The Path Of Knowledge Is Open To All That Have The Determination To Walk It

The Path Of Knowledge Is Open To All That Have The Determination To Walk It

The Presidents Forum has existed for over 20 years, and is both a venue for collaborative innovation between presidents and a collective voice for advocacy on behalf of our students.

March 30, 2023

The Honorable Miguel Cardona Secretary
U.S. Department of Education,
Office of Postsecondary Education
400 Maryland Ave. SW, Second Floor
Washington, DC 20202 Docket ID ED-2022-OPE-0103

Dear Secretary Cardona,

 The Presidents Forum has existed for over 20 years, and is both a venue for collaborative innovation between presidents and a collective voice for advocacy on behalf of our students. Our 16 institutions—including HBCU’s, community colleges, private institutions, and fully online colleges—are united by the non-traditional learners we serve, and because we embrace a shared spirit of innovation in order to meet the needs of our students. Our goal is reflected in Lyndon Johnson’s remarks in signing the Higher Education Act into Law in 1965: to ensure that “the path of knowledge is open to all that have the determination to walk it.” The institutions of the Presidents Forum are focused not on a narrow, elite set of students, but instead on the “all” that was envisioned by President Johnson. We serve those who have traditionally been left behind on the path to opportunity: low income students, students of color, veterans and active duty military students, working parents, and older adults.

 The vision for equity in education that unites us has been made all the more imperative by the events of recent years: a pandemic that has emphasized the importance of innovation and collective action; a national movement to address inequity wherever it lies; and a turbulent economy that has revealed the importance of equipping individuals with skills that can provide them with resilience and adaptation. Lyndon Johnson’s words are more true today than when they were first spoken: “And it is a truism that education is no longer a luxury. Education in this day and age is a necessity.” In order for America to realize its potential, it is necessary to ensure that access to higher education is expanded, and that opportunity is not the purview of the few. For each of our institutions, innovation has been the key that has unlocked our ability to provide education that is more affordable and more accessible than has been possible in prior generations. Higher education today shares the same goals as it did decades ago, but how we serve students looks very different—and this is a good thing. Technologically driven innovations have enabled education to reach more students, with more success, than we ever could achieve through traditional means. At the Presidents Forum, we embrace innovation that benefits students: that which makes it possible for us to define a system that meets students where they are, and supports students with the resources they need to be successful—rather than a traditional model that forces students to adapt to the institution.

Utilizing technology has necessarily made our operations more complex—and this is true for institutions that deliver education in person as well as those that employ online modalities. Software is beautiful in its ability to interface across systems, to create opportunities for students to pursue their studies at the time and place of their choosing, to support students in their learning and career goals, and to help us as institutions learn more about what works for our students and to do better by them. But these systems are developed, operated, and maintained at scale: for each of the 5,500+ Title IV institutions to hire a team of developers to create and maintain duplicative but proprietary educational software would result in exorbitant expense at no gain to students. Thus, we have partnered with a range of providers in order to build and improve our offerings. Our accreditors have worked with us to understand these changes over time. As the Department notes, we rely on more partners than we would have in Lyndon Johnson’s time. Many of these partnerships enable the technological provision of our academic program—but many more of them enable us to provide additional services to students in order to ensure their success.

We understand that the Department is curious about how higher education institutions are partnering with outside contractors in this technologically driven age. However, we urge the department to rescind its recent Dear Colleague letter issued on Third Party Servicers (TPS) for the following reasons:

  • The change in the interpretation of the law is significantly different from prior Department guidance on TPS, and from how this area of the law has been historically understood by industry participants.
  • It would have a significant impact and administrative burden, raising costs for students and impeding the ability of institutions to provide needed services. There is no identified harm to students that is being resolved by this administrative change that in any way justifies the costs of compliance that would be incurred.
  • Outside contractors used in the provision of higher education services are already evaluated by other regulatory bodies, most notably accreditors.

 How Third Party Services have Historically Been Understood

Third party servicers were defined in the law to clearly relate to outside contractors involved in the provision of Title IV funds, including their processing and disbursement. This definition has been supported by the Department through Dear Colleague letters issued in 2012 and 2015. No Congressional action has since taken place that would support any change in Congress’s intent regarding the definition of Third Party Services, nor in Congress’s intent to change the authority of the Department to control the inner workings of higher education institutions. As a reminder, the relevant text of the law is below.

