Re: Comments on Accountability in Higher Education and Access Through Demand-Driven Workforce Pell: Pell Grant Exclusion Relating to Other Grant Aid; and Workforce Pell Grants

 Dear Under Secretary Nicholas Kent,

 The Presidents Forum appreciates the Department’s engagement through these directed questions and the opportunity to contribute to the development of Workforce Pell. As a nonprofit organization composed of innovative college and university leaders, we are committed to advancing student-centered policies that expand access and improve outcomes for working learners and other nontraditional students.  

We recognize that successful implementation will be critical to realizing the full potential of Workforce Pell. As the Department finalizes its approach, we encourage a framework that is clear, consistent, and practical for institutions to implement, and that supports expanded access and strong outcomes for students.

Where relevant, we also encourage alignment with existing regulatory approaches to promote consistency and avoid unnecessary complexity for institutions serving students across state lines, including in how student location is determined.

Directed Questions

Written Arrangements To Provide Educational Programs (§ 668.5(c))

The Presidents Forum appreciates the Department’s recognition of the role partnerships can play in strengthening eligible workforce programs. High-quality workforce programs are closely aligned with employer and industry needs, and that alignment often depends on collaboration with external partners who bring specialized expertise, training environments, and real-world application into the educational experience.

In many cases, effective workforce programs integrate instruction delivered in partnership with employers or other industry-aligned organizations. These partnerships help ensure programs remain responsive to labor market demand and that students acquire skills that translate into employment and earnings outcomes. The depth of these partnerships is often central to program quality and student success.

The proposed 25 percent limitation may unintentionally constrain the development of high-quality workforce programs by limiting institutions’ ability to fully leverage these partnerships. In some cases, institutions may be required to replicate training components that are more effectively delivered in collaboration with industry, reducing program effectiveness and increasing costs without clear benefit to students.

While we recognize the Department’s interest in ensuring appropriate oversight, we believe this can be achieved while allowing greater flexibility. The proposal is more restrictive than the framework that has historically governed written arrangements in Title IV programs, and we encourage the Department to consider a similarly flexible approach here.

Accordingly, we recommend that the Department allow written arrangements that exceed 25 percent where appropriate institutional control and oversight are maintained. This flexibility will better support innovative, employer-aligned programs that deliver strong outcomes for students.

Ineligibility Due to Grant or Scholarship Assistance (§ 690.5)

This provision effectively shifts the Pell Grant from a first-dollar to a last-dollar benefit in certain circumstances. For decades, Pell has served as the foundational source of financial aid for low-income students, with state, employer, institutional, and philanthropic support layered on top. Many of these aid programs have been designed with the expectation that Pell funding will be applied first in a student’s financial aid package.

Altering this structure, even in limited situations, may have unintended consequences for students. State and local aid programs, employer tuition benefits, and private scholarships may not be structured to adjust seamlessly to a last-dollar Pell model. As a result, students may face reduced total aid or increased complexity in calculating or determining financing for their education, particularly for working learners who rely on multiple sources of support.

Policy should encourage employer investment in education. This change may affect employer participation in workforce education programs. If employer-provided assistance reduces or eliminates Pell eligibility, it may create disincentives for employers to invest in their employees’ education or for students to utilize available employer benefits, which could undermine the goal of expanding access to demand-driven workforce programs.

The proposed requirement to recalculate aid and potentially return Pell funds when additional non-Federal assistance is identified and exceeds the student’s cost of attendance may further increase complexity and uncertainty for both students and institutions. Changes in financial aid eligibility throughout an award year may be difficult for students to navigate and could introduce administrative challenges for institutions attempting to manage multiple funding sources in real time and provide students with as much aid as possible.

Given these considerations, we encourage the Department to carefully assess the broader impacts of this provision on students and existing aid ecosystems. Any additional reporting, oversight, or enforcement mechanisms should be designed to minimize disruption to these systems, reduce unnecessary administrative burden, and avoid discouraging employer, state, or philanthropic investment in student success.

Components Determined by Governors (§ 690.93)

The Presidents Forum supports the Department’s goal of ensuring that eligible workforce programs are aligned with labor market demand.

As the Department implements this requirement, it will be important that the process for state approval is clear, efficient, and capable of operating at the scale required to meet workforce needs. Workforce demand is often regional or national in nature, particularly in high-demand sectors where employers operate across state lines and where remote work is increasingly common. Many workforce programs are designed to prepare students for employment opportunities that extend beyond a single state.

