Measuring What Matters in Workforce Training

Measuring What Matters in Workforce Training

by | Oct 23, 2026 | Innovation, Video

Measuring What Matters in Workforce Training

Employers are investing in workforce training. But the size of those investments tells us only part of the story.

The more important question is what changes for workers.

Alison Griffin shared lessons from her work with FutureRise, a Colorado-based foundation supporting employer-aligned postsecondary programs. Her message: completion and job placement are starting points, not the finish line.

Looking beyond the first job

“Placement in a job is the minimum of what we should be tracking,” Griffin said.

To understand whether training is delivering lasting value, Griffin encourages institutions and employers to look at what happens next. Do workers earn more than they did before training? Does their pay continue to grow? Are they advancing within their organizations?

Credentials also need value beyond a single workplace. Training that counts with only one employer can leave a worker vulnerable if that job disappears. Credentials recognized by other employers, or that build toward a degree, can create more options for long-term advancement.

Building the pipeline together

Employer investment is changing how training programs are designed.

Rather than simply hiring graduates, employers are helping shape programs from the beginning. Griffin sees opportunities to expand earn-and-learn models, apprenticeships, and degree pathways that respond to changing skill needs.

Colleges can play an important role by bringing competing employers to the same table.

That convening role is especially valuable for smaller employers that cannot build a talent pipeline alone. By working together, employers and institutions can develop training that serves an industry rather than just one company.

Lessons from Colorado

Griffin pointed to Colorado’s construction industry as an example.

Through Project SCALE, industry partners are bringing together union and nonunion employers, small and large businesses, and education and nonprofit organizations to address shared workforce needs.

The effort spans fields such as electrical work and HVAC, with opportunities in rural and urban communities. It also serves more than one population: adults seeking to build new skills, young people entering the workforce, and employers preparing for retirements and industry growth.

For higher education leaders, the lesson is to think beyond individual employer partnerships and consider where institutions can help build a shared regional training system.

The bottom line

More investment in training creates an opportunity. Better outcomes show whether that opportunity is reaching workers.

For institutions, that means designing programs with employers, building credentials that travel, and measuring progress beyond completion and the first job.

The goal is not simply a stronger talent pipeline. It is a clearer path to lasting career opportunity.

Watch the full Presidents Forum conversation with Alison Griffin to learn more.

Read Griffin’s reporting in The RISE Report.

Transcript

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Measuring What Matters: How Alamo Colleges District Is Helping Students Make Every Credit Count

Measuring What Matters: How Alamo Colleges District Is Helping Students Make Every Credit Count

by | Oct 21, 2026 | Innovation

When Tania Kaur enrolled at St. Philip’s College in 2022 after graduating high school a year early, she was looking for an affordable way to begin her higher education journey. What she found was a supportive community of faculty and advisors who helped put her on a path to law school.

Now, Kaur is working toward her Juris Doctor at Indiana University Maurer School of Law and plans to graduate in May 2028. Her story shows that student success is not just about earning degrees, but also about transferring schools without losing time or money.

Kaur was the first in her family to go to college, and at first, figuring out degree requirements and the transfer process felt overwhelming. Her academic advisor, Christine Sauceda, and the Alamo Colleges District Transfer Advising Guides (TAGs) helped her plan her classes so her credits would count toward her bachelor’s degree at the University of the Incarnate Word (UIW).

After three semesters at St. Philip’s College, Kaur transferred to UIW with all her credits intact and nearly all her core requirements completed, allowing her to enter as a junior.

“None of that immense progress would have been possible without the great advisors at Alamo Colleges,” Kaur said.

She earned her bachelor’s degree from UIW, double-majoring in sociology and political science, with a focus on international relations and a minor in history.

Redefining Transfer Success

At Alamo Colleges District, student success means more than just transferring to a four-year school. What really matters is making sure the courses students take count toward their degree, so they can avoid extra classes, extra costs, and delays in graduating.

This idea is what drives the TAGs program.

Started in 2016, TAGs give students a clear academic path based on their major and the university they want to transfer to. The guides show which courses will transfer and how those credits will count toward a bachelor’s degree.

