黑料传送门

黑料传送门鈥檚 Response to (submitted September 13, 2024)听

In August 2024, the Department of Education requested feedback on how to best support completion of the 2025-2026 FAFSA form. 黑料传送门 identified several resources, tools, and changes that could improve the FAFSA completion process for students, financial aid administrators, and institutions.听

黑料传送门鈥檚 Public Comments on (submitted August 23, 2024)

The Department of Education鈥檚 proposed regulations revise the definitions and reporting requirements for distance education, while also streamlining the process for Return to Title IV (R2T4) by requiring online institutions to take attendance and document withdrawals within 14 days of a student鈥檚 last attendance. 黑料传送门 expressed support for measures focused on ensuring quality and transparency but raised concerns about the proposed rules鈥� emphasis on delivery mode rather than quality. The comments also recommended clarifications to the R2T4 provisions and called for a more thorough cost-benefit analysis before issuance of a final rule.听

黑料传送门鈥檚 Public Comments on (submitted July 20, 2023)听

In July 2023, the Department of Education announced plans to establish a negotiated rulemaking committee and solicited comments on the Secretary of Education鈥檚 ability to modify, waive, or compromise federal student loans. 黑料传送门鈥檚 comments indicated support for improved college affordability and transparency but expressed opposition to large-scale debt relief through administrative channels, advocating instead for legislative reform that could ensure lasting changes and accountability. 黑料传送门 stated that widespread debt forgiveness could lead to unintended consequences, such as increased borrowing and taxpayer burden, and emphasized the importance of measures that hold institutions accountable and provide students with financial transparency.听

黑料传送门鈥檚 Public Comments on (submitted June 20,2023)听

Under this notice of proposed rulemaking, the Department of Education addressed five subjects: 1) financial value transparency and gainful employment, 2) financial responsibility, 3) administrative capability, 4) certification procedures, and 5) ability to benefit.听

Financial Value Transparency and Gainful Employment:听

Overall, 黑料传送门 supported the Department鈥檚 goal of helping students make informed choices through increased institutional transparency and accountability. 黑料传送门 offered several recommendations to help the Department achieve this goal. One of 黑料传送门鈥檚 recommendations, making transparency information available through the FAFSA portal, will be considered for addition in a future year, as the Department stated it would not be possible to incorporate the change to the 2024-25 FAFSA portal.听

Financial Responsibility:听

黑料传送门 suggested two adjustments to the proposed financial responsibility modifications that would reduce institutional burdens while still protecting students. These recommendations pertained to institutional reporting and events that trigger Department action. The Department incorporated both adjustments into the final rule.听

Administrative Capability:听

黑料传送门 expressed a commitment to the proper administration of its programs and services under the new rules. However, two recommendations were made: 1) delaying full implementation of administrative capability requirements until July 1, 2025, and 2) extending the placement timeline for clinical or externship opportunities to 90 days to address issues that could arise during the placement process. The Department declined to incorporate either recommendation into the final rule.

Certification Procedures:听

黑料传送门 urged the Department to withdraw proposed rules that could arguably undermine State Authorization Reciprocity Agreements (SARA) and reduce access to education. 黑料传送门 highlighted the benefits of SARA in expanding student access to higher education and protecting students through uniform eligibility requirements. The Department鈥檚 final rule kept SARA intact and provided acknowledgment of students who live in one state but plan to work in another.听

Ability to Benefit:

黑料传送门 admissions criteria include high school graduation or the equivalent and 黑料传送门 is, therefore, not currently involved with the Ability to Benefit (ATB) process. 黑料传送门 provided general support for the Department鈥檚 proposed changes, stating the new rules will clarify and simplify the ATB process for both states and institutions.听听

黑料传送门鈥檚 Public Comments on (submitted May 22, 2023)听

黑料传送门 provided feedback on the 2024-2025 FAFSA, supporting efforts to simplify the form but expressing concerns about the removal of the housing choice question. 黑料传送门 stated that this omission complicates the estimation of student costs and urged the Department of Education to reinstate the question.听

