Anne D. Cartwright Play Audio Recording of Name Pronunciation

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

• Guided multiple institutions—including schools affiliated with healthcare entities in complex healthcare transactions—through change of control merger/acquisition processes including in interactions with, and compliance with the requirements of, accreditors and USED.
• 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 institution of higher education through response to significant preliminary compliance findings by U.S. Department of Education (USED), coordinating education team in internal inquiries; assisting with institutional system and policy development; and preparing written submissions to USED demonstrating that institution remediated findings and resolved concerns. USED's final determination accepted institution's response and resolution efforts, issuing limited final findings.
• Led team supporting transaction in which an institution of higher education acquired another to operate as a subsidiary from due diligence through USED and other approvals, including education, corporate, intellectual property, real estate, tax, environmental, and immigration aspects of transaction and ongoing compliance.
• Prepared colleges and universities for imminent USED Federal Student Aid program reviews, leading team in updating outdated policies, developing procedural enhancements, spot-checking student files, and staff preparation. Result was ready-to-go action plans for improved compliance available for USED review upon site visit.
• Counseled institutions on applying USED 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 and distance education concerns. Developed detailed plans for enhancing institutional compliance and mitigating risks.
• Guided large proprietary university through Gainful Employment Alternate Earnings Appeal, including implementation of alumni survey, obtaining USED clarification and successful submission of appeal under shifting Department expectations.
• Represented private faith-based liberal arts college during USED Title IV program review, reducing potential noncompliance liabilities from +$6 million to less than $4,000 through file review and analysis, demonstrating compliance to support reduction.
• Supported institutions in navigating intersection of developing athletics rules and Federal Student Aid implications of NIL and House payments.
• Coordinated approximately 2,500 Borrower Defense to Repayment responses for an institution, deploying artificial intelligence to assess complaints and generate responses to meet client goals and USED deadlines.

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 preparing for merger of their parent health system that amounted to a change in ownership under USED, accreditor, state, and other regulatory agency requirements, assisting health systems in understanding requisite timelines, financial commitments, and relevant merger and shared service agreement terms.
• 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.
• 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 (ACGME) and healthcare regulatory requirements.

Compliance and Training

• Developed and presented training for numerous college and university administrators and employees, including general back-to-school legal updates; customized advanced Title IX coordinator, investigator and adjudicator workshops; and civil rights investigator trainings.
• Served as outside investigator for schools and universities, providing independent analysis of sexual misconduct complaints raised under Title IX policies.
• Conducted in-depth legal compliance audits of educational institutions' key policies and procedures, nondiscrimination systems and operational functions to improve compliance and align with legal and risk-management best practices.
• 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.

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 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.
• Supported several institutions in responding to U.S. Department of Education investigations arising from third-party complaints of discrimination in relation to programming of unrelated, external 501(c)(3) organization.
• 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.