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1 U . S . DEPARTMENT OF EDUCATION

2 O F F I C E OF POSTSECONDARY EDUCATION

5 P U B LIC REGIONAL HEARING FOR

6 NEGOTIATED RULEMAKING

9 U . S . Department of Education

10 FB-6 Auditorium

11 4 00 Maryland Avenue, SW

12 Washington, D.C. 20202

13 W e d nesday, November 8, 2006

14 9:00 A.M. – 4:00 P.M.

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1 U.S. Department of Education

2 Public Hearing
3 Washington, D.C. – November 8, 2006
4 Panelist
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7Representing the Office of Postsecondary Education:
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9David Bergeron
10Director, Policy and Budget Development Staff
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12Dan Madzelan
13Director, Forecasting and Policy Analysis Staff
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16Representing the Office of General Counsel:
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18Lisa Kanter
19General Attorney
20Division of Regulatory Services
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1 P R O C E E D I N G S1

2 1 D A V I D B E R G ERON: Good morning. I am

3t r y i n g t o g e t t h e s e things started, and I always

4s t a r t a m i n u t e b e f o re it is time for us to really

5b e g i n t h e h e a r i n g . I do that because I know it

6a l w a y s t a k e s a b o u t a minute for folks to get

7o r g a n i z e d a n d r e a d y to start these proceedings.

8 T h i s i s o u r fourth in a series of regional

9h e a r i n g s i n p r e p a r a tion for negotiated rulemaking.

10W e h a v e b e e n f o r t u n ate at our hearings at Berkeley

11a n d C h i c a g o t o b e h osted by institutions of higher

12e d u c a t i o n , U n i v e r s i ty of California at Berkeley and

13L o y o l a U n i v e r s i t y o f Chicago. Those were very good

14h e a r i n g s , v e r y p r o d uctive hearings, and we are very

15p l e a s e d t h a t t h e y w ent as well as they did.

16 W e h a d o u r third hearing in Orlando as

17p a r t o f t h e F e d e r a l Student Aid’s Fall Conference,

18s o w e d i d h a v e t h a t last week. We had a number of

19w i t n e s s e s a t t h a t h earing that had been part of the

20c o n f e r e n c e , s o t h e y brought things that they heard

21a n d c o n c e r n s t h a t t hey had, as a result of what

22t h e y h e a r d , t o u s , that was also very productive.

23O n e o f t h e t h i n g s t hat has been striking as we have

24g o n e a r o u n d a n d h a d these hearings is the

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1r e m a r k a b l e s t u d e n t s who have testified for us on

2i s s u e s o f c o n c e r n t o them, and I am sure, during

3t h e c o u r s e o f t h e d ay, we will hear from more

4s t u d e n t s , a n d I t h i nk you will be as impressed as I

5h a v e b e e n - - t h e i r r e marks at each of these hearings.

6 L e t m e i n t r oduce the people who are

7s i t t i n g u p h e r e , a n d, during the course of the day,

8f o l k s m a y c h a n g e . Lisa Kantor is with our Office

9o f G e n e r a l C o u n s e l , and she will be with us, and

10o t h e r s m a y j o i n u s during the day from the Office

11o f G e n e r a l C o u n s e l as their schedules permit.

12 D a n M a d z e l a n, you all know, because I

13t h i n k a n y b o d y w h o h as been around negotiated

14r u l e m a k i n g k n o w s t h at he is our federal negotiator

15p a r e x c e l l e n c e , e x c ept for one little thing: His

16s e s s i o n s t e n d t o g o long. I have a feeling that

17w i l l b e a n i n d i c a t o r of the day, because we have

18m a n y f o l k s s c h e d u l e d to speak, which is why I want

19t o t r y t o g e t d o n e with this introductory stuff

20v e r y q u i c k l y . D a n is the Director of Forecasting

21a n d P o l i c y A n a l y s i s in the Office of Postsecondary

22E d u c a t i o n w h e r e I a m his colleague and peer.

23 I a m D a v i d Bergeron. I am Director of

24P o l i c y a n d B u d g e t D evelopment in the Office of

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1P o s t s e c o n d a r y E d u c a tion.

2 T h i s i s , a s you all know, the Department’s

3h e a d q u a r t e r s b u i l d i ng, and I don’t work here. I

4w o r k a c r o s s t o w n a t K Street, and so I had to go

5e x p l o r i n g b e c a u s e I knew one thing everyone needs

6t o k n o w w h e n t h e y c ome to a building they are not

7f a m i l i a r w i t h , a n d that is where the restrooms are,

8a n d t h e y a r e t h a t w ay--the men’s room is on the

9r i g h t s i d e ; t h e l a d ies room is on the left--and I

10t h i n k t h a t i s a l l o f those logistical things.

11 L e t m e t a l k a little about negotiated

12r u l e m a k i n g a n d t h e process we are engaged in.

13W h i l e d o i n g t h e p u b lic hearings, we are still

14a c c e p t i n g p u b l i c c o mment in written form through

15t o m o r r o w . A t t h e s ame time, we are accepting

16n o m i n e e s f o r f e d e r a l negotiators for that process.

17O n c e w e g e t a l l o f the public comments and get the

18n o m i n e e s , w e w i l l d o two things, we will develop a

19n e g o t i a t i n g a g e n d a that takes into account the

20p u b l i c c o m m e n t w e r eceived and allows us to

21i d e n t i f y i s s u e s t h a t we believe we can reach

22a g r e e m e n t o n , a n d n egotiate through to notice of

23p r o p o s e d r u l e m a k i n g early next year.

24 O u r p l a n r i ght now is to begin

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1n e g o t i a t i o n s i n m i d -December, have about a six-week

2b r e a k b e t w e e n t h e f irst and second negotiating

3s e s s i o n s , a l i t t l e longer than we have typically

4d o n e , a n d r e a l l y t r y to get this process a little

5b i t e a r l i e r o n o u r schedule than we have had in

6r e c e n t y e a r s . A s I said, this process is really

7g o i n g t o b e d r i v e n by the public comment that we

8r e c e i v e d , a n d w i l l receive, today and tomorrow.

9 S o w e w i l l be taking very seriously the

10c o n c e r n s t h a t f o l k s have expressed about our

11r e g u l a t i o n s a n d t h e things we need to change, and

12w e w i l l d o t h a t . T he only thing, going in, we knew

13w e w o u l d f i r s t b e d oing for certain and absolutely

14w a s t o n e g o t i a t e a r ound Academic Competitiveness

15a n d N a t i o n a l S M A R T Grants, and these--we knew that

16t h o s e t w o n e w p r o g r ams really did impact and

17i n f l u e n c e o u r c h a n g e of direction of our programs

18i n w a y s t h a t a r e f u ndamentally different from what

19w e h a v e d o n e b e f o r e , and really did warrant

20n e g o t i a t e d r u l e m a k i ng, even though we will have

21o p e r a t e d t h e p r o g r a ms first under interim final

22r u l e , a n d t h e n a f i nal regulation that we issued

23m o s t r e c e n t l y - - t h e final regulation on November 1 s t .

24 I s t h a t a l l of the introductory things

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1t h a t I n e e d e d t o s a y?

2 D A N M A D Z E L A N: We just have to remind

3t h e m - -

4 D A V I D B E R G E RON: Yes.

5 D a n n y r e m i n ded me that, as you come

6f o r w a r d , i f y o u c o u ld identify yourself and state

7y o u r n a m e a n d y o u r organization so that the

8r e c o r d e r c a n h a v e t hat information and make sure

9t h a t i t i s c o r r e c t in the record. She is going to

10w o r k f r o m o u r l i s t . If necessary, if you are

11r u n n i n g t o o l o n g , w e will hold up a stop sign.

12 [Laughter.]

13 D A V I D B E R G E RON: We have not had to use

14t h e s t o p s i g n i n o u r other three hearings; I hope

15a n d e x p e c t t h a t w e will not today. We will keep

16t r a c k o f t i m e , a n d we will try to keep the

17w i t n e s s e s t o f i v e m inutes. Sometimes we run a

18l i t t l e l o n g , b u t w h at we have experienced,

19p a r t i c u l a r l y w h e n w e have students testify, or

20p e o p l e w h o a r e j u s t nervous to speak in public like

21I a m , t h e y t e n d t o speak faster than normal and

22t h e y g e t d o n e m o r e quickly. One of the benefits of

23t h a t i s t h a t w e w i l l bring in students throughout

24t h e d a y t h a t m a y b e were not scheduled first thing

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1i n t h e m o r n i n g b e c a use their schedules did not

2a l l o w t h e m t o d o t h at. So we will be flexible to

3a c c o m m o d a t e t h o s e a nd try to stay on time.

4 W i t h t h a t , we will start.

5 D A V I D B E R G E RON: Jean Morse, the

6m i c r o p h o n e i s b e h i n d you.

7 JEAN MORSE: Good morning.

8 D A V I D B E R G E RON: Good morning.

9 JEAN MORSE: I am Jean Morse, and I serve

10a s P r e s i d e n t o f t h e Middle States Commission on

11H i g h e r E d u c a t i o n , a regional accreditation body

12s e r v i n g o v e r 5 0 0 i n stitutions in the Middle

13A t l a n t i c r e g i o n o f the United States and the

14C a r i b b e a n . I a l s o appear today as the Vice Chair

15o f t h e C o u n c i l o f R egional Accrediting Commissions,

16k n o w a s C - R A C , t h a t is composed of all of the

17r e g i o n a l h i g h e r e d u cation accrediting commissions

18i n t h e U n i t e d S t a t e s.

19 M y r e m a r k s are meant to compliment those

20o f m y c o l l e a g u e s i n C-RAC who have testified at

21p r i o r h e a r i n g s h e l d in their regions. Thank you

22f o r t h e o p p o r t u n i t y to participate in the

23c o n s i d e r a t i o n o f n e w regulations that will affect

24t h e s e v e n r e g i o n a l accreditors, their 3,000 member

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1i n s t i t u t i o n s , a n d t he 17 million students served by

2t h o s e i n s t i t u t i o n s .

3 C - R A C s u p p o rts many of the constructive

4s u g g e s t i o n s i n t h e report by the Commission on the

5F u t u r e o f H i g h e r E d ucation convened by the

6S e c r e t a r y o f t h e U . S. Department of Education. Our

7p o s i t i o n i s o u t l i n e d in responses to the

8C o m m i s s i o n ’ s d r a f t reports, and messages to our

9m e m b e r s , a l l o f w h i ch are posted on our Web sites.

10 T h e f o l l o w i ng additional five comments

11a d d r e s s t h e n e w r e g ulations that might affect

12a c c r e d i t a t i o n , a n d the first relates to timing.

13 A l t h o u g h C - RAC welcomes improvements,

14c e r t a i n l y , o f t h e r egulations that implement the

15H i g h e r E d u c a t i o n A c t of 1965, it supports waiting

16t o a d o p t n e w r e g u l a tions until Congress has

17c o m p l e t e d t h e r e q u i red reauthorization of the

18H i g h e r E d u c a t i o n A c t. C-RAC has worked with

19c o n g r e s s i o n a l r e p r e sentatives on reauthorization,

20a n d w e w i l l c o n t i n u e to do so. Reauthorization

21s h o u l d c l a r i f y c o n g ressional requirements, and

22t h o s e r e q u i r e m e n t s may require different

23r e g u l a t i o n s f r o m t h ose which might be under

24c o n s i d e r a t i o n n o w .

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1 A s e x p l a i n e d in a prior hearing by my

2c o l l e a g u e , D r . C r o w , it is really difficult for our

3i n s t i t u t i o n s t o i m p lement frequent changes in

4d i r e c t i o n . I t i s a n evaluation process that is

5c o n t i n u o u s t h a t s t a rted way in advance, and it is

6v e r y h a r d t o c h a n g e in midstream.

7 T h e s e c o n d point has to do with

8t r a n s i t i o n s t o n e w regulations. Again, C-RAC

9p r o m o t e s c o n t i n u o u s changes and improvements in

10p r a c t i c e s m a n d a t e d by the Department’s regulations,

11b u t w e s u p p o r t t h e use of pilot projects to test

12t h e u s e f u l n e s s o f n ew approaches. We also support

13g r a d u a l a n d c a r e f u l transitions. All of the C-RAC

14r e g i o n a l a c c r e d i t o r s and their member institutions

15a r e a l r e a d y i n t h e midst of major initiatives to

16d e f i n e a n d a s s e s s s tudent learning and, just as

17i m p o r t a n t l y , t o d o so in a manner that is supported

18b y f a c u l t y a n d s t u d ents and that produces

19i n f o r m a t i o n t h a t c a n be used for continuous

20i m p r o v e m e n t . W e r e commend that regulatory

21i n i t i a t i v e s s u p p o r t shared goals of improving

22s t u d e n t l e a r n i n g w i thout derailing the important

23w o r k o f r e g i o n a l a c creditors to improve student

24l e a r n i n g t h a t i s a l ready under way. There is a lot

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1o f w o r k g o i n g o n i n campuses now, and we want the

2t r a n s i t i o n t o t a k e that into account.

