Washington, DC, February 23, 2018 – In response to a request for stakeholder input on the Higher Education Act Reauthorization, Joe May, president of Rebuilding America’s Middle Class (RAMC) and chancellor of the Dallas County Community College District, issued the following letter outlining RAMC’s recommendations.

Dear Chairman Alexander and Ranking Member Murray:

On behalf of Rebuilding America’s Middle Class (RAMC), a coalition of state and individual community college systems from across the nation – representing over 120 colleges and 1.5 million students, I am providing comments on the reauthorization of the Higher Education Act (HEA) as outlined in your February 13, 2018 press release seeking stakeholder input. RAMC appreciates the opportunity to comment on Access and Innovation before the hearing on Reauthorizing the Higher Education Act held on January 25, 2018.

Community colleges have an unparalleled commitment to accessibility, which encourages traditionally underrepresented audiences to pursue a college degree. We serve 45 percent of all first-time freshmen, 40 percent of our students are the first in their family to attend college, and a significant proportion of our nation’s minority undergraduates attend community colleges, including 42 percent of all African American undergraduates, nearly half of all Hispanic undergraduates, and 56 percent of Native American undergraduates. Community colleges have historically existed to make higher education accessible for everyone and match our employers’ need for a large, diverse workforce. Accordingly, we believe that the Federal government needs to make sure that financial aid policies work for nontraditional students who work and have families and are increasingly turning to community colleges for access to higher education.

RAMC members believe that the Pell Grant program is the key to ensuring low-income students can afford college. Community colleges are the most affordable of the many options facing students; yet, even at our institutions, low-income community college students overwhelmingly rely on this critical federal student aid program.

While Title IV was originally designed to encourage the attainment of baccalaureate degrees, current law does not allow for students to receive Title IV benefits unless they are in a program that is at least 600 contact hours in length. Perhaps this was acceptable policy when only a quarter of our population needed a postsecondary credential, it is not acceptable when we have thousands of jobs going unfiled that require less than one year of education, but more than a high school degree. Sixty-five percent of jobs in the workforce require some form of postsecondary education.

The current system keeps students locked into low-wage jobs because they can’t afford to take time off to earn an associate or bachelor’s degree. Therefore, RAMC supports allowing Pell Grants to be used to pay for career and technical education certificates for programs with as few as 150 clock-hours of instruction. Coupled with this focus on short-term certificate acquisitions, RAMC believes the HEA needs to encourage private sector partnerships with our postsecondary institutions. By partnering with employers, we can certify work eligible programs that meet employer’s needs while helping people get hired.

We urge you to consider making the following changes to modernize the Pell grant program and incentivize completion and persistence for all students:

• Encourage colleges to leverage partnerships with employers.

• Allow Pell to be used for short-term training certificates, for example, 150 clock-hours of instruction.

• Extend Pell eligibility to potentially 14 semesters.

Federal programs have a built-in bias towards first- time, full-time residential college experiences. RAMC supports efforts to update and expand the ability of The Integrated Postsecondary Education Data System (IPEDS) and other Federal data programs, and to improve State longitudinal data systems, to be more useful to community colleges and their students.

Policymakers and the stakeholder community need to work to create new performance metrics that make sense for community college populations. This would require not only the development of new data for performance indicators but also the reduction or elimination of data collection that is unnecessary, duplicative, or unused. This would require the rationalization of existing data collection at the State and Federal levels to reduce overall collection efforts and assure usage of common data across governmental units.

Accordingly, we recommend for a reauthorized HEA to:

• Allow for new definitional and instructional language that addresses the unclear existing IPEDS definitions and instructions.

• Allow community colleges to report current dual enrolled students separately in the IPEDS fall enrollment survey.

• Allow community colleges to report current dual enrolled students separately in the IPEDS 12-month enrollment survey.

