PEER Center Comments: Regulations to Implement the Reconciliation Law
The PEER Center submitted comments on the Department of Education’s recent initiation of a rulemaking process to implement changes made to higher education policy through P.L. 119-21 (OBBBA). Our comments are briefly described below, and attached.
Transparency and Accountability
As the Department works to implement the accountability framework in OBBBA, we urged it to also consider important complements to those rules. Most importantly, we urged that the Department maintain strong regulations for both financial value transparency and gainful employment.
As the Department prepares draft regulations to implement the reconciliation law’s “do no harm” accountability framework, we make several recommendations in areas that will be especially important to consider:
Improve Field-of-Study Groupings for Earnings Threshold for Graduate Programs
Minimize the Education Department’s Administrative Burden in Appeals and Reinstatement Processes
Maintain Strong Requirements for Transparency
We also urge the Department to release existing FVT/GE data in advance of the rulemaking.
Workforce Pell
We provide several recommendations for implementing the federal requirements within the new provision extending Pell Grants to very-short-term programs that can meet certain state and federal requirements. These include:
Assess Eligibility for Workforce Pell Prior to Extending Federal Dollars to Programs
Ensure Accurate, High-Quality Data in Assessing Pell Grant Eligibility
Provide Transparency Into the Outcomes and Offerings of Workforce Pell Programs
Loan Repayment
The reconciliation law included a variety of changes to student loan repayment. The changes to income-driven repayment in particular will help many low-balance borrowers become debt-free sooner. However, higher payments and a longer time to forgiveness for many of the very lowest-income borrowers are likely to increase defaults among those borrowers. As the Department implements changes to student loan repayment, we encourage policymakers to consider the details that will help to smooth implementation for borrowers, and particularly for the lowest-income borrowers. These include:
Limit Administrative Burden for Students Wherever Possible
Provide Clarity to Borrowers About How They Can Access the Repayment Plans for Which They Are Eligible
Loan Limits
The reconciliation law establishes new limits for graduate student borrowers, and the impacts of these changes will be significant for the field. While we agree that some limits were sorely needed, particularly for certain fields with a lower return on investment, the Department should anticipate significant challenges as institutions respond and borrowers adapt to the new environment. We urge the Department to:
Develop a Careful, Data-Driven Approach to Defining Graduate Programs and Professional Programs