Over the past decade, the initiative has expanded from seven university partners to 22, with more than 3,000 Transfer Advising Guides developed to support student success.

Looking Beyond the Numbers

The growing number of transfer guides and university partners shows the program’s progress, but other measures also help tell the story of student success.

At the Alamo Colleges District, the average time to earn an associate degree is 3.4 years, compared to the statewide average of 3.6 years.

For students like Kaur, the impact goes beyond the numbers.

Her time at St. Philip’s College did more than just help her transfer. An introductory sociology class sparked a new interest that shaped her studies and future career goals.

Now in law school, Kaur hopes to pursue a career focused on human rights, family law, and child advocacy.

“You have the chance to gain the same level of education you would at a private institution for a much lower price. Plus, advisors and faculty at Alamo Colleges are truly there to support you and help you reach your goals,” Kaur said.

As the Alamo Colleges District continues to expand its university partnerships and improve the transfer process through new technology, its focus remains on helping students make the most of the time, effort and money they invest in their education.

For students like Kaur, that means turning an affordable start at a community college into a pathway to advanced education and a meaningful career.

Her story offers an important reminder for higher education leaders: measuring what matters means looking beyond transfer rates to ensure students’ credits count toward their degrees and move them closer to their goals.

Learn more about how the Alamo Colleges District is advancing student success through its Transfer Advising Guides.

Bringing Clarity to Student Borrowing

Bringing Clarity to Student Borrowing

by | Oct 16, 2026 | Video, Working Learners

Bringing Clarity to Student Borrowing

Private student loans can help cover a college financing gap, but students and families need clear information about borrowing costs, loan terms, and repayment before choosing a loan. In this Presidents Forum Podcast, Chance Russell, co-founder and chief business officer at Desata, explains how colleges can support informed private student loan decisions as federal borrowing rules change.

Why are colleges paying more attention to private student loans?

Changes to federal student borrowing limits may leave some students and families looking for additional ways to pay for college. For colleges and financial aid offices, helping students navigate private education loans can be challenging: policies and compliance requirements take time, and many teams have limited staff and resources.

Russell said the gap between policy and implementation can affect more than financial aid administration. When students cannot understand or access financing options, the cost of college may become an enrollment barrier.

What should students compare when evaluating private student loans?

Students and families should look beyond an advertised interest rate. A teaser rate may not reflect the rate a particular borrower will receive, so comparing loan offers requires clear information about the terms and the cost of borrowing. As Russell put it, “they should know what they’re getting into before they get started.”

Transparent information can help borrowers make decisions that fit their circumstances. It also helps institutions explain college costs and financing options without overstating what any one loan can offer.

How can colleges guide students without choosing a loan for them?

Colleges have several ways to respond when students need private education loans. They can provide no recommendation, create a preferred lender list, or point students to a third-party comparison resource. Each approach has different tradeoffs, and preferred lender lists require careful attention to compliance and transparency.

Russell cautioned that saying nothing does not necessarily give students neutral guidance: students may instead rely on online search results or loan marketplaces where advertising can influence which offers they see. Institutions evaluating comparison tools can ask how loans are ranked, how the platform is funded, and whether its incentives could affect recommendations.

How are student borrowing, college costs, and career outcomes connected?

Russell said colleges can strengthen decision-making by making education costs clearer and considering how programs prepare students for work. Employers can share feedback about the knowledge and skills they need, while institutions can use that feedback to improve programs and communicate outcomes to prospective students.

Bottom Line

For higher education leaders, the takeaway is practical: clear information about college costs, private student loan terms, and education outcomes can help students and families make more informed decisions.

Transcript

Wesley Smith (00:00.465)
Hey Chance, welcome to the President’s Forum Podcast.

Chance Russell (00:09.794)
Wesley, it’s great to be here.

Wesley Smith (00:11.301)
Hey, a lot of our members know you. They’ve worked with you over the years at in both Congress and at the department. But for those who haven’t worked with you directly, can you start us out today by telling us a little bit about your background and how you got to where you are now?