3 T h e t h i r d p oint had to do with current

4r e g u l a t i o n s . T h e r eport by the Commission on the

5F u t u r e o f H i g h e r E d ucation criticizes processes

6t h a t s t i f l e i n n o v a t ion, emphasize inputs and

7p r o c e s s e s o v e r o u t c omes, and impose unnecessary and

8t i m e - c o n s u m i n g b u r d ens. C-RAC regional accreditors

9h a v e a l l a d o p t e d n e w standards that promote the

10p r i m a r y i m p o r t a n c e of learning outcomes over

11p r o c e s s e s . I w o u l d like to emphasize that, because

12I a m n o t s u r e t h a t has been clear in some of the

13d i s c u s s i o n t h a t i s going on. We are very much

14c o m m i t t e d t o e m p h a s izing learning outcomes.

15H o w e v e r , w e d o b e l i eve in the continuing value of

16e n s u r i n g t h e p u b l i c of the ability of accredited

17i n s t i t u t i o n s t o c o n tinue to provide promised

18r e s u l t s b y r e v i e w i n g certain resources and

19p r o c e s s e s .

20 W e h a v e m a n y ideas to improve our

21p r o c e s s e s . I n c r e a s ing the flexibility of the

22D e p a r t m e n t ’ s r e g u l a tions would aid us considerably

23i n t h e s e i n i t i a t i v e s. Many of those regulations

24c o n s t r i c t u s , i n t e rms of the kinds of processes

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1a n d i n p u t s t h a t w e must require of our institutions

2a n d t h a t a r e r e q u i r ed of us. We will welcome the

3o p p o r t u n i t y t o w o r k with the Department to identify

4r e g u l a t i o n s t h a t g o vern those inputs and processes

5o f a c c r e d i t o r s a n d , indirectly, those of accredited

6i n s t i t u t i o n s . W e t hink that could go far to

7i m p l e m e n t i n g s o m e o f the suggestions in the

8S p e l l i n g s R e p o r t .

9 T h e f o u r t h point has to do with

10t r a n s p a r e n c y . A g a i n, C-RAC supports current

11i n i t i a t i v e s u n d e r c onsideration by the Department

12t o r e d u c e a n d r e v i s e the data it collects from

13a c c r e d i t e d i n s t i t u t ions so that results can be

14p u b l i c i z e d i n a m a n ner that is useful to the

15p u b l i c , t o i n s t i t u t ions, and to policymakers. C-

16R A C w e l c o m e s t h e o p portunity to work with the

17D e p a r t m e n t t o c l a r i fy what types of data are

18p r a c t i c a l a n d u s e f u l, and to consider what

19p r o c e s s e s w o u l d r e s pect the needs of students, the

20d i v e r s i t y o f i n s t i t utions, and the role of

21a c c r e d i t a t i o n i n h e lping institutions to improve

22t h r o u g h p e e r r e v i e w , that is a balancing act.

23 F i n a l l y , t h ere has been concern expressed

24a b o u t t h e r e g i o n a l nature of institutional

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1a c c r e d i t a t i o n . T h r ough C-RAC, all of the U.S.

2r e g i o n a l a c c r e d i t o r s have spoken with a single

3v o i c e t h r o u g h o u t t h e process of reauthorization of

4t h e H i g h e r E d u c a t i o n Act, and the deliberations of

5t h e F u t u r e s C o m m i s s ion. We wish to assure the

6D e p a r t m e n t o f o u r c ontinuing ability to implement

7c h a n g e s c o n s i s t e n t l y across the country, as we have

8a l r e a d y d o n e w i t h r espect to policies and practices

9c r e a t e d b y C - R A C , a nd adopted by all of its

10m e m b e r s .

11 T h a n k y o u a gain for the opportunity to

12o f f e r c o m m e n t s .

13 D A V I D B E R G E RON: Thank you.

14 D A V I D B E R G E RON: Barbara Briltingham.

15 B A R B A R A B R I LTINGHAM: Good morning.

16 D A V I D B E R G E RON: Good morning.

17 B A R B A R A B R I LTINGHAM: My name is Barbara

18B r i l t i n g h a m , a n d I serve as Director of the

19C o m m i s s i o n o n I n s t i tutions of Higher Education of

20t h e N e w E n g l a n d A s s ociation of Schools and

21C o l l e g e s , a l s o r e f e rred to as NEASC.

22 T h e C o m m i s s ion is the regional accrediting

23b o d y f o r 2 2 6 c o l l e g es and universities in the six

24N e w E n g l a n d s t a t e s .

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1 I a p p e a r t o day on behalf of the Council of

2R e g i o n a l A c c r e d i t i n g Commissions, known as C-RAC,

3a n d I o f f e r t h e s e c omments to complement those of

4m y c o l l e a g u e s , D r . Barbara Beno, Chair of C-RAC;

5D r . S t e v e n C r o w , p a st Chair of C-RAC; Dr. Belle

6W h e e l a n , w h o h e a d s the Commission for the Southern

7A s s o c i a t i o n o f C o l l eges and Schools, all of whom

8h a v e p r e v i o u s l y t e s tified at regional hearings; and

9J e a n M o r s e , f r o m w h om you just heard.

10 T h a n k y o u f or this opportunity to talk

11a b o u t i s s u e s i m p o r t ant to the Department of

12E d u c a t i o n a n d t o C - RAC.

13 M y c o m m e n t s today reflect my experiences

14w i t h a c c r e d i t a t i o n . Before joining the staff at

15N E A S C , I s e r v e d a s a team chair, or member, for

16f i v e o f t h e s e v e n r egional accrediting commissions,

17a n d o n t h e b o a r d o f five national accreditation-

18r e l a t e d o r g a n i z a t i o ns, including CHEA. And also,

19b e f o r e j o i n i n g t h e NEASC staff, I served as a

20m e m b e r a n d C h a i r o f the NEASC Commission.

21 I j o i n m y c olleagues and others in

22s u p p o r t i n g t h e r e q u ested delay in negotiated

23r u l e m a k i n g a s i t a p plies to accreditation until the

24H i g h e r E d u c a t i o n A c t has been reauthorized. As

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1S t e v e C r o w a n d o t h e rs have testified, changes in

2r e g u l a t i o n s t h a t c o me too frequently are disruptive

3a n d c o n f u s i n g t o o u r institutions. Regional

4a c c r e d i t o r s a r e a l l engaged in important work

5f o c u s i n g o n o u r s t a ndards, policies, and processes,

6i n c r e a s i n g l y o n t h e effectiveness of institutions

7i n e n s u r i n g s t u d e n t learning. Absorbing two rounds

8o f n e w r u l e s i n t o o ur processes within a short

9p e r i o d o f t i m e h a s great potential to represent a

10c o u n t e r p r o d u c t i v e d istraction from our focus on

11s t u d e n t l e a r n i n g a s sessment and institutional

12i m p r o v e m e n t .

13 T h e p a s t 3 0 years has arguably seen more

14c h a n g e i n h i g h e r e d ucation than the previous 300.

15W e a r e n o w w e l l i n t o a powerful shift within

16c o l l e g e s a n d u n i v e r sities, as the focus is

17i n c r e a s i n g l y o n w h a t students are learning and not,

18s i m p l y , o n w h a t f a c ulty are teaching. A large and

19g r o w i n g p r o p o r t i o n of faculty think differently

20a b o u t t h e i r w o r k t h an they did just a few years

21a g o . Why is this?

22 T o a v e r y l arge extent, the changes are

23d u e t o r e s e a r c h o n how students learn and how

24i n s t i t u t i o n s c a n p r omote their success. Just last

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1w e e k , t h e D e p a r t m e n t’s National Postsecondary

2E d u c a t i o n C o o p e r a t i ve Meeting here in Washington,

3D . C . , f o c u s e d o n m u ch of this research. The paper

4p r e s e n t e d b y G e o r g e Koo of Indiana University and

5h i s c o l l e a g u e s p r o v ided a vivid and useful summary

6o f w h a t w e n o w k n o w . In the 40-page bibliography

7o f t h e p a p e r , i t i s rare to find a reference from

8b e f o r e t h e e a r l y 1 9 80s, and stunning to see how

9m u c h o f t h e r e s e a r c h has been accomplished just in

10t h e p a s t d e c a d e .

11 T h e s t a n d a r ds and policy of C-RAC reflect

12m u c h o f t h i s r e s e a r ch. A portion of the research

13h a s a l s o b e g u n t o i mprove how student learning is

14a s s e s s e d , a n d r e g i o nal accreditation has been a

15m a j o r c h a m p i o n o f a dvances in research and practice

16i n t h e a r e a s o f a s s essment. Indeed, most

17r e g i o n a l l y a c c r e d i t ed institutions will freely say

18t h a t a c c r e d i t a t i o n has been the constant instrument

19o f i n c r e a s i n g e x p e c tations for colleges and

20u n i v e r s i t i e s i n t h e area of assessment.

21 A s o u r a c c r editation system continues to

22c h a n g e , w e s h o u l d e nsure that it keeps an

23a p p r o p r i a t e b a l a n c e on ensuring the quality of the

24e d u c a t i o n a n d a s s e s sing the results of that

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1e d u c a t i o n . S u r e l y they go together. Just as

2s u r e l y , t e s t i n g a l o ne will not give us the

3i m p r o v e m e n t s w e a l l want. There is much exciting

4w o r k o n o u r c a m p u s e s as higher education

5i n s t i t u t i o n s l e a r n how to assess students in the

6l i g h t o f t h e i r o w n mission and goals, and use the

7r e s u l t s f o r i m p r o v e ment. At the same time,

8r e g i o n a l a c c r e d i t a t ion has an increasingly

9i m p o r t a n t r o l e t o p lay in ensuring that the public

10h a s t h e i n f o r m a t i o n that it expects and needs

11r e g a r d i n g o u r i n s t i tutions.

12 W h i l e a s k i n g that negotiated rulemaking on

13a c c r e d i t a t i o n b e d e layed until after the Higher

14E d u c a t i o n A c t i s r e authorized, C-RAC is also

15c o m m i t t e d t o w o r k i n g with the Department to ensure

16t h e e f f e c t i v e n e s s o f our processes. Indeed, we are

17c u r r e n t l y e n g a g e d i n conversations around

18s u b s t a n t i v e c h a n g e and how accreditation ensures

19p r o p e r o v e r s i g h t o f branch campuses.

20 W e a p p r e c i a te the opportunity to work

21t o g e t h e r i n t h e s e c omplex and important areas.

22T h r o u g h t h i s c o o p e r ation, we look forward to

23e n s u r i n g t h a t o u r a ccreditation system serves the

24i n c r e a s i n g l y c o m p l e x system of higher education in

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1t h e i n t e r e s t s o f t h e public good.

2 T h a n k y o u v ery much.

3 D A V I D B E R G E RON: Thank you.

4 D A V I D B E R G E RON: Patricia Kapper, good

5m o r n i n g .

6 P A T R I C I A K A PPER: Good morning.

7 T h a n k y o u f or the opportunity to

8p a r t i c i p a t e i n t o d a y’s hearing. I am Dr. Patricia

9K a p p e r , a n d I a m t h e Chief Academic Officer for

10C a r e e r E d u c a t i o n C o rporation.

11 I j o i n e d C E C in 1997, as Director of

12E d u c a t i o n a n d P l a c e ment, when the company had 18

13c a m p u s e s . C E C h a s grown significantly since then,

14b o t h i n s i z e a n d s t ature. We are focused on five

15h i g h - g r o w t h f i e l d s , visual communication and design

16t e c h n o l o g i e s , i n f o r mation technology, business

17s t u d i e s , c u l i n a r y a rts, and healthcare.

18 W e w e l c o m e the Commission’s report and the

19c h a l l e n g e s t h a t i t presents. We commend Secretary

20S p e l l i n g s f o r h a v i n g the courage to ask for

21c o n c r e t e a n d b o l d s olutions to the problems facing

22s t u d e n t s i n p o s t s e c ondary institutions today.

23 I a m h e r e t o highlight three issues raised

24b y t h e C o m m i s s i o n : number one, remedial and

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1d e v e l o p m e n t a l c o u r s e work for incoming students,

2s e c o n d l y , b a r r i e r s to the transfer of credit

3b e t w e e n i n s t i t u t i o n s, and thirdly, recording and

4t r a c k i n g i n d i v i d u a l student progress and outcomes.