 For purposes of this subchapter and part C of subchapter I of chapter 34 of Title 42, the term “third party servicer” means any individual, any State, or any private, for-profit or nonprofit organization, which enters into a contract with–

(1) any eligible institution of higher education to administer, through either manual or automated processing, any aspect of such institution’s student assistance programs under this subchapter and part C of subchapter I of chapter 34 of Title 42;  or

(2) any guaranty agency, or any eligible lender, to administer, through either manual or automated processing, any aspect of such guaranty agency’s or lender’s student loan programs under part B of this subchapter, including originating, guaranteeing, monitoring, processing, servicing, or collecting loans.

The Burden of the DCL is Significant

This change in interpretation—from contractors related to the processing of “any aspect” of student assistance programs or those related to “any aspect” of student loan programs including originating, guaranteeing, monitoring, processing, servicing, or collecting loans, to any entity contracted for “any aspect” of any program delivered with Title IV funds—would increase the number of “Third party servicers” at our institutions from a handful, that are involved in our financial aid processing, to hundreds or thousands which are involved across the full spectrum of our activities.

 This is because higher education institutions are highly complex entities. A typical campus may include dining facilities, residential facilities, physical plant that requires cleaning and maintenance, curricular design and development, physical technology infrastructure, cloud based software services, financial and investment management, medical services, social work capabilities, academic instruction, career services, a significant HR function, sports and recreation facilities, security services, institutional research functions, daycare facilities, transportation services, and complex scientific and medical research facilities. The “technology” stack, as in most modern organizations, involves a massive number of systems that work together to enable our institutions to operate—and prepare students to operate in—the information age in which we live.

 In short, higher education institutions today, in addition to providing academic offerings—which, even for on-campus institutions, is a hugely complex undertaking—also serve as gyms, restaurants, medical offices, police forces, lawn care services, road and building maintenance crews, accounting firms, event planners, career recruiters, speakers bureaus, book publishers, and laundromats. Each of our institutions seek to focus our activities on where we can best provide value for students, and to eliminate unnecessary costs for students. To that end, each of our institutions contracts with outside entities—for everything from janitorial services to software—in order to avoid organizational complexity, to reduce costs, and to provide excellence to our students.

 The information and authority that the Department seeks in its recent DCL would require intensive and costly compliance efforts at every higher education institution—as well as at the Department. The benefit to students from these incurred costs is unclear.

 Who Evaluates the Academic Program

Accreditors have the expertise and processes in place to ensure that the “provision of educational content and instruction” meet high quality standards. The Department does not have the expertise, staff or resources to review how content and instruction are provided, and this was not the intention of Congress in defining Third Party Services, as affirmed by multiple Dear Colleague letters on Third Party Services. Accreditors, on the other hand, use expert review teams to dive deeply into how academic programs are constructed, what activities are conducted by the institution, to ensure that outsourcing arrangements are done in the service of students—to enhance quality and to reduce costs—and that the institution has ultimate governance and control of academic programs. Accreditation is not a perfect system—but significant changes to the role and scope of accreditation should not be made through subregulatory guidance.

 It is important to understand that our accreditors are up to date in how outside contractors are involved in the educational program. Where accreditors have issues with the academic program being outsourced or outside the governance of the institution, they are vocal and authoritative. This is the case for both traditional and for online programs.

 The Bigger Prize

The Department’s resources are scarce and precious—as are those of institutions, and even more so, our students. We beseech the Department to refocus away from scrutinizing every aspect of how institutions support students and deliver instruction, and instead double down on its mission to promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access. We urge the Department to rescind the most recent Dear Colleague letter; it is clearly an overreach of the law and stands in contradiction to all previous guidance from the Department on this issue. We stand aligned with the Department on the bigger prize: innovating to create pathways to opportunity for every individual, particularly those most in need of them.

Best Regards,

 

Wesley Smith
Executive Director
The Presidents Forum
80 M St SE Suite 130
Washington DC, 20005

