Dear Under Secretary Kent,
The Presidents Forum is a national network of 15 college and university presidents committed to expanding access, affordability, and accountability in higher education. Our member institutions collectively serve more than one million students, many of whom are working adults, parents, veterans, and first-generation learners. Our institutions are leaders in distance learning and workforce-aligned credentialing.
Our guiding principle is simple: accreditation policy should protect quality and students while creating space for institutions to expand access, recognize learning, innovate responsibly, and deliver meaningful educational and economic outcomes.
Transfer Credit Modernization
The Presidents Forum supports efforts to reduce unnecessary transfer barriers, enhance credit portability, and improve transparency. For working adults, military-connected learners, caregivers, and students with experience across apprenticeships, industry certifications, and workforce learning, recognition of stackable prior learning can reduce both time to completion and cost.
The proposed regulations appropriately require clearer transfer-credit policies, including criteria for prior learning from military service, employment, demonstrated competency, and non-degree or non-credit programs. We also support moving away from decisions based primarily on the identity of the sending institution or accreditor and toward academic comparability and applicability. At the same time, institutions should retain academic judgment and discretion in determining whether transfer credit is equivalent, current, and applicable to a particular program of study.
For many adult and working learners, a prompt transfer-credit evaluation is essential to understanding program requirements, cost, and time to completion before enrollment. Procedural requirements should therefore promote transparency and due process without creating delays that prevent students from moving efficiently into their programs.
We encourage the Department to permit standardized denial reasons tied to published policies and allow institutions to use existing academic petition or appeal processes. The Department should also clarify that reasonable, consistently applied residency requirements or transfer-credit limits remain permissible.
Access-Oriented Outcome Measures
The Presidents Forum supports accountability metrics that focus on meaningful student outcomes. The proposed regulations appropriately consider completion, employment, continued education, and economic returns. However, how those measures are applied is especially important for open-access institutions.
Completion or earnings measures can reflect differences in the students institutions enroll as much as the value institutions provide. Open-access institutions often serve working adults, first-generation students, military-connected learners, caregivers, and students returning after stopping out. Accountability frameworks should not create incentives for institutions to improve outcomes by becoming more selective.
The proposed regulations recognize that student achievement should be considered in relation to institutional mission and may differ across institutions and programs. We encourage the Department to build on this principle by considering measures of value added and economic lift, including earnings growth, career advancement, and continued education.
Outcomes-Based Accreditation
The Presidents Forum supports shifting accreditation toward student achievement, educational value, and continuous improvement. Forum institutions demonstrate that high-quality education can be delivered through distance education, competency-based models, accelerated, employer-based, and other emerging approaches designed around working and adult learners. The proposed regulations appropriately recognize the principle of modality neutrality by focusing accreditation on quality of learning and student outcomes while allowing flexibility in how, where, and over what timeframe learning occurs, without requiring separate standards solely because of modality.
Accreditation should prioritize evidence of learning, completion, student mobility, employment, economic value, and consumer protection while allowing flexibility in instructional structure, staffing, calendars, and program design. These outcomes should be evaluated in the context of the credential, occupation, program purpose, and institutional mission, particularly for essential fields where earnings alone may not capture the full value of the education.
The proposed regulation also encourages agencies to reduce barriers to innovative educational models and avoid duplicative reporting, excessive documentation, and unwarranted prescriptive processes. We support that direction and encourage a final framework that strengthens quality and accountability without creating new barriers to access, mobility, or innovation.