5 F i r s t , t h e students who are falling

6t h r o u g h t h e c r a c k s of the existing system often

7f i n d a p l a c e a t a C EC school. 70 percent of our

8s t u d e n t s a r e o v e r t he age of 21, and 39 percent are

9m i n o r i t i e s . M a n y o f our students are the first in

10t h e i r f a m i l i e s t o a ttend college. Our schools are

11o f t e n t h e f i r s t s t e p to new lives for countless

12s t u d e n t s .

13 L i k e o t h e r colleges and universities

14a c r o s s t h e c o u n t r y , CEC schools must address the

15d e f i c i e n c i e s o f a n educational system that

16g r a d u a t e s s t u d e n t s from high school without the

17b a s i c s k i l l c o m p e t e ncies required for postsecondary

18e d u c a t i o n . T o b r i d ge the chasm between these

19s t u d e n t s k i l l l e v e l s and college work, our schools

20o f f e r a n a r r a y o f r emedial and developmental

21c o u r s e s .

22 F o r i n s t a n c e, our schools offer a two-

23t i e r e d s y s t e m o f d e velopmental courses in the

24s u b j e c t s o f m a t h a n d English. It is our belief

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1t h a t t h e i m p r o v e m e n ts that we have made to our

2d e v e l o p m e n t a l c u r r i culum have produced more

3s u c c e s s f u l s t u d e n t s who are actively engaged in

4t h e i r e d u c a t i o n .

5 I n a n e f f o r t to replicate the success of

6s t u d e n t s e n r o l l e d i n these types of programs, we

7h a v e d e s i g n e d a d e v elopmental curriculum to be

8r o l l e d o u t t o o v e r 70 campuses across the country

9t h i s y e a r . E v e r y s tudent will participate in a

10c o r e c o n t e n t c o u r s e each term designed specifically

11t o i m p r o v e s t u d e n t skill levels, while also

12e n g a g i n g t h e m i n t h eir program or degree subject

13m a t t e r . W e a r e c o m mitting time and resources to

14p r o g r a m s s u c h a s t h ese to help students succeed

15t h r o u g h o u t t h e i r e d ucation experience, and to

16e n h a n c e t h e i r c o n f i dence and their mastery of basic

17s k i l l s i n a r e a s s u c h as math, reading, and writing.

18 S e c o n d l y , a nother obstacle for our

19s t u d e n t s i s t h e o n e the Commission identified as a

20p r o b l e m f o r s t u d e n t s nationwide, barriers to the

21t r a n s f e r o f c r e d i t between institutions. Our

22s t u d e n t s h a v e f o u n d the obstacles to transferring

23t h e i r h a r d - e a r n e d c redits to be two-fold. First,

24t h e y e x p e r i e n c e b i a s toward our operation as

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1p r o p r i e t a r y i n s t i t u tions. Second, they encounter

2a d m i n i s t r a t o r s a n d faculty who object to our

3n a t i o n a l a c c r e d i t a t ion, and reject transfer credits

4w i t h o u t a n o b j e c t i v e evaluation. If the

5a c c r e d i t a t i o n , b e i t national or regional, meets

6t h e s t a n d a r d s o f t h e Department of Education, it

7o u g h t t o b e s u f f i c i ent for the institutions our

8s t u d e n t s w o u l d l i k e to attend.

9 W e a r e e n c o uraged by the Commission’s

10s e r i o u s l o o k a t t h e shortcomings of the existing

11a c c r e d i t a t i o n p r o c e ss. We support the development

12o f a r e g u l a t o r y f r a mework that is neutral to

13w h e t h e r a n i n s t i t u t ion is accredited by a national

14o r r e g i o n a l b o d y .

15 T h i r d , a n o t her way to increase

16o p p o r t u n i t i e s f o r s tudents is to rectify the

17p r o b l e m o f c a p t u r i n g performance outcomes. The

18r e a l i t y t o d a y i s t h at many students attend multiple

19s c h o o l s a n d c o m p l e t e their education in a non-

20l i n e a r w a y . T h e r e is a critical need to capture

21p e r f o r m a n c e o u t c o m e s so that parents and students

22h a v e r e l i a b l e , a c c u rate data to consider when

23m a k i n g c o l l e g e d e c i sions.

24 W e s u p p o r t the Commission’s efforts to

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1a d d r e s s t h i s p r o b l e m, including its recommendation

2t o d e v e l o p a p r i v a c y-protected higher education

3i n f o r m a t i o n s y s t e m that collects, analyzes, and

4u s e s s t u d e n t - l e v e l data. We agree that the

5p r o p o s e d s y s t e m s h o uld be designed in such a way as

6t o e n s u r e a b s o l u t e student privacy.

7 W e a l s o u r g e the Commission not to

8i m p l e m e n t t h i s h i g h er education information system

9a s a n u n f u n d e d m a n d ate on institutions. The

10C o m m i s s i o n r e c o g n i z ed this potential financial

11b u r d e n o n i n s t i t u t i ons and students, and we fully

12s u p p o r t i t s r e c o m m e ndation that the federal

13g o v e r n m e n t p r o v i d e incentives for states’ higher

14e d u c a t i o n a s s o c i a t i ons, university system, and

15i n s t i t u t i o n s t o d e v elop inter-operable, outcomes-

16f o c u s e d a c c o u n t a b i l ity systems. We look forward to

17w o r k i n g w i t h S e c r e t ary Spellings and others in the

18D e p a r t m e n t , n o t o n l y on designing this proposed

19s y s t e m , b u t a l s o o n implementing other solutions to

20t h e p r o b l e m s f a c i n g students in postsecondary

21i n s t i t u t i o n s t o d a y .

22 T h a n k y o u v ery much for allowing me the

23o p p o r t u n i t y t o b e w ith you today.

24 D A V I D B E R G E RON: Thank you very much.

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1 D A V I D B E R G E RON: Is Luke Swarthout--thank

2y o u .

3 L U K E S W A R T H OUT: Swarthout, but very

4g o o d - - m o s t p e o p l e m angle it.

5 M y n a m e i s Luke Swarthout. I am the

6H i g h e r E d u c a t i o n A d vocate for the State Public

7I n t e r e s t R e s e a r c h G roup, or the State PIRGs.

8 T h e P I R G s a re a nationwide network of

9s t a t e - b a s e d , n o n - p a rtisan, non-profit

10o r g a n i z a t i o n s . W e work with students in about 30

11s t a t e s a n d a b o u t 2 0 0 campuses. We work on federal

12i s s u e s o n b e h a l f o f college students, which is why

13I a m h e r e t o d a y .

14 I w o u l d l i k e to begin by thanking the

15D e p a r t m e n t f o r b e g i nning this negotiated rulemaking

16w i t h s u c h a n o p e n p rocess. In response to your

17o p e n n e s s , s t u d e n t s , citizens, and organizations

18a r o u n d t h e c o u n t r y have responded by asking for

19m e a n i n g f u l r e f o r m s to the student loan programs.

20 T o m o r r o w , t he public comment period will

21e n d f o r t h i s r u l e m a king, but, by then, 150 students

22f r o m 1 4 s t a t e s w i l l have testified before public

23h e a r i n g s , m o r e t h a n 1,000 students and parents will

24h a v e c o m m e n t e d t o t he Department, and dozens of

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1o r g a n i z a t i o n s w i l l have sent letters in support of

2t h e f i v e - p o i n t p l a n to fix student loan repayment.

3 N o w , A m e r i c an colleges and universities

4p l a y a p i v o t a l r o l e in training our nation’s

5c i t i z e n s , l e a d e r s , innovators, public servants, and

6e d u c a t o r s . I n t o d a y’s economy, a college education

7i s m o r e d e s i r a b l e t han ever before. Millions of

8h i g h s c h o o l s t u d e n t s strive for its promise and the

9b e n e f i t s i t b r i n g s for both the individual and

10s o c i e t y . W h i l e c o l lege education has grown over

11t h e p a s t t w o d e c a d e s, state appropriations and

12f e d e r a l a i d h a v e f a iled to keep pace. As a result,

13t u i t i o n a n d f e e s h a ve increased, grants have failed

14t o k e e p p a c e , a n d , as costs continue to swell,

15s t u d e n t s a r e t a k i n g on more and more debt to pay

16f o r t h e i r d e g r e e s . Two-thirds of all four-year

17c o l l e g e g r a d u a t e s i n 2000 left school with debt,

18c o m p a r e d t o a b o u t 4 6 percent in 1993.

19 M a n y g r a d u a tes comfortably repay their

20l o a n s , b u t a n i n c r e asing number of borrowers face

21d i f f i c u l t r e p a y m e n t burdens. Our student loan

22r e p a y m e n t s y s t e m s h ould give struggling borrowers

23i n c e n t i v e t o p a y w h at they can to work and to avoid

24d e f a u l t . U n f o r t u n a tely, the tools that are

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1s u p p o s e d t o a s s i s t borrowers with payments on

2f e d e r a l l o a n s a r e i nadequate, confusing, and

3i n c o n s i s t e n t , t o o o ften providing the wrong

4i n c e n t i v e s . W i t h o u t improved protection for

5b o r r o w e r s , t h e n a t i on may see an increase in its

6d e f a u l t , i t s b a n k r u ptcies, rather than an increase

7i n m o r e p r o d u c t i v e graduates who can contribute

8f u l l y t o o u r s o c i e t y.

9 T o s o l v e t h e challenges of student debt,

10w e u r g e y o u t o a d o p t the five-point plan for fair

11l o a n r e p a y m e n t . T h e five points, and I am sure you

12h a v e h e a r d t h e m b e f ore and will hear them later,

13a r e , i n b r i e f :

14 F i r s t , l i m i t student loan payments to a

15r e a s o n a b l e p e r c e n t a ge of income, 10 percent in most

16c a s e s , n o m o r e t h a n 15 percent. That would cap the

17a m o u n t t h a t t h e b o r rower would repay, and ensure

18t h a t s t u d e n t l o a n p ayments don’t prevent borrowers

19f r o m c o v e r i n g o t h e r basic costs, like housing or

20f o o d .

21 S e c o n d , a c k nowledge that borrowers with

22c h i l d r e n h a v e l e s s available income for student

23l o a n r e p a y m e n t . C u rrently, the formulas do not

24i n c l u d e d e p e n d e n t s in their calculation, even

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1t h o u g h p a r e n t s w i t h children have less available

2i n c o m e t o p u t t o w a r ds debt repayment.

3 T h i r d , p r e v ent added interest from making

4t h e p r o b l e m e v e n w o rse for borrowers in hardship

5s i t u a t i o n s . S t u d e n ts who enter hardship can be

6s u b j e c t t o b a l l o o n i ng interest payments that drive

7u p t h e s i z e o f d e b t and make it harder to pay down.

8T h e e f f o r t o f p i l i n g interest we actually believe

9i s c o u n t e r - p r o d u c t i ve, and, in fact, discourages

10r a t h e r t h a n e n c o u r a ges on-time repayment.

11 F o u r t h , c a n cel the remaining debts when

12b o r r o w e r s h a v e m a d e income-based payments for 20

13y e a r s . F o r m o s t s t udents, college will be a

14w o r t h w h i l e i n v e s t m e nt that results in higher income

15a n d t h e c a p a c i t y t o manageably repay. For some

16s m a l l p e r c e n t a g e o f students, however, the

17i n v e s t m e n t w i l l n o t yield financial rewards. For

18t h e s e s t u d e n t s w h o make good faith efforts to repay

19t h e l o a n s , w e b e l i e ve it is in the best interest of

20t h e g o v e r n m e n t a n d the borrower to retire the debts

21a f t e r 2 0 y e a r s .

22 F i f t h a n d f inally, simplify the process of

23a p p l y i n g f o r h a r d s h ip deferral. The process should

24b e e a s y . W e w a n t t o encourage students to take

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1a d v a n t a g e o f t h e o p portunities afforded them by the

2D e p a r t m e n t , a n d s i m plifying the process is critical

3t o m a k e s u r e t h e i m plemented reforms take hold.

4 W i t h t h e s e five changes taken together, it

5w i l l m a k e i t e a s i e r for students to repay their

6l o a n s o n t i m e . F u r thermore, based on the analysis

7b y p u b l i c a d v o c a t e s , we believe it is fully within

8t h e a u t h o r i t y o f t h e Department to make these

9c h a n g e s .

10 I w a n t t o t ake one moment before I finish

11t o a c k n o w l e d g e t h a t there are other steps the

12f e d e r a l g o v e r n m e n t must take to make college more

13a f f o r d a b l e , i n c l u d i ng increasing student aid like

14t h e P e l l G r a n t . H o wever, we believe that the

15D e p a r t m e n t c a n , t h r ough this rulemaking, make

16i m p o r t a n t i m p r o v e m e nts that help students and

17g r a d u a t e s m a n a g e t h eir loans.

