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Aaron Lacey


St. Louis
314 552 6405 direct

Aaron's practice is dedicated entirely to helping institutions of higher education navigate complex legal and regulatory matters.

With time served both as outside and in-house counsel, Aaron has substantive experience in the array of federal, state, and accrediting agency laws and standards that govern postsecondary institutions, and is a frequent writer and speaker on topics relating to higher education policy and the federal financial aid programs. He also is the editorial director of REGucation, the firm's higher education law and policy blog.

Aaron regularly represents institutions in administrative proceedings before state licensing entities, accrediting agencies, and the U.S. Department of Education, including matters arising from audits, program reviews, and investigations of the Office of Inspector General.

In support of institutional initiatives, he assists clients in drafting and negotiating a wide variety of agreements, including domestic and international articulation, consortium, licensing, marketing, and agency contracts, and in the case of postsecondary mergers and acquisitions, stock and asset purchase agreements. Aaron also assists with the management of regulatory and government agency relationships, policy creation and implementation, strategic planning, and compliance systems design.

Aaron previously served for four years as Senior Vice President of Regulatory Affairs and Strategic Development for a multi-campus, postsecondary institution, where he managed regulatory and government affairs for the institution's 24 campus locations and its online division, as well as aspects of the institution's public relations and strategic development efforts. Prior to going in-house, Aaron served for nearly eight years in the higher education practice of a prominent Washington, D.C., law firm.

Aaron is a member of the National Association of College and University Attorneys and of the American Bar Association.


Gainful Employment Disclosures and Student Warnings

New Audit Guidelines for Higher Educational Institutions

Final Borrower Defense Rule Webinar Series

The Elimination of Pre-Dispute Arbitration Clauses and the New Repayment Rates for Proprietary Schools

Changes to Closed School and False Certification Discharge

The Revised Financial Responsibility Standards

The New Borrower Defense Framework

Borrower Defense Rule Webinar Series

Gainful Employment Webinar Series

The Clery Act

Competency-Based Education


The future of gainful employment: Three points, a calendar, and a webinar

Webinar to examine new rules for proprietary school audits

Recordings now available for final Borrower Defense Rule webinars

Thompson Coburn hosts webinar series on Department of Education’s final Borrower Defense Rule

Title IX and due process: ED tells Wesley that accused student not treated fairly

ED’s new rules for teacher preparation programs

Proposed Borrower Defense Rule webinar recordings now available

ED terminates recognition of ACICS: Next steps

ED issues proposed rules for higher ed distance learning programs

NLRB issues two key decisions affecting higher ed


"How to Project Gainful Employment Rates,"
Thompson Coburn Desk Guide, March 2016

Co-Author, "The Nuts and Bolts of Reauthorization,"
Career Education Review, October 2015

Co-Author, "Rethinking the Regulatory Environment of Competency-Based Education,"
American Enterprise Institute's Center on Higher Education Reform, May 2015


Presenter, “The State of Gainful Employment: Current and Future Challenges for Schools”;
National Association of State Administrators and Supervisors of Private Schools – Annual Conference, April 2017

Panelist, “Regulatory and Compliance Aspects of International Online and Continuing Education”;
University Professional & Continuing Education Association, February 2017

Co-Presenter, “FSA: The New Audit Guide”;
New York State Financial Aid Administrators Association, January 2017

Presenter, “Hot Topics in Higher Education”;
Louisiana Association of Private Colleges and Schools Executive Management Meeting, January 2017

Presenter, “USED Program Review Preparation and Unwrapping the Borrower Defense Rule”;
Missouri Association of Student Financial Aid Personnel - Annual Conference, December 2016

Presenter, “The Borrower Defense Final Rules”;
New York State Financial Aid Administrators Association – 48th Annual Conference, November 2016

Presenter, “Gainful Employment: Preparing for the Next Six Months”;
Kansas Board of Regents – Annual State Meeting, October 2016

Presenter, “Structuring International Recruiting and Marketing Arrangements and Gainful Employment: Effectively Challenging Debt-to-Earnings Rates”;
Association of Private Sector Colleges and Universities - Annual Conference, June 2016

Co-Presenter, “Federal Perspectives in Higher Education”;
United States Distance Learning Association National Conference, May 2016

Presenter, "ADA Title III Fundamentals";
Commercial Vehicle Trade Association - Fall Conference, October 2015

Panelist, "The Promise (and Perils) of Competency-Based Education";
Roundtable Webinar Series Presented by University Professional & Continuing Education Association and Penn State University, September 2015

Presenter, "Paper Nirvana: Crafting Enrollment Documentation that's Great for Students and Schools Alike";
Association of Private Sector Colleges and Universities - Webinar, August 2015

Co-Presenter, "Competency-Based Education: The Path to Program Approval";
Association of Private Sector Colleges and Universities - Annual Conference, June 2015

Presenter, "Managing Crime, Security, and Allegations of Sexual Misconduct on the Christian Campus";
Council for Christian Colleges and Universities - 39th Annual President's Conference, January 2015

Co-Presenter, "Rightsizing the Right Way Restructuring and Realignment in Higher Education";
Webinar, September 2014