The Presidents Forum appreciates the opportunity to respond to the Senate Health, Education, Labor, and Pensions (HELP) Committee’s Request for Information on improving the federal financial aid system. We commend Chair Cassidy and the Committee for seeking input from across the higher education community to make student aid more transparent, accessible, and effective for today’s learners.

The Presidents Forum is a national network of 19 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. Together, we focus on policies and practices that align postsecondary education with the needs of students, employers, and the modern workforce.

The responses below embody the Forum’s shared commitment to student-centered innovation and collaborative problem solving. It draws on the expertise of our member institutions, which are leaders in distance learning, competency-based education, and workforce-aligned credentialing. Across every question, our guiding principle is simple: financial aid policy should empower learners to make informed choices, complete their programs, and achieve lasting economic mobility.

Wesley Smith, 

Executive Director

 

Price Transparency

1. What are the pros and cons of the federal government developing a universal net price calculator vs. students relying on individual colleges’ calculators? 

The Presidents Forum supports efforts that make costs clearer and easier to compare. For working learners and adult students, consistent and accessible cost information is essential to planning and persistence. A single, standardized calculator could simplify the process, requiring the same inputs across institutions and helping students understand total costs before they enroll.

However, a universal tool must account for the nuances of real cost. Many institutions serve nonresidential students who already cover housing, food, and transportation. These expenses can make a total “cost of attendance” appear higher and less attainable than it is. In addition, if differential tuition or program-specific fees are omitted, estimates may understate actual costs.

Any federal model should balance transparency with contextual accuracy, ensuring that students can distinguish between direct institutional charges and general living expenses.

A universal calculator must also recognize the diversity of learner populations. Costs and available benefits can vary significantly for military students, community college transfers, and corporate learners whose tuition assistance or credit transfer arrangements reduce direct institutional charges.

 

2. What data elements would the federal government need to collect in order to build a truly useful universal net price calculator? 

A universal calculator would only be valuable if the data behind it are complete, comparable, and consistently reported. Each institution should provide a full set of standardized cost-of-attendance elements including tuition and fees, textbooks and supplies, housing, food, transportation, and personal expenses so students can make accurate side-by-side comparisons.

To ensure transparency, all categories should be mandatory. Institutions should not be able to omit or skip fields, since incomplete data would undermine the calculator’s accuracy and fairness for students.

For many working learners and other nontraditional students, the mix of expenses and resources differs from those of recent high school graduates. Any federal model should be flexible enough to reflect these varied circumstances while maintaining clear and consistent definitions across institutions.

Comprehensive and standardized reporting will make the calculator a reliable tool for students, institutions, and policymakers alike while strengthening transparency and accountability without adding unnecessary complexity.

3. What actions should the federal government consider to ensure that students and families can compare non-tuition costs, such as housing and food, across colleges?

To make non-tuition cost comparisons meaningful, all institutions should be required to report a consistent set of categories, including housing, food, transportation, textbooks and supplies, and personal expenses. Each category should be mandatory so that students receive a complete and comparable view of total costs.

• Standardize data collection: Colleges should report non-tuition expenses using common definitions and include on-campus and off-campus housing, meal plans, transportation, textbooks and supplies, and miscellaneous personal costs. Standardization would make comparisons clearer and reduce confusion for students and families.
• Centralize and publicize information: The federal government could expand existing tools, such as the College Scorecard or a universal net price calculator, to display non-tuition costs in one place. Centralized and accessible information would allow students to understand total costs earlier in their decision-making process.
• Require timely and transparent updates: Institutions should update their non-tuition cost data annually and explain how figures are calculated. This transparency would ensure that families are relying on current and accurate information.
• Include regional and instructional context: Costs such as housing and food vary widely by geography and by delivery model. Notably, an institution serving primarily online students should ensure estimates match the varied realities of where students actually live, not where the institution is located.
• Enhance outreach and guidance: Clear explanations and outreach can help students, especially working learners, understand how non-tuition costs relate to their own circumstances and which expenses are already part of their existing living budgets.