18 A s a n a t i o n , we value college education

19b e c a u s e i t s t r e n g t h ens our society and supports the

20i n d i v i d u a l . A c o l l ege education presents students

21w i t h n e w o p p o r t u n i t ies, be they economic, social,

22o r i n t e l l e c t u a l . I f we allow the way that we

23f i n a n c e c o l l e g e t o undermine these core

24o p p o r t u n i t i e s , w e h ave done a great disservice to

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1o u r n a t i o n a n d t o o ur citizens. We believe the

2D e p a r t m e n t c a n h e l p strengthen higher education by

3i m p l e m e n t i n g t h e s e meaningful reforms.

4 T h a n k y o u s o much.

5 D A V I D B E R G E RON: Thank you, Luke.

6 D A V I D B E R G E RON: Judith Eaton, please.

7 J U D I T H E A T O N: Good morning.

8 I a m J u d i t h Eaton. I am the President of

9t h e C o u n c i l f o r H i g her Education Accreditation. We

10a r e a n i n s t i t u t i o n a l membership organization of

11s o m e 3 , 0 0 0 d e g r e e - g ranting colleges and

12u n i v e r s i t i e s , a n d w e also carry out an analogous

13f u n c t i o n t o t h a t c a rried out by the Department of

14E d u c a t i o n , t h e r e c o gnition of accrediting

15o r g a n i z a t i o n s . A t present, we recognize 60

16i n s t i t u t i o n a l a n d p rogrammatic accreditors,

17i n c l u d i n g t h e r e g i o nal accreditors from whom you

18h e a r d e a r l i e r t o d a y .

19 I w a n t t o o ffer a few comments with regard

20t o a c c r e d i t a t i o n a n d the anticipated negotiated

21r u l e m a k i n g . T o d o this, we will focus a bit on the

22S p e l l i n g s ’ C o m m i s s i on Report. There are a number

23o f p l a c e s i n t h e S p ellings Commission where,

24i n d e e d , t h e v a l u e o f accreditation is acknowledged.

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1T h e i m p o r t a n c e o f i ts role ensuring quality, the

2i m p o r t a n c e o f i t s r ole in providing access to

3f e d e r a l f u n d s , s t a t e funds, and private funds, the

4r o l e t h a t i t p l a y s with regarding to easing, not

5g u a r a n t e e i n g , t r a n s fer of credit. On the other

6h a n d , t h e R e p o r t i s , at times, rather critical of

7a c c r e d i t a t i o n , r a i s ing questions about the level of

8q u a l i t y , r a i s i n g q u estions about the capacity to

9e n c o u r a g e i n n o v a t i o n, and raising questions about

10p u b l i c a c c o u n t a b i l i ty.

11 W h a t , f r o m our perspective, is going on

12h e r e i s n o t a m a t t e r of right or wrong about

13a c c r e d i t a t i o n . C l e arly, institutional and

14p r o g r a m m a t i c a c c r e d itation in the U.S. has

15d e m o n s t r a t e d i t s i m portant value, but rather we

16h a v e g o t s o m e d i s c o nnects. We have got a clash of

17e x p e c t a t i o n s a r o u n d some very important issues.

18S p e c i f i c a l l y , t h e i ssue of, “for whom does

19a c c r e d i t a t i o n e x i s t ”; who is served by

20a c c r e d i t a t i o n .

21 T h e R e p o r t ’ s expectation is that the

22p u b l i c i s , f i r s t a n d foremost, the audience of

23a c c r e d i t a t i o n . A c c reditation practice over the

24y e a r s - - i n s t i t u t i o n s and programs have been the

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1p r i m a r y a u d i e n c e , t he primary recipients of the

2w o r k o f a c c r e d i t a t i on.

3 I t h i n k w e have a clash of expectations

4w i t h r e g a r d t o s t u d ent learning outcomes. The

5R e p o r t e x p e c t s s t u d ent learning outcomes to provide

6m a j o r a n d c e n t r a l e vidence to judge quality,

7e v i d e n c e t h a t i s e a sily and publicly available. As

8y o u h a v e a l r e a d y h e ard this morning with regard to

9a c c r e d i t a t i o n p r a c t ice, all accreditors call for

10e v i d e n c e o f s t u d e n t learning outcomes, they have

11b e e n d o i n g t h i s f o r a number of years. They do it

12i n a b r o a d e r c o n t e x t of calling for various types

13o f i n f o r m a t i o n b y w hich to judge quality, and they

14e x p e c t a n d , i n d e e d , respect the institutions and

15p r o g r a m s t h a t t h e y review with regard to making

16t h i s i n f o r m a t i o n a b out student learning outcomes

17a v a i l a b l e .

18 W e h a v e a t hird clash around the issue of

19c o m p a r a b i l i t y . T h e expectation in the Report is

20t h a t i n f o r m a t i o n o n quality would be presented so

21t h a t s t u d e n t s a n d t he public can quickly make

22c o m p a r i s o n s a m o n g i nstitutions. Accreditation

23p r a c t i c e , h i s t o r i c a lly--information about quality

24i s j u d g e d i n r e l a t i on to the goals established by

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1a n i n s t i t u t i o n a n d program, first and foremost,

2a c r o s s i n s t i t u t i o n s or programs to a lesser extent.

3C o m p a r a b i l i t y i s a very, very complicated judgment.

4 A f o u r t h c l ash that we have relates to

5t r a n s p a r e n c y , o r t h e extent to which information is

6p r o v i d e d t o t h e p u b lic. The report calls for a

7c o m p r e h e n s i v e a r r a y of information, even on the

8r e s u l t s o f a c c r e d i t ation reviews, an end to what

9s o m e p e o p l e c a l l “ t he black box of accreditation.”

10A c c r e d i t a t i o n p r a c t ice is a mix of public

11i n f o r m a t i o n a n d p r i vate information. It is not

12s i m p l y e v e r y t h i n g i s public.

13 S o t h e r e i s no, as I said earlier, right

14o r w r o n g , h e r e . W e do have a clash of

15e x p e c t a t i o n s , a n d t hese are very, very important

16i s s u e s t o a l l o f u s in higher education today and,

17i n d e e d , t o t h i s s o c iety. We are talking about who

18i s t h e a u d i e n c e , o u tcomes comparability, and

19t r a n s p a r e n c i e s . A n d these clashes are coming at a

20c h a l l e n g i n g t i m e i n our society, generally. They

21a r e u n d e r m i n i n g , t o some extent, the longstanding

22a c c r e d i t a t i o n - f e d e r al government relationship that

23h a s b e e n v e r y , v e r y successful going back to 1952,

24w h e n t h e f e d e r a l g o vernment began publishing a list

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1o f n a t i o n a l l y a c c r e dited institutions. We have had

2a v e r y , v e r y s u c c e s sful public-private partnership

3a c c r e d i t a t i o n i n t h e federal government.

4 S o , g i v e n t he clashes, and given the

5h i s t o r y o f o u r s u c c essful relationship, how do we

6e n d t h e c l a s h e s ? H ow do we bridge the gap? How do

7w e m a i n t a i n t h e s u c cessful partnership? CHEA has

8o f f e r e d a n u m b e r o f thoughts and an action plan, a

9f r a m e w o r k , f o r d o i n g just this.

10 F i r s t , I t h ink it is important, as you

11h a v e a l r e a d y h e a r d from earlier presenters, that we

12a l l a c k n o w l e d g e t h a t the issues raised by the

13R e p o r t a r e f u n d a m e n tal, they are key, they need to

14b e a d d r e s s e d . T h a t acknowledged, CHEA has put

15t o g e t h e r w h a t w e c a ll an accountability agenda, it

16h a s f o u r k e y e l e m e n ts. We do think more needs to

17b e d o n e w i t h r e g a r d to evidence of student learning

18o u t c o m e s . W e d o t h ink that we can provide more

19i n f o r m a t i o n t o t h e public about institution and

20p r o g r a m p e r f o r m a n c e . We can move toward greater

21t r a n s p a r e n c y , a n d w e at least have to engage, as

22d i f f i c u l t a s i t i s , this comparability issue. Our

23e m p h a s i s i s o n a c c r editation serving the public

24i n t e r e s t . W e a r e c oncerned to strengthen the

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1q u a l i t y o f h i g h e r e ducation. We want to further

2e n h a n c e t h e c r e d i b i lity and trust in accreditation

3t h a t w e h a v e l o n g e njoyed. Our agenda is a program

4f o r a c t i o n . W e h a v e a series of recommendations.

5W e a r e a f o r u m i n w hich we are bringing

6a c c r e d i t o r s , i n s t i t utions, and the public together

7t o a d d r e s s t h i s .

8 A v i t a l s i g nificance from our perspective

9i s t h a t t h i s a g e n d a needs to be realized through

10o u r l o n g s t a n d i n g p a rtnership with institutions,

11p r o g r a m s , a c c r e d i t o rs, and the government--a

12c o o p e r a t i v e e f f o r t , not an effort where we, in the

13h i g h e r e d u c a t i o n a n d accreditation enterprise, find

14o u r s e l v e s s i m p l y r e sponding to various

15p r e s c r i p t i o n s .

16 A g a i n , t h e issues are important. We thank

17y o u f o r u n d e r t a k i n g this effort, and we look

18f o r w a r d t o w o r k i n g with you.

19 D A V I D B E R G E RON: Thank you.

20 D A V I D B E R G E RON: Constance Kelly Rice.

21 A s y o u c o m e in, Constance, I remind you to

22s t a t e y o u r n a m e a n d the organization you are

23a f f i l i a t e d w i t h , p l ease.

24 C O N S T A N C E K ELLY RICE: Good morning, Ms.

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1L i s a K a n t o r , M r . D a vid Bergeron, Mr. Dan Madzelan,

2a n d f e l l o w a u d i e n c e .

3 I a m C o n s t a nce Kelly Rice, the Director of

4t h e U p w a r d B o u n d P r ogram, St. Paul’s College,

5L a w r e n c e v i l l e , V i r g inia.

6 T h a n k y o u s o very much for the opportunity

7t o d a y t o s p e a k b e f o re you.

8 M y c o l l e a g u es and I are here to address a

9n o t i c e o f a b s o l u t e priority for the classic Upward

10B o u n d P r o g r a m . W e both have substantial procedural

11p r o b l e m s w i t h t h e p roposed priority. We especially

12o b j e c t t o t h e f a c t that this process effectively

13c h a n g e s a c o n g r e s s i onal priority for an

14a d m i n i s t r a t i v e o n e , a practice we view as

15p r e c e d e n t - s e t t i n g a nd disturbing.

16 W h e n a u t h o r izing the Upward Bound Program,

17C o n g r e s s s p e c i f i c a l ly did not include these

18a d d i t i o n a l e l i g i b i l ity requirements in the

19s t a t u t o r y l a n g u a g e . This reflects congressional

20i n t e n t t o p r o v i d e f lexibility to local programs in

21d e t e r m i n i n g t h e s t u dents who would benefit most

22f r o m t h e s e s e r v i c e s . This flexibility is

23p a r t i c u l a r l y i m p o r t ant because Upward Bound seeks

24t o s e r v e a p o p u l a t i on of students who are difficult

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1t o r e a c h . T h e s e s t udents tend to be highly mobile,

2a n d m a n y m a y b e f o r ced to change schools due to a

3p a r e n t ’ s j o b l o s s , housing needs, or other factors.

4T h e p r o p o s e d e l i g i b ility requirements could create

5a d d i t i o n a l b a r r i e r s to higher education for these

6s t u d e n t s .

7 T h e p r i o r i t y asserted is such a marked

8d e p a r t u r e f r o m e x i s ting program design that it

9e f f e c t i v e l y s u b s t i t utes a new program for the one

10t h a t C o n g r e s s a u t h o rized and provided the funds to

11o p e r a t e . T h e p r o p o sed priority discards the

12c u r r e n t f l e x i b i l i t y to vary the program in

13a c c o r d a n c e w i t h l o c al needs, substituting in its

14p l a c e a m o n o l i t h i c federal edict about whom to

15s e r v e .

16 B y e s t a b l i s hing a priority for a cohort of

17n i n t h g r a d e s t u d e n t s, the proposal would

18d i s e n f r a n c h i s e a l l the tenth and eleventh graders

19t h a t C o n g r e s s i n t e n ded to be served by the Upward

20B o u n d s e r v i c e s . W e all know teenagers who mature

21s l o w l y , a n d o n l y l a te in high school realize that

22t h e y w a n t t o g o t o college, they could no longer be

23s e r v e d .