Given these realities, the structure and execution of the approval process will be critical. If the process is overly complex or time-intensive, it may limit institutions’ ability to expand access to high-quality programs through distance education in a timely manner. This could reduce opportunities for students, particularly working learners, who depend on flexible access to programs aligned with in-demand careers.

We encourage the Department to prioritize the development of a streamlined and scalable approach for state approval that enables coordination across multiple states where appropriate. A clear and efficient framework will better support the expansion of high-quality workforce programs while maintaining alignment with labor market needs and preserving appropriate state involvement.

 

Value-Added Earnings: Interim Value-Added Earnings Metric (§ 690.95(a))

The Presidents Forum encourages the Department to prioritize clarity, stability, and effective implementation as it develops the value-added earnings framework for eligible workforce programs.

As the Department considers whether to introduce interim measures or additional layers of accountability, it is important to avoid creating a system that is overly complex or difficult for institutions to implement. Workforce Pell has the potential to expand access to high-quality, demand-driven programs, but that potential depends on a regulatory framework that institutions can navigate efficiently and consistently.

An overly complex or rapidly evolving accountability structure may create uncertainty for institutions, limit their willingness to develop new programs, and ultimately reduce the availability of opportunities for students. This is particularly important for programs designed to serve working learners, where flexibility, speed to market, and alignment with employer needs are critical.

We encourage the Department to focus on developing a clear and sustainable long-term approach to measuring student outcomes, rather than introducing additional interim requirements that may complicate implementation. A streamlined and well-understood framework will better support institutional participation, program innovation, and improved outcomes for students.

 

Value-Added Earnings: Exclusion of Certain Students in the Completer Cohort (§ 690.95(a))

The Presidents Forum supports the Department’s commitment to developing a value-added earnings metric that meaningfully reflects program outcomes while maintaining fairness across diverse student populations. As the Department considers the composition of the completer cohort, we believe it is both appropriate and necessary to exclude students who are actively enrolled in postsecondary education at the time earnings are measured.

This consideration is particularly important for nontraditional students, including working adults and military-connected learners, who often pursue education through incremental, stackable pathways. Workforce Pell programs are designed not only to support immediate employment outcomes, but also to enable continued educational progression through credentials that are transferable and build toward higher levels of degree attainment. As a result, many students will intentionally re-enroll in subsequent programs shortly after completion as part of a planned pathway to career advancement.

For these students, short-term earnings may not accurately reflect the value of the initial program, as they may be balancing employment with continued education or temporarily deferring full labor market participation to complete additional credentials. Including actively enrolled students in the value-added earnings calculation could therefore understate program effectiveness, particularly for programs intentionally designed to support upward mobility through continued learning.

Excluding currently enrolled students is also consistent with the Department’s longstanding approach in other accountability frameworks, including the 2023 Gainful Employment regulations and earnings metrics reported through the College Scorecard. Maintaining this consistency will support clearer interpretation of outcomes and provide a more accurate comparison across programs and institutions.

We recognize the Department’s concern that exclusions may introduce unintended incentives. However, in this context, the risk of distortion is greater if actively enrolled students are included, as doing so may discourage institutions from designing programs that promote continued education and credential progression. Such an outcome would run counter to the goals of Workforce Pell, which emphasizes alignment with workforce needs while supporting long-term economic mobility.

From an administrative perspective, excluding students who are actively enrolled should not create a significantly additional burden. The Department already has access to enrollment data through its existing systems, and applying a consistent exclusion across accountability measures may reduce complexity for institutions by aligning expectations across frameworks.

Accordingly, we recommend that the Department exclude students who are actively enrolled in postsecondary education at the time earnings are measured from the value-added earnings cohort. This approach will better reflect the realities of nontraditional student pathways, support the design of stackable and transferable workforce programs, and ensure that accountability metrics accurately capture both immediate and long-term value for students.

Value-Added Earnings: Process for Combining Multiple Cohorts (§ 690.95(h))

The Presidents Forum recognizes the Department’s goal of ensuring that value-added earnings metrics can be calculated for a broad set of programs, including those with smaller enrollment levels, by combining multiple cohorts to meet minimum sample size thresholds. We support the objective of increasing transparency and consistency in accountability measures while reducing the need for data suppression.

