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

Dear Speaker Johnson,

The Presidents Forum, a collaborative network of 17 innovative higher education institutions committed to expanding access and opportunity for working learners, writes to urge reforms to Section 127 of the Internal Revenue Code. Our member institutions serve over 1 million students annually, with a particular focus on working adults seeking to advance their education and careers. Our commitment to expanding educational access and creating debt-free pathways to higher education compels us to advocate for modernizing this critical program.

The current $5,250 annual limit on tax-free employer-provided educational assistance has remained unchanged since 1986. When adjusted for inflation, this amount would be approximately $15,000 today. This outdated cap significantly limits the program’s effectiveness in supporting working learners. While 73% of workers express interest in utilizing education assistance benefits, this drops to 39% when they must pay taxes on amounts exceeding the current cap. Taxes on payments above the cap are prohibitively high and discourage students from pursuing additional coursework within the same year.

As institutions deeply invested in workforce development and career advancement, we strongly support modernizing Section 127 through three key reforms:

• Increasing the tax-free limit to better reflect current education costs
• Indexing the amount to inflation to maintain its value over time
• Expanding eligible expenses to include books and educational tools

In an era of rapid technological change and increasing demand for upskilling and reskilling, modernizing Section 127 would help more Americans access the education they need without incurring substantial debt.

We applaud the House Ways and Means Committee for including language that adjusts the $5,250 cap for inflation starting in 2026. We urge Congress to support transformative legislation like the Upskilling and Retraining Assistance Act (H.R. 6401) and the Upward Mobility Enhancement Act (H.R. 6402), sponsored by Representatives Danny Davis and Randy Feenstra. Investing in America’s workforce will strengthen our economy, support working learners, and help employers attract and retain talented employees.

Sincerely,

The Presidents Forum

To Whom It May Concern:

The Presidents Forum represents 16 higher education institutions serving approximately one million students nationwide. Our association is committed to fostering accountable innovation, serving working learners, and prioritizing student success through high-quality, accessible education. After reviewing the House Education and Workforce Committee’s reconciliation legislation, we wish to highlight several important considerations as this process moves forward.

We are encouraged by elements of the bill that promote student success. Specifically, we applaud the expansion of Pell Grant eligibility to short-term, workforce-aligned programs and the commitment to maintaining essential funding for the Pell Grant program. We applaud the House for not excluding online programs, which are essential to a modern, inclusive higher education system. These provisions will help ensure that higher education remains accessible to students seeking to advance their careers through targeted educational opportunities.

We have concerns about other aspects of the legislation. The elimination of subsidized loans would increase the cost of attendance for low income individuals, and the proposed requirement for students to complete 30 credits annually to maintain Pell Grant eligibility (versus the current 12-credit-per-semester standard) creates significant barriers for working adults pursuing higher education. Students who would otherwise use Pell grants to pursue a degree may opt out rather than take additional credit hours they cannot manage due to work or other commitments. These changes make it harder for non-traditional students—especially working adults—to access higher education and improve their lives.

We support accountability measures for both students and institutions. Student outcomes should be the primary basis for accountability measures, rather than focusing on process inputs. Under any financial risk sharing arrangements institutions should have the ability to restrict federal loans for specific programs where appropriate. Additionally, the Department should be required to regularly report to Congress on the effectiveness of risk-sharing provisions.

The Presidents Forum stands ready to engage in further dialogue on these critical issues and serve as an essential voice for working learners in higher education policy discussions. Our member institutions’ deep experience in serving non-traditional students provides valuable insights that can help shape policies that truly support student success and workforce development. We welcome the opportunity to collaborate with policymakers to ensure that higher education remains accessible and effective for all learners.

Sincerely,

Wesley Smith

Executive Director
Presidents Forum

Dear Acting Under Secretary Bergeron:

The Presidents Forum is a coalition of sixteen not-for-profit institutions serving approximately one million students nationwide. Our members share an access orientation and a commitment to student success, innovation, and flexible learning opportunities for working adults.

Our institutions serve working learners who juggle education with career and family responsibilities—a population historically overlooked in regulatory discussions. Moving forward, the Department should prioritize including negotiators who deeply understand and actively serve working learners. Representatives from institutions that specialize in serving working learners can provide critical insights into how proposed regulations might impact student access, persistence, and success.

We advocate for focused and limited regulatory development that respects state oversight and fosters accountable innovation. We believe that regulations should emphasize student outcomes over delivery methods, enabling institutions to innovate while maintaining quality and accountability across all learning modalities.