24 T h e r e q u i r e ment that 30 percent of newly

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1a d m i t t e d s t u d e n t s b e at high academic risk for

2f a i l u r e w o u l d d e p r i ve certain ninth grade students,

3t h o s e w h o m a y d o w e ll in school, from receiving the

4U p w a r d B o u n d s e r v i c es they may require.

5 T h i s b u r e a u cratic brainstorm is deeply

6f l a w e d . F i r s t , i t substitutes local educators’

7j u d g m e n t s a b o u t w h o should be served, reducing

8l o c a l f l e x i b i l i t y t o manage programs effectively.

9 S e c o n d , i t automatically deprives some

10s t u d e n t s t h a t a r e n ot failing academically from

11r e c e i v i n g s e r v i c e s . I personally have a problem

12w i t h t h i s a s b e i n g a director. It overlooks the

13f a c t t h a t s o m e e x c e llent Upward Bound candidates

14m a y b e s u r v i v i n g i n school, but may be at risk at

15f a i l i n g i n l i f e .

16 F i n a l l y , t h e proposal creates a troubling

17g r a y a r e a b e t w e e n c ongressional intent, as

18e x p r e s s e d i n s t a t u t ory language, sometimes

19a m p l i f i e d b y r e p o r t language, and the Department’s

20c o n s t i t u t i o n a l o b l i gation to carry out that intent

21i n a s t r a i g h t f o r w a r d manner.

22 W e a p p r e c i a te that the Department is

23e n g a g e d w i t h t h e p r oblem of reducing the

24u n a c c e p t a b l e h i g h n umbers of high school students

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1w h o d r o p o u t p r i o r to graduation. We, however,

2s t r o n g l y u r g e y o u t o discard this proposed priority

3s e t t i n g e f f o r t i n f avor of working with Congress

4a n d t h e h i g h e r e d u c ation community to develop

5p r o m i s i n g a p p r o a c h e s to solving this problem.

6 T h a n k y o u s o much for your attention and

7g i v i n g m e t h e o p p o r tunity to speak.

8 D A V I D B E R G E RON: Thank you, Dr. Rice.

9 D A V I D B E R G E RON: Janice Satterthwaite.

10 J A N I C E S A T T ERTHWAITE: Good morning.

11 D A V I D B E R G E RON: Good morning.

12 J A N I C E S A T T ERTHWAITE: I am Janice

13S a t t e r t h w a i t e , P r e s ident for the Virginia

14A s s o c i a t i o n o f E d u c ational Program Personnel.

15 O n b e h a l f o f the 16 Upward Bound programs

16i n t h e g r e a t C o m m o n wealth of Virginia, I bring you

17g r e e t i n g s .

18 H o w g r e a t t his America is, because last

19n i g h t I s t a y e d u p , probably until about 12:30

20w a t c h i n g t h e r e t u r n s, and then I got in my car and

21d r o v e a t 1 : 3 0 t h i s morning so that I could take a

22t r a i n t o b e h e r e , b ecause it is that important.

23 N o w , a l t h o u gh I am not a director of

24U p w a r d B o u n d , I a m passionate about TRIO and, as I

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1s a i d , I a m t h e P r e s ident for the State Association.

2 T h i s m o r n i n g, I want to specifically

3a d d r e s s t h e e v a l u a t ion process proposed under the

4p r i o r i t y t h a t M r s . Rice just spoke about. Under

5t h i s e v a l u a t i o n p r o cess, the Department is

6p r o p o s i n g t h a t U p w a rd Bound recruit twice as many

7s t u d e n t s a s c a n b e served to create a control

8g r o u p . Y o u w a n t u s to recruit students into Upward

9B o u n d , a n d t h e n t e l l them that they are being

10s t u d i e d , n o t t h a t t hey will be able to utilize the

11s e r v i c e s a s o u r o t h er classic Upward Bound

12s t u d e n t s , n o t t h a t they will have those

13o p p o r t u n i t i e s t o g o to college. For me, that is a

14b i t i n h u m a n e a n d u n ethical, accepting those who

15m e e t t h e c r i t e r i a a nd treating them as if there are

16a p l a c e b o .

17 I a m a r e t i red Air Force officer. I truly

18u n d e r s t a n d a c c o u n t a bility. Evaluate me, evaluate

19t h e p r o g r a m s , e v a l u ate all the TRIO staff, but

20d o n ’ t b r i n g i n a c o ntrol group of students, those

21a t - r i s k s t u d e n t s , t hat need every opportunity and

22e v e r y c h a n c e - - t h a t we may be the only chance that

23t h e y h a v e t o g o t o college--don’t bring them in as

24a c o n t r o l g r o u p , a n d then tell them, no, they can’t

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1b e a p a r t .

2 T o q u o t e D a vid Ward, who is President of

3t h e A m e r i c a n C o u n c i l of Education, “If this

4p r i o r i t y - s e t t i n g a p proach is adopted, it is easy to

5i m a g i n e t h a t m a n y o ther programs administered by

6t h e D e p a r t m e n t w i l l be subject to a wholesale

7r e d e s i g n o u t s i d e t h e normal legislative and

8r e g u l a t o r y p r o c e s s e s.”

9 T R I O r e a l l y does work. We can look at

10S e n a t o r M a m i e E . L o cke from the state of Virginia.

11S h e w a s a p r o d u c t o f Upward Bound out of Tupelo,

12M i s s i s s i p p i . S o t h ese programs are all over, not

13j u s t l o c a l . S h e w a s the first African-American

14f e m a l e m a y o r i n t h e city of Hampton. Or we could

15c h e c k w i t h R i c h a r d Wright, who is an Upward Bound

16o f H a m p t o n U n i v e r s i ty’s Upward Bound program, and

17w h o i s t h e y o u n g e s t administrator in the school

18s y s t e m i n t h e c i t y of Hampton.

19 S o , o n b e h a lf of the Commonwealth of

20V i r g i n i a , I s t r o n g l y urge you to discard the

21p r o p o s e d p r i o r i t y - s etting effort in favor of

22w o r k i n g w i t h t h e C o ngress and the higher education

23c o m m u n i t y t o d e v e l o p promising solutions to solve

24t h i s p r o b l e m .

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1 I t h a n k y o u all this morning for giving us

2t h e o p p o r t u n i t y t o bring our concerns.

3 D A V I D B E R G E RON: Thank you.

4 D A V I D B E R G E RON: Trea McPherson.

5 T R E A M c P H E R SON: Good morning.

6 M y n a m e i s Trea McPherson. I am a student

7a t t h e U n i v e r s i t y o f Connecticut, and I am the

8S t a t e B o a r d C h a i r m a n of ConPIRG, and the National

9S t u d e n t H i g h e r E d u c ation Task Force Leader.

10 W h e n I g r a d uate, I will accumulate about

11$ 2 0 , 0 0 0 i n d e b t . T o give you a perspective about

12t h a t , i t i s a b o u t t hree years of in-state tuition

13a t t h e U n i v e r s i t y o f Connecticut, it is about one

14y e a r o u t - o f - s t a t e f or the University of

15C o n n e c t i c u t , a n d i t is about one year in-state for

16r o o m a n d b o a r d .

17 S p r i n g 2 0 0 6 was a hard year for my wallet.

18T h e f e d e r a l b u d g e t cut of $12 billion hurt, and my

19l i t t l e s i s t e r c h o s e to go to private school. It is

20v e r y d i f f i c u l t t o f inance college today. My

21p a r e n t s w e r e p r e p a r ed, they started saving when I

22w a s i n e l e m e n t a r y s chool, but they were not

23p r e p a r e d f o r t h e r i sing costs from then until now.

24 C o l l e g e i s seemingly becoming less and

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1l e s s a f f o r d a b l e a s the college degree seems to be

2m o r e e s s e n t i a l f o r decent employment. Due to the

3a m o u n t o f d e b t , s t u dents have to take jobs during

4s c h o o l t o p a y f o r s tudent debt after they graduate.

5T h e y a l s o h a v e t o t ake jobs which they are over-

6q u a l i f i e d f o r b e c a u se of the deteriorating job

7m a r k e t t h e y f a c e w h en they graduate.

8 I t a l s o s e e ms required that students have

9t o p u t o f f t h e i r d e bt for graduate school, for

10m a r r i a g e , a n d f o r h ome ownership, because they

11a c c u m u l a t e t o o m u c h debt to afford such things.

12T h e l i f e - c h a n g i n g d ecision that students will have

13t o m a k e f o r s t u d e n t loan debt is actually changing

14t h e i r m a j o r t o a m o re lucrative job. It is not

15j u s t s t u d e n t s t h a t are going from an abstract

16p r o f e s s i o n t o a m o r e practical one, students who

17w a n t t o b e t e a c h e r s and social workers are forced

18i n t o t h e w o r l d o f b usiness and engineering because

19o f t h e i m m e d i a t e p a yout that they receive when they

20g r a d u a t e f r o m s c h o o l.

21 I f t h e y w a n t to go into teaching or social

22w o r k , t h e y m u s t s e t aside a good portion of their

23s a l a r y t o p a y f o r s tudent debt. They can only

24r e a l l y a f f o r d s u c h things as basic shelter, food,

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1a n d t r a n s p o r t a t i o n to their job every day, and the

2r e s t o f i t h a s t o g o to pay for student debt.

3 P a y i n g o f f debt is one of the first

4v a l u a b l e l e s s o n s y o u learn as a college student.

5Y o u l e a r n h o w t o b u dget your money and you learn

6h o w t o b e f i s c a l l y responsible, while also paying

7o f f t h e d e b t t h a t y ou owe. It builds character,

8a n d m u s c l e , a n d i t also builds credit, so it helps

9u s a l o t - - h o w t o l e arn in life. But students are

10s t a r t i n g t o b e c o m e more--the debt that they are

11a c c u m u l a t i n g i s b e c oming more and more

12u n m a n a g e a b l e .

13 S t u d e n t s h a ve to fall into practices, such

14a s u s i n g t h e i r c r e d it card to pay for student

15d e b t - - w h i c h i s a h o rrible, horrible practice. They

16h a v e t o f a l l i n t o b ad habits like that in order to

17p a y f o r s t u d e n t d e b t that they will accumulate

18a f t e r s c h o o l .

19 T h e f i v e - p o int plan would help students

20l i k e t h i s t o h e l p r epay their loans in an

21a f f o r d a b l e f a s h i o n , because students that take in

22l i t t l e i n c o m e , i t h elps them--it puts a cap on how

23m u c h t h e y h a v e t o p ay back in a certain amount of

24t i m e . T h e y w i l l s t ill pay back the debt; it will

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1j u s t b e a l o t e a s i e r on them.

2 A s H i g h e r E ducation Task Force Leader for

3t h e N a t i o n a l S t u d e n t Forum, I would like to thank

4y o u g u y s f o r h a v i n g hearings in Washington, D.C.,

5B e r k e l e y , C h i c a g o , and Orlando. I just heard from

6a l l t h e s t u d e n t s t h at went to all of those

7h e a r i n g s , t h e y s a i d it was great. We appreciate

8y o u g u y s t a k i n g t h e time to listen to us, because

9i t i s r e a l l y i m p o r t ant for students to have a voice

10a b o u t t h e i r o p i n i o n , especially for student debt.

11 Thank you.

12 D A V I D B E R G E RON: Thank you, Trea.

13 D A V I D B E R G E RON: Jeff Ticehurst. Good

14m o r n i n g , J e f f .

15 J E F F T I C E H U RST: Hi, my name is Jeff

16T i c e h u r s t , a n d I a m Senator in the Undergraduate

17S t u d e n t G o v e r n m e n t and a student at the University

18o f C o n n e c t i c u t .

19 A l l m y l i f e I have been told to work hard

20a n d o p p o r t u n i t i e s w ould present themselves. So,

21d u r i n g h i g h s c h o o l , I was a student leader, held a

22p a r t - t i m e j o b , a n d eventually graduated in the top

23f i v e p e r c e n t o f m y class. I worked hard during

24h i g h s c h o o l , s o I w ent for opportunities in

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1c o l l e g e . W h a t I f o und were student loans. After

2r a i s i n g t h r e e c h i l d ren and paying for higher

3e d u c a t i o n f o r o t h e r family members, my parents

4i m p o s e d t h e r e s p o n s ibility of financing my college

5e d u c a t i o n o n m e . I thought I had everything under

6c o n t r o l u n t i l t h e e nd of my freshman year.

7 A l t h o u g h I saved some money during high

8s c h o o l a n d r e c e i v e d local scholarships, I still had

9a h e f t y s t u d e n t l o a n after my first year, and

10r e a l i z e d m y d r e a m o f college education, the

11A m e r i c a n D r e a m , t h e dreams of so many other college

12s t u d e n t s , m i g h t b e slipping away because of

13o v e r w h e l m i n g s t u d e n t loans. I decided to enroll in

14a c o m m u n i t y c o l l e g e full-time over the summer while

15a l s o h o l d i n g a f u l l -time job. By taking summer

16c l a s s e s , I w a s a b l e to trim a year off my college

17c a r e e r a n d , c o n s e q u ently, prevent an extra $15,000

18i n s t u d e n t l o a n s .

