The U.S. Department of Education intends to commence negotiated rulemaking on programs authorized under Title IV of the Higher Education Act of 1965, and invited public feedback on changes to the federal student loans programs, Federal Pell Grants, and other changes to the Title IV.
PCC Executive Director Kyle Southern provided comments, urging the department to include those who are most affected by changes to Pell and federal loan programs to be at rulemaking negotiating table. He also provided three suggestions for the department to consider when implementing the Workforce Pell Program.
Read his full remarks below:
Good afternoon, I am Dr. Kyle Southern, and I serve as Executive Director of the Partnership for College Completion, a Chicago-based nonprofit, nonpartisan organization that advances solutions across Illinois that address historic inequities in our higher education system.
I first want to encourage the Department to ensure essential constituencies have voices at the upcoming negotiating tables. We thank the Department for its attention to students and borrower representation. For both rounds of rulemaking the Department has proposed to take on, however, tables should also include a distinct seat for representatives from civil rights organizations. The substantial, historic changes to loan programs, Pell, and other proposed areas will have especially direct effects on student populations most often marginalized by our country’s economic and educational systems. Accordingly, organizations that center advocacy for these diverse populations should have a seat to present data and give voice to students and borrowers who stand to gain or lose the most because of the Department’s actions. Further, proposed topics directly implicate campus-based financial aid administrators, yet the Register notice does not include them as stakeholders at the expected tables. We encourage the Department to include a distinct seat for financial aid professionals or their professional association during the upcoming rounds of negotiations.
Legislation passed by Congress and signed by the president earlier this year opens eligibility for students pursuing short-term workforce training programs to qualify for Pell Grants to cover their programs’ cost—an initiative with longstanding bipartisan interest. More than 250,000 Illinois college students rely on Pell Grants to help pay for their degree programs, and PCC is concerned about the long-term fiscal sustainability of Pell—a concern heightened by the projected funding shortfall Congress must move to address fully, not just the partial fix in its recent bill. Governors will play a key role in determining program eligibility to participate in Workforce Pell, and as a state-focused policy organization, we are committed to advocating principles that protect both the sustainability of Pell overall and the students who rely on Pell in financing the cost of their postsecondary programs of study.
As the Department moves to implement Workforce Pell Program eligibility, we elevate three primary considerations:
- Programs should be required to demonstrate proven earnings benefits for their completers.
- The Department should establish a workable, reliable, and readily accessible platform for transparency concerning program approvals, completion, earnings, and other key metrics.
- The Department should put strong guardrails in place that deter predatory actors and high-cost, low-quality programs from entering Workforce Pell participation.
In short, the Department should require programs to meet federally mandated requirements as a precondition for Pell participation eligibility.
By following these principles, the Department can fulfill its responsibility to protect students, taxpayers, and the long-term sustainability of the Pell Program. Failing to implement regulations that reflect these principles would likely lead to a repeat of a familiar cycle in which high-cost, low-quality, and predatory institutions rush to enroll students to boost their own bottom lines, rather than the earning potential of the people enrolling.
Thank you for the opportunity to provide these comments and considerations as the Department moves forward with its coming rounds of rulemaking.