Regulations
In addition to advocating for full implementation of the gainful employment rule, borrower defense rule, and 90/10 rule, the coalition supports a broader set of regulations that strengthen protections for students’ investments in higher education and taxpayers’ contributions to federal financial aid programs. In recent years, we have supported the Education Department’s efforts to update regulations including those on accreditation, distance education, state authorization, administrative capability, financial responsibility, and cash management. Following Congress’ restoration of Pell Grant eligibility for incarcerated students, we also support the Department’s full implementation of prison education program regulations oriented toward ensuring the quality of programs regardless of setting.
In July 2025, the Education Department announced its intent to establish two negotiated rulemaking committees, one of which will consider changes to higher education accountability issues. The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee will focus on policy changes related to some of the coalition’s priorities, including:
- Amending Financial Value Transparency and Gainful Employment regulations
- Establishing of a minimum earnings requirement for all degree programs
- Defining accountability standards for a new Workforce Pell Grant available to very short-term programs lasting 8-15 weeks
Throughout the negotiated rulemaking process, we will urge the Department to develop regulations that protect student borrowers from low-quality, predatory programs that leave them with burdensome debt and meager earnings and safeguard taxpayer investments in federal financial aid.
Coalition members also share concerns about the quality of programs facilitated by online program managers (OPMs) and the potential problematic revenue-sharing relationships between OPMs and institutions of higher education. Through white labeling of college courses, third-party OPMs can offer pre-packaged content to students who otherwise believe they are enrolling in programs designed and facilitated by well-recognized institutions under their branding. Persistent concerns about low-quality instruction in these online courses that are tied to their institutions in name only has led to legal action against some institutions that partner with OPMs. We advocate for federal action to rein in these problematic behaviors, including by rescinding a longstanding loophole that enables OPMs to skirt federal law against incentive-based recruitment that encourages companies to drive up enrollment in online courses without regard to program quality.