Chance Russell (00:26.562)
Yeah, absolutely. And again, you know, can’t thank you enough for for having me on here. you guys do great work. so a little bit about myself. my background and in my career is is federal student aid policy. So, you know, I started working on the House Education and Workforce Committee in 2019, served there for about seven years, where I ultimately led the higher ed team, focused on student aid policy, and worked on many of the provisions that were included in the one big beautiful bill act, particularly

Around workforce Pell and student loan repayment simplification. from there, I actually went to the Department of Education and served there for around nine months as deputy chief economist, where I was helping to implement those said reforms on Pell and repayment. you know, and being on both sides of that, you see kind of the gap between policy and implementation pretty fast. Congress writes a policy, the partner writes the rules, and you know.

You have institutions, you know, and financial aid offices where there’s, you know, only a couple of people to help make it work by a given deadline with, you know, no new tools to do so. And that’s why my co-founders and I started DeSada, where we’re building these new tools for free for institutions to help them navigate these changes and and close the gap. So, you know, we’ve got a a new calculator that helps institutions see the impact of some of the student loan limits that have been put in place.

As well as our soon to be released tool clarified, which is a private student loaning ranking engine that institutions can confidently point students to and who have, you know, federal aid that doesn’t cover their their total costs.

Wesley Smith (02:02.968)
I I love the background because there are a lot of a lot of folks out there that haven’t really thought about the difference between, you know, writing legislation and then implementing it and actually having it work. And that’s a pretty significant difference. And you’ve been watching that on both sides. On on the finance side in higher education, you’ve mentioned gaps a couple times. So tell me what you realized when after after, you know.

legislation’s passed and you’re like, okay, now the implementation starts. What are the gaps and what are you working on to you know bridge those gaps?

Chance Russell (02:42.145)
Yeah, you know, I’ll start on just when anytime you have a brand new policy, and you know, this is the first time I think in 15 years where we’ve had real significant legislative change in higher ed financing, it’s gonna be difficult no matter what. You know, the department, they have their own timelines that they have to meet that are set by Congress. And so, you know, everyone’s operating under a constrained system. But what you start to see is that something that seems simple in a couple lines in law.

Wesley Smith (03:02.45)
Mm-hmm.

Chance Russell (03:10.975)
Oftentimes ends up being much more difficult to implement in practice. And we saw, especially on the student loan side, for a long time, institutions have not really had to grapple with recommending private student loans. you know, we used to have you know, essentially you could borrow for grad or for parents up to cost of attendance. And so you haven’t had to have those conversations and

Wesley Smith (03:12.806)
Yeah.

Chance Russell (03:40.972)
What we notice is a lot of institutions are struggling when it comes to that because it’s a big compliance issue. for instance, you have to go through an RFI process, you have to do annual reporting, et cetera. And that’s a lot to do in a couple of months. And especially when these are important enrollment decisions, right? For precedents, why this is important. This isn’t just how much a student gets and when they enroll, it’s if they enroll.

Wesley Smith (03:55.878)
Right.

Wesley Smith (04:05.276)
Right, right. you you’re doing this work and you’re thinking through, you know, what do institutions care about? how how do they have to approach this to make it work? But you know, one of the things from the presence forum perspective that we we always want to prioritize is how do students navigate it? How do families navigate it? And give us your your experience on what these changes mean to students and

families when they’re looking at their your educational, you know, financing options.

Chance Russell (04:38.667)
Yeah, you know, with the changes in the One Big Beautiful Bill Act, I mean, I’ll also kind of start with your latter point of the question. So one in four grad parent borrowers are now, you know, if borrowing was what it was last year, are being pushed to the private market, there would be a funding gap. Of course, you know, you may see institutions that may adjust their pricing or their institutional aid or, you know, kind of play around with their programs, but there’s a large share that’s going into the private student loan market. And for that, for in for

Students, kind of like how I mentioned, institutions have not had to grapple with giving that guidance. So students and families are getting a lot of noise. and whether that’s on the loan limit side or repayment, I mean, all the time I’m seeing on Instagram or TikTok things that aren’t exactly true and are either a marketing or, you know, well, you could put this in the same category as like clickbait, right? And I think students and families get pushed around when they don’t have that.

