Wes (07:33.942) Amy, welcome to the show and let’s get right to it. The Department of Education just reversed course. Graduate Plus loans will now count toward the new lifetime borrowing limit under the one big, beautiful bill. What does that actually mean for students that are trying to finance their graduate education? Maybe we should start with, give our listeners background on what happened and then let’s answer that question.

Amy Glynn (07:56.885) Yeah, so when we’re talking about those new lifetime borrowing caps, the department had previously told schools that graduate plus loans would not count towards the $257,500 lifetime cap established under OB-3. In a webinar last week, this guidance was shifted and schools have been told that once a student is no longer eligible for the legacy provisions, previous borrowed grad plus loans will count against that lifetime cap.

And this is a really significant change for institutions that are serving those non-traditional students who are trying to fund their education. They are at severe risk of losing access to all Title IV aid for graduate programs because we know those funding sources are limited to the student loan portfolio.

Wes (08:43.118) Interesting. Okay, so give us the students who are most affected by this.

Amy Glynn (08:47.796) Yeah, students at greatest risk of having to stop out because of this change are going to be those in some of our more costly programs. If you think about things that are in the medical field, dental, our counseling programs, doctoral students, all doctoral students, but especially ones who are enrolled part time. Obviously, it’s our students who previously borrowed Graphic Plus looking to return to school.

And those are individuals who are going to face potential challenges by hitting that lifetime cap. Because the cap never resets. Even if a student has repaid or paid down their student debt, the cap is established and once you hit it, you lose access to those funding programs.

Wes (09:32.342) Interesting, interesting. Okay, so we know that students have to be aware of this now. And that also, I mean, you speak from an administration perspective. You’ve been there on the ground working in financial aid. Tell us what institutions need to know about the change.

Amy Glynn (09:36.448) Thank

Amy Glynn (09:49.044) Yeah, it’s one thing to understand the change. They probably need to shift their advising and their packaging, their financial aid offers that have been established, especially for students that are in these affected populations who are taking courses this summer, but especially students who are starting in the fall in a more traditional sense.

And so they need to understand the provisions. They need to establish a communication protocol to advise or re-advise students. And they need to be prepared to be incredibly nimble because this guidance could change again. You we thought we had a pretty clear understanding based on good faith negotiations that these loans were not going to count against a student’s cap. And this reversal

has significantly changed things and created a level of uncertainty in the knowledge that we did have around negotiations that are on an incredibly aggressive and tight timeframe already.

Wes (10:54.242) So speaking of the timeframe, let’s conclude with some details on the timeframe. What does it look like moving forward?

Amy Glynn (11:01.374) Yeah, so final regulations are supposed to be published a minimum of 30 days before the effective date. Effective date is July 1 of 26. So the time frame is pretty fast and pretty furious and is coming at us real quick.

Wes (11:18.624) Amy, thanks for your time. It was very clear and very useful.

Amy Glynn (11:22.443) Thanks Wes.

Wesley Smith (02:24.214) Today I’m joined by President’s Forum Policy Director, Cam Mortenson, and Policy Fellow, Amy Glenn. We’re here to break down what presidents need to know about the ahead rulemaking. Cam and Amy, thanks for joining.

Cameron Mortensen (02:44.092) Thanks Wes, happy to be here.

Amy Glynn (02:46.029) Thanks so much for having me.

Wesley Smith (02:48.206) Hey, so let’s start with the first question right out of the box. What should presidents prioritize to build workforce Pell programs that work at scale, especially across states and for mobile and working learners? Amy, what do you think?

Amy Glynn (03:03.553) Yeah, so when I think about Workforce Pell, I don’t think about it as a new program. I think about it as a shift in how we operate and expand what we’re already doing really well. Like you said, the students that’s designed for our students who are reskilling, working adults, military connected, parenting students, right? They’re mobile, they’re balancing a lot, and they’re really outcome focused. So the questions for presidents, I really think are three key ones. Can your programs…

Can your program development model support the speed and agility that you need? Can your governance process accommodate iteration at the speed and need for the program relevance? And do you have the infrastructure to track and meet the completion and placement metrics? So this means really having flexibility in how our programs are built and revised, along with strong employer partnerships. Some of those highest quality programs rely deeply on that industry partnership and insight.

