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