Dr. Monty Sullivan, President of Rebuilding America’s Middle Class (RAMC), a coalition of community colleges, and president of the Louisiana Community and Technical College System, this week issued the following comments on behalf of RAMC expressing concern for the updated requirements and responsibilities for third-party servicers (TPS) and institutions set forth in a recent Dear Colleague Letter from the U.S. Department of Education (ED):

While we are aware of this “multiverse” of vendors on our campuses, the fact remains that many nonprofits and individuals work to help students enroll in and make financial aid decisions about how to attend our institutions and complete their credentials and degrees. ED cannot reasonably expect our colleges to know if an individual high school guidance counselor is providing individualized financial aid advice to students seeking to attend our colleges or if a new nonprofit college access program focuses in on enrollment at one of our campuses. Many community organizations dedicate time, money, and other resources to help many of our students, and oftentimes do so without notifying a college or needing to enter into a formal agreement with our institutions. If our institutions must suddenly become responsible for supplying vendor documentation for auditing purposes and be jointly liable for any violations, this could cause many of these community partnerships to dissolve. It is hard to imagine that is what the Department intends.

Finally, this updated guidance has the potential to jeopardize many of our institutions’ innovative approaches to providing high-quality, educational experiences for our students that ensure students stay in school and are able to complete their credential or degree. Many of our members currently contract with businesses that are owned by foreign entities that use groundbreaking technologies and techniques to provide a range of services to our institutions and students. Under the new third-party servicer guidance, these institutions would no longer be allowed to contract with these entities, reducing in one fell swoop the quality assistance our students have come to expect with no ready replacements.

Sullivan urged ED to rescind this updated guidance and engage in discussions with stakeholders on how to acquire the information sought by the Department, noting that “such an approach would allow the high-quality services provided for our students to continue without jeopardizing effective community relationships.”

To read the letter in full, click here.