At the same time, as the Department considers the appropriate structure for cohort aggregation, it is important to ensure that the resulting metric remains timely, accurate, and reflective of current program outcomes, particularly for workforce programs that primarily serve nontraditional students, including working adults and military-affiliated learners.

These student populations often engage in education through flexible, iterative pathways that are responsive to changing workforce demands. Programs designed for working learners are frequently updated to reflect employer needs, incorporate new technologies, or align with evolving industry standards. Additionally, many Workforce Pell-eligible programs are intentionally structured as stackable and transferable credentials that encourage re-enrollment and continued skill development over time.

In this context, aggregating earnings outcomes across multiple years may unintentionally blend results from materially different program structures, labor market conditions, and student experiences. Older cohorts may reflect prior versions of a program or different economic environments, which could limit the ability of the metric to accurately capture the value of current program offerings. This may be particularly pronounced for programs serving military-connected students, where mobility, deployment cycles, and transition periods can also influence both enrollment patterns and early earnings outcomes.

We also note that nontraditional students often experience more gradual earnings progression as they balance employment, education, and other responsibilities. As a result, the timing of earnings measurement and the cohorts included can significantly influence how program value is reflected in accountability metrics.

While cohort aggregation can improve statistical reliability, extending the aggregation window too far may reduce the responsiveness of the metric and create misalignment with the pace at which workforce programs evolve. This could, in turn, discourage innovation or delay program improvements if institutions perceive that outcomes will not be reflected in accountability measures for several years.

From an administrative perspective, a clearly defined and limited aggregation approach can help balance the need for sufficient sample size with the importance of maintaining a metric that is understandable and actionable for institutions, students, and policymakers.

Accordingly, we recommend that the Department maintain a reasonable and limited cohort aggregation window of no more than the three most recent award years, avoiding the inclusion of older cohorts that may not reflect current program design or labor market conditions. This approach will support the calculation of stable earnings metrics while preserving their relevance for workforce programs serving nontraditional learners.

We further encourage the Department to consider safeguards or contextual indicators where programs have undergone significant changes, to ensure that accountability measures accurately reflect current performance. A balanced approach to cohort aggregation will better support transparency, program innovation, and the continued development of high-quality, workforce-aligned educational opportunities for working adults and military-affiliated students.

Value-Added Earnings: Programs Serving Out-Of-State Students (§ 690.95(k))

As the Department finalizes its approach to adjusting earnings for geographic differences, it is important that the methodology does not disadvantage programs that serve students across state lines, particularly through distance education.

Many workforce programs are designed to reach students beyond a single state, including working learners who rely on online and hybrid models to access education. These programs play a critical role in expanding access to training aligned with in-demand careers. An approach that applies different earnings adjustments based on the geographic distribution of students may unintentionally penalize these models, even when they produce strong outcomes.

Programs serving a broader, multi-state population should not be evaluated under a framework that places them at a disadvantage relative to programs serving primarily in-state students. Differences in methodology should not result in unequal treatment based on delivery model or student geography.

We encourage the Department to adopt an approach that ensures consistent and equitable evaluation of programs, regardless of whether they serve students locally or across state lines. Maintaining neutrality across delivery models will be important to preserving access, innovation, and student opportunity within Workforce Pell.

 

Sincerely,

Wesley Smith

Executive Director

Presidents Forum

Docket ID ED-2025-SCC-0382

Dear Acting Chief Data Officer Fu,

The Presidents Forum appreciates the opportunity to comment on the Department’s request regarding the Integrated Postsecondary Education Data System (IPEDS) information collection, including the Admissions and Completion Transparency Survey (ACTS). Our member institutions collectively serve more than one-million learners, many of whom are working adults, transfer students, military-affiliated learners, and others who have historically been underserved by traditional enrollment and admissions models.

We share the Department’s commitment to transparency and responsible data modernization. To be effective, however, this collection must align with the operational realities of institutions that serve diverse student populations. Our comments below respond to each of the Department’s five directed questions.

1. Is this collection necessary to the proper functions of the Department?

We agree that clear and comparable admissions and aid information can support the Department’s oversight responsibilities. At the same time, the necessity of the proposed expansion depends on whether ACTS meaningfully distinguishes between selective and open-access institutions.