19 Y e t , e v e n b y attending a community college

20o v e r t h e s u m m e r a n d attending a state school for a

21s h o r t e n e d t i m e , I w ill owe roughly $50,000 after

22g r a d u a t i o n . T o t r a nslate, this means that, for ten

23y e a r s a f t e r g r a d u a t ion, I will owe roughly $500 a

24m o n t h i n s t u d e n t l o ans. I think about this

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1o v e r w h e l m i n g f i n a n c ial burden every day as it

2s t r a i n s m y f i n a n c i a l capabilities now, and for the

3r e s t o f m y l i f e . Y et, my financial struggles are

4m i c r o s c o p i c i n c o m p arison to thousands of other

5s t u d e n t s . M a n y l o w -income families, including

6t h o s e o f b o t h h a r d - working students and parents,

7c a n n o t e v e n c o n s i d e r college, be it a community

8c o l l e g e , s t a t e u n i v ersity, or other university,

9b e c a u s e t h e r e a r e i nsufficient funds in student

10l o a n p r o g r a m s .

11 A l t h o u g h f u nds are understandably tight,

12s t u d e n t l o a n p r o g r a ms, programs that directly aid

13i n f i n a n c i n g a c o l l ege education and lead to

14o p p o r t u n i t y , s h o u l d not be cut. What is a better

15i n v e s t m e n t t h a n h e l ping thousands of students gain

16f i n a n c i a l r e s o u r c e s to pursue their aspirations, to

17o p e n u p f u t u r e e m p l oyment opportunities, and to

18e x p a n d t h e k n o w l e d g e of the next generation through

19h i g h e r e d u c a t i o n ? The future of thousands of

20f a m i l i e s r e l i e s o n their ability to fund higher

21e d u c a t i o n .

22 I s t r o n g l y urge the Department of

23E d u c a t i o n t o e n a c t the five-point plan to help make

24s t u d e n t s o b t a i n a l oan program that is affordable

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1a n d m a n a g e a b l e .

2 I t h a n k y o u for your time to speak today.

3T h a n k y o u .

4 D A V I D B E R G E RON: Thank you.

5 D A V I D B E R G E RON: Rebecca Fritz. Good

6m o r n i n g .

7 R E B E C C A F R I TZ: Hello.

8 M y n a m e i s Rebecca Fritz, and I am Student

9U n d e r g r a d u a t e S e n a t or for the University of

10C o n n e c t i c u t .

11 I f t h e n u m b er of loans becomes more

12e x p e n s i v e a n d h a r d e r to pay, then few students will

13h a v e t h e m o n e y t o g o to school. We are the next

14g e n e r a t i o n , a n d w e need to be given a way we can

15p a y f o r c o l l e g e s o we can become great doctors,

16l a w y e r s , j o u r n a l i s t s, and other professionals who

17w i l l , i n t u r n , i m p r ove society.

18 F o r t h o s e w ho do receive financial loans,

19i t c a n l e a d t h e m i n to great debt, which can take

20h a l f t h e i r l i f e t o pay off. Raising the student

21l o a n i n t e r e s t r a t e s hurts students when they get

22i n t o t h e r e a l w o r l d . It will be hard enough to

23s u r v i v e i n a n o n - c o llege environment, but when you

24a d d o n t h e d e b t s t h ey have acquired even before

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1t h e y s t a r t , t h i s g i ves them a disadvantage.

2R a i s i n g t h e i n t e r e s t rates may not seem like a big

3d e a l , b u t i t i s t o students who need as much money

4a s t h e y c a n g e t i n order to get themselves on their

5f e e t .

6 I a s k y o u t o help out the next generation

7a n d e n a c t a f i v e - p o int plan for manageable debt. I

8w i l l b e a s k i n g C o n g ress to cut loan interest rates,

9t o o , b u t I f e e l t h e Department of Education should

10d o i t s p a r t .

11 Thank you.

12 D A V I D B E R G E RON: Thank you, Rebecca.

13 D A V I D B E R G E RON: Jennine Clark, please.

14 J E N N I N E C L A RK: Good morning.

15 D A V I D B E R G E RON: Good morning.

16 J E N N I N E C L A RK: My name is Jennine Clark.

17I a m a s o p h o m o r e a t the University of Connecticut,

18a n d I a m s t u d y i n g p harmacy. I am a Senator of the

19U n d e r g r a d u a t e S t u d e nt Government, and I am on the

20E x t e r n a l A f f a i r s C o mmittee.

21 L a s t y e a r , funding for student loan

22p r o g r a m s w a s c u t b y $12.7 billion. This, along

23w i t h r i s i n g t u i t i o n , makes it more difficult for

24s t u d e n t s t o p a y f o r education beyond high school.

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1I u r g e y o u t o a d o p t the five-point plan and make

2c o l l e g e m o r e a f f o r d able and realistic for students.

3 I a m o n e o f five children. My parents

4e n c o u r a g e d m y o l d e r brother to go to school

5w h e r e v e r h e w a n t e d , so he chose Carnegie Mellon

6U n i v e r s i t y i n P i t t s burgh. This university is

7n e a r l y $ 4 0 , 0 0 0 a y e ar, but my parents wanted him to

8d o w h a t e v e r h e w a n t ed. So he is now a junior, and

9I a m a s o p h o m o r e , s o we are in school at the same

10t i m e , a n d w h e n I w a s choosing college, I was forced

11t o t a k e p r i c e i n t o consideration, because my

12p a r e n t s w e r e a l r e a d y in debt. So I am at the

13U n i v e r s i t y o f C o n n e cticut, and the pharmacy program

14t h a t I a m g o i n g t h r ough is six years--and when you

15g e t i n t o t h e p h a r m a cy school, the tuition rises

16e v e n m o r e , s o t h e e xtra two years of college plus

17t h e r i s i n g t u i t i o n is definitely going to put my

18p a r e n t s o v e r t h e e d ge.

19 I a l s o h a v e three younger siblings, one is

201 4 , o n e i s 1 3 , a n d one is 10. So they are all

21g o i n g t o b e i n s c h o ol around the same time, as

22w e l l . S o , a s s o o n as I get to start paying back my

23s t u d e n t l o a n s , m y l ittle sister is going to be

24e n t e r i n g c o l l e g e , p utting my parents in debt more.

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1 I t i s h a r d enough to pay off college debt

2f o r o n e s t u d e n t , a n d most families do have more

3t h a n o n e c h i l d - - t h e se days, students need to go to

4c o l l e g e i n o r d e r t o find a job to help them pay

5t h e i r l o a n s b a c k . No matter how bright the student

6c o u l d b e , w i t h o u t c ollege, the chances of finding a

7j o b a r e p r e t t y s l i m , while finding a good job are

8g e t t i n g s l i m m e r e v e ry day, and college is becoming

9m o r e a n d m o r e a n e c essity in life.

10 T h u s , I u r g e you, once more, to rethink

11f u n d i n g f o r c o l l e g e loans, and to adopt the five-

12p o i n t p l a n t o m a k e college more affordable and

13r e a l i s t i c f o r s t u d e nts.

14 T h a n k y o u f or your time.

15 D A V I D B E R G E RON: Thank you.

16 D A V I D B E R G E RON: Jackie Herseman.

17 J A C K I E H E R S EMAN: Good Morning.

18 I a m J a c k i e Herseman, Director of the

19U p w a r d B o u n d P r o g r a m for Marsh University in

20H u n t i n g t o n , W e s t V i rginia.

21 I a m w i t h m y two colleagues from a few

22m o m e n t s e a r l i e r , a n d I thank you for allowing us

23t h e s e m o m e n t s t o d a y .

24 I a m h e r e t o protest the absolute

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1p r i o r i t i e s t h a t h a v e been mandated for the Upward

2B o u n d P r o g r a m . I a ppreciate the name of this

3m e e t i n g b e i n g n e g o t iated rulemaking. It seems more

4f a i r t h a n a b s o l u t e priorities, which seem a little

5l i k e a n o x y m o r o n t o me.

6 I a m f i r s t concerned that the Upward Bound

7P r o g r a m , s i n c e 1 9 6 5 , has taken students in ninth,

8t e n t h , a n d e l e v e n t h grades. This absolute priority

9s a y s t h a t w e c a n o n ly take ninth graders and a few

10t e n t h g r a d e r s . W e l l, number one, the law is very

11c l e a r o n t h i s . N u m ber two, we all know that ninth

12g r a d e r s d o n ’ t k n o w what they want to do this

13w e e k e n d , m u c h l e s s with the rest of their lives.

14 [Laughter.]

15 J A C K I E H E R S EMAN: So it is frequently a

16d i f f i c u l t s e l l t o g et them to come to a six-week

17p r o g r a m i n t h e s u m m er that is about school.

18 T e n t h g r a d e rs tend to be a little more

19f o c u s e d a n d r e a s o n a ble. We don’t often take

20e l e v e n t h g r a d e r s , w e realize that the longer kids

21a r e i n U p w a r d B o u n d , the better they do, but this

22h a s b e e n a d e c i s i o n that has been left at the local

23l e v e l f o r y e a r s b e t ween the director and the

24p r o j e c t t o d e c i d e , because every student in every

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1s c h o o l d i s t r i c t i s different.

2 T h e s e c o n d absolute priority that we have

3a p r o b l e m w i t h i s t he taking of high-risk students

4o n l y - - w h e r e a l a r g e portion of whom are going to

5h a v e t o b e h i g h - r i s k. The definition of “high-

6r i s k ” i s a c o n c e r n . Number one, it is only

7s t u d e n t s w i t h l e s s than a 2.5 GPA. This may be

8d i f f i c u l t - - I a m f r o m Appalachia--for folks to

9b e l i e v e w e a r e f r o m out of there, but I know this

10i s n o t j u s t u s , s e v eral of our rural schools, if

11y o u g o t o s c h o o l e v eryday, you get a 3.0. I have

12k i d s w i t h 3 . 0 s i n m y high school who make 16s on

13t h e A C T . T h e r e i s no college prep curriculum. I

14h a v e a s c h o o l w i t h no foreign language.

15 N o w , I c a n ’ t fix that system. Is it

16r i g h t ? No. T h a t s chool has been taken over by the

17s t a t e o f W e s t V i r g i nia twice. I can’t fix that

18s y s t e m , b u t I c a n s erve those students there, but I

19c a n ’ t u n d e r t h i s p r iority, because they are making

20o v e r a 2 . 5 — - t h a t ’ s crazy. While those who came up

21w i t h t h e s y s t e m m i g ht say, “Fine, go to the No

22C h i l d L e f t B e h i n d s tandardized test criteria.”

23T h a t s a y s t h a t t h e student must have not met

24p r o f i c i e n c y l e v e l i n one of the areas on the No

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1C h i l d L e f t B e h i n d t est. We have a problem in West

2V i r g i n i a , a g a i n . O ur test is called the West Test,

3b e c a u s e i t i s o n l y given in West Virginia, and it

4h a s c o m e u n d e r h i g h criticism lately for being

5h i g h l y i n f l a t e d .

6 W h e n a s a m p le of students took the

7n a t i o n a l s t a n d a r d i z ed test, less than 30 percent

8m a d e p r o f i c i e n c y l e vels, almost 65 percent make it

9o n t h e W e s t T e s t . So those scores are grossly

10i n f l a t e d . T h o s e s t udents look like they are doing

11m u c h b e t t e r t h a n t h ey are, but yet we have to take

12s t u d e n t s w h o h a v e n ot met that proficiency level.

13 S o t h e s e c r iteria do not work in West

14V i r g i n i a . I h a v e t alked to colleagues; they do not

15w o r k i n m a n y , m a n y other places, and I think,

16p a r t i c u l a r l y , a r e u nfair to the rural students.

17 I i m p l o r e y ou to stay with what the law

18c l e a r l y s a y s , w h i c h is, first generation and low-

19i n c o m e a r e t h e s t u d ents we serve, and that they

20s h o w s o m e a c a d e m i c need. We have an academic need

21i n e a c h p r o g r a m , b u t it is based on that area, and

22t h e n e e d s i n t h a t a rea, and that is defined by the

23d i r e c t o r i n t h a t p r oject. It is what the law says,

24a n d i t i s w h a t w e r eally want to stay with.