Clear guidance, whether that’s from the federal government, but more importantly, from institutions. And institutions are who they trust, right? When they have a financing gap for college, who are they going to go to first, right? The place where they’re enrolling. so what we’ve seen is is confusion. And it’s it’s kind of the same reason. You know, we’re we’re building these tools for for institutions. A lot of this is is student facing as well, kind of like clarified that I had mentioned earlier. We’re trying to come in and fill that information gap in an honest way.

Wesley Smith (05:45.765)
Right.

Wesley Smith (06:03.826)
Right. Well, we we’ve had these conversations before chance that and I think we’re both on the same page, that transparency of cost is just a high priority. And we’ve got to figure out not only cost, but you know what the outcomes of of education are as well. And the more we can do to get that in the hands of consumers, the better off the market will be in higher education, the better off our institution, the healthier

Institutions will be if we can get that transparency across the finish line. Now, do you do you feel like we’re moving in the right direction on that? What do you what do you think needs to happen there?

Chance Russell (06:41.163)
Yeah, absolutely. I mean, I’ll I’ll start. I mean, I’m very glad that you all, you know, you brought this question up because it’s something that when I, you know, every boss that I have worked for previously and you know, their counterpart on the other side of the aisle are gonna say transparency is key. You’re not gonna find a lot of disagreement, especially when it comes to price. Right. You know, higher education traditionally has been one of these the only market where you don’t know how much you pay until four years later. Like imagine buying a house.

And in three years, well, actually we raise the price. You know, that’s it it’s it becomes difficult. And whether that’s on college pricing or really on the loan side too, which is something that we’ve been seeing since we started De Sada, is that, you know, there’s a lot of gimmicks that can happen out there. And at the end of the day, it’s deterring, you know, it’s either deterring enrollment or it’s leading students to maybe not make the decision that’s best for them. I I’ll give you an example. When it comes to private student loans,

You’re gonna see all the time rates as low as 2.5%. Well, that’s below the federal borrowing cost right now. So if a lender was, you know, lending at 2.5% to everybody, they would be out of business in about a month. but that’s what you see. You see these flashy teaser rates, and it’s luring, you know, you know, it’s it’s distorting the decision making process for students and family when it comes to borrowing. And I think you can say the same way when it comes to college pricing, but

Yeah, on the loan side in particular, like kind of the need is right now with these new caps, like we need honesty, we need transparency. And what are what are you gonna pay? Right? A loan is not like this is one of the bigger financial decisions that students and families are gonna make in their life. And you know, call me crazy, but I think they should know what they’re getting into before they get started.

Wesley Smith (08:29.33)
Absolutely. I completely agree. You mentioned something that is, I think, true for most consumers, most students. And that is they trust the institutions more than they trust, you know, the the marketing that’s hitting them. And so they’re gonna look to, you know, the the institutions, the colleges, universities that they’re that they’re looking to enroll in to for help in navigating, you know, student finance decisions. What do you think the role is of the college and university in that?

In that process.

Chance Russell (09:00.577)
Yeah, you know, I would say when it comes to recommending private student loans in particular, you know, schools kind of have like three options. First, it’s say nothing, be neutral, say student, go out and find your find your loan. And I I say neutral and I want to put quotes around that because it’s not neutral. And I’ll come back to that in a second. Your second option is you can do what’s called a preferred lender list, where you request information from lenders about, you know, their products, and then you decide, you know, which lenders you want.

To to recommend. Now that comes with a lot of compliance issues. it’s a lot of work. and it’s it’s risky because essentially in 2007, you had institutions that unfortunately were taking, I guess, kickbacks, as you would say. You get to go on a cruise, you get to go to Vegas, et cetera, if you put our loans first. Lots of investigations went into that and Congress cracked down on it. Now, that part of the law has not changed with OB3.

