Public Comment Letter Regarding the Confidentiality and Disclosure of State Unemployment Compensation (UC) Information
September 22, 2023
CHEPP submitted the following public comment to the US Department of Labor’s Request for Information (RFI) Federal-State Unemployment Compensation (UC) Program; Confidentiality and Disclosure of State UC Information. Specifically, this comment answers the questions regarding access and use of UC data by private, postsecondary institutions of higher education. CHEPP supports institutions of higher education having access to UC data to help inform academic program development, improvement, and closure. Access to this data would also help inform students’ decisions regarding degree pathways and economic outcomes for different careers, as well as improve higher education institutions’ understanding of program outcomes by region, informing student academic and career advising.
Comment Letter to the Senate HELP Committee regarding the reauthorization of ESRA
Public Comment Letter Regarding the Requirements and Responsibilities of Third-Party Servicers (TPS)
March 30, 2023
CHEPP submitted the following public comment to the U.S. Department of Education on the requirements and responsibilities of third-party servicers (TPS). In February 2023, the Department released updated guidance on TPS that greatly expanded the number of higher education institution contracts that are considered a TPS entity. TPS previously only applied to contractors directly administering Title IV dollars, not the administration of Title-IV eligible programs. CHEPP’s letter outlines considerations the Department should make in implementing this expansion, such as whether this gives more contractors heightened access to student data and how to handle when current contractors do not comply with the new guidance.
Public Comment Letter Regarding Improving the Guidance on the Incentive Compensation and Bundled Services