How AI Turned Public Comments Into Policy Insight

How AI Turned Public Comments Into Policy Insight

by | Dec 17, 2025 | Policy, Video

How AI Turned Public Comments Into Policy Insight

Why it matters:

Public comment processes shape federal policy, but volume has made them hard to use. AI is changing that.

What happened:

Analyst Phil Hill used AI tools to analyze all 1,124 public comments submitted to the Department of Education ahead of negotiated rulemaking. Work that once took months now takes hours.

What he found:

  • Workforce Pell is harder than headlines suggest. The real risk is not runaway programs. It is guardrails so tight they may limit scale and impact.
  • Implementation is the battleground. Non-term programs, earnings measures, placement rates, and stackable credentials introduce complexity the aid system has not handled before.
  • Public comments contain real expertise. Financial aid leaders and practitioners surfaced practical insights that often get lost.

The bigger takeaway:

AI does not replace public input. It makes it usable. Thousands of fragmented comments become actionable intelligence for policymakers and negotiators.

What’s next:

Hill plans to reuse this AI-driven approach to evaluate upcoming rulemaking outcomes and to assess whether final regulations respond to what the public actually said.

Bottom line:

AI can transform public comments from a box-checking exercise into a learning engine for smarter, student-centered policy.

Comments on IPEDS ACTS

by | Dec 16, 2025 | Press Release

Docket ID ED-2025-SCC-0382

Dear Acting Chief Data Officer Fu,

The Presidents Forum appreciates the opportunity to comment on the Department’s request regarding the Integrated Postsecondary Education Data System (IPEDS) information collection, including the Admissions and Completion Transparency Survey (ACTS). Our member institutions collectively serve more than one-million learners, many of whom are working adults, transfer students, military-affiliated learners, and others who have historically been underserved by traditional enrollment and admissions models.

We share the Department’s commitment to transparency and responsible data modernization. To be effective, however, this collection must align with the operational realities of institutions that serve diverse student populations. Our comments below respond to each of the Department’s five directed questions.

1. Is this collection necessary to the proper functions of the Department?

We agree that clear and comparable admissions and aid information can support the Department’s oversight responsibilities. At the same time, the necessity of the proposed expansion depends on whether ACTS meaningfully distinguishes between selective and open-access institutions.

The current exemption language requiring institutions to admit 100 percent of all applicants does not reflect how open-access admissions operate in practice. Institutions routinely deny applicants for reasons unrelated to selectivity, including federal student-aid eligibility requirements, administrative prerequisites, suspicious enrollment activity, residency constraints, or program-specific criteria. These considerations do not involve evaluating academic achievement factors such as cumulative grades or standardized assessments.

The Department’s 2025–2026 IPEDS screening question takes a more flexible approach by identifying institutions as open admission when they admit virtually all students who have completed a high school diploma or equivalent. Drawing on this framework could help ACTS better reflect how open-access admissions policies operate.

We encourage the Department to consider alternative approaches that better distinguish highly accessible institutions from those employing selective admissions. Options may include definitions that focus on admitting students who meet basic objective eligibility criteria or definitions that rely on admissions thresholds, such as 90 or 95 percent, to reflect high-access institutional missions. Exploring these alternatives would allow ACTS to focus on institutions that use selective admissions practices while avoiding unintended burden for institutions designed to provide broad access.

2. Will this information be processed and used in a timely manner?

Timely processing is unlikely unless implementation is prospective. Many institutions with rolling, year-round, or multi-entry enrollment models do not align with the fall-based admissions structure assumed in ACTS. When the reporting framework does not match institutional operations, timeliness and accuracy are compromised.

Requiring retroactive reporting will further impair timeliness. Institutions cannot recreate historical data in formats that were never collected. Any reconstruction would result in incomplete and unreliable information.

Applying the collection prospectively beginning no earlier than the 2026–2027 cycle would significantly improve timeliness and data quality.

3. Is the estimate of burden accurate?

The estimate of burden does not capture the additional workload required for institutions that serve high numbers of adult, transfer, online, and military-connected learners.

The primary factors increasing burden are:

  • The exemption structure, which as currently written captures institutions that are not selective.
  • Misalignment between ACTS assumptions and year-round or multi-entry enrollment pathways.
  • The need to reconfigure student-information and financial-aid systems on an accelerated timeline.
4. How might the Department enhance the quality, utility, and clarity of the information to be collected?

The clarity and usefulness of ACTS would be strengthened by two adjustments.

Clarify how non-need-based aid should be interpreted

Institutions offer many forms of aid that are not tied to financial need, including merit programs, first-generation scholarships, teacher education or nursing program awards, and substantial aid packages for veterans and service members. Without clear guidance, institutions risk misclassifying these forms of support, which would reduce the consistency and comparability of ACTS data. Clear definitions and examples from the Department would help ensure that institutions categorize these awards accurately.

