Comments on Docket ID: ED-2025-OPE-0151
Dear Under Secretary Kent:
The Presidents Forum is a coalition of 19 not-for-profit institutions serving over one million students nationwide. Our members share a commitment to innovation that leads to greater access and measurable increases in student success.
Our institutions serve many learners who balance education with career and family responsibilities—a population historically overlooked in regulatory discussions. The Department should prioritize negotiators who understand and actively support these students. Representatives from institutions specializing in working learner education can provide valuable insights into how proposed regulations affect student access, persistence, and success.
We advocate for focused and limited regulatory development that respects state oversight and promotes accountable innovation. As the Department conducts negotiated rulemaking sessions to implement the One Big Beautiful Bill Act, we urge a measured approach that consistently prioritizes student success and educational flexibility.
Given the significant impact these negotiated rulemaking sessions will have on financial aid administration, we join many others, including the National Association of Student Financial Aid Administrators (NASFAA), in advocating that both the AHEAD and RISE constituencies should include financial aid administrator representation.
Based on our values, approach, and perspective, we offer the following recommendations for regulatory changes to enhance efficiency, transparency, and student outcomes.
Comments on Issues Under Consideration by the RISE Committee:
- Definitions: We urge the Department to provide clear and comprehensive definitions of what qualifies as a “professional program.” While 34 CFR 668.2 defines “professional degree,” the definition is not comprehensive and may not encompass all programs that should rightfully be classified as professional in nature. We recommend that the Department and negotiators build upon existing definitions while acknowledging their limitations.There is a critical need to develop more robust criteria that reflect the evolving landscape of professional education, particularly as new and innovative professional programs emerge across various disciplines. Negotiators should explore how students enrolled in dual degree programs where only one program is defined as “professional” would be impacted. A collaborative approach to expanding these definitions would ensure that students in legitimate professional programs have access to appropriate loan limits that reflect the unique costs and demands of their education.If licensure is used as a criterion for professional definition, negotiators should explore how licensure requirements vary by state and how this will impact program definition. This could unfairly advantage schools in some states that do require licensure as part of the program, providing schools in those states with higher loan limits than schools in states where licensure is not required. This situation could lead to significant unintended consequences.
- Less-Than-Full-Time Enrollment: This provision directly impacts working learners and non-traditional students, who form the core constituencies of our member institutions. We are deeply concerned about how proportions will be implemented. It is vital that students currently attending at less than full-time status can continue their education without disruption.The Department should maintain institutional flexibility to define full-time status for graduate students. When establishing a methodology for less-than-full-time enrollment, this flexibility must remain intact. We recommend that recalculations for students enrolled less than full-time follow the same requirements as Pell Grant recalculations, which would align processes and reduce administrative burden. Lastly, we encourage the Department, if following the recalculation methodology, to allow for loan eligibility for less than half time students.Clear definitions, straightforward instructions, and simplified implementation processes are essential to prevent additional barriers for working learners. The Presidents Forum stands ready to provide expertise and feedback on implementation approaches that will best serve these student populations.We know that loan limits are being considered both within and outside of the RISE Committee, as the department is developing a new schedule to disburse loans based on enrollment. In that process, we urge similar considerations of consistent calculations and process, reducing administrative burden, and maintaining flexibility for both institutions and students.
Comments on Issues Under Consideration by the AHEAD Committee:
- Accountability Measures: The Presidents Forum emphasizes that accuracy and effectiveness should take precedence over timeliness in implementation. While we fully support transparency efforts and remain dedicated to improving student outcomes, we recognize the challenge institutions face in managing both Financial Value Transparency (FTE) and Gainful Employment (GE) requirements simultaneously. We urge the Department to work toward establishing a single, coherent accountability framework—whether by incorporating new measures into the existing FVT or GE structures or by developing a new, comprehensive approach. This consolidated framework would reduce institutional burden while still maintaining robust accountability, ultimately allowing institutions to focus more resources on directly serving students rather than managing duplicative compliance requirements.
- Pell Grant Changes: While we understand the Department’s desire to eliminate overpayment to students without demonstrated need, we are concerned about effectively transforming Pell from a first-dollar to last dollar program. This fundamental shift would create significant administrative challenges for other aid programs that operate after Pell awards have been determined, such as state promise programs. As institutions implement changes required by the reconciliation legislation, maintaining appropriate eligibility thresholds is essential for optimal financial aid packaging. This complexity underscores why financial aid administrators should be key stakeholders in these discussions, particularly when considering important interactions with external scholarships that arrive after initial packaging or other sequencing challenges.
- Workforce Pell: The Presidents Forum welcomes the implementation of the Workforce Pell program, an initiative we have championed as a top policy priority for years. We believe proper implementation of this program is paramount to its success in serving working learners and addressing critical workforce needs. As this program takes shape, we urge the Department to carefully consider how states and institutions will collaborate across state lines—a factor that will significantly impact program effectiveness. Accountability standards for the Workforce Pell program must balance quality assurance with practicality.We anticipate that reciprocity agreements for credentialing and licensing acceptance will be essential to ensure student mobility and maximize economic outcomes. Drawing from our integral role in developing SARA (State Authorization Reciprocity Agreements), we believe a similar framework is crucial for successful Workforce Pell implementation. We urge the Department to consider this when crafting regulations that streamline processes across state boundaries, reduce student barriers, promote educational and licensure mobility, and ensure short-term programs lead to meaningful employment. Additionally, collaboration with the licensing community during regulation development is vital. The Presidents Forum stands ready to contribute our expertise in developing these cross-state collaboration mechanisms.
We are committed to fostering a higher education environment that is effective, affordable, and focused on student success. The Forum is prepared to collaborate with the Department and other stakeholders to provide insights that will deliver the best outcomes.
Sincerely,
Wesley Smith
Executive Director
Presidents Forum