Scope note: This comparison uses the Senate Armed Services Committee–reported text of S. 4784 and the House Armed Services Committee–reported text of H.R. 8800, both dated June 15, 2026. The House subsequently considered floor amendments.

Executive summary

The Senate bill contains the more significant provisions for institutions serving active-duty students. It would increase the permissible military tuition-assistance rate, establish extensive standards governing institutional participation in Department of Defense education programs, and increase student-loan repayment assistance for members of the Selected Reserve.

The House bill places greater emphasis on specialized defense workforce education, including new graduate programs at the Uniformed Services University, expanded eligibility under the SMART Defense Education Program, and academic credit for certain defense internships.

On housing, the approaches are complementary but distinct. The House bill focuses more directly on Basic Allowance for Housing calculations and barracks oversight, while the Senate bill emphasizes tenant remedies and accountability in privatized military housing.

Comparison

Most consequential issues for higher education

1. Institutional participation protections

The Senate’s institutional-eligibility language is likely the most important issue for colleges enrolling active-duty servicemembers. It would generally require DoW participation decisions to rest on objective, institution-neutral criteria rather than categorical judgments about an institution or its organizational structure. It expressly preserves DoW’s authority to enforce program-wide eligibility standards, funding caps, and other neutral requirements, but excludes for-profit institutions from the bill’s protections.

For nonprofit online institutions and institutions with multiple schools, subsidiaries, or instructional units, this language could provide greater certainty that servicemembers will not lose tuition assistance or other DoW support solely because of the institution they attend.

2. Tuition-assistance modernization

The Senate’s authorization to increase the tuition-assistance ceiling to $350 per semester hour would be a meaningful update. However, the provision does not itself guarantee that every military service will adopt the higher amount. DoW would retain discretion to prescribe implementing regulations and determine the actual benefit level.

The accompanying reporting requirement is also significant because it moves beyond enrollment counts and calls for measures connecting DoW education investments to educational attainment, recruitment and retention, mission readiness, and successful transition to civilian life.

3. Research security compliance

The Senate bill contains substantially more extensive research-security requirements for institutions conducting DoW-funded research. These include a formal DoW Research Security Program, support and training for participating institutions, restrictions involving foreign entities of concern, and potential limits on DoW funding for noncompliant institutions or researchers.

Research universities would need to examine the eventual definitions, waiver standards, institutional due-diligence requirements, and relationship between the NDAA language and existing federal research-security requirements.

4. Workforce pathways

The House bill more clearly advances specialized education-to-workforce pathways. Its SMART Defense Education Program language could make career-focused or alternative educational programs eligible alongside traditional associate, bachelor’s, and advanced degrees, depending on the final statutory wording and implementation. It also facilitates agreements through which students can obtain academic credit for qualifying defense internships.

This approach may create new partnership opportunities for colleges offering cybersecurity, engineering, critical-minerals, logistics, and other defense-relevant programs.

Likely conference issues

The following provisions appear most likely to require substantive House-Senate negotiation:

1. The Senate’s $350 tuition-assistance authority, because the House does not contain a comparable policy change.
2. The Senate’s institutional-participation protections, particularly the exclusion of for-profit institutions and limitations placed on DoW discretion.
3. The Senate’s research-security framework, which may raise institutional compliance, foreign-collaboration, and administrative-burden concerns.
4. The House BAH package, including the lower threshold for extraordinary housing-rate adjustments and treatment of BAH under the basic needs allowance.
5. The House’s specialized workforce and academic-pathway provisions, including SMART eligibility and credit-bearing internships.

Bottom line

For institutions serving active-duty and reserve-component students, the Senate bill is generally more consequential, particularly because of tuition assistance, student-loan repayment, and institutional-participation protections. For institutions engaged in defense research, the Senate bill also presents the greater potential compliance impact.

The House bill offers stronger provisions on BAH adequacy, barracks transparency, and specialized defense workforce pathways. A final conference agreement could combine the House’s housing and workforce provisions with the Senate’s education-benefit and institutional-participation provisions, producing a broader package than either bill currently contains on its own.

Principal sources

• Senate Armed Services Committee filing notice and official S. 4784 text.
• House Armed Services Committee FY 2027 NDAA resources and official reported text of H.R. 8800.
• GovInfo legislative record for the House-reported version.

Chairman Cassidy,

I am writing on behalf of the Presidents Forum to share our perspective on the importance of protecting and strengthening the Pell Grant program as Congress considers its funding and long-term sustainability. Pell Grants are foundational to expanding opportunity for millions of students, including many of the learners our institutions serve.

The Presidents Forum is a nonprofit organization made up of innovative college and university presidents committed to helping more students succeed through accountable innovation in higher education. Our 16 member institutions collectively serve more than one million students, including working adults, veterans, first-generation students, parents, and learners from all walks of life. We are united by a shared commitment to improving student outcomes through innovation in higher education. To learn more about the Presidents Forum, our mission, and our member institutions, visit www.presidentsforum.org.