Statement of support for expanding Pell grants for short-term credentials 

Statement of support for expanding Pell grants for short-term credentials

The 21st century economy requires new approaches to ensure all Americans have access to economic and educational opportunities.  As a collaborative of college and university presidents, the Presidents Forum fully supports expanding Pell Grants for short-term credentials, which H.R. 496, the Promoting Employment and Lifelong Learning (PELL) Act., will do. Innovative, short-term credential programs are creating pathways to resilient careers that fit into the lives of all learners, but many of these programs are not currently accessible to students who rely on financial aid to finance their education. This bill addresses the lack of student aid for many of these emerging short-term credential programs that provide job-ready skills. This legislation recognizes the struggles that nontraditional learners, low-income learners, and learners of color face in balancing learning with earning and care-taking obligations. Educational opportunity should be measured by the value that it creates for learners, not whether it is demarcated by online, competency, clock, or credit hour.  We also appreciate the legislation’s emphasis on accountability: federal student aid funds must be accompanied by clear outcomes and transparency in order to protect learners and taxpayers and to ensure workforce alignment and high quality in higher education. We support our congressional leaders taking action to modernize higher education and the Presidents Forum urges Congress to take this meaningful step towards addressing the needs of learners and their families. Together, we can empower learners and help them gain valuable workforce credentials—tapping the full potential of our great nation.

Read the full thread here: https://twitter.com/PresidentsForum/status/1618747191841165315?s=20&t=pCui8SScW2JfNG0tqu0Ixg

 

To Congress: Short-Term Pell Needs Online Education

To Congress: Short-Term Pell Needs Online Education

In the following letter sent to members of Congress on June 13, 2022, Presidents Forum members, along with other education and business leaders advocate for the expansion of the short-term Pell Grant program to include online education institutions.

Dear Speaker Pelosi, Leader McCarthy, Leader Schumer, Leader McConnell, Senator Murray, Senator Burr, Representative Scott, and Representative Foxx:

Thank you for your leadership on higher education and workforce policy issues to ensure all Americans have the skills to get a good-paying job. The undersigned organizations represent innovative universities serving large numbers of working adults, through models that deliver education to best meet the needs of such learners, including through online platforms. We also represent the Skills First Coalition–a new group of employers and education providers that support skills-first policies that shift the focus from traditional degrees as proxies for knowledge to verifiable competencies, skills, and work-based learning opportunities. We are writing today to call for the elimination of any exclusions to online education programs in expanded Pell eligibility in the final Bipartisan Innovation Act.

We recognize the bipartisan efforts to expand Pell Grant eligibility to high-quality, short-term skills and job training programs that would allow part-time students and mid-career professionals to qualify for shorter-term learning opportunities, including internships or community college classes. Working adults and students who currently enroll in short-term programs to upgrade their skills must pay out of pocket which creates a barrier for many individuals.

In addition to cost, working adults face a range of barriers to accessing traditional models of post-secondary education and training. Whether due to child or other care challenges, the need to earn a salary to support a family, and other hurdles to flexibility and time, today’s working adult learners need education models that recognize these challenges, not compete with them. During the COVID-19 pandemic, the nation experienced the benefits of the option of online models, and in a recent survey, 73 percent of students indicated a preference to take online courses post-pandemic.

While we acknowledge the original intent of the benchmark JOBS Act (S.864, H.R. 2037), we are concerned the provisions in the House-passed America COMPETES Act that exclude online education programs will weaken the purpose of the provisions to provide access and affordability to students and working adults. Additionally, the exclusion of online programs runs counter to the $65 billion broadband infrastructure deployment included in the Infrastructure Investment and Jobs Act that will ensure all Americans have access to reliable high-speed internet to help close the digital divide. Participation in today’s economy, and in many of our most important jobs in cybersecurity and information technology, require technical skills and connectivity, and training options must also provide for this modern need.

The language in COMPETES contains protections to support quality programs for learners. We support inclusion of such protections and believe our institutions should be held to all the same standards, regardless of model. More importantly, in the workplace, we are seeing a growing demand for online, high-quality skills training and certification programs that offer the flexibility and relevance for employees and learning outcomes valued by employers who are doing the hiring. However, the language excluding online programs is a penalty, not a protection, for those learners for whom online programs are their only access point to education and training. Because having time and being able to control one’s schedule is a function of privilege, allowing only programs that tie students to being at a physical location at a preordained time excludes low-income learners who have less time than others and often do not control their work schedules, as is common in many sectors of the economy.

As the House and Senate work to reconcile the differences between USICA and COMPETES, and move toward passage, we urge the conferees to ensure students who most need access to short-term Pellbe able to have the option of participating through online programs. By excluding students in online programs and not aligning it with existing Pell Grant and WIOA regulatory frameworks the COMPETES Act denies access to a significant population of students who must receive the skills needed to be able contribute to the workforce and improve their lives. We ask that you amend the language to remove the online exclusion.

Ensuring all learners have access to training and upskilling is crucial to meeting the demands of the nation’s students and working adults. We thank you for your attention to this critical matter and your continued support of higher education and learners throughout the country.