Well, more people need private loans. Those same constraints on institutions are there. I think, you know, that is absolutely better than going with option one and saying no, but it’s something that you need to, you know, assess as an institution yourself. The risk, the benefits, etc. The third is to be able to point to like a neutral third party. And I want to be very, you know, I won’t use quotations on neutral like I did for option one because it’s very important that it is neutral. What you’re seeing today.

Is these affiliate loan marketplaces or these other platforms? There’s two things happening. One, it’s pay for play, the highest lender, the lender that pays the most has the biggest ad budget. They’re gonna show up. And B, they’re taking a cut of the volume of the loan. So if you got like a ten thousand dollar loan, maybe the affiliate marketer, that third party, takes five percent a cut of that. What is that doing? It’s incentivizing higher borrowing. So

This brings me back to that first option. When you say nothing, it may be, you know, that you are reducing your compliance risk, but it’s not neutral by any means. Students are going to Google, they’re going to these spots where biggest ad spend wins, and it’s not based on borrower fit. so what I would say is weigh your options when it comes to recommending private student loans, but also look at, you know, actual neutral tools and you know, full disclosure, that’s why we built.

Chance Russell (11:22.071)
clarified, it’s what we’re trying to do here, whether it’s, you know, having a published methodology of how we rank loans or, you know, how we’re funded, look for those tools, but just don’t don’t leave with saying nothing. And if you are going to recommend loans, ask the right questions. Students don’t need another teaser rate. They need to know what they’re getting into.

Wesley Smith (11:41.285)
Right, right. Okay, Chance, I’m gonna give you the the last word on this, but I want you to think big and think out, you know, a decade or two even. where do you see federal borrowing? the federal borrowing rules and and and private lending market going in the next couple decades? Like w how does this evolve? What what do you see happening in the future?

Chance Russell (12:09.163)
Yeah, and I the this is the type of stuff I like to think about. But let me start with like a couple year horizon here. I think there’s going to be the need for some regulatory, well, some legislative clarity around who gets higher borrowing limits. So if you recall, if you’re a grad student, some students get around 20,000 bucks, some get 50,000. And that’s all around this professional definition. There’s tons of lawsuits that are happening with it. It’s just unfortunate the department’s kind of been put in a place where they define what

Wesley Smith (12:32.23)
Right.

Chance Russell (12:38.849)
professional is, but Congress kind of put a constraint on that. so I could imagine, you know, some legislative clarity there. Now, does Grad Plus come back? I think the answer is no. I think if you talk to folks on both sides of the aisle, they are going to say that some institutions, you know, may have abused that privilege for, you know, quote, as many in Congress put it as uncapped lending. So what does that mean for the long term?

I think right now institutions are seeing kind of this, for lack of a better word, I don’t want to call this perfect, but perfect storm of an enrollment decline. You have loss of faith in higher education itself, and you have massive changes on the funding side. I think it’s gonna force institutions, I think for the better to think differently and to innovate, right? And to change how they’re, you know, whether it’s increasing transparency or rethinking college pricing altogether,

I think that that’s the direction we’re moving in. And I’m an eternal optist optimist. There may be bumps along the way, but I think we’re gonna end up in a place where financing is gonna be based on outcomes. Enrollment’s gonna be based on transparency about those outcomes and transparency on the price. And the winners are gonna be the ones that get in early.

Wesley Smith (13:57.789)
Right. Right. I like that. I like that vision of you know, outcomes-based orientation as we move forward. I also really like the analysis around the disruption because I just think we’re in such a a a new era of higher education, not only in the finance side, but just the AI side, the innovation side, that there’s so much changing right now. I can’t imagine.

That that’s not going to have a significant impact on how institutions handle the the you know the cost side, how how the lending takes place, the whole student finance experience I think has to be different, has to change in the future. I’m I’m really confident that outcomes will prevail at at the end of the day. But one of the things that that is really hard to measure right now is the outcome.

do you think that do you think that in as we move forward on this, that employer engagement will will be determinative on how we measure outcomes and also how we finance higher education moving forward? What’s the role of an employer moving forward?

