Anne D. Cartwright Play Audio Recording of Name Pronunciation

Mergers, Acquisitions & Change of Control

• Guided multiple institutions—including schools affiliated with healthcare entities in complex healthcare transactions—through change of control merger/acquisition processes, including interactions with, and compliance with the requirements of, accreditor, state, USED, and other agencies.
• Led team supporting a transaction in which an institution of higher education acquired another to operate as a subsidiary, from due diligence through USED and other regulatory approvals, including the education, corporate, intellectual property, real estate, tax, environmental, and immigration aspects of the transaction and ongoing post-closing compliance.
• Advised multiple nursing and health sciences colleges affiliated with regional hospital systems through sale and change-of-ownership transactions, coordinating regulatory approvals alongside the underlying healthcare system merger or divestiture.

Title IV Federal Student Aid, Scholarships, & Other Student Funding

• Assisted institutions in developing institutional loan and student account payment programs compliant with student finance, Truth in Lending Act, and state consumer finance law requirements.
• Served as counsel to institutions responding to USED Office for Civil Rights investigations related to scholarships, evaluating scholarships and other programming to ensure compliance with nondiscrimination laws and USED Title IX and Title VI expectations, as well as state obligations.
• Guided an institution of higher education through response to significant preliminary compliance findings by USED, coordinating the education team on internal inquiries, assisting with institutional system and policy development, and preparing written submissions demonstrating that the institution remediated findings and resolved concerns; USED's final determination accepted the institution's response and resolution efforts, issuing limited final findings.
• Prepared colleges and universities for imminent USED Federal Student Aid program reviews, leading teams in updating outdated policies, developing procedural enhancements, spot-checking student files, and preparing staff, resulting in ready-to-go action plans available for USED review upon site visit.
• Counseled institutions on applying USED's still-developing data privacy, breach, and disclosure reporting requirements concerning Federal Student Aid information.
• Conducted reviews at colleges and universities of high-risk Title IV compliance areas, including returns of Title IV funds, satisfactory academic progress, incentive compensation, and distance education concerns, developing detailed plans for enhancing institutional compliance and mitigating risk.
• Guided a large proprietary university through a Gainful Employment Alternate Earnings Appeal, including implementation of an alumni survey, obtaining USED clarification, and successful submission of the appeal under shifting Department expectations.
• Represented a private faith-based liberal arts college during a USED Title IV program review, reducing potential noncompliance liabilities from more than $6 million to less than $4,000 through file review and analysis demonstrating compliance.
• Supported institutions in navigating the intersection of developing athletics rules and Federal Student Aid implications of NIL and House settlement payments.
• Worked with numerous institutions in addressing issues around foreign gift and contract reporting under Section 117 of the Higher Education Act, including reporting responsibilities and interpretation of USED demands for information.
• Coordinated approximately 3,500 Borrower Defense to Repayment responses for an institution, deploying artificial intelligence to assess complaints and generate responses that met client goals and USED deadlines.

Accreditation

• Represented accrediting agencies in responding to USED compliance findings identified in staff reports and in related Senior Department Official (SDO) proceedings, developing written submissions and supporting evidence to address Department concerns.
• Prepared accrediting agencies for hearings before the National Advisory Committee on Institutional Quality and Integrity (NACIQI), including developing hearing strategy, preparing witnesses, and drafting materials addressing recognition and renewal criteria.
• Worked proactively with accrediting agencies to review and update policies and procedures to align with evolving USED expectations and regulatory requirements, reducing the risk of future compliance findings.

Civil Rights & Nondiscrimination

• Led institutional responses to multiple USED Office for Civil Rights compliance reviews and complaint investigations under Title VI and Title IX, including reviews addressing admissions, athletics, and scholarship programs.
• Supported medical schools in responding to U.S. Department of Justice and U.S. Department of Education inquiries concerning admissions, scholarships, and association affiliations.
• Served as outside investigator for colleges and universities conducting Title IX and other civil rights investigations, including athletics-related complaints, complaints filed with state human rights agencies, and complaints in academic medicine research settings.
• Advised university system clients on Title VI compliance reviews and related state and federal civil rights inquiries affecting multiple campuses within the system.
• Developed and delivered civil rights and Title IX investigator training programs addressing institutional response to complaints for education investigators and decision-makers.

Academic Medical Programs

• Conducted investigations of alleged bullying and other misconduct by principal investigators at academic medical centers.
• Guided multiple nursing and health sciences institutions in merger and acquisition transactions, including mergers and acquisitions of parent health systems.
• Led a privileged investigation into physician conduct at an academic medical center, coordinating with institutional leadership on findings and remedial measures.
• Led hospital inquiry related to medical resident resignations to ensure compliance with legal and accreditation requirements and support effective residency program operations.
• Counseled fellowship and residency programs in responding to accreditation complaints and accreditor action related to compliance with institutional and program requirements, including matters before the Accreditation Council for Graduate Medical Education.
• Assisted academic medical centers and other institutions in analyzing risks and intersecting emerging legal, nondiscrimination, and agency requirements surrounding COVID-19 vaccinations for employees and students in education programs.
• Partnered with members of Husch Blackwell's Healthcare team to ensure optimal structure for residency and fellowship programs, ensuring compliance with Accreditation Council for Graduate Medical Education and healthcare regulatory requirements.
• Advised an academic medical center on a Title IX matter involving a physician, coordinating compliance with institutional policy and applicable healthcare regulatory requirements.

Developing Incident Response

• Counsel numerous institutions in adapting to shifting federal executive administrative priorities, including by providing rapid analysis of law applicable to nondiscrimination, grant compliance, and 501(c)(3) obligations, and ensuring policies and practices align with requirements while supporting institutional mission.
• As a key member of the firm's COVID-19 resource team, advised clients on accessing pandemic-driven financial assistance—including Paycheck Protection Program (PPP) and Higher Education Emergency Relief Fund (HEERF) compliance—and vaccination considerations.
• Provided counsel to institutions experiencing mass email campaign complaints related to institutional practices, assessing institutional response and recommending best practices for resolution and ongoing monitoring.

Primary Outside Counsel

• Provided "first phone call" responses to K-12 schools, colleges, and universities, guiding them through legal, policy, and procedure considerations related to situations presenting potential nondiscrimination, student disability accommodation, governance, contract review, financial aid, and employment issues.
• Served as touchpoint for college and university boards conducting institutional presidents' evaluations and setting strategic goals.
• Guided schools through measured approaches to concerning student conduct—including use of social media and escalating threats—and resulting discipline, all while balancing potential disability, other discrimination, privacy, speech, and other legal considerations.
• Served as ongoing outside general counsel to multiple colleges and universities, serving as the primary point of contact across higher education regulatory, governance, student, and employment matters.