Align ACTS with modern enrollment patterns

Rolling admissions, high transfer volume, and military and working-adult populations are common across many institutions. A collection that assumes a traditional first-year fall cohort will not produce accurate or comparable data for these students. Clarifying these structural considerations would improve both the quality and utility of the information collected.

5. How might the Department minimize the burden of this collection, including through information technology?

Burden can be reduced in several targeted ways.

Limit reporting to prospective data only

Historical data cannot be reconstructed in a way that meets ACTS standards. Prospective reporting is more accurate, feasible, and consistent with the goals of the collection.

Revisit the exemption criteria

Considering alternative approaches to defining open-access institutions such as focusing on applicants who meet the basis for admission or using thresholds that reflect high-access missions would better align exemptions with institutional practice and reduce unnecessary reporting burden.

Extend the implementation timeline

A timeline beginning no earlier than the 2026–2027 cycle would allow institutions to adapt information systems, update data definitions, coordinate with external vendors, and ensure accurate reporting.

Support technology-enabled reporting

Machine-readable specifications, clear definitions, and alignment with existing systems will promote both accuracy and efficiency.

Conclusion

To ensure that ACTS advances the Department’s goals without unintentionally burdening institutions committed to access, we respectfully recommend that the Department:

  • Clarify key definitions including non-need-based aid
  • Explore alternative approaches to defining exemptions for access oriented institutions
  • Eliminate retroactive reporting
  • Align ACTS with year-round and multi-entry enrollment structures
  • Extend the implementation timeline
  • Provide clear, consistent guidance to support automated reporting

We welcome further dialogue to ensure that federal data systems advance the success of today’s learners.

Sincerely,

Wesley Smith

Executive Director

 

How WGU’s LERs Power Smarter Pathways for Every Learner

How WGU’s LERs Power Smarter Pathways for Every Learner

by | Dec 12, 2025 | Outcomes and Accountability

By Scott Pulispher, Western Governors University

At WGU, we believe that education must be designed to benefit individuals first and foremost by connecting them with opportunity. After all, when individuals thrive, workforce strength, economic vitality and innovation follow. That same belief guides our work on our Learning and Employment Record (LER), which we launched in 2025—while LERs create value in many ways, their primary purpose is a tool for empowering individuals.

LERs are secure, skills-rich digital credentials that make an individual’s skills both visible and verifiable, whether they were acquired through formal education, work experience, military service, volunteerism, or other life experiences. By recognizing skills development and learning wherever it happens and presenting it in a standardized, interoperable format, LERs enable a fuller and more accurate representation of a person’s capabilities.

In December 2025, I had the opportunity to testify before the U.S. House Subcommittee on Higher Education and the Workforce about the potential of LERs and the promising results we’re already seeing.

Now available to nearly 60,000 students, alumni, and employees, WGU’s LER platform is designed to be student-centric, skills-rich, and provide pathfinding and career exploration from day one.

  • Student-centric: WGU’s LER platform was built as a student-first solution, designed to give learners the agency to verify their skills, identify gaps, and share their verified education and career achievements in a secure, portable record.
  • Skills-rich: Our LER platform is not merely a collection of digital credentials; it is skills articulated. WGU was uniquely positioned to build skills-rich LERs given our approach to program design that: 1) defines workforce skills and groups them into competencies; 2) creates assessments to verify mastery of competencies; and 3) builds courses to prepare students for those assessments. This approach stands in contrast to what is often practiced at other institutions, where degrees are organized around courses and general statements of purpose rather than a clear articulation of the cumulative knowledge, skills, and abilities expected of graduates.
  • Pathfinding and Career Exploration: More than just a tool to connect with employers, WGU’s LER platform is designed to be used as soon as students begin their educational journey, helping them to understand their current skill profile, discover career pathways, and follow a personalized roadmap toward their desired profession. In this way, LERs unlock powerful pathfinding tools, allowing students to explore without drifting aimlessly and racking up student debt in the process.

Early Results

Early feedback underscores the potential of this model to drive clarity, confidence, and career mobility:

  • 87% of users found value in having all their education and career information in one place.
  • 78% said seeing their skill gaps helped clarify how they qualify for certain jobs.
  • 76% believe LERs will help them advance in their careers.

Few things are more profoundly human than enabling individuals to pursue a self-determined life. WGU’s LER—while seemingly abstract—exists for that purpose: it translates what our students know and can do into real opportunity.

Making Education Work for Working Learners

Making Education Work for Working Learners

by | Dec 10, 2025 | Policy

Q&A with Gregory W. Fowler, PhD, President, University of Maryland Global Campus (UMGC)

The question of higher education’s value is front and center for today’s learners and
employers. How is UMGC improving outcomes for adults in the workforce and military?

