Feb. 23, 2018
The Honorable Lamar Alexander
Chair, Committee on Health, Education, Labor and Pensions
455 Dirksen Senate Office Building
Washington, DC 20510
The Honorable Patty Murray
Ranking Member, Committee on Health, Education, Labor and Pensions
154 Russell Senate Office Building
Washington, DC 20510
Re: University of Colorado鈥檚 Principles and Priorities for Reauthorizing the Higher Education Act
Dear Chairman Alexander and Ranking Member Murray:
Thank you for soliciting input from the public as the Senate prepares to reauthorize the Higher Education Act (HEA). On behalf of the University of Colorado (CU), a public research university with multiple campuses serving Colorado, the nation, and the world through high-quality education, research, public service and healthcare delivery, we write to offer several principles and priorities to help inform this effort. We hope you will continue to consider us a partner and a resource as you work on this important reauthorization.
Access and Affordability
CU is dedicated to ensuring that college is accessible and affordable for its students, which is why the university invested over $184 million in institutional aid for students across our four campuses last year. Over the last five years, CU institutional aid has far eclipsed federal grant aid, which totaled $66 million in 2017. In addition, our campuses are piloting innovative programs, such as the 精品SM在线影片 Pact, which includes a four-year tuition guarantee and the elimination of course and program fees. All four campuses are committed to increasing access to online courses and open education resources to decrease costs.
The federal government remains a key partner in our efforts to keep college affordable and we strongly believe that any HEA reauthorization should not only preserve but also strengthen federal student aid programs. We support federal efforts to simplify the federal aid process, improve aid programs, enhance information for students and families, and reduce unnecessary regulatory burden.
Pell Grants
The Pell Grant program is the cornerstone of the federal financial aid system. We support year-round Pell Grants and indexing the maximum Pell Grant award to inflation. We also urge you to consider making all Pell Grant funding mandatory and no longer subject to the annual appropriations process. The vast majority of need-based aid given to CU students is through the Pell Grant program 鈥� nearly $50 million in 2017.
Campus-Based Aid Programs
In addition to Pell Grants, we strongly support campus-based aid programs including Supplemental Educational Opportunity Grants (SEOG) and Federal Work-Study (FWS). Last year, SEOG provided much-needed auxiliary grant aid to nearly 1,500 of CU鈥檚 lowest income undergraduate students, including in nursing programs at our CU Anschutz Medical Campus. FWS empowered nearly 1,900 students with demonstrated financial need to work on CU campuses 鈥� often in areas related to their degree 鈥� to earn money to help with their education expenses. The university also contributes matching funds to these programs 鈥� a 鈥渟kin-in-the-game鈥� requirement that maximizes federal investment. We see value in streamlining federal aid programs and could support a one grant, one loan, one work-study model, as long as the savings from campus-based programs are fully reinvested into aid programs that directly benefit students.
Federal Loan Programs
We support preserving subsidized loans for undergraduate students. More than 15,000 undergraduate students across CU鈥檚 four campuses relied on subsidized loans to help with their education expenses in 2017. Subsidized loans allow students to borrow during their years of study without interest accruing and increasing their overall debt at graduation. The American Council on Education (ACE) estimates that eliminating the in-school interest subsidy for undergraduates would result in the average student paying 45 to 87 percent more interest over a ten-year repayment period.
Congress has already eliminated subsidized loans for graduate and professional students, which is why their continued access to GRAD PLUS and even federal unsubsidized loans is essential. We are deeply concerned by the erosion of federal support for our graduate and professional students 鈥� and urge that this not continue. Last year, PLUS loans offered CU graduate students access to an additional $50 million to help pay for school 鈥� $28.5 million of which was disbursed to graduate students in the biomedical and health sciences at our CU Anschutz Medical Campus. We urge policymakers to maintain these essential graduate student loan options, as well as strong repayment terms, income-based repayment programs, and access to Public Service Loan Forgiveness (PSLF). A reduction of PSLF benefits would disproportionately harm underserved rural, urban, and tribal communities in Colorado and across the nation. We also support Congress鈥� efforts to eliminate origination fees for both student and parent loans.
FAFSA Simplification
We support efforts to simplify the federal aid process including the Free Application for Federal Student Aid (FAFSA), which will make it easier for low-income and first-generation students to apply for federal aid. We also support simplifying the FAFSA verification process and eliminating FAFSA questions that have no bearing on assessing student financial need. We recommend Congress evaluate expanding the IRS Data Retrieval Tool to overcome current data limitations, which necessitate that schools ask students for additional documentation 鈥� obfuscating rather than streamlining the aid application process.
