What the Updated PPA Signature Requirements Mean for M&A and Investment in Education

March 17, 2026 | Webinar | Duane Morris LLP

Please join us for our webinar, What the Updated PPA Signature Requirements Mean for M&A and Investment in Education, which will take place on Tuesday, March 17, 2026 at 1:00 p.m. Eastern. 

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About the Program

On January 16, 2026, the U.S. Department of Education issued an Electronic Announcement, “Program Participation Agreement Signature Requirements” (GEN-26-04), addressing when an owner-entity of a Title IV-eligible institution may be required to sign a program participation agreement (PPA) under Section 498 of the Higher Education Act (HEA). The guidance reflects a more restrained enforcement posture of the signature requirements. However, as discussed in our previous Alert, it does not resolve the underlying tension between the Department’s regulatory approach and the text of the HEA. Investors, lenders and other transaction participants rely on predictable regulatory processes to assess risk, structure transactions and ensure ongoing compliance with Title IV requirements—and the absence of such clarity can introduce uncertainty that discourages otherwise viable transactions.

Our webinar will provide a clear, practical assessment of:

• The statutory and regulatory origins of the PPA signature requirement
• What GEN-26-04 changes, and what it does not
• The current risk profile for institutions (for-profit and private non-profit), owners, investors and lenders
• How this issue intersects with change-of-ownership, financial responsibility and other Title IV regulations
• What to expect from the Department’s next steps, including potential rulemaking

We will also discuss how institutions, investors and lenders should be thinking about structuring transactions in light of the current state of play.

Presenters 

Jed Brinton, Senior Vice President and General Counsel, Career Education Colleges and Universities

Anthony J. Guida Jr., Partner and Team Lead, Duane Morris Education Industry Group

About Duane Morris

Duane Morris’ Higher Education Group regularly advises investors, institutions and nonprofit organizations on complex mergers and acquisitions, changes of control and other strategic combinations and alliances across both the proprietary and private nonprofit higher education sectors. The group has extensive experience structuring transactions to address Title IV regulatory requirements, accreditation considerations, financial responsibility issues and risk allocation, including transactions involving private equity sponsors, nonprofit conversions, consolidations, joint ventures and affiliation models. This experience positions the group to provide practical, market-informed guidance on evolving Department of Education policies and their impact on institutional strategy and transactional execution.

About CECU

Career Education Colleges and Universities is the national association representing private postsecondary trade schools and career colleges. CECU’s membership includes 900 campuses across the United States and shares member benefits through a partnership with Canada’s National Association of Career Colleges.