As Congress considers how to address the current Pell Grant funding shortfall, we encourage you to fully fund the Pell Grant program while preserving the broad access that has made it one of the nation’s most successful investments in students. We also support strong well designed accountability that focuses on the outcomes that matter most to students, including completion, employment, cost, and earnings. Students, policymakers, and taxpayers should be able to see the value that Pell Grants help create.

As Congress intended in passing the bipartisan FAFSA Simplification Act, the updated FAFSA process has helped make financial aid more accessible and is expected to continue to increase the number of students who qualify for and seek Pell Grants. That success should be met with a continued federal commitment to ensuring that every eligible student has access to the support they need to pursue higher education.

As Congress considers options to strengthen the long-term sustainability of the Pell Grant program, we encourage solutions that do not alter summer Pell grant eligibility or award disbursement, or come at the expense of other need-based federal student aid programs that support the financial well-being and success of low-income students. Strengthening Pell should complement, not diminish, the broader federal financial aid system. We encourage Congress to fully fund Pell Grants while preserving the critical need-based supports that help students enroll, persist, and successfully complete their education.

For the students our institutions serve, Pell Grants represent opportunity. They allow individuals to invest in themselves, enroll in programs that lead to meaningful careers, build new skills, increase their lifetime earnings, and create better futures for themselves and their families. We see Pell Grants open doors for working adults returning to school, veterans transitioning into civilian careers, parents seeking greater financial stability, and students who simply need an opportunity to reach their potential.

The Presidents Forum is focused on measurable change in students’ lives. We believe success should be measured by the lift we provide, where students begin versus where they finish, and how education changes their opportunities. We are committed to meeting students where they are, keeping barriers low, and expanding access to high quality education. Pell Grants are one of the most important tools available to make that possible.

Thank you for your continued leadership on behalf of students. We welcome the opportunity to continue this conversation and to share what we are seeing from the learners and institutions we serve. If the Presidents Forum can be a resource as Congress considers the future of the Pell Grant program, we would be pleased to work with you and your staff.

Overview

The Senate’s bipartisan Continuing Resolution (CR), released on August 2, 2026, includes a provision that would temporarily delay implementation of the Office of Management and Budget’s (OMB) proposed revisions to the Uniform Guidance (2 CFR Part 200) through December 11, 2026. If enacted, the provision would preserve the current federal grant management framework while Congress completes appropriations negotiations and OMB continues reviewing public comments on the proposed rule.

The Continuing Resolution must still be reconciled with the House version before a final funding measure can be sent to the President for signature. As negotiations continue, the provision delaying implementation of the Uniform Guidance revisions could be modified, retained, or removed.

Why It Matters

Many Presidents Forum institutions receive federal grants and other forms of federal financial assistance that are governed by the Uniform Guidance. The proposed revisions represent one of the most significant updates to federal grant administration in more than a decade, with potential implications for grant oversight, compliance requirements, and the administration of federal financial assistance across agencies.

If the delay is included in the final appropriations measure, institutions will continue operating under the existing Uniform Guidance through December 11, 2026. This would provide additional time to evaluate the proposed changes, monitor federal guidance, and prepare for any future implementation requirements.

What Institutions Should Monitor

Over the coming months, Presidents Forum institutions should monitor several developments:

• Whether the final Continuing Resolution retains the provision delaying implementation of the Uniform Guidance revisions.
• Any announcements from OMB regarding a revised implementation timeline or changes to the proposed rule following its review of public comments.
• Guidance issued by federal agencies and higher education associations regarding compliance expectations during the delay period.
• Potential operational, compliance, and administrative impacts if the revised Uniform Guidance ultimately takes effect.

Looking Ahead

Until a final appropriations measure is enacted, institutions should continue complying with the current Uniform Guidance requirements. The Presidents Forum will monitor congressional negotiations, OMB rulemaking, and related federal guidance, providing updates as additional information becomes available.

The Department of Education released its final Workforce Pell rule, creating the framework for expanding Pell Grant eligibility to short-term, workforce-aligned programs.

The Presidents Forum submitted comments earlier this year focused on ensuring the rule supports working learners, employer partnerships, innovation, and scalable implementation. We are encouraged to see several important changes reflected in the final rule.

The Presidents Forum represents 17 institutions dedicated to student-centered education and accountable innovation in higher learning. Spanning two-year and four-year colleges and collectively serving approximately 1 million students, the Forum has been an active participant in the Workforce Pell rulemaking process from the start.

