360 Degrees Education v. U.S. Dept of ED and American Massage Therapy Association v. U.S. Dept of ED (2024) Challenging Bare Minimum Rule
Description
Two lawsuits filed in two separate U.S. District Courts challenge a new regulation that has been known colloquially as the “Bare Minimum Rule”, effective July 1, 2024. The rule limits Title IV aid for Gainful Employment (GE) programs to only the minimum hours a state requires for licensure. This replaced the prior rule allowing up to 150% of state minimum hours. In June 2024, a nationwide injunction was granted to temporarily block the rule, and the U.S, Department of Education announced it would continue enforcing the 150% standard. The litigation remains pending.
Action to be taken
- Follow current standard: Continue using the 150% of state minimum hours rule for Title IV eligibility.
- Monitor litigation: Stay updated on court proceedings that may change requirements.
- Prepare for change: Be ready to adjust program lengths or aid eligibility if the Bare Minimum Rule is reinstated.
Ruling Date
June 21,2024 – Preliminary Injunction granted (nationwide) Litigation pending
Resources
360 Degree Education, LLC v. U.S. Department of Education (4:24-cv-00508); District Court, N.D. Texas; Using “Court Listener” to follow the litigation steps
American Massage Therapy Association v. U.S. Department of Education, No. 24-cv-01670 (D.D.C.). Using Pacer Monitor to follow the litigation steps