Last month the Department hosted two public hearings after announcing their intent to do another round of Negotiated Rulemaking Sessions on Borrower Defense to Repayment and Gainful Employment. At the hearings; students, legal assistance organizations that represent students, institutions of higher education, state agencies, accrediting agencies, representatives from secondary markets, and many membership associations gave suggestions for additional topics and perspectives that should be considered for action by future rulemaking committees in the upcoming negotiated rulemaking sessions.
Meanwhile, public comments, written testimonies and untold numbers of political position papers served as divergent rallying calls from stakeholders of every kind ranging from students, aid administrators, and veterans groups to borrowers, niche associations and dozens of State Senators and Attorneys General.
It seems that everyone has an issue they’re fighting for and sometimes, it can be difficult choose an issue to get behind. Regardless of the title or position you hold, or whether your institution is public, private or proprietary; one thing we can all agree on is that in higher ed students come first. Always.
Without institutions of higher ed, there would be no students. Ask yourself…where would the students go if we were not here? And thus it is easy to begin thinking about the needs of our institutions. However, in doing so, we cannot forget one overriding factor in our search for advocating. Students come first. Always.
So what are the top issues among college leaders? As we often say in the FA office…THAT DEPENDS.
I recently ran two informal polls on Twitter.
The first asked respondents what their top issue was; choosing between Borrower Defense, DACA, Gainful Employment, and Title IX. 67% of participants said Gainful Employment, followed by 17% each for Borrower Defense and DACA. Title IX didn’t get any votes, but the survey was hardly representative.
The second poll surveyed respondents asking which factor they thought was contributing most to the decline in the number of colleges following a report that the number of postsecondary institutions nationwide has declined for four straight years now. Choosing between factors such as Rising Student Debt, Regulation, Lower Enrollment and Rising Costs, 45% cited Regulation. Another 36% cited lower enrollment, with 19% citing Rising Costs. Rising Debt received no votes.
What these surveys tell us is that the hotter the issue, the more people stand up to make their voices heard. You can bet that rising debt and Title IX are extremely important issues that people are advocating for too. And while my polls were mainly for fun and talking points, the takeaway here for us all this summer as we weigh the stakes across higher ed, is that you need to be involved in advocacy.
So what’s the best way to get involved? Here are four tips to help you get started.
Decide which topics are important to you.
In Higher Ed, there is an abundance of causes to support. Choose something that interests you. Are you worried about budget cuts affecting student aid or about equity and access issues? What are you naturally drawn to? That’s probably a great place to start.
NASFAA, the largest postsecondary education association recently released list of priorities for 2017 and beyond which include support for legislation to simplify the FAFSA, improve Consumer Information and strengthen need based aid.
Save Student Aid is a coalition of 85 higher education organizations which includes such members as AACRAO, The College Board, and NACUBO. Save Student Aid is working to do just that – preserve and perhaps expand funding for the students that need it the most.
Volunteer for a committee in the professional associations you belong to.
Finding groups that align with your interests and profession is easy. In my home state of Connecticut, I recently joined the CAPFAA State and Federal Relations Committee. I’m already learning a lot about their advocacy efforts which are driven by the needs and concerns of their members. I’m also a member of several other committees in state and regional associations. It is a great way to explore the issues that are important in your state and an opportunity to get directly involved in supporting state initiatives.
Participate in Public Comments and Negotiations.
In addition to the in-person comments made during the recent public hearings held by ED on GE and BD, more than 1700 written comments were online. Take a cue from Betsy Mayotte at American Student Assistance or Mary Lynn Hammer at Champion College Services to see great examples of professional advocacy in action.
Betsy Mayotte at American Student Assistance provided public comments supporting the Gainful Employment Rules and Borrower Defense to Repayment on behalf of students.
Mary Lyn Hammer submitted testimony seeking relief for more than 6000 students erroneously flung into default as a result of the Department incorrectly calculated cohort default rate data.
Become a Neg-Reg negotiator.
Negotiators are nominated by the public and selected by the Department and nominations are solicited in the Federal Register when the Department announces its intent to establish a committee. But don’t wait for someone to nominate you, go ahead and nominate yourself if you’re so inclined. As Eileen O’Leary, Past NASFAA National Chair and Past MASFAA President said “There is a Superhero inside all of us; we just need the courage to put on the cape”. Got yours?
Not sure where to begin, here’s a great primer that can serve as your point of entry to learning about Higher Ed Negotiated Rulemaking.
Until next month, I hope you have a wonderful summer and a smooth transition “Back to School” this fall. As always feel free to reach out – I always love hearing from you.