"In recent years, we have monitored DFSCA compliance and how the Education Department is enforcing the law. And, in sum, we have found that many colleges appear to be noncompliant, and more are being investigated and fined. In research for a 2016 white paper, we uncovered 57 instances where the department found violations between 2014 and 2015. And in a 2017 study, we found that all but two of Michigan’s 28 public community colleges suffered significant failures in compliance. Meanwhile, as we describe in a 2018 law review article about the Education Department’s most recent investigations (especially Penn State), the bar for compliance has also been gradually raised."
-Bradley D. Custer and Michael M. DeBowes