Data and Transparency
CU believes Congress should ensure that the data collected by the federal government are useful, consistent across other federally mandated reporting requirements, and provide accurate and timely information to students, families, and policymakers in their decision-making processes.
We urge Congress to review and cautiously consider any methods for evaluating universities based on their students鈥� performance. We support efforts to reform how the federal government tracks university graduation rates, which currently only include 鈥渇irst-time, full-time鈥� students and fail to capture a large number of existing full-time, part-time, and transfer students enrolled at public colleges and universities across the country, including CU. Over half of CU Denver鈥檚 undergraduates are transfer students. Without access to accurate data, students and parents lack important information they need to be wise consumers of higher education. The Student Achievement Measure (SAM) initiative, which includes over 600 institutions including CU鈥檚 campuses, is a preferable replacement for the current federal graduation rate.
Furthermore, evaluating individual academic programs as a measure of the entire institution may hinder program development and educational innovation. For instance, how would a dual program between two different colleges be treated, particularly in light of student desires for interdisciplinary learning? Will these proposals create a disincentive to the marketplace creating new programs to meet the rapidly evolving demands of the 21st century?
In addition, we believe that a three-year timeline for requiring some repayment of loans as a measure of Title IV eligibility is problematic and a disincentive to graduates moving into particular areas of need. For example, the three-year timeline arbitrarily punishes institutions whose students go on to join a longer graduate program, the military, or the Peace Corps. 精品SM在线影片 ranks No. 11 in the nation for graduates serving as Peace Corps volunteers.
We also encourage Congress to provide institutional flexibility for creating online net-price calculators. Current federal requirements are not consumer friendly and the federally mandated net price calculator is underutilized by students compared to our own institutional aid calculator. We also recommend reducing the number and specificity of student consumer information disclosures, which are burdensome and frequently ignored by our students.
Reduce Unnecessary Regulation
At CU, we take our responsibility as a steward of federal resources seriously and we make every effort to keep tuition affordable for students and families. Over the last decade, we鈥檝e streamlined and improved our business practices to increase efficiencies. As a result, CU鈥檚 administrative overhead is now more than 20 percent below the national peer average 鈥� savings that we pass on to our students through lower tuition and better support services.
We urge Congress to implement the recommendations from the Task Force on Federal Regulation of Higher Education, which CU President Bruce Benson served on at the request of Senator Michael Bennet, and which reflects CU input and priorities. The Task Force鈥檚 2015 report 鈥淩ecalibrating Regulation of Colleges and Universities鈥� identifies more than 50 Department of Education (ED) regulations, which are duplicative, ambiguous, contradictory or costly 鈥� and some of which are unrelated to the university鈥檚 core missions of education, research and public service.
We also caution against implementing a one-size fits all regulatory approach for higher education institutions. We support flexibility within the accreditation and financial aid processes to encourage institutions to try innovative programs in response to rapidly changing market demands and workforce needs. We hope Congress will encourage federal agencies, including ED, to limit guidance issued outside of the Negotiated Rulemaking Process, including sub-regulatory guidance and Dear Colleague
Letters, which infringe on institutional flexibility and make it more challenging for schools to fulfill essential work, including awarding aid to deserving students. Research from the National Association of Student Financial Aid Administrators shows that increasingly complex federal regulations have diminished the amount of time universities have to provide essential support services to students such as face-to-face counseling, outreach efforts, time spent with target populations and loan counseling.
Finally, we hope Congress will carefully consider risk-sharing proposals. We are concerned that risksharing models will benefit schools with wealthier students and limit access to higher education by discouraging institutions from enrolling low-income and first-generation students. We are also opposed to schools taking on risk-sharing for student loan collection and repayment until there is some evidence that federal loan servicers are operating efficiently.
We want to express our appreciation for this opportunity to offer input on the reauthorization of the Higher Education Act. Please do not hesitate to contact us to discuss our comments on this important set of issues, which impact students, families, the workforce pipeline and the U.S. economy.
Sincerely,
Philip DiStefano, Chancellor
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Dorothy Horrell, Chancellor
University of Colorado Denver
Venkat Reddy, Chancellor
University of Colorado Colorado Springs
Donald Elliman
University of Colorado Anschutz Medical Campus