Chance Russell (15:16.457)
Absolutely. I mean, if I’m sitting here as an employee, I am an employer now, I guess, as we started this company. Like, I want to make sure that the students that I’m getting are well prepared. And right now, if you talk to employers, whether that’s in tech and in AI, I mean, recently you just saw Meta, right? They’re gonna be rolling out their own their own like I guess, credentials in a sense to help folks because it, you know, the what they’re getting right now is not

what they expected. And I think for too long employers had sat on the sideline, but now they can’t. so where I see kind of the financing side when it comes well and just the influence from employers going is you’re going to see a lot more, I think, demands on what is it that students are learning, transparency about that, and the ability to prove that it works. And that means you, you know, your members are producing graduates that go into the workplace and those they’re they’re staying there. Employers are happy about it because that’s that’s really not the case at the moment.

on the financing side, you know, you’re seeing different kind of companies pop up that are are trying to look at this, or if you look at like these loan repayment assistance programs that employers are starting to kind of build up, they care about it, right? It’s a recruitment tool, but they’re only gonna recruit those that have the knowledge and the skills to succeed in their workplace. So it’s it’s I’m glad to see more employer engagement. I think everyone in Congress on both sides of the aisle would agree with that.

Wesley Smith (16:31.292)
Yeah.

Chance Russell (16:39.521)
But at the end of the day, there is still, you know, the role for the institution to give employers what they need. And employers should be providing that feedback to institutions as well to help them shape.

Wesley Smith (16:49.008)
Yeah. A lot of work to do here. Chance, we really appreciate you joining. We appreciate your expertise and being being free with it. Thanks for coming on and sharing.

Chance Russell (16:59.028)
Absolutely, Wesley. Happy to do it.

Measuring What Matters

Measuring What Matters

by | Oct 2, 2026 | Outcomes and Accountability, Video

Measuring What Matters

Higher education has no shortage of data. The more important question is whether institutions are measuring what truly reflects student success.

This October, the Presidents Forum is exploring how colleges and universities can look beyond traditional metrics to better understand whether learners are persisting, completing, advancing in their careers, and seeing meaningful value from their education.

Moving Beyond Traditional Metrics

Enrollment and completion remain important, but they do not tell the whole story. Institutions also need to understand how well their programs serve working adults, military-connected learners, first-generation students, and others whose pathways may not follow a traditional timeline.

Measuring what matters means connecting institutional data to the outcomes students experience. It means asking whether programs create clear pathways, whether support systems help learners overcome barriers, and whether education leads to real opportunity.

Policy Updates

The Forum continues to monitor federal developments that could shape this work. The National Defense Authorization Act remains under consideration, including provisions related to Military Tuition Assistance.

The public comment period for the Department of Education’s proposed Accreditation, Innovation, and Modernization regulations has also closed. The Forum is now watching for the final rule and preparing to help members understand what it may mean for accreditation, transparency, and institutional practice.

Turning Listening Into Action

The Forum has completed its Innovation Blueprint listening sessions with institutional members and collaboration partners. Those conversations have helped clarify the priorities, challenges, and opportunities that should guide the next phase of the work.

Members and partners will build on that foundation when the Forum gathers in Dallas in November. The focus will be on turning shared insights into practical action—and ensuring innovation is measured by the outcomes it creates for learners.

The Bottom Line

Better measurement is not about collecting more data. It is about focusing on the information that helps institutions make better decisions, demonstrate impact, and deliver stronger outcomes for students.

Transcript

Hi, everyone. Here’s a quick look at what’s happening at the Forum in October.

On the policy front, the National Defense Authorization Act is still under consideration, including provisions related to Military Tuition Assistance. We’ll continue monitoring its progress and keep you updated.

The comment period for the Department of Education’s proposed AIM regulations has closed, and we’re now waiting to see what is included in the final rule.

Our communications theme for October is “Measuring What Matters.” We’ll explore how institutions can look beyond traditional metrics to better understand student success and demonstrate their impact.

Finally, thank you to everyone who participated in our Innovation Blueprint listening sessions. We’ve now completed the partner sessions, giving us clear priorities to build on. And we look forward to turning those conversations into action when we gather in Dallas in November.

Comments on AIM

by | Sep 22, 2026 | Press Release

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.