To Whom It May Concern:

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

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

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

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

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

Sincerely,

Wesley Smith

Executive Director
Presidents Forum

Dear Acting Under Secretary Bergeron:

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

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

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

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

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

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

Sincerely,

Wesley Smith

Executive Director
Presidents Forum

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

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

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

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

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

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

Sincerely,

The Skills First Coalition

Information Technology Industry Council (ITI) International Paper
LinkedIn
Presidents Forum
Retail Industry Leaders Association (RILA) Salesforce, Inc.
Semiconductor Industry Association (SIA) Society for Human Resource Management
(SHRM)
U.S. Chamber of Commerce

Dear Secretary Cardona,

We write to you today on behalf of the Presidents Forum, which is composed of seventeen non-profit institutions committed to innovation in higher education and representing nearly a million students. The Forum is dedicated to prioritizing student needs and success above all other interests. With this approach and the unique student population we serve, we have become the leading voice for working learners in America.

As institutions that utilize technology and innovation to best serve our students, we emphasize the need for parity in mode and method regulation. As the education environment evolves, the importance for regulatory consistency has become more evident. We are committed to continuously improving student success outcomes for all students. We also are very concerned about the proposed regulations that focus on instructional modality and method rather than on outcomes. These regulations will be counter productive and will lead to accountability for the wrong metrics. 

At the foundation of all of our comments today is our belief that embracing technology and innovation in higher education is radically improving student access and outcomes. Accountability and transparency are necessary components to ensure innovation leads to improved outcomes. Regulators should advance accountability and transparency that is agnostic to modality and reveres student outcomes as paramount. 

Today, we write to apply this paradigm to proposed language contained in the July 23, 2024, Notice of Proposed Rulemaking. In general, we worry these proposed changes are representative of a broader approach to roll back and limit distance learning. Specifically, our comments concern the proposed language contained in §668.41(h), §668.22(b)(3)(ii), and 600.2(1)(iv).

668.41(h): Reporting of student enrollment in distance education or correspondence courses. For each recipient of title IV, HEA assistance at the institution, the institution must report to the Secretary, in accordance with procedures established by the Secretary, the recipient’s enrollment in distance education or correspondence courses.

668.22(b)(3)(ii): An institution must, within 14 days of a student’s last date of attendance, document a student’s withdrawal date determined in accordance with paragraph (b)(1) of this section and maintain the documentation as of the date of the institution’s determination that the student withdrew.

600.2(1)(iv): In distance education, 50 to 60 minutes in a 60-minute period of attendance in a synchronous class, lecture, or recitation, where there is opportunity for direct interaction between the instructor and students. 

In the case of 668.41(h), we understand that distance education courses are regulated under the Higher Education Act, and therefore requiring enrollment reporting is reasonable. Our greater concern is with the usage of this data once collected. It would be inappropriate to use this information to compare the quality of online and in-person learning. This study, published by the Center for Higher Education Policy and Practice, explains the dangers in making such comparisons. In short, “…Online, blended, and in-person delivery are modalities for learning, not proxies for the quality of instruction, pedagogy, and course design.” (Pg. 7)

Our principle of regulatory parity leads us to be extremely concerned about 668.22(b)(3)(ii). While we recognize and appreciate the intention of protecting taxpayer dollars by returning Title IV funds that are not being used appropriately, we believe the proposed rule violates this principle of parity. While many of our institutions have access to data to help identify when engaged distance-learners cease to engage, creating standards that aren’t applied to all modalities is problematic. The proposed carve-out for doctoral candidates further reinforces the perception that the Department treats elements of traditional education differently than online programs. We recommend that all institutions make timely title IV refunds regarding student withdrawals using the best data available to the institution regarding a student’s last date of attendance. 

The concept of attendance is rooted in traditional in-person higher education. Our institutions are the leading forces in using innovation to better meet students where they are, and providing a learning process that works for them. This means that distance learning is more than creating an in-person classroom through video conferencing. In these unique and strategic modalities, the traditional usage of classroom attendance limits learners and diminishes our ability to provide accessible educational opportunities to learners of all backgrounds and at all stages of life. Furthermore, applying attendance as a measure of academic engagement for asynchronous learning and not for synchronous learning is an example of inconsistent regulation of modality. 

Our concerns also involve the proposed definition change included in 600.2(1)(iv), which eliminates asynchronous instruction under the definition of “clock-hour.” Requirements that restrict asynchronous education limit the flexibility that many working learners need in order to be successful. 