Sincerely,

Scott Pulsipher
President, WGU
Chairman of Board, Presidents Forum

Michael Hansen
Chief Executive Officer Cengage Group
Co-chair, Skills First Coalition

David N. Barnes
Vice President Global Workforce Policy IBM Corporation
Co-chair, Skills First Coalition

Ginni Rometty
OneTen Co-Chair & former CEO and chairman of IBM

Eloy Oakley
Chancellor, California Community Colleges

Paul LeBlanc
President, Southern New Hampshire University

Sue Ellspermann
President, Ivy Tech Community College

Kate Smith
President, Rio Salado College

Robert Mong
President, University of North Texas at Dallas

David Schejbal
President, Excelsior College

Frank Dooley
President, Purdue University Global

Ed Klonoski
President, Charter Oak State College

Gregory Fowler
President, University of Maryland Global Campus

E.R. Anderson
Director, Public Affairs Randstad North America

Pathbreaking College and University Presidents Call for Deeper Industry Collaboration to Meet Workforce Needs

Pathbreaking College and University Presidents Unveil Blueprint for Higher Education Reform in the Face of Multiple Crises

In a new report, members of the President Forum compile high-impact recommendations for integrating higher education with the world of work

WASHINGTON, March 24, 2021 /PRNewswire/ — With millions of displaced workers looking to retool for new careers, the Presidents Forum, a national nonprofit network of seventeen innovative college and university leaders, unveiled a new report highlighting the need for stronger collaboration between institutions and employers and industry partners to support a more inclusive and equitable economic recovery. The report, Transforming Together: Aligning Higher Education with the Changing World of Work, is rooted in the frontline experience of the nation’s largest online universities, community and technical colleges, minority-serving institutions, and state higher education systems.

“Millions of displaced workers are turning to higher education for solutions as they work to reinvent themselves for new roles—often in unfamiliar industries,” said Dr. David Andrews, president of National University. “As higher education works to serve an older, more diverse and heterogeneous student population, institutions should rightly feel a heightened sense of urgency to deliver more precise learning experiences that translate into career-relevant skills and a shorter-term economic payoff.”

Drawing on case studies and examples of how institutions are bridging higher education and the world of work, the report shares five key strategies for how institutions can engage employers and develop stronger linkages between academic programming and workforce needs. These strategies include developing opportunities for lifelong learning beyond a bachelor’s degree, such as short-term certificates and microcredentials, as well as partnering with employers and peer institutions to create a shared vocabulary around skills and competencies.

Recent surveys show that one in four Americans without a college degree believe that a degree will not improve their career opportunities. In summer 2020, nearly three in five displaced workers were not confident that they could find a new job that would be a good fit for their skillset. At the same time, over one-third of the skills required for jobs across all industries have changed over the past three years.

“To make good on higher education’s promise of social and economic mobility, colleges must find new ways to match the demands of an increasingly complex economy and labor market,” said Kate Smith, president of Rio Salado College. “As the jobs we do and the way that we do them change faster than ever, collaboration with employers requires a new level of creativity, entrepreneurship, and agility from institutions, if they are to equip students with in-demand skills that are tightly-linked to the needs of the broader economy.”

The new report is the product of the second virtual event in the Learners First Convening series, a set of collaborative convenings with Presidents Forum members, policy experts, employers, and innovators focused on rebuilding higher education in the aftermath of the pandemic. Over the next 12 months, the series will surface insights and best practices from Presidents Forum members and produce resources and tools for peer institutions.

“During this chapter of enormous economic uncertainty for colleges, students and the country, a focus on workforce relevance is paramount for institutions of higher education,” said Jim Manning, executive director of the Presidents Forum. “This report offers vivid and powerful examples of how leading-edge institutions are developing stronger and more explicit connections among academic experiences and credentials and economic opportunity.”

Founded in 2002 by a small group of forward-thinking university and community college leaders who were early adopters of online learning and focused on serving working adults, the Presidents Forum advances innovation in policies and practices to ensure the promise of higher education for working learners and other fast-growing student populations.

About the Presidents Forum: The Presidents Forum is a non-profit 501(c)(3) membership organization of college and university presidents and chancellors as well as leading education stakeholders committed to reinventing higher education for our diverse student population – traditional, non-traditional, and working learners. We are dedicated to the continuous reinvention of higher education and exploring transformative education models by sharing knowledge, implementing best practices, and making policy recommendations.