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Letter to Wendy Macias regarding the Higher Education Act

Dear Ms. Macias:

On behalf of the National Education Association's (NEA) 3.2 million members, we thank you for the opportunity to submit comments regarding issues under the Higher Education Act to be considered for action by negotiating committees.

The National Education Association has a strong interest in a range of issues relating to the Higher Education Act. We will be submitting under separate cover at the appropriate time a formal request to participate in the negotiated rulemaking, given the importance to our members of the issues outlined below. We would particularly like to be at the table to provide input on provisions that affect our educator members, student members and prospective members.

We also have an interest in working with the Department on issues outside the scope of this rulemaking that impact not only our higher education faculty and student members, but the millions of NEA members personally impacted by higher education issues in their own families or in their role in k-12 education. We have provided some additional detail on some of these issues at the end of these comments.

Issues for Negotiated Rulemaking

Teacher Quality Partnership Grants
We have a strong interest in this new program, which authorizes the Secretary to award competitive five-year grants to partnerships that include a high-need local educational agency, a high-need school or consortium of high-need schools, an institution of higher education, its school of education as well as its school of arts and sciences, and a "public or private educational organization." Of particular interest are the requirements of these new partnerships relative to teacher preparation programs, teaching residency programs, mentoring, induction, the roles of faculty, schools that host clinical experiences, and numerous others.

Collective Bargaining Rights
The law includes a "savings clause" to protect collective bargaining rights under the provisions of Title II. Implementation of this provision is of great interest to NEA.

Adjunct Teacher Corps
A new Adjunct Teacher Corps program is authorized in Title II. The Secretary is authorized to award competitive grants, for not longer than five years, to LEAs or other eligible entities "to identify, recruit, and train qualified individuals with subject matter expertise in mathematics, science, or critical foreign languages to serve as adjunct content specialists." The law stipulates that such specialists are "not the primary providers of instructional services to a student, unless the adjunct content specialist is under the direct supervision of a teacher…" This is a program of great concern to NEA

Preparing General Education Teachers to More Effectively Educate Students with Disabilities
These new five-year, competitive "Teach to Reach" grants would be awarded to eligible partnerships to improve the preparation of general education teacher candidates to ensure that they "possess the knowledge and skills necessary to effectively instruct students with disabilities in general education classrooms."

Graduate Fellowships to Prepare Faculty in High-Need Areas at Colleges of Education
This new program provides competitive grants to institutions to offer graduate fellowships to address current and future faculty shortages in schools of education. Priority is given to the fields of elementary and secondary school mathematics and science, special education, and English language learners.

TEACH Grants
Title IV of HEOA includes changes to the new TEACH Grant program. NEA has concerns regarding provisions that would allow TEACH Grant recipients to teach in the shortage field in which they are prepared, even if that field is no longer a "shortage" or "high need" area once they complete their preparation or service requirement.

Loan Forgiveness
Changes to Title IV include a number of new loan forgiveness benefits for certain public sector employees, school counselors, school librarians, school administrators, teachers and other professionals who choose various arenas of public service. NEA welcomes this relief for these professionals and looks forward to working on behalf of our education workforce members to ensure that implementation fulfills the intent of the new provisions.

Other Issues

We are very pleased with the steps that have been taken to make college more affordable for low- and middle-income families, particularly the increases in the Pell Grant maximum award. However, much more needs to be done to ensure that everyone who wants to can pursue higher education. For example,

  • Restoring the lost purchasing power of the Pell Grant so that students are not overburdened with loan debt;
  • Making student loans more affordable by lowering interest rates, limiting the percentage of income students spend repaying loans, increasing the availability of direct loans, and reinstating the refinancing of existing loans;
  • Retaining and expanding campus-based educational support programs such as TRIO, Upward Bound and Gear-Up to ensure that educationally and financially disadvantaged students have the support they need to succeed in postsecondary education;
  • Providing more federal aid to states to support all higher education institutions - from community and technical colleges to doctoral institutions, encompassing all two and four year institutions.

Teach for America (Title VIII)
NEA has a strong interest in the required study comparing TFA teachers to their colleagues who completed traditional teacher preparation programs. The required study must meet peer review standards of the education research community with reviewers having expertise in a number of areas, including assessment and instruction.

Provisions in the Act aim to ensure that every student in higher education is offered better and timely access to affordable course material, by balancing students' abilities to manage textbook costs through advanced planning with respect for faculty's legitimate academic freedom concerns.

College Partnership Grants
This new program provides financial incentives for institutions and states to develop articulation agreements. This is a prudent investment, assuming these agreements include significant input from educators, and preferable to imposing new regulatory frameworks or mandates in this area.

Transfer of Credit
The law requires that institutions adopt clear policies on credit transfer with the intent of making it easier for students to transfer their credits from institution to institution. NEA supports these as long as the academic validity of the transferred credit is academically appropriate.

Thank you again for the opportunity to comment on these important issues.


Diane Shust, Director of Government Relations

Randall Moody, Manager of Federal Advocacy