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1 O u r s t u d e n t s design our shirts each

2s u m m e r , a n d l a s t s u mmer this one said, “We’re all

3s t a r s i n U p w a r d B o u nd.” She did not say, “Unless

4y o u a r e i n t h e e l e v enth grade, or unless you have

5h i g h e r t h a n a 2 . 5 G PA.” Please let us stay with

6t h e l a w .

7 Thank you.

8 D A V I D B E R G E RON: Allan Carlson.

9 A L L A N C A R L S ON: Good morning.

10 D A V I D B E R G E RON: Good morning.

11 A L L A N C A R L S ON: My name is Allan Carlson.

12I a m t h e P r e s i d e n t of the Howard Center for Family

13R e l i g i o n a n d S o c i e t y in Rockford, Illinois.

14 I a m a s o c i al historian, interested

15p a r t i c u l a r l y i n t h e interplay of public policy with

16f a m i l y f o r m a t i o n , f amily stability, and fertility.

17 F r o m 1 9 8 8 - 1 993, I served via appointment

18b y P r e s i d e n t R e a g a n on the National Commission of

19C h i l d r e n , a n d I a m the author of ten books on

20f a m i l y q u e s t i o n s .

21 A d e f e c t i n most analyses of the effects

22o f s t u d e n t l o a n d e b t is that they view student

23b o r r o w e r s o n l y a s i ndividuals, some discrete

24e x a m p l e s o f h o m o e c onomicus, rational actors moving

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1t h r o u g h t h e i r l i v e s alone.

2 I n f a c t , m o st young adults are in real, or

3f a c e p o t e n t i a l , n e w family relationships, notably

4a s a s p o u s e o r p a r e nt, which do or may complicate

5t h e i r l i v e s , a n d w h ich require a more complex

6c a l c u l u s . M o r e o v e r , such relationships are not

7o n l y i n d i v i d u a l c o n cerns. The future of every

8h u m a n s o c i e t y r e s t s on the successful creation of

9n e w f a m i l i e s . S o i n my allotted time, I would like

10t o e x p l o r e b r i e f l y the impact of student loan debt

11o n f a m i l y r e l a t i o n s hips.

12 N o t a b l y , t h e National Student Loan Survey

13c o n d u c t e d i n 2 0 0 2 f inds 14 percent of student

14b o r r o w e r s r e p o r t i n g that their debt burden has

15d e l a y e d m a r r i a g e , u p from 7 percent in 1991. Also

16i n 2 0 0 2 , 2 1 p e r c e n t of student borrowers have

17r e p o r t e d t h a t t h e i r debt burden has resulted in

18d e l a y s i n h a v i n g c h ildren, up from 12 percent in

191 9 9 1 . R e s e a r c h i n both Australia and the United

20S t a t e s s h o w s a c o r r elation between student loan

21d e b t a n d a r i s i n g p ropensity by persons, ages 20-

222 9 , t o c o n t i n u e l i v ing with their parents.

23 A s t u d y r e p orted in the Journal of

24M a r r i a g e a n d F a m i l y finds student debt burden among

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1y o u n g a d u l t s l i n k e d to a growing preference for

2c o h a b i t a t i o n r a t h e r than marriage. A 2005 inquiry

3b y t h e R o c h e s t e r I n stitute of Technology reports

4t h a t n e a r l y h a l f o f the young singles interviewed

5“ I n d i c a t e t h a t t h e i r current debts will probably

6d e l a y t h e i r p l a n s t o start a family.”

7 A r e c e n t s u rvey of so-called “marital

8s t r e n g t h s ” c l o s e l y associates debt burden with the

9q u a l i t y o f m a r r i a g e . 76 percent of self-described

10“ h a p p y c o u p l e s ” r e p ort that major debts are not a

11p r o b l e m f o r t h e m . However, 56 percent of self-

12d e s c r i b e d “ u n h a p p y couples” state that “Major debts

13a r e a p r o b l e m f o r u s.”

14 C r e i g h t o n U niversity Center for Marriage

15a n d F a m i l y p r o v i d e s a detailed study of 42

16p o t e n t i a l p r o b l e m s facing young, married couples.

17F o r r e s p o n d e n t s i n their 19-20's, debt brought into

18m a r r i a g e i s r a t e d t he biggest problem they face,

19b i g g e r , e v e n , t h a n in-laws.

20 [Laughter.]

21 A L L A N C A R L S ON: Respondents married one

22y e a r o r l e s s a l s o r eport debt brought into marriage

23a s t h e i r b i g g e s t p r oblem.

24 W e c o u l d a l so chart some preliminary

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1n u m b e r s t h a t r e f l e c t the impact of student debt on

2s u b s e q u e n t f a m i l y b ehaviors. The sharp decline of

3t h e m a r r i a g e r a t e b etween 1984 and 2003 is

4c o n c e n t r a t e d a m o n g persons ages 20 to 24, where the

5b u r d e n o f u n d e r g r a d uate debt would be the most

6p r o n o u n c e d . A s i n d icated earlier, the marriage-

7d i s c o u r a g i n g p r e s s u res of student debt may be a

8f a c t o r i n d r i v i n g u p the number of cohabitating

9c o u p l e s b y o v e r 2 0 0 percent since 1980.

10 F i n a l l y , d u ring the 1980s and 1990s, there

11w a s a d r a m a t i c f a l l in the relative fertility of

12A m e r i c a n w o m e n w i t h four-year college degrees, that

13i s , w h e n c o m p a r e d t o all other American women.

14T h i s r e l a t i v e d e c l i ne by nearly 25 percent isolates

15a s p e c i a l , n e w , a n t i-natalist, anti-child force

16f o u n d o n l y a m o n g c o llege-educated women. As cause,

17t h e e v i d e n c e p o i n t s to student loan debt.

18 T h o s e w h o c rafted the federal loan program

19i n t e n d e d t o s t i m u l a te investment in education, and

20t o i m p r o v e w h a t e c o nomists call “human capital,”

21t h a t i s , t h e e x i s t e nce, skills, and knowledge of

22i n d i v i d u a l s . I n p r actice, the system appears to be

23c o n t r i b u t i n g t o t h e postponement of marriage, to

24t h e p o s t p o n e m e n t o r the prevention of the birth of

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1c h i l d r e n . I n s h o r t , the existing system is anti-

2m a r r i a g e a n d a n t i - f amily.

3 S o w h a t s h o uld be done to relieve these

4u n i n t e n d e d c o n s e q u e nces? On behalf of my

5o r g a n i z a t i o n , I w a n t to endorse the five-point plan

6f o r m o r e m a n a g e a b l e student loans. I think you all

7k n o w t h e f i v e p o i n t s. I want to underscore, in

8p a r t i c u l a r , p o i n t n umber two, recognize that

9b o r r o w e r s w i t h c h i l dren have less income available

10f o r s t u d e n t l o a n p a yments, and adjust repayment

11r a t e s a c c o r d i n g l y .

12 I u r g e t h e Department to implement these

13p r o v i s i o n s f o r r e g u latory reforms.

14 Thank you.

15 D A V I D B E R G E RON: Thank you.

16 D A V I D B E R G E RON: Mary Jane Harris.

17 M A R Y J A N E H ARRIS: Good morning.

18 D A V I D B E R G E RON: Good morning.

19 M A R Y J A N E H ARRIS: My name is Mary Jane

20H a r r i s . I a m t h e D irector of the Department of

21A c c r e d i t a t i o n a t t h e American Physical Therapy

22A s s o c i a t i o n , a n d i n that capacity I serve as the

23p r i m a r y s t a f f l i a i s on to the Commission on

24A c c r e d i t a t i o n i n P h ysical Therapy Education,

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1c o m m o n l y k n o w n a s C APTE.

2 C A P T E i s a specialized programmatic

3a c c r e d i t i n g o r g a n i z ation that has been recognized

4b y t h e S e c r e t a r y s i nce 1977. CAPTE is not a Title

5I V g a t e k e e p e r . C A P TE currently accredits 209

6e n t r y - l e v e l e d u c a t i on programs for physical

7t h e r a p i s t s a t t h e p ost-baccalaureate level, and 233

8e d u c a t i o n p r o g r a m s for physical therapist

9a s s i s t a n t s a t t h e a ssociate degree level.

10 I n t h e i n t e rest of full disclosure, I

11s h o u l d a l s o s a y t h a t, in my free time, I currently

12s e r v e a s t h e C h a i r of the Board of Directors of the

13A s s o c i a t i o n o f S p e c ialized and Professional

14A c c r e d i t o r s , t h o u g h I am not here today as a

15r e p r e s e n t a t i v e o f A SPA.

16 I w o u l d l i k e to thank you for the

17o p p o r t u n i t y t o r e s p ond to the Secretary’s

18a n n o u n c e m e n t o f n e g otiated rulemaking related to

19t h e H i g h e r E d u c a t i o n Act, particularly as it might

20b e a f f e c t e d b y t h e report of the Commission on the

21F u t u r e o f H i g h e r E d ucation.

22 I t i s m y u n derstanding that the purpose of

23t h i s h e a r i n g i s t o gather information that will set

24t h e a g e n d a f o r t h e planned negotiated rulemaking,

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1a n d t o t h a t e n d I w ould like to make the following

2c o m m e n t s .

3 L e t m e b e g i n by adding my support to the

4c o m m e n t s m a d e b y o t her accreditation colleagues at

5t h i s , a n d p r e v i o u s , hearings regarding negotiated

6r u l e m a k i n g a b o u t S u bpart H, in the absence of

7l e g i s l a t i v e c h a n g e in that portion of the Higher

8E d u c a t i o n A c t . I , too, believe that negotiated

9r u l e m a k i n g a b o u t a c creditation at this time is

10p r e m a t u r e , i f o n l y because it may have to be

11r e p e a t e d a f t e r l e g i slative action that now appears

12t o h a v e b e e n p o s t p o ned until next year. Negotiated

13r u l e m a k i n g i s n o t a n inexpensive undertaking, so to

14d o i t t w i c e d o e s n o t seem to be in the best

15i n t e r e s t o f t h e a c c rediting community, the

16e d u c a t i o n a l c o m m u n i ty, the Department, or the

17t a x p a y e r .

18 I f , h o w e v e r , it is the Department’s

19d e t e r m i n a t i o n t o e n gage in negotiated rulemaking

20a b o u t a c c r e d i t a t i o n as announced, then there are

21t h r e e i s s u e s t h a t I would like to place on the

22r e c o r d f o r c o n s i d e r ation as that process occurs.

23 F i r s t , t h o u gh it never says so, the

24C o m m i s s i o n R e p o r t a ppears to be directed at

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1u n d e r g r a d u a t e e d u c a tion and at institutional

2a c c r e d i t a t i o n , y e t any changes that might be made

3i n t h e e x p e c t a t i o n s for accreditation will affect

4a l l a c c r e d i t o r s t h a t seek the Secretary’s

5r e c o g n i t i o n . C u r r e ntly, of the 60 accrediting

6o r g a n i z a t i o n s r e c o g nized by the Secretary,

7a p p r o x i m a t e l y 4 0 o f them are specialized

8p r o g r a m m a t i c a c c r e d itors and, of those, somewhere

9b e t w e e n 1 5 a n d 2 0 p rimarily accredit programs at

10t h e p o s t - b a c c a l a u r e ate level.

11 W h e r e i n s t i tutional accreditors are

12e n g a g e d i n t h e r e v i ew of a wide variety of

13i n s t i t u t i o n s w i t h d iverse missions, many degree

14o p t i o n s , a n d a p l e t hora of possible expected

15o u t c o m e s , s p e c i a l i z ed and programmatic accreditors

16a r e d i s c i p l i n e - s p e c ific, and typically review

17p r o g r a m s w i t h s i m i l ar missions and more focused

18e x p e c t e d o u t c o m e s . So accreditation is not a

19m o n o l i t h i c e n t e r p r i se, and therefore consideration

20m u s t b e g i v e n t o i d entification of those issues

21t h a t r i g h t l y p e r t a i n to all accrediting

22o r g a n i z a t i o n s , a n d those that may be more directly

23r e l a t e d t o i n s t i t u t ional accrediting organizations,

24o r t o s p e c i a l i z e d a nd programmatic accrediting

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1o r g a n i z a t i o n s . F u r ther, care must be taken to

2m i n i m i z e a n y u n i n t e nded consequences of a one-size-

3f i t s - a l l a p p r o a c h t o the regulation of accrediting

4o r g a n i z a t i o n s .

5 S e c o n d , t h e Futures Commission Report

6s p e a k s t o t h e n e e d for accreditation to serve the

7p u b l i c i n t e r e s t , b u t I would submit that there is

8n o s i n g l e p u b l i c i n terest. Indeed, there are many

9p u b l i c s , a n d m a n y i nterests, and accreditation must

10a d d r e s s n u m e r o u s a n d often competing elements of

11t h e p u b l i c s , a n d t h e interests of those publics.

