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Welcome to GlennBogart.com!
Glenn Bogart, J.D., started his consulting business in the area of higher education compliance and administrative litigation in 1992. Services provided include:
On-site Title IV compliance reviews
Acquisition due diligence in compliance
Responses to program reviews, audits
Appeals of Final Determinations
Appeals of Emergency Actions
Accreditation responses and appeals
Mr. Bogart's impressive qualifications in the compliance field provide assurance to clients that they are hiring the best:
Independent consultant since 1992
Former financial aid executive and director of financial aid
Former program review officer, U.S. Dept. of Education
Juris Doctor, Western New England College, 1986
25 years' experience in Title IV
Please Enjoy Your Stay.
Mensa membership -- Your assurance of -- well -- nothing, really, except a modicum of intelligence.
If you are a college executive, you will probably find some things of interest on this site. Look around, and come back soon -- the site will change from time to time.
Please feel free to contact Mr. Bogart by calling
or, send e-mail to:
Glenn Bogart Compliance
Due process, ED-style.
Can you say, "Reimbursement?"
My editor at "Career Education Review" said my website might be better if I would lose the attitude. Then he said, if I did that, I wouldn't be me, so, never mind. As you will see, I took his advice. That is, the "never mind" advice.
I do have an attitude where the US Department of Education is concerned. That attitude is as follows: Just enforce the regulations the way you wrote them, and stop acting as if your second-guesses (Dear Colleague Letters and program reviewer biases) are the law.
That said, let me assure you all that I am exquisitely sensitive to those Dear Colleague Letters and program reviewer biases, and I do my best to help my compliance review clients understand them. I would never advise anyone to ignore stuff like that. More than once I have said, "You can't die in every ditch, and this is not one in which you should make your stand."
In my compliance reviewer role, my job is to let you know what you're doing, or not doing, that could get you into difficulties with ED, whether ED's position has any merit or not.
In my administrative litigation role, my job is to make mincemeat of any and all Dear Colleague Letters, unless there is something in them that works to your advantage -- in which case, I will embrace the DCL to the death in order to defend you. That is one thing that is to your advantage in an adversarial situation -- the DCL provides you with safe harbor, but you are not bound by it. And I will take advantage of this advantage shamelessly, to your benefit.
The main thing I bring to your table is that I know the reality of school operations, and I also know the administrative case law. I have been a regulator, and I have been a defender of schools against regulators. If you can find find somebody who is in a better position to help you, then hire that person. If not, then consider hiring me. If I am available, I probably will accept.