And we don’t want our policy to unintentionally limit that. It also means, like you said, consistency and engagement across states because students aren’t confined to one place. Universities that are used to leveraging NC-SARA to minimize state authorization burden are really going to need to ensure that they have a framework in place if developing those programs through distance education to meet those state unique needs.

and understand that their programs may not be authorized in all states because labor market and workforce demands are different. So like the most important thing is it’s about design with the learner in mind, stackable programs, clear pathways and strong support, which is exactly what our institutions are really great at already.

Wesley Smith (04:47.05) Right, right. like your emphasis though. I mean, this will be a little bit of something to navigate when it comes to scaled institutions that are operating in 50 states.

Amy Glynn (05:00.105) Absolutely.

Wesley Smith (05:01.56) Cam, what are your thoughts on presidents? What should they be prioritizing as they build towards Workforce Pell eligible programs?

Cameron Mortensen (05:10.32) Yeah, to play to continue on the cross state functionality piece is as as the laws written programs eligible for work for spell are going to be have to be approved by the state’s governor.

So it’s going to be really important for states and institutions to create a system where programs, especially those delivered online by institutions across the country, can be reviewed and approved so that students learning across the country are able to access these funds for programs that are relevant in more than just one state. So we’re going to need to all work together, states, governors, states, and institutions, in order to find the way to most efficient.

efficiently do that.

Wesley Smith (05:54.402) Yeah, right. mean, that’s going to be, hopefully, we can piggyback on, Sarah, or some other system that gets us essentially consensus from the states on what programs should meet these requirements and what programs don’t. I guess the tension there is

It’s really designed for local workforce as well. I don’t know if there is an easy resolution to this other than saying collaboration is really, really important as we move forward. Any thoughts on that, Amy?

Amy Glynn (06:31.062) that’s a big one to tackle. I agree with you absolutely, collaboration is key. We are already seeing states roll out proposed legislation and language that would have different accountability measures than the federal government would have different requirements. And so really trying to figure out how to find a solution that is elegant.

and well positioned to protect both students and institutions will be really important in seeing success in workforce Pell implementation.

Wesley Smith (07:10.518) Yeah, lots of work left to figure these things out, especially on 50 state operations. Let’s talk about a little bit, though. You mentioned states are working on some accountability, and the accountability framework is tough to say exactly what it should be. But tell us, we’re at the president’s forum, so we care about student-centric accountability frameworks. What does that look like? How can we do that without blocking innovation?

Amy Glynn (07:39.629) Yeah, I think the key here for the accountability conversation is about balance. We have to get the balance right. We absolutely want to protect students and ensure quality, but we also have to make sure we’re not building something so complex that institutions pull back from serving those students. And so one thing that’s really important is recognizing

how working learners actually move through education and getting our voice into the conversation about establishing these metrics. So with these programs, the goal is actually to increase access to stackability of the credentials so that students can re-enroll quickly.

their earnings won’t always show up in a straight line. So schools should not be penalized for having a student move more quickly into a subsequently related program. So if we don’t design these metrics carefully, looking at who’s included, when we measure, we risk missing the real value of the programs, especially for the non-traditional working adult. And so when you think about this,

Fairness really matters, right? Institutions serving students online or across states should not be at a disadvantage to traditional brick and mortar institutions. And right now there really is a risk of that. So at its best, accountability should create clarity and trust, but still leave room for institutions to respond to those workforce needs. And we need to work with our federal partners and the state partners in that triad to make sure that happens.

Wesley Smith (09:12.216) Well, I mean, to your point, the whole reason Workforce Pell was considered a necessity by legislators, by Congress, Congress thought, hey, we have some pathways to opportunity that aren’t necessarily four-year or bachelor’s or associate degrees. Whatever those look like right now, they’re not that. They’re short-term credentials that could work. And the idea here is to make these accessible to as many people as we can.

The risk that we run is with accountability frameworks that are too robust, do you actually discourage people from moving in that direction and programs from qualifying for those? But at the same time, you want to make sure that if you are putting federal dollars and investing those behind them, you get it right and you do have workforce opportunities that result in it. So Cam, tell us what your thoughts are on accountability. How do you strike that right balance?