Together, these actions would strengthen transparency, improve comparability, and support more informed financial decisions without imposing unnecessary complexity on institutions.

Value Transparency

4. What are the strengths and weaknesses of the College Scorecard? 

The College Scorecard is a valuable tool that promotes transparency and helps students compare colleges based on cost, outcomes, and other key factors. Its simple layout and accessible design make it easy to navigate, offering a clear starting point for students and families exploring their options.

However, the Scorecard presents several challenges that limit its usefulness, particularly for the growing number of working learners and students enrolled in nontraditional programs. The data are largely based on fall enrollment rather than a twelve-month unduplicated headcount, which understates enrollment at institutions with rolling admissions or flexible start dates. As many innovative and access-focused schools serve students year-round, this approach does not fully reflect their reach or mission. In addition, excluding noncredit learners from reported totals gives an incomplete picture of how institutions contribute to workforce development and lifelong learning.

The Scorecard also tends to present cost and outcome information primarily for traditional students, which overlooks significant learner populations served by many Presidents Forum institutions. Military and veteran students, community college transfers, and corporate learners often experience different pricing structures and benefit programs that are not captured in current Scorecard categories. Public institutions with in-state and out-of-state tuition rates face similar challenges in conveying accurate cost comparisons. A more nuanced presentation of these learner categories would make the Scorecard more accurate and useful for all students.

While some lag in data is expected in any federal reporting system, maintaining data that are as timely and representative as possible is important to preserve the Scorecard’s credibility and usefulness.

 

5. What policy changes would improve the quality of data on college value that are available to prospective students and their families?

Improving data on college value begins with providing students and families with information that reflects the realities of today’s higher education landscape. System-level averages often mask important differences in student outcomes. For many learners, especially working adults making career-based decisions, program-level data are far more meaningful than institution-wide figures. Reporting employment rates and median earnings by program would allow students to better understand their potential return on investment and choose pathways aligned with their goals.

As Workforce Pell begins to be implemented, program-level data will become even more important. Students considering short-term or certificate programs will need clear information on outcomes and return on investment to make informed decisions about where to enroll. Reliable data on employment and earnings by program will help ensure that Workforce Pell achieves its goal of connecting education to economic opportunity.

A search function that helps users identify all programs within a given distance or discipline would make value comparisons more intuitive and actionable.

The Presidents Forum supports continued modernization of education data systems to provide clear, accurate, and program-level information that empowers students to make informed choices. We welcome the opportunity to work with policymakers on approaches that highlight true educational value for today’s diverse learners.

6. How can the federal government partner with private and non-profit entities to ensure that information on college value reaches prospective students and their families?

The federal government can expand the reach and usefulness of college value information by partnering with schools, community organizations, and employers to engage students earlier and more effectively. Many students make key decisions about college before completing high school, yet few have access to clear, contextual information about costs, financial aid, and long-term value. Collaborating with nonprofit and private partners to integrate these topics into high school counseling, community programming, and digital outreach would help students and families make better-informed choices.

Partnerships with employers also offer an important opportunity. Training and information sessions for companies and nonprofit organizations on educational benefits and Section 127 education assistance programs could help expand awareness of existing pathways for adults to pursue education with employer support. These collaborations would connect the dots between college value, career advancement, and workforce development.

By encouraging employers and other organizations to fully leverage the tax advantages of education benefits, we can advance efforts to make information about college value more accessible, actionable, and relevant for every type of learner.

Financial Aid Offers

7. Over the last few years, many colleges have adopted best practices in their financial aid offer letters. What lessons have they learned from this change in practice? 

Institutions that have refined their financial aid offer letters have learned that clarity and structure matter most. Separating grants and scholarships from loans and using plain, student-friendly language helps students and families understand what funding is truly available and what must be repaid. Clear labeling and straightforward explanations on the true cost of attendance reduce confusion and make it easier for students to make responsible financial choices.