黑料传送门鈥檚 Public Comments on (submitted March 30, 2023)听

In February 2023, the Department of Education released a Dear Colleague Letter (DCL) that expanded the definition of a Third-Party Servicer (TPS). 黑料传送门 expressed concerns that this new definition includes entities not traditionally subject to TPS requirements, which could overwhelm institutions. 黑料传送门 also cautioned that the expanded definitions could divert focus from student outcomes, create heavy administrative burdens, and limit innovation and partnerships. To mitigate these risks, 黑料传送门 urged the Department to rescind the DCL and engage in a more formal process to revise TPS requirements.听 On May 16, 2023, the Department issued another DCL that removed the effective date of the previous letter and indicated plans to issue final revisions at a future date. In July 2024, the Department announced that further regulatory promulgation of third-party servicers would take place through formal negotiated rulemaking, and in October 2024, it was announced that the DCL would be rescinded.听

黑料传送门鈥檚 Comments on (submitted February 10, 2023)听

黑料传送门 provided input on the Department of Education鈥檚 proposed rulemaking on Income-Driven Repayment, which included the introduction of the SAVE Plan for student borrowers. 黑料传送门 backed aspects of the proposal aimed at simplifying and standardizing repayment rules, eliminating negative amortization, and reducing complexity for borrowers. However, 黑料传送门 did not fully endorse the proposed rulemaking due to significant financial implications for taxpayers. 黑料传送门 stressed the importance of a reasonable and lasting approach to regulation that removes confusion and makes the financial aid process less burdensome.

黑料传送门鈥檚 Response to (submitted February 10, 2023)听

The Department of Education requested feedback on how to identify low-value postsecondary programs. In its response, 黑料传送门 noted that the value offered by programs and institutions varies significantly, but this information is not readily available to students. 黑料传送门 stated that increased transparency would help students make better-informed decisions and encourage institutions to focus on value. An ROI metric, for example, could help students assess the value of pursuing a program. 黑料传送门 also recommended providing students with financial value information and student outcomes data before enrollment and suggested basing financial aid allocations on the value an institution provides.听

听

黑料传送门鈥檚 Public Comments on (submitted August 26, 2022)听

The Department of Education requested comments on prison education programs, the 90/10 rule for calculating revenue, and changes in ownership. 黑料传送门 expressed support for expanding Pell Grant eligibility within the prison system to help incarcerated individuals access education and gain life-changing opportunities. 黑料传送门 also supported proposed modifications to the change of ownership rules, particularly the updated definition of "nonprofit institution." 黑料传送门 did not comment on the 90/10 rule, as this rule only applies to proprietary institutions.听

听

黑料传送门鈥檚 Public Comments on (submitted August 12, 2022)

In this notice of proposed rulemaking, the Department of Education requested comments on several topics: borrower defense to repayment, interest capitalization, public service loan forgiveness (PSLF), and student loan discharges due to total and permanent disability, school closures, and false certification. Regarding borrower defense to repayment, 黑料传送门 expressed support for allowing borrowers to file claims when they have been wronged by an institution. 黑料传送门 emphasized that this process should be transparent and afford institutions the opportunity to respond to these claims. Additionally, 黑料传送门 backed the elimination of non-statutory student loan interest capitalization and supported many of the proposed changes to the PSLF program.听

听

黑料传送门鈥檚 Response to the National Telecommunications and Information Administration鈥檚 (submitted February 4, 2022)听

The National Telecommunications and Information Administration (NTIA) requested feedback on broadband implementation efforts. In response, 黑料传送门 highlighted the digital divide's impact on education, especially during the COVID-19 pandemic, and advocates for higher education's role in broadband access programs. 黑料传送门 also emphasized the importance of including higher education institutions as subgrantees and partners in state broadband plans to ensure access, adoption, affordability, digital equity, and inclusion. 黑料传送门 also stressed the need to ensure that State Digital Equity Plans align with broader goals in education, workforce development, and essential services. 鈥�

黑料传送门鈥檚 Response to (submitted September 23, 2021)听

黑料传送门 offered feedback on the PSLF Program, pointing out its underutilization and suggesting improvements. 黑料传送门 noted that the program is underused due to its complexity and restricted eligibility criteria. Additionally, the application and certification processes are cumbersome and would benefit from clearer instructions. 黑料传送门 recommended increasing awareness, simplifying the rules, making processes more user-friendly, and expanding eligibility.听