Cameron Mortensen (10:11.43) Yeah, I think Amy’s point on on credential stacking is really important because if we set up an accountability system that is tracking the is always tracking the income of students right as they come out of programs, we’re going to de incentivize.

institutions that are encouraging students to continue their education after these workforce training programs. And I don’t think that’s necessarily the motive that we want to give. as Amy said, we really want to be student focused. We want to focus on we all I also think it’s really important that we have an accountability system that does focus on outputs rather than delivery method or other sorts of inputs. But there’s just really important nuances such as

the credential stacking.

that we need to make sure we get right. I think one other point is we don’t want to have a constantly, we don’t want to constantly be moving the goalposts. Let’s get, let’s set up a system and let’s stick to it and let’s take the time to make sure we get it right. Actually, I don’t want to say stick to it. I, I’m going to reset that part. let’s, let’s take our time to set up a system that we can all feel good about and is, is bringing true accountability, which, which we support, but let’s get it right. And let’s not try to

rush into something that will lead us to having to change it soon after.

Wesley Smith (11:37.548) Right. You did say something, Kam, that every time I hear it, I want to say amen while people are mid-sentence to it. And that is we should be working with outcomes, not inputs, when it comes to accountability. We shouldn’t be telling institutions how to get the right outcomes. We should be judging them based on their outcomes. And that’s just one of the fundamental principles that the President’s Forum has been.

advocating for decades now at this point.

Let’s let me let me move us to the final question and that is I want to look beyond workforce Pell and I want to look at other aspects of the ahead rulemaking What should institutions watch for? In any other regard Let’s not let’s put workforce Pell aside and look at other issues that that ahead addressed

Wesley Smith (12:39.382) Amy, why don’t you lead on this?

Amy Glynn (12:41.182) Yeah, so as we look what’s coming through the AHEAD and the AEM negotiations, I think the president should really be focused on how accountability is taking shape in practice. We know the direction. There’s going to be a stronger emphasis on earnings and outcomes, return on investment. We’ve seen it in AHEAD, obviously, in the accountability framework. We’ve seen it in the accreditation negotiations.

But the details really matter. How cohorts are defined. How long is data aggregated? Whether we’re accounting for students who continue their education. Those are things that are really going to determine whether these metrics actually reflect reality. The other thing I’d watch for is complexity. There’s a risk of building something that’s technically sound, but really hard to implement given our outdated data structure.

And that can slow down innovation, especially for workforce programs that need to move quickly. And then just making sure that all of this aligns with how students actually progress today, especially in our stackable pathways. For me, it’s more, it’s a moment less about where policy is going and more about whether we got the design right.

Wesley Smith (13:58.776) Right. I love your point about complexity. It’s getting it right, being right theoretically is a lot different than being right practically and driving outcomes for students. And complexity has that ability to kind of suffocate innovation if we spend too much time on the complexity of measuring outcomes. So we’ve got to get that. We’ve got to have solid outcomes, but we have to do it in a way that doesn’t suffocate innovation.

Cam, tell us anything to add to that. What else should we be looking for in the ahead rulemaking?

Cameron Mortensen (14:36.848) Yeah, I mean, just as far as kind of a schedule goes, there’s obviously a lot happening right now as far as higher education regulation executive rulemaking goes. The public comment period for the workforce Pell portion of AHEAD just closed. That’s what we’ve been talking about today. We are also going to get an NPRM, a notice of proposed rulemaking on the accountability measures that were considered in the AHEAD rulemaking.

that this is published, we’ll have finished the first week of that accreditation, innovation, and modernization or AEM negotiation. And then the next session of that will be taking place in May the 18th through the 22nd. So there’s a lot going on right now, a lot that we as the President’s Forum are following and will be involved in. So definitely stay tuned and we’re always happy to hear others’ thoughts and input as well.

Wesley Smith (15:36.142) Thanks, Cam. Thanks, Amy. We appreciate you joining us and giving us some insight on Workforce Pell specifically and what’s next in the ahead rulemaking.

Cameron Mortensen (15:46.374) Thanks.

Amy Glynn (15:47.319) Thanks for having me.