Presidents Forum Recommendations

The Presidents Forum encouraged the Department to:

• Preserve Pell as a foundational source of aid rather than effectively shifting it to a “last-dollar” program
• Allow greater flexibility for employer and apprenticeship partnerships
• Create a streamlined and scalable approval process for workforce programs
• Avoid overly complex interim accountability metrics
• Ensure value-added earnings metrics fairly reflect working learners and students continuing their education
• Avoid disadvantaging institutions serving students across multiple states

What changes were made in the final rule?

Several important changes aligned with concerns raised by the Presidents Forum and other stakeholders:

Pell packaging remains largely intact.
The Department clarified that Pell Grants will continue to be packaged as “first-dollar” aid, helping preserve coordination with employer benefits, scholarships, and state aid programs.

Greater flexibility for apprenticeship partnerships.
The Department agreed that Registered Apprenticeship programs should have additional flexibility beyond the proposed 25 percent cap on instruction delivered through written arrangements. This recognizes the important role employers and industry partners play in workforce education.

Currently enrolled students are excluded from value-added earnings calculations.
The Department agreed with concerns that including students who continue into additional education programs could unfairly distort earnings outcomes for institutions serving working learners and stackable credential pathways.

No interim value-added earnings metric.
The Department declined to create an interim earnings metric during the early years of implementation, reducing unnecessary complexity and allowing institutions to focus on long-term student outcomes. At the same time, they will still be included in job placement rate metrics.

What concerns remain?

The final rule also creates significant new approval and oversight responsibilities for governors, states, and the Department itself.

While the addition of bilateral agreements between states may help support multi-state workforce programs, the overall approval structure risks becoming administratively burdensome. Workforce programs are most effective when institutions can respond quickly to employer demand and evolving labor market needs.

Workforce Pell represents a major opportunity to expand access to high-quality, workforce-aligned education for working learners and adult students. The next challenge is implementation. The Presidents Forum will continue to support a higher education system that is student-centered, scalable, and practical.

Frequently Asked Questions

What is the Workforce Pell final rule?

The Workforce Pell final rule, released by the Department of Education on May 18, 2026, establishes the framework for extending Pell Grant eligibility to short term workforce training programs, including programs as short as eight weeks. Previously, Pell Grants were generally limited to programs lasting at least 15 weeks.

The rule takes effect July 1, 2026. Eligible programs must range from 150 to 599 clock hours, lead to a recognized postsecondary credential that can stack into a higher level credential or degree, and prepare students for high skill, high wage, or in demand occupations.

How many students could benefit from Workforce Pell?

The impact could be significant. The Department of Education estimates that approximately 187,000 Pell recipients annually could enroll in eligible workforce programs between fiscal years 2026 and 2035.

These students are largely working adults, career changers, military connected learners, and individuals seeking faster pathways into employment or career advancement. Many previously had limited access to federal financial aid for short term workforce training and often relied on out of pocket funding.

What changed between the proposed rule and the final rule?

Several provisions changed in response to feedback from the Presidents Forum and other stakeholders.

Pell Grants will continue to function as first dollar aid, preserving coordination with employer tuition assistance, scholarships, and state aid programs.

The Department expanded flexibility for Registered Apprenticeship partnerships beyond the originally proposed cap on instruction delivered through written arrangements.

The Department also declined to implement an interim value added earnings metric during the early years of implementation, reducing unnecessary complexity during rollout.

In addition, students who continue their education after completing a workforce program will be excluded from value added earnings calculations, helping ensure institutions are not penalized for creating stackable credential pathways. At the same time, currently enrolled students will still be included in job placement rate calculations, creating an important distinction between the two accountability measures.

What did the Presidents Forum recommend and what was reflected in the final rule?

The Presidents Forum submitted comments focused on four core priorities: preserving Pell as a foundational first dollar aid program, supporting flexibility for employer and apprenticeship partnerships, encouraging a streamlined and scalable approval process, and ensuring accountability metrics fairly reflect working learners and students who continue their education.

The final rule reflects meaningful movement across each of these areas, particularly around earnings metrics, apprenticeship flexibility, and Pell packaging.

What concerns remain about implementation?

The final rule creates significant new approval and oversight responsibilities for governors, states, and the Department itself.

While the addition of bilateral agreements between states may help support multi state workforce programs, the broader approval structure risks becoming administratively burdensome. Workforce programs are most effective when institutions can respond quickly to changing employer demand and labor market needs.

The Presidents Forum will continue engaging with policymakers and stakeholders to support implementation that is clear, student centered, and scalable.

Who is the Presidents Forum?

The Presidents Forum is a coalition of innovative two year and four year colleges and universities committed to advancing student centered education and accountable innovation in higher education.

Forum institutions collectively serve approximately one million learners, including working adults, military connected students, and other nontraditional learners. The organization has been actively engaged in Workforce Pell policy discussions and will continue contributing to implementation conversations as the rule moves forward.

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