Colleges have also found value in visually engaging and interactive formats that highlight key details without overwhelming students with fine print. These approaches make critical information more accessible to first-generation students, working learners, and others who may be navigating the process independently.

As a convener of institutions committed to student-centered innovation, the Presidents Forum supports continued collaboration among colleges, policymakers, and design experts to refine communication tools that help every student understand the full scope of their financial aid options.

8. What barriers exist to more colleges adopting best practices with their offer letters? 

Several barriers can make it difficult for schools to fully adopt best practices in financial aid offer letters. For many institutions, technology and system limitations are a primary challenge. Updating financial aid software or integrating new templates often requires coordination with IT teams or external vendors and can involve added costs or long implementation timelines. Smaller or resource-constrained colleges may find these transitions especially difficult.

Another barrier is the concern that presenting the full cost of attendance alongside limited institutional aid may discourage students from enrolling. Some institutions hesitate to include indirect costs such as housing, food, textbooks and supplies, or transportation in offer letters, even though doing so improves transparency. The most effective way to address this is through clear communication that helps students understand the difference between direct costs paid to the institution and indirect costs they already manage in their daily lives.

The Presidents Forum encourages collaboration and shared learning across the higher education community to overcome these barriers. As a convener of innovative institutions, the Forum supports the development of adaptable templates, guidance, and technology solutions that make best practices feasible for colleges of every size and model.

9. How should colleges communicate information about parent PLUS loans, which have less favorable terms than regular student loans and are not available to all families?

Colleges should take a proactive and transparent approach when communicating information about Parent PLUS loans. These loans differ from other types of aid, and families benefit from understanding their unique eligibility requirements, repayment obligations, and long-term financial implications before making borrowing decisions.

Institutions should include clear and detailed information about Parent PLUS loans in or alongside the financial aid offer letter, as well as on their websites. This should go beyond a basic description and clearly outline the credit-based nature of the loan, the application process, and how it differs from student loans. Providing an estimated repayment schedule and highlighting that repayment typically begins shortly after the final disbursement can help parents plan responsibly and avoid unexpected financial strain.

Importantly, Parent PLUS loans should be presented as an optional resource rather than as an assumed or automatic component of the financial aid package. The financial aid offer should first outline grants, scholarships, and student loans, followed by information about Parent PLUS loans that may be available if additional funding is needed.

By making this information easily accessible, timely, and specific, colleges can support responsible borrowing and help families make informed financial choices that align with their long-term goals.

Informed Borrowers 

10. What information on student loan repayment is most important for students to have when they are taking out the loans? 

Students need clear and timely information that helps them understand how much they owe, what repayment will look like, and what supports are available if challenges arise.

They should receive a simple, personalized summary showing their cumulative loan balance, anticipated monthly payment segmented by principal and interest, total repayment period, and projected interest costs. Knowing these details helps students plan responsibly and avoid accumulating unexpected debt.

Students also need clear explanations of their rights and responsibilities, including options for prepayment, forbearance, and deferment, and the consequences of default. Providing this information in plain language at the time of borrowing and throughout their studies empowers students to make informed decisions and manage their repayment successfully.

11. What is the best way to communicate information about loans to students so that they actively process it and do not just sign disclosures without reading them? 

Students engage most effectively with loan information when it is interactive, personalized, and easy to understand. Schools have learned that providing information alone is not enough; students need opportunities to process and apply it. Interactive modules, short checkpoints, or counseling sessions at key points during the academic year help reinforce understanding and allow students to ask questions before accepting loans.

Many Presidents Forum institutions already use proactive communication and personalized data to help students understand how borrowing decisions affect their future repayment. By presenting individualized loan estimates and encouraging students to borrow only what they need, these institutions have reduced average student debt while maintaining strong academic and financial outcomes.

The federal government could support this effort by strengthening and expanding the Annual Student Loan Acknowledgment program to ensure all borrowers receive personalized, easy-to-read information about their total debt, repayment options, and projected obligations before borrowing each year.

12. Are there special considerations that colleges should take when communicating information to students attending the short-term, workforce-oriented programs that will become eligible for Workforce Pell Grants in the coming years?

