Linda,
The removal of the 12 safe harbors prohibited referrals for a fee. Here is an exerpt from the Program Integrity Rules. "(2) Whether the commission, bonus,or other incentive payment is provided to any person based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, which are defined as activities engaged in for the purpose of the admission or matriculation of students for any period of time or the award of financial aid. If the answer to each of these questions is yes, the payment would not be permitted under section 487(a)(20)… >>>