College and university campuses need to be safe and provide constructive learning environments for our nation’s students. To facilitate this RAMC believes that existing campus sexual assault provisions should be strengthened. With several legislative proposals presently pending before Congress, RAMC Members stand ready to work with you and your staff to ensure that the Higher Education Act facilitates a safe learning experience for our students that recognizes the diversity of physical campus structures throughout our nation.

Community colleges provide an essential pathway for many students to begin what eventually leads to a four-year degree. While our campuses provide the initial learning experience for these students, the recognition of their success is only attributed to the four-year school. In addition, a student that transfer to a four-year school, but never achieves a bachelor degree never benefits from their success at our institutions.

To remedy this shortcoming, RAMC recommends that Congress modify the Higher Education Act and other relevant laws to allow students to be awarded an associate’s degree from the community college they attended when they successfully complete the necessary credits. This would ensure that these students have a marketable degree regardless of whether they complete their four-year education and ensure the contributions of their attendance at a community college are recognized.

Significantly fewer students borrow at a typical community college compared to four-year institutions of higher education. Due to this lower number of borrowers, the mechanism used to calculate cohort default rates is unfair to community colleges who have small numbers of borrowers. If a small portion of these small number of borrowers, default on their loans during the cohort default period, the community college can lose access to Title IV. We urge the Committee to closely examine how a small cohort of borrowers can impact an institution’s Title IV eligibility.

With the last reauthorization of the Higher Education Act, Congress took steps to simplify the FAFSA, and the Administration has since permitted students to electronically pre-populate the FAFSA with their IRS data. Despite these changes, more must be done to make this process easier for low-income students. Additional simplification will help more low-income students enter and remain in college. For example, an even greater improvement would be to require directly using tax return data from a student’s prior year tax return to determine a student’s financial contribution to college costs — in lieu of the data required by the FAFSA.

The current Higher Education Act’s existing policies do not align well with non-traditional partnerships, and ultimately the students pay the cost. As we often discover when attempting to implement innovation solutions for students and employers, both existing policies and regulations make implementation a challenge.

For example, in 2015 the U.S. Department of Education initiated an experimental program designed to accelerate and evaluate innovation through partnerships between colleges and universities and non-traditional providers of education. The goals of EQUIP are straightforward – provide more Americans with the skills, knowledge, and training they need for the jobs of today and tomorrow. This is accomplished by breaking down the silos between organizations that almost never collaborate, despite the fact that they often have a shared mission.

The Dallas County Community College District, a regionally accredited community college system, in partnership with StraighterLine, a non-accredited, non-institutional provider of postsecondary education proposed to the U.S. Department of Education an initiative to work together to improve college access while lowering both the educational delivery cost and the cost to students. The partnership creates a pathway for students to earn an associate degree by taking over 50% of their courses through StraighterLine’s online platform, allowing 600 students the opportunity to receive an Associate in Science in Business or an Associate in Arts in Criminal Justice for little or no out of pocket cost.

However, getting to that point required a multi-step approval process between representatives in the U.S. Department of Education and by the regional office. The process often lead to confusion, making it unclear who was making the decisions. We believe the focus should be on accountability of results, not accountability of processes. Innovative programs like this should include innovative processes – outside of the bureaucratic norm.

We recommend:

• Additional statutory flexibility to allow collaboration among non-institutional providers.

• Prioritize career and technical education certificates and degrees, and provide them the same value as baccalaureate and advanced degrees.

A reauthorized HEA must encourage freedom and flexibility to innovate. The new Higher Education Act must prioritize career and technical education certificates and degrees and provide them the same value as baccalaureate and advanced degrees. Businesses are pleading for higher education to fill their talent pipelines, but they have become frustrated at a system that is too slow and unresponsive. Thank you for your consideration of our comments. RAMC members stand ready and willing to help you in any way we can as the reauthorization process moves forward.

Sincerely,

Joe May

Board Chair, Rebuilding America’s Middle Class (RAMC)

Chancellor, Dallas County Community College Distric