Based on our values, approach, and perspective, we offer the following recommendations for regulatory changes to enhance efficiency, transparency, and student outcomes.

• Income Driven Repayment: We recommend the department address the volatility and lack of continuity surrounding income-driven repayment programs. The ongoing cycle of legal challenges, policy shifts, program rollouts, and rescissions creates significant uncertainty for borrowers trying to manage repayment. This environment makes it nearly impossible for borrowers to make informed, long-term financial decisions. A durable and predictable repayment framework—one that borrowers can rely on—should be the cornerstone of this rulemaking effort. An income driven approach can prevent borrowers from unintentionally enrolling in plans that do not match their financial capacity and would help reduce delinquency and default, particularly for those from low-income or non-traditional backgrounds.
• Identity Verification: Requiring robust identity verification measures in FAFSA applications ensures the integrity of the financial aid system. The Department should implement more secure verification protocols so that institutions can better ensure that aid is distributed to legitimate applicants and reduce improper payments. While institutions support system integrity, the Department should be the one to implement and maintain appropriate verification protocols. This ensures consistent standards across all institutions while keeping the verification process manageable for prospective students.
• Limit Interest Costs for Students: Limiting student loan interest capitalization to reduce the overall burden on borrowers. Interest capitalization significantly increases the total amount students must repay, often leading to extended repayment periods and increased financial strain. We encourage the Department to implement policies that minimize interest capitalization and work collaboratively with Congress to establish lower interest rates for federal student loans.
• Loan Servicer Improvements: To enhance efficiency and improve borrower experience, loan servicing processes should be streamlined. We recommend consolidating and standardizing processes across servicers to reduce complexity. Performance-based contracting should be implemented to create accountability and reward servicers who maintain high-quality service and low default rates. Furthermore, the Department should incentivize servicers to modernize their platforms through automation and digital solutions—this would enable faster processing times, fewer errors, and better borrower communication.
• Public Service Loan Forgiveness: The Presidents Forum strongly supports the Public Service Loan Forgiveness (PSLF) program as a critical tool for encouraging public service careers and reducing student debt burden. Clear PSLF eligibility requirements and application processes are essential for students to make informed decisions about their career paths and successfully navigate loan forgiveness opportunities.

The Presidents Forum is committed to fostering a higher education environment that is effective, affordable, and focused on student success. We believe that process plays a vital role in creating such an environment—any significant changes require comprehensive public input and feedback. We maintain that reforms not addressed in the Department’s original posting warrant their own dedicated rulemaking sessions. We look forward to providing input on additional important measures in future sessions.

Sincerely,

Wesley Smith

Executive Director
Presidents Forum

Dear Speaker Johnson, Leader Schumer, Leader Jeffries, and Leader McConnell:

The Skills First Coalition, a consortium of employers and innovative education providers advocating to advance policies that invest in and strengthen the alignment between education and skills training for in-demand jobs, is writing today to express our strong support for the bipartisan, bicameral, “A Stronger Workforce for America Act,” and urges its swift passage.

As a Coalition, we have consistently called on Congress to modernize the Workforce Innovation and Opportunity Act to advance a skills-based economy, expand and prioritize employer-led training, and support high-quality outcomes with high-quality data. America’s learners, workers, and employers must have access to education and workforce development that keeps pace with technological advancements, is accountable for outcomes, is flexible in its delivery, and is innovative in its offerings of high-quality learning.

A Stronger Workforce for America Act takes significant steps to provide more direct reskilling and upskilling to American workers. Specifically, we support the following provisions that create more opportunities for workers and improve America’s competitive advantage on the global stage:

• Directing no less than 50% of funds toward workforce skills education, ensuring our workforce system focuses on its primary goal of providing learners with in-demand occupational skills needed to compete in today’s labor market.
• Promoting employer-led learning models, better linking education to work.
• Incentivizing states to expand the adoption of skills-based hiring and learning that reward an individual’s competencies, knowledge, and prior work experience.
• Increasing the cap on incumbent worker training, helping our current workforce to reskill and upskill so they can remain competitive.
• Including digital literacy as a foundational skill to better align with an ever-changing economy.
• Encouraging states to streamline access to the Eligible Training Provider List and offer reciprocity among each other to ensure more individuals access high-quality education providers.
• Promoting better access to centralized data tools, including state wage records and the National Directory of New Hires, to measure outcomes consistently, reliably, accurately, and in real-time.
• Allowing high-quality in-person, online, and hybrid learning models that individuals can access in a variety of flexible and innovative ways.

We commend this bipartisan, bicameral agreement and urge its final passage.

Sincerely,

The Skills First Coalition

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