFO relied on compliance team? Still liable! Admissions VP followed industry practice? GUILTY! We’ve seen executives imprisoned for violations by employees they never met!
Asset forfeiture reaches personal wealth! Salary from “fraudulent” school? Clawback! Bonuses? Forfeited! Retirement accounts? Seized! One college president lost his home, savings, and freedom!
Look, we’re not your typical education lawyers who just handle accreditation. We’re federal criminal defense attorneys who specialize in keeping school officials out of prison when Title IV issues become criminal!
We understand the impossibly complex web of Title IV regulations. We know how 90/10 calculations really work and what DOE accepts. We can demonstrate good faith compliance efforts even with technical violations. Most importantly, we prevent civil investigations from becoming criminal prosecutions!
Other firms tell you to cooperate with DOE and fix problems. That’s EXACTLY how executives end up in federal prison! The government doesn’t care about educating students – they want False Claims Act recoveries and criminal convictions. We fight strategically, protecting your freedom and institution!
Call us RIGHT NOW at 212-300-5196
Education fraud investigations destroy schools overnight!
Former DOE prosecutors – Title IV defense experts – Available 24/7!
Don’t wait another second! DOE is analyzing your IPEDS data! DOJ is calculating False Claims Act damages! Whistleblowers are meeting with prosecutors! Your accreditor is preparing emergency action! Every day increases liability!
Remember – education fraud isn’t about compliance anymore. Its about federal prison and institutional death. One 90/10 miscalculation, one recruiter bonus, one false certification can trigger criminal prosecution and school closure. You need someone who understands Title IV complexity AND federal criminal defense. Call us NOW before that CID becomes handcuffs!
Very diligent, organized associates; got my case dismissed. Hard working attorneys who can put up with your anxiousness. I was accused of robbing a gemstone dealer. Definitely A law group that lays out all possible options and best alternative routes. Recommended for sure.
- ROBIN, GUN CHARGES ROBIN
NJ CRIMINAL DEFENSE ATTORNEYS