Clear and practical communication will be essential as Workforce Pell is implemented. Many students enrolling in short-term, workforce-oriented programs will be working adults seeking to upskill quickly or transition into new careers. Colleges should ensure these students understand both the immediate and long-term value of their programs, including how short-term credentials can serve as stepping stones toward higher degrees or additional certifications that lead to career advancement.

Students should also receive clear explanations of how Workforce Pell interacts with existing aid rules, including lifetime Pell Grant limits, enrollment intensity, and proration for shorter programs. Transparent information on these factors helps students plan how best to use their eligibility and avoid surprises later in their educational journey.

It is equally important to help students see these programs as part of a stackable, lifelong learning pathway rather than a one-time experience. Communicating how credentials can build on one another to open future opportunities reinforces the idea that education and career growth are continuous, connected processes.

13. Other insights on how the federal government can work with all stakeholders to advance pro-student and pro-family policies.

One area that deserves federal emphasis is ensuring the timely processing and delivery of all forms of student aid, including military and veteran education benefits. Delays in disbursement can create unnecessary hardship for students who rely on these funds to cover tuition, housing, and other essential expenses. Prioritizing the accuracy and timeliness of aid delivery would reinforce the federal government’s commitment to supporting the success of military-affiliated students and their families.

 

 

 

 

Comments on Docket ID ED-2025-SCC-0382 — Integrated Postsecondary Education Data System (IPEDS) 2024-25 through 2026-27.

Dear Acting Chief Data Officer Fu:

The Presidents Forum is a coalition of 19 nonprofit, accredited institutions serving more than one million learners nationwide. Our members share a deep commitment to expanding access, advancing workforce opportunity, and achieving measurable student outcomes through a focus on innovation. Together, we represent the full spectrum of today’s learners—including working adults, military-connected students, and others historically overlooked in the design of higher education policy and regulation. Each of our institutions serves as a laboratory for student-centered innovation, testing and scaling models that make education more affordable, attainable, and aligned with the needs of learners and employers alike.

Open-Access Institutions

We respectfully recommend that institutions meeting the Department’s definition of open admission be exempt from ACTS admissions and scholarship reporting. These institutions do not employ selective admissions practices and therefore present minimal risk of noncompliance with Title VI. Requiring reporting from open-admission institutions would yield data of limited analytical value while diverting effort from the core mission of providing opportunity to all learners.

Highly Inclusive Institutions

If the Department determines that additional data elements beyond race-sex reporting should be collected, any such new requirements should not apply to institutions that accept a high percentage of applicants, such as over 85 percent. This threshold would maintain transparency while recognizing the inclusive mission of access-oriented colleges and universities. For institutions with high acceptance rates, the additional data would not offer meaningful differentiation but would pose substantial feasibility challenges. 

Feasibility and Data Quality

The proposal to require retrospective reporting of five years of admissions and scholarship data presents significant feasibility and data-quality concerns. Most access-oriented institutions do not maintain historical data in the structure or granularity contemplated by ACTS. Reconstructing these data would be technically impractical, and any partial information obtained would likely be incomplete or inconsistent across years. For these reasons, the Department should limit ACTS implementation to prospective data collection only, ensuring that future reporting is accurate, standardized, and aligned with common definitions.

Privately Funded Scholarships

We further recommend that privately funded institutional scholarships—those supported entirely through non-federal and non-state resources—be excluded from ACTS reporting requirements.

Conclusion

The Presidents Forum and its member institutions remain committed to advancing transparency and accountability in ways that genuinely serve students. We urge the Department to ground ACTS implementation in feasibility, data quality, and institutional context—exempting open-admission institutions, limiting additional requirements to those with less than 85 percent selectivity, excluding privately funded scholarships, and applying new reporting prospectively. These adjustments will strengthen the quality and utility of ACTS while supporting institutions’ shared mission to expand educational opportunity.

Sincerely,

Wesley Smith

Executive Director
Presidents Forum

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