The assumption behind the proposed removal of asynchronous education from the definition of “clock-hour” is concerning. Asynchronous education is inherently no less effective than synchronous activities, and students can receive the same (or higher) level and quality of instruction from asynchronous learning opportunities. Again, we urge regulation promulgation that focuses on outcomes, rather than modality. 

The Presidents Forum and Department of Education share the goal of providing quality, effective, and affordable higher education to learners across the country. Our institutions provide an invaluable resource to working and underprivileged learners, and maintain that parity in regulation, transparency, and accountability are necessary to providing the highest quality education to all students. 

Sincerely,

Wesley Smith

Executive Director

Presidents Forum

Presidents Forum, governors unite to help Americans disagree better

SALT LAKE CITY (July 12, 2024)

One big thing

Indiana leaders have armed the nation’s governors with training designed to help Americans disagree better.

Why it matters

Governors have expressed concern about the rising level of vitriol in public and private discourse, including on college campuses.

Utah Governor Spencer Cox made the issue the primary policy initiative of the National Governors Association (NGA), which he chaired for the past year.

“Americans disagree about a lot of things and that’s reasonable, as long as we can debate issues without attacking individuals,” said Governor Cox. “The Presidents Forum has been an incredible partner in collaborating with our governors to create compelling and effective training to help learners develop the skills they need to disagree productively. I know the governors are eager to implement this work in their respective states.”

Go deeper

Ivy Tech Community College President Sue Ellspermann and Purdue Global University Chancellor Frank Dooley joined Becky Takeda-Tinker, president of Colorado State University Global (CSU Global) and Gregory Fowler, president of the University of Maryland Global Campus (UMGC), at the NGA summer meetings in Salt Lake City, Utah to present three state collaborations to create trainings around the NGA’s disagree better initiative.

In collaboration with their home state governors, these institutions are looking to provide the next generation of leaders with the skills and competencies to handle disagreement in a more productive way than it is now handled.

“The governors are showing real leadership by combating the inability to disagree without being disagreeable. It’s a real issue with far-reaching impacts,” said Pres. Ellspermann. “Our training is designed to help students master the skills that will allow them to navigate difficult issues more effectively.”

Dooley sees the training as a key part of building a successful career.

“In today’s workplace, few skills are more critical than the ability to navigate disagreement,” said Dooley. “I believe this and similar courses will address this needed skill development very effectively, with positive impacts for our communities.”

Takeda-Tinker sees higher education as the right place to focus on developing the skills to disagree better. 

“The governors see the growing hostility in public discourse as a significant challenge that hampers their ability to address difficult policy issues,” said President Takeda-Tinker. “Our job was to provide tools that could help address the issue and we agreed that there are skills to help residents and learners of all ages to disagree better and those skills are valuable not only as they build their careers, but in all aspects of their lives.”

Fowler sees the ability to disagree better as essential to professional and personal success. 

“In the modern workplace, the ability to manage disagreements is vital and we need to equip our students with the skills they need to succeed,” said Fowler. “Courses like those we have designed will effectively foster this essential skill, benefiting our communities in numerous ways and I’m grateful for the leadership the governors have shown on this important issue.”

How it works

In Indiana, Ivy Tech and Purdue Global, joined Governor Eric Holcomb’s office, state agencies, and business and community leaders to create a four-week four module course. The course will be delivered as a microcredential and will be piloted in the fall by faculty at both institutions, then students. At the end of the training, students will earn a badge they can add to their Indiana Achievement Wallet. By partnering together and co-teaching the course, this microcredential will be able to reach dual credit, traditional, and working learners. 

In Colorado, CSU Global led the way and collaborated with Governor Jared Polis to create a fully-online, instructor-facilitated course designed to equip learners with healthy conflict styles, tools, and strategies for resolution. The four-module, four-week course available at $175 provides a college credit that can be applied to CSU Global’s undergraduate programs and has garnered positive feedback from course completers. Learner data to-date reflects that prior to the course, 44 percent of students self-reported feeling very uncomfortable or uncomfortable having conversations where they disagreed. After course completion, 100 percent of students self-reported that they felt comfortable or very comfortable having conversations where they disagreed. 

In Maryland, UMGC is working to educate learners, including their military students occupying positions overseas and on the front lines of world stages, to navigate difficult issues and conversations. UMGC has approached Disagree Better as part of a larger redesign process within their institution. They plan to integrate the principles of productive disagreement and concepts into a redesign of their general education curriculum, which is based on an explicit framework of 25 skills across five competency areas. This process will support people in the various contexts of their lives to acquire and deploy these skill sets. 

What’s next?

These trainings will continue to be refined and it is anticipated that this new focus will remain a critical focus of higher education moving forward.

About the Presidents Forum

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