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Letter to the Senate HELP Committee Leaders

April 24, 2015

Dear Senators Alexander and Murray,

On behalf of the three million members of the National Education Association and the students they serve, we would like to submit these comments on reauthorization of the Higher Education Act. While we appreciate the opportunity to comment on the white papers on transparency, accreditation, and risk sharing, these issues need to be addressed as well:

  • Making college more affordable. The student debt burden stands at $1 trillion and exceeds total credit card debt. Two out of three students must borrow money to attend college. Many graduate with crushing debt that is also hurting America’s economy—they cannot afford to buy homes or cars, start businesses, support families, invest, or contribute to economic growth in other ways.
  • Improving teacher preparation. To help ensure teachers are profession-ready from the first day they enter the classroom, encourage comprehensive residencies that go beyond traditional student teaching and require teacher candidates to demonstrate that they have the skills and knowledge necessary for effective practice—for example, by completing a classroom-based performance assessment.
  • Recognizing educators as stakeholders. Under traditional principles of shared governance in higher education—principles that NEA advocates—faculty and staff participate in the governance of their institutions. Faculty should have primary responsibility for determining curricula, methods of instruction, and subject matter; establishing requirements for degrees and certificates; reviewing institutional budgets; and making recommendations on financial issues that impact academic programs.
  • Supporting contingent faculty. Contingent faculty have different job titles at different institutions. Regardless of what they are called—adjuncts, lecturers, or instructors—they confront the same reality: low pay, few or no benefits, and little job security. The majority of new faculty hired by colleges and universities are contingent—not tenured or tenure-track—and NEA will continue to fight to ensure they are treated fairly.

We look forward to discussing the full range of issues with you and your staff. Our comments on the white papers follow.


One of the strengths of the American higher education system is its wide variety of institutions. This variety poses challenges with regard to providing clear, accurate, and meaningful data to the public without overwhelming them with numbers. Students and their families deserve useful information. NEA supports efforts to increase the transparency of such information.

Various agencies have already created numerous portals for information on higher education institutions, but prospective college students do not use them as much as they could. While making information easier to find and use is a priority, the relationship between data and educational quality can be problematic. For example, it is widely acknowledged that the current definition of graduation/completion rate is inadequate and that the cohort default rate can be manipulated.

We are also concerned that easily quantified data often takes the place of data that is more useful to students. They deserve to know who teaches their courses and what proportion of institutional spending stays in the classroom. Students should also have a clear picture of their ability to access counseling and advising services.

We agree that the Department of Education should be encouraged to work with other federal agencies like the Bureau of Labor Statistics. The Internal Revenue Service already provides data to prepopulate the Free Application for Federal Student Aid (FAFSA) to help eliminate fraud and abuse. The Treasury Department and the Consumer Financial Protection Bureau also have a role to play in ensuring student loan borrowers are treated fairly.


Although reforms are needed, the peer-driven accreditation process is sound in terms of ensuring educational quality and good stewardship of taxpayer dollars. The different types of accreditation—national, regional, and programmatic—are confusing. We agree that accreditors are often distracted by issues that have little to do with education quality, that accreditation could be risk-adjusted to focus resources on bad actors, and that the meaning of accreditation status needs to be communicated more clearly to students and families.

While we are willing to look at a variety of possible reforms to the system, we do not support doing away with the requirement that institutions must be accredited in order for their students to be eligible for federal financial aid. Without this requirement, fraud and abuse would become a bigger problem than they already are.

Risk Sharing

We accept the white paper’s underlying proposition that too much of the risk in today’s student aid landscape falls on students and families. We also agree that the existing federal student aid “system of choice and competition has worked well, and remains a hallmark of the success of our American higher education system.” In FY 2015 alone, “approximately $138 billion … in the form of grants and loans” helped students attend colleges and universities of their choice.

We take serious exception, however, to the criticism of “generous cost of attendance policies”—i.e., providing aid beyond the cost of tuition, books, and fees. Transportation, room and board, and personal expenses are legitimate costs associated with attending college. For working adults, child care needs to be added to the mix.

We also take exception to the claim that the 90-10 rule is not tenable—for-profit institutions of higher education could raise venture capital or diversify just as other for-profit entities do. The gainful employment requirement, which attempts to do some of what the white paper proposes, should be given time to work. Developing a different approach would be time-consuming and further delay accountability.

Other than giving states and institutions more autonomy, the new approaches proposed in the white paper do not appear promising—for example, holding institutions accountable for students’ success could be an incentive to reduce rather than broaden access to higher education. Seventy percent of those who default on their student loans do not finish their programs of study. To address this problem, we need to invest in academic and other support services—more faculty as well as student advisors.

Where will the money come from? We could do what the countries that have overtaken the United States in post-secondary accomplishment routinely do: invest directly in higher education. The trend is clear: the United States ranks 5th in the percentage of 25-64 year olds with higher education degrees and 14th in the percentage of 25-34 year olds with higher education degrees. One-third of the money spent on higher education in countries that have surpassed us comes from private sources; in the United States, two-thirds of the money spent on higher education comes from private sources. (Source: Education at a Glance 2012: OECD Indicators)

We all agree that access and affordability are key issues in discussions of the reauthorization of the Higher Education Act. NEA’s nationwide campaign, Degrees Not Debt, aims to make higher education accessible to all segments of America’s increasingly diverse student population, including adult learners. We urge Congress to:

  • Help students get their degrees faster by reinstating year-round Pell Grants
  • Allow federal student loans to be refinanced when interest rates decline
  • Expand loan forgiveness programs to cover contingent faculty and encourage careers in teaching, education, and other forms of public service
  • Expand dual enrollment and early college programs to allow more students to earn college credits while still in high school
  • Streamline federal loan repayment plans to create a single income-based option with affordable monthly payments
  • Restore federally subsidized loans for graduate students
  • Permit private student loans to be discharged in bankruptcy
  • Provide incentives for states to reinvest in higher education, not shift costs to students and families
  • Help students begin a pathway to a post-secondary degree by eliminating community college tuition

We look forward to discussing these issues further with you and your staff as reauthorization of the Higher Education Act proceeds.


Mary Kusler 
Director of Government Relations