Today, learners and employers are increasingly likely to demand evidence of education’s return
on investment. At UMGC, we respond by designing learning experiences that meet students
where they are and align with the realities of the workplace. Listening to our learners is at the
core of that approach.

In a recent survey of UMGC’s winter 2025 graduate candidates, 35 percent reported that, as a
result of education, they had secured a new job, promotion, or raise, or made a career change,
some before ever crossing the stage. That speaks volumes about the power of learning
experiences that are flexible, career-relevant, skills-focused, and supported by services tailored
to working adults.

Similarly, in a recent alumni survey, 97 percent said their UMGC education prepared them well
for the workforce. Fully 40 percent reported salary increases, 40 percent advanced in their
current roles, and 32 percent changed jobs as direct outcomes of their education. These results
are a testament to the work we do every day.

How are partnerships helping amplify your impact?

Strategic partnerships continue to remove obstacles and accelerate learner progress. This year,
we worked with military leaders, police departments, and corporate partners to expand access
and turn real-world experience and training into academic credit. More than 83 percent of this
year’s graduates worked full-time while studying, and partnerships helped make that possible;
in fact, in FY 25, almost 6,000 learners had their education paid for in whole or in part by an
employer … saving them more than $23 million.

That impact is reflected in our graduating class, as well, which includes 2,218 learners who
enrolled through corporate partnerships. Another 1,802 are community college transfers, many
of whom enrolled through our alliances with more than 65 community colleges nationwide,
offering seamless credit transfers, no application fees, and access to dedicated advisors.

UMGC has always focused on meeting the needs of nontraditional and underserved
populations. What trends are you seeing?

This year, 17,855 learners earned a UMGC degree or certificate—the largest graduating class in
our history. More than 44 percent identified as underrepresented populations, a 24 percent
increase over last year. That is transformation in action. And thanks in part to expanded
transfer and work experience credits, time-to-degree dropped below 36 months for the first
time ever.

UMGC has a longstanding relationship with military learners. What changes have you seen
this year?

Serving military learners has been part of our DNA since 1947, and more than half of our
learners are military affiliated. This year, that demographic represented 42 percent of our
graduating class; veterans alone increased by 35 percent. By awarding credit for military rank,
we help these learners—who often face deployments and relocations—achieve their goals
faster, wherever they are in the world.

And we continue to expand career-relevant credential options. For example, our new Drones &
Autonomous Systems certificate program prepares learners to use these technologies in sectors
including public safety and defense. Other new technology-focused offerings include artificial
intelligence and supply chain logistics.

Cybersecurity also remains a popular option among military learners … and it’s not purely
academic. The UMGC cybersecurity team includes students, alumni, and faculty, and recently
earned first place honors in a regional competition that included hands-on coding,
cryptography, and network analysis challenges. Currently, the team ranks first in the United
States and sixth in the world among universities in the ongoing Hack the Box competition.

Where are you focused as we enter 2026?

Looking to 2026, our priorities are clear. Technology is evolving at lightning speed and shaping
our world in ever-changing ways. We believe that we must harness new and emerging
technologies to help us do more of what matters most, amplifying human connection and
learning. That means freeing faculty to mentor and inspire, empowering staff to innovate, and
ensuring every learner receives personalized support.

At UMGC, transformation isn’t a buzzword. It is a sustained commitment to reimagining what a
university can be and delivering on the promise of education for every student we serve.

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Dual Enrollment That Delivers

Dual Enrollment That Delivers

by | Dec 8, 2025 | Innovation

Dual Enrollment That Delivers

Weber State shows what early-college innovation can deliver. Their dual enrollment and concurrent enrollment programs give high school students access to real college courses for just $5/credit—and a faster, more affordable path to opportunity.

Why it matters:

Early access to high-quality college coursework is one of the most effective levers for increasing affordability, accelerating completion, and expanding workforce pathways.

What’s happening:

  • 16,000+ high school students earned Weber State credits last year.
  • Courses are true college classes—not high school courses with optional credit.
  • Students can complete general ed, career pathways, or even industry-recognized certificates before graduating high school.
  • Weber State places advisors directly in high schools to guide students into coherent, stackable pathways.

The impact:

  • Families save thousands each semester.
  • Students build confidence, explore majors early, and avoid excess credits.
  • Utah employers gain a stronger pipeline of talent—some graduates enter the workforce with credentials in fields like advanced manufacturing, automotive tech, and cybersecurity.
  • Students who continue to college arrive with momentum, clearer goals, and less debt.

Bottom line: 

When colleges meet students where they are, remove cost barriers, and align coursework with real pathways, learners accelerate—and communities benefit.