黑料传送门鈥檚 Public Comments on (submitted October 7, 2020)听

In response to the COVID-19 pandemic, the Department of Education proposed a priority for grant applications aimed at building capacity for remote learning. The focus areas included technology utilization and access, personalized learning, and performance-based assessments that promote competency-based education (CBE). The proposal also included potential definitions for remote learning, CBE, and interoperable credentials. 黑料传送门 supported the proposed definitions for CBE and interoperable credentials and suggested that references to short-term credentials be reframed to certificates or micro- and stackable credentials.听听

听

黑料传送门鈥檚 Public Comments on (submitted May 4, 2020)听

Western Governors University (黑料传送门) supported the U.S. Department of Education's proposed rules on Distance Education and Innovation, emphasizing the importance of regulatory clarity, flexibility, and shared accountability among federal, state, and accrediting bodies. 黑料传送门 commended the revised definitions and standards for academic engagement, credit hour, and distance education, while advocating for institutional flexibility in financial aid delivery models. The university also supported provisions for timely program approval, clear compliance standards, and streamlined certification procedures. 鈥� 黑料传送门 recommended allowing early adoption of the final regulations before July 1, 2021. 鈥�

黑料传送门鈥檚 Public Comments on (submitted January 9, 2020)听

黑料传送门 expressed its full support for the proposed TEACH Grant program regulations, which simplify requirements, improve transparency, and establish reconsideration processes for grant-to-loan conversions. 黑料传送门 expected the new regulations to reduce inappropriate debt and align with Congress's legislative intent.

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黑料传送门鈥檚 Public Comments on (submitted September 14, 2018)

In July 2018, the Department of Education announced plans to establish a negotiated rulemaking committee and requested comments on the core functions of accreditation and access to high-quality, innovative programs. 黑料传送门鈥檚 response recommended more support for innovative learning models, uniform accountability standards across delivery methods, and the inclusion of quality assurance entities in the accreditation process. 黑料传送门 also stressed the need to update the Higher Education Act to align with technological advancements and to ensure affordability, access, and workforce readiness.听

听

黑料传送门鈥檚 Public Comments on (submitted September 13, 2018)听

黑料传送门 commented on the Department of Education鈥檚 proposal to replace gainful employment regulations with a process that would update the College Scorecard, or another online tool, to offer program-level outcomes for all higher education programs participating in Title IV. 黑料传送门鈥檚 letter emphasized the need for better accountability measures for all Title IV eligible institutions, stating that current gainful employment regulations lack appropriate levels of accountability. It highlighted 黑料传送门鈥檚 competency-based education model and advocated for public policy that advances quality, access, affordability, and transparency. The letter suggests using loan repayment rates and publishing graduation rates and median earnings to improve accountability and aid student decision-making.

黑料传送门鈥檚 Public Comments on (submitted September 26, 2017)听

These written comments are an extended version of a public statement given in response to the Department of Education鈥檚 request for suggestions on higher education regulations that might be suitable for repeal, replacement, or modification. Highlighting 黑料传送门鈥檚 Responsible Borrowing Initiative, we encouraged the Department to maintain its Experimental Sites Initiative and advocated for regulations that reduce student loan debt and improve the efficiency of financial aid distribution.听

听

黑料传送门鈥檚 Public Comments on (submitted August 24, 2016)听

This notice of proposed rulemaking set forth the criteria for eligibility in Title IV financial aid programs. Additionally, it outlined the necessary disclosures for students enrolled in distance education and correspondence courses. While 黑料传送门 endorsed state reciprocity agreements, it expressed concerns regarding the proposed state authorization regulations for distance education providers.

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黑料传送门鈥檚 Public Comments on (submitted May 2, 2016)

黑料传送门 responded to the Department of Education鈥檚 proposed rule on teacher preparation accountability, expressing concerns that online institutions are judged differently from traditional colleges, risking biased evaluations and data issues. 黑料传送门 noted that the system could result in inconsistent state ratings, unfairly impacting distance education programs鈥� TEACH grant eligibility. They urged the withdrawal of the proposal and suggested collaborating with Congress for fair accountability measures.