Resources

Letter

Comment Letter to the Senate HELP Committee regarding the reauthorization of ESRA

April 19, 2023

CHEPP submitted the following comments to a request for input from the Senate Health, Education, Labor, and Pensions (HELP) Committee regarding its consideration of the reauthorization of the Education Sciences Reform Act (ESRA). To help inform the ESRA reauthorization process, CHEPP’s comments explain how education research can better capture data that is relevant for today’s higher education learners. The letter also asks Congress to use ESRA to improve reporting on innovative practices to better inform higher education policies, as well as improve data collection on college students with disabilities.

Letter

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.

Letter

Public Comment Letter Regarding Improving the Guidance on the Incentive Compensation and Bundled Services

March 16, 2023

CHEPP submitted the following public comment to the U.S. Department of Education as part of its process to improve guidance on the incentive compensation prohibition, particularly with respect to bundled services. Since 2011, higher education institutions have been permitted to use revenue sharing, or paying contracted entities based on per-student enrollment, when those entities provide a bundle of services, including marketing and recruitment. In this letter, CHEPP outlines how to preserve the revenue share model while also ensuring that these relationships are in the best interest of students. CHEPP also provides the Department with reporting and transparency requirements to consider using for these revenue share relationships.

Letter

Public Comment Letter Regarding Public Transparency for Low-Financial-Value Postsecondary Programs

February 10, 2023

CHEPP submitted the following public comment to the U.S. Department of Education’s request for information (RFI) Regarding Public Transparency for Low-Financial-Value Postsecondary Programs. Students pursuing a higher education are changing; they are working, raising children, and financially dependent from their parents. CHEPP agrees that transparency and accountability for programs are essential but believes that the interests of today’s learners must be captured when measuring program value. A single value index would not adequately capture factors like student access and belonging that drive many learners’ decisions when choosing a higher education program. We hope this information is helpful to the Department in developing a new low-financial-value program measure.