The current exemption language requiring institutions to admit 100 percent of all applicants does not reflect how open-access admissions operate in practice. Institutions routinely deny applicants for reasons unrelated to selectivity, including federal student-aid eligibility requirements, administrative prerequisites, suspicious enrollment activity, residency constraints, or program-specific criteria. These considerations do not involve evaluating academic achievement factors such as cumulative grades or standardized assessments.

The Department’s 2025–2026 IPEDS screening question takes a more flexible approach by identifying institutions as open admission when they admit virtually all students who have completed a high school diploma or equivalent. Drawing on this framework could help ACTS better reflect how open-access admissions policies operate.

We encourage the Department to consider alternative approaches that better distinguish highly accessible institutions from those employing selective admissions. Options may include definitions that focus on admitting students who meet basic objective eligibility criteria or definitions that rely on admissions thresholds, such as 90 or 95 percent, to reflect high-access institutional missions. Exploring these alternatives would allow ACTS to focus on institutions that use selective admissions practices while avoiding unintended burden for institutions designed to provide broad access.

2. Will this information be processed and used in a timely manner?

Timely processing is unlikely unless implementation is prospective. Many institutions with rolling, year-round, or multi-entry enrollment models do not align with the fall-based admissions structure assumed in ACTS. When the reporting framework does not match institutional operations, timeliness and accuracy are compromised.

Requiring retroactive reporting will further impair timeliness. Institutions cannot recreate historical data in formats that were never collected. Any reconstruction would result in incomplete and unreliable information.

Applying the collection prospectively beginning no earlier than the 2026–2027 cycle would significantly improve timeliness and data quality.

3. Is the estimate of burden accurate?

The estimate of burden does not capture the additional workload required for institutions that serve high numbers of adult, transfer, online, and military-connected learners.

The primary factors increasing burden are:

• The exemption structure, which as currently written captures institutions that are not selective.
• Misalignment between ACTS assumptions and year-round or multi-entry enrollment pathways.
• The need to reconfigure student-information and financial-aid systems on an accelerated timeline.

4. How might the Department enhance the quality, utility, and clarity of the information to be collected?

The clarity and usefulness of ACTS would be strengthened by two adjustments.

Clarify how non-need-based aid should be interpreted

Institutions offer many forms of aid that are not tied to financial need, including merit programs, first-generation scholarships, teacher education or nursing program awards, and substantial aid packages for veterans and service members. Without clear guidance, institutions risk misclassifying these forms of support, which would reduce the consistency and comparability of ACTS data. Clear definitions and examples from the Department would help ensure that institutions categorize these awards accurately.

Align ACTS with modern enrollment patterns

Rolling admissions, high transfer volume, and military and working-adult populations are common across many institutions. A collection that assumes a traditional first-year fall cohort will not produce accurate or comparable data for these students. Clarifying these structural considerations would improve both the quality and utility of the information collected.

5. How might the Department minimize the burden of this collection, including through information technology?

Burden can be reduced in several targeted ways.

Limit reporting to prospective data only

Historical data cannot be reconstructed in a way that meets ACTS standards. Prospective reporting is more accurate, feasible, and consistent with the goals of the collection.

Revisit the exemption criteria

Considering alternative approaches to defining open-access institutions such as focusing on applicants who meet the basis for admission or using thresholds that reflect high-access missions would better align exemptions with institutional practice and reduce unnecessary reporting burden.

Extend the implementation timeline

A timeline beginning no earlier than the 2026–2027 cycle would allow institutions to adapt information systems, update data definitions, coordinate with external vendors, and ensure accurate reporting.

Support technology-enabled reporting

Machine-readable specifications, clear definitions, and alignment with existing systems will promote both accuracy and efficiency.

Conclusion

To ensure that ACTS advances the Department’s goals without unintentionally burdening institutions committed to access, we respectfully recommend that the Department:

• Clarify key definitions including non-need-based aid
• Explore alternative approaches to defining exemptions for access oriented institutions
• Eliminate retroactive reporting
• Align ACTS with year-round and multi-entry enrollment structures
• Extend the implementation timeline
• Provide clear, consistent guidance to support automated reporting

We welcome further dialogue to ensure that federal data systems advance the success of today’s learners.

Sincerely,

Wesley Smith

Executive Director

 

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