12 F o r e x a m p l e , it is in the public interest

13t o p r e s e r v e c o n d i t i ons that enable institutions and

14p r o g r a m s t o r e v e a l their weaknesses to accreditors

15w i t h o u t f e a r o f p u b lic relations consequences, and

16t h e n l e t a c c r e d i t o r s supervise the improvements

17n e e d e d t o a d d r e s s t hose weaknesses. This feature

18o f a c c r e d i t a t i o n h a s enabled accreditors to promote

19i m p r o v e m e n t s i n e d u cation that have benefited

20m i l l i o n s o f s t u d e n t s.

21 O n t h e o t h e r hand, it is also important

22f o r a c c r e d i t o r s t o provide accurate and timely

23p u b l i c i n f o r m a t i o n , but my accreditation colleagues

24a n d I w o u l d a s k , “ W hat information is the public

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1s e e k i n g ? ” A n d , m o r e importantly, “do accreditors

2h a v e t h e i n f o r m a t i o n being sought?” Or, put

3a n o t h e r w a y , “ i s t h e information that accreditors

4h a v e a b o u t i n s t i t u t ions and programs really what

5t h e p u b l i c w a n t s ? ” It seems to me that we should

6h a v e a n s w e r s t o t h e se questions before enacting

7r e g u l a t i o n s t h a t p l ace added burden, both in time

8a n d c o s t , o n a c c r e d iting organizations,

9i n s t i t u t i o n s , a n d p rograms to provide information

10t h a t m a y c r e a t e m o r e problems than it solves, and

11m a y n o t b e w h a t t h e public needs or wants.

12 W h i c h b r i n g s me to my third comment. The

13C o m m i s s i o n R e p o r t c alls for, among other things, a

14s i g n i f i c a n t i n c r e a s e in the transparency of the

15a c c r e d i t a t i o n p r o c e ss, and goes so far as to

16r e c o m m e n d t h a t a c c r editation be made public in

17t h e i r e n t i r e t y . A s a programmatic accreditor, I do

18b e l i e v e t h a t t h e r e can be, and should be,

19a d d i t i o n a l i n f o r m a t ion available to the public

20a b o u t a c c r e d i t a t i o n decisions and findings. I

21d i s a g r e e , h o w e v e r , with the notion that making

22r e p o r t s a v a i l a b l e t o the public would be good

23p u b l i c p o l i c y .

24 T h e p r i m e r eason for this position is that

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1n o t a l l i n s t i t u t i o n s and programs are undergoing

2a c c r e d i t a t i o n s c r u t iny at the same time. Indeed,

3d e p e n d i n g o n t h e l e ngth of the accreditation cycle,

4a s f e w a s o n e i n t e n institutions and programs are

5b e i n g r e v i e w e d a t a ny one time. Herein lies the

6p o t e n t i a l f o r u n i n t ended consequences, when, for

7e x a m p l e , t h e r e a r e a number of programs in a given

8d i s c i p l i n e i n a g i v en city all competing for the

9s a m e s t u d e n t s , a n d only one of them is in the

10p o s i t i o n o f h a v i n g its “dirty laundry” out for all

11t o s e e .

12 A s i d e f r o m the potential for students to

13m i s i n t e r p r e t t h e i n formation in an accreditation

14r e p o r t , w h e r e i s t h e good public policy in having

15a n a c c r e d i t a t i o n d e cision become the catalyst for

16i m b a l a n c e s i n t h e l ocal education marketplace,

17s h o u l d t h e o t h e r p r ograms choose to exploit the

18s i t u a t i o n i n t h e i r recruitment practices?

19 F u r t h e r , a t what point should the

20i n f o r m a t i o n n o l o n g er be considered current, and

21t h e r e f o r e n e e d t o b e removed from public

22a v a i l a b i l i t y ? A n d , if it is removed at some

23r e a s o n a b l e t i m e , i t is likely, given the cycles,

24t h a t m o s t o f t h e t i me there will be no information

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1a v a i l a b l e f o r t h e p ublic to view.

2 I n s u m m a r y , the issue of transparency in

3t h e a c c r e d i t a t i o n p rocess raised by the Commission

4R e p o r t m a y b e v a l i d , but it is significantly more

5c o m p l i c a t e d t h a n i t may appear. Any negotiated

6r u l e m a k i n g a b o u t t h is issue must be done with the

7f u l l r e c o g n i t i o n o f all of the issues, and it must

8b e d o n e i n a m a n n e r that respects the diversity of

9a c c r e d i t i n g o r g a n i z ations, and that eliminates, to

10t h e e x t e n t p o s s i b l e , any unintended consequences.

11 Thank you.

12 D A V I D B E R G E RON: Thank you.

13 D A V I D B E R G E RON: Rolf Lundberg, please.

14 R O L F L U N D B E RG: Good morning.

15 M y n a m e i s Rolf Lundberg. I am Senior

16V i c e P r e s i d e n t o f C ongressional and Public Affairs

17a t t h e U n i t e d S t a t e s Chamber of Commerce.

18 T h e C h a m b e r is the world’s largest

19b u s i n e s s f e d e r a t i o n , representing more than 3

20m i l l i o n b u s i n e s s e s across the country.

21 T h a n k y o u f or the opportunity to appear

22t o d a y .

23 I a m h e r e t oday because of the priority

24t h a t t h e U . S . C h a m b er places on improving the

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1q u a l i t y o f e d u c a t i o n and investment in the

2w o r k f o r c e . N u m e r o u s indicators tell us that our

3e d u c a t i o n a l s y s t e m at all levels is not producing

4e n o u g h i n d i v i d u a l s with the skills to meet

5e m p l o y e r s ’ n e e d s . Our members consistently tell us

6t h a t d e f i c i e n c i e s i n the education and training of

7t h o s e t h a t t h e y n e e d to hire and advance are among

8t h e m o s t s e r i o u s p r oblems that they face.

9 T o a d d r e s s these problems, the U.S.

10C h a m b e r i s u n d e r t a k ing a number of initiatives.

11O n e o f t h e m i s a c o alition that we have formed, the

12C o a l i t i o n f o r a C o m petitive American Workforce,

13w i t h p r o v i d e r s o f p ostsecondary education that have

14a r e c o r d o f i n n o v a t ion and success in workforce

15e d u c a t i o n , t h e y a r e Corinthian College, Capella

16U n i v e r s i t y , D e V r y , and Kaplan.

17 W e a r e v e r y pleased that the Department

18h a s a n n o u n c e d i t s p lans to conduct a negotiated

19r u l e m a k i n g , a n d w e would like to participate. The

20F e d e r a l R e g i s t e r n o tice indicates a willingness to

21a d d r e s s r e g u l a t o r y changes suggested by the final

22r e p o r t o f t h e C o m m i ssion on the Future of Higher

23E d u c a t i o n . T h e C h a mber and the Coalition agree

24w i t h m a n y o f t h e f i ndings and conclusions in the

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1C o m m i s s i o n R e p o r t .

2 B e g i n n i n g w ith the observations in the

3p r e a m b l e t h a t , q u o t e, “Not everyone needs to go to

4c o l l e g e , ” b u t “ e v e r yone needs a postsecondary

5e d u c a t i o n , ” a n d t h a t too many college graduates

6“ e n t e r t h e w o r k f o r c e without the skills employers’

7s a y t h e y n e e d . ” T h e Commission has laid out a road

8m a p f o r r e f o r m . T h e Chamber and the Coalition

9s u p p o r t a w i d e - r a n g ing negotiated rulemaking that

10c o n s i d e r s t h e r e c o m mendations in the Commission’s

11f i n a l r e p o r t .

12 W i t h t h a t , we propose that the negotiated

13r u l e m a k i n g a g e n d a i nclude the following subjects.

14 F i r s t o f a l l, transfer of credit. One of

15t h e a r e a s t h e C o m m i ssion rightly emphasizes is

16t r a n s f e r o f c r e d i t . This is a problem because of

17c h a n g e s i n t h e n e e d s of today’s postsecondary

18s t u d e n t s a n d e m p l o y ers. The Commission Report

19c a l l s f o r r e d u c i n g barriers to transfer, and

20a l l o w i n g s t u d e n t s t o move more easily between and

21b a c k i n t o i n s t i t u t i ons. As the final report notes,

22t h i s w o u l d r e d u c e c osts, expand access, reduce time

23t o c o m p l e t i o n , a n d improve institutional

24t r a n s p a r e n c y . I t w ould also improve the ability of

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1t h e p o s t s e c o n d a r y e ducational system to respond

2e f f i c i e n t l y t o w o r k force and employer needs.

3 T w o r e g u l a t ory reforms would begin

4s i g n i f i c a n t l y t o a d dress these problems, in our

5v i e w . F i r s t , i n s t i tutions of higher education that

6p a r t i c i p a t e i n t h e Title IV student financial aid

7p r o g r a m s s h o u l d b e required to establish clear

8p o l i c i e s o n t r a n s f e r of credit and to make those

9p o l i c i e s p u b l i c . S econdly, such institutions

10s h o u l d n o t b e p e r m i tted to deny credit transfers

11b a s e d s o l e l y o n t h e accreditation of the

12i n s t i t u t i o n f r o m w h ich the student is seeking to

13t r a n s f e r c r e d i t s , p rovided that the institution is

14a c c r e d i t e d b y a n a g ency recognized by the

15S e c r e t a r y .

16 M a n y i n s t i t utions refuse even to evaluate

17t h e c r e d i t s e a r n e d by students at other

18i n s t i t u t i o n s , b a s e d solely on those institutions’

19a c c r e d i t a t i o n . T h e re are no legitimate reasons for

20t h e s e p r a c t i c e s . W e believe that the Department

21h a s s u f f i c i e n t e x i s ting statutory authority to

22a d o p t r e g u l a t o r y c h anges to facilitate transfer of

23c r e d i t s i n t h e c o n d itions for institutional

24p a r t i c i p a t i o n i n t h e Title IV programs and the

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1a c c r e d i t i n g a g e n c y recognition requirements.

2 A s e c o n d s u bject to address is

3t r a n s p a r e n c y a n d a c countability. These are also

4m a j o r t h e m e s i n t h e Commission’s final report. As

5t h e C o m m i s s i o n f i n d s, students and parents lack

6g o o d i n f o r m a t i o n o n the value that colleges will

7p r o v i d e t h e m , a n d p olicymakers lack data to help

8t h e m d e c i d e w h e t h e r the national investment in

9h i g h e r e d u c a t i o n i s paying off.

10 T h e C o m m i s s ion proposes the creation of a

11c o n s u m e r - f r i e n d l y i nformation database that would

12p r o t e c t t h e p r i v a c y of students, but still be a

13v i t a l t o o l f o r a c c o untability, policymaking, and

14c o n s u m e r c h o i c e . T he U.S. Chamber and our

15C o a l i t i o n e n d o r s e t hese concepts. The members of

16t h e C o a l i t i o n a l r e a dy live with a great deal of

17t r a n s p a r e n c y a n d o b jective accountability--measures

18f o r w h a t m a t t e r s m o st, student achievement.

19 W e s u p p o r t the Commission’s interest in

20e x p l o r i n g h o w a c c r e ditation can better measure

21q u a l i t y t h r o u g h t h e use of student outcomes, and

22i m p r o v e a c c e s s t o i nnovative learning methods, such

23a s o n l i n e e d u c a t i o n , while ensuring quality.

24H i g h e r e d u c a t i o n i n stitutions and accrediting

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1a g e n c i e s c a n d o m o r e in this area. We believe that

2t h e D e p a r t m e n t a l r e ady has sufficient statutory

3a u t h o r i t y t o d e v e l o p and adopt regulations

4e m b o d y i n g t h e s e p r o posals in Sections 485 and 486

5o f t h e H i g h e r E d u c a tion Act.

6 T h e n e x t s u bject the negotiated rulemaking

7s h o u l d a d d r e s s , i n our view, is reform of the

8f i n a n c i a l a i d d e l i v ery system. The Commission

9f o u n d t h a t t h e c u r r ent financial aid system is a

10m a z e , c o n f u s i n g , c o mplex, inefficient, and

11d u p l i c a t i v e . E v e n more crucially, the system

12f r e q u e n t l y d o e s n o t direct aid to students who

13t r u l y n e e d i t . T h e Chamber supports the

14C o m m i s s i o n ’ s c a l l f or reform in this area.

15 O n e a r e a f o r the Department to examine is

16t h e s y s t e m f o r t h e delivery of Pell Grants to

17s t u d e n t s w h o w i s h t o accelerate progress toward

18t h e i r e d u c a t i o n a l o bjectives by attending on a

19y e a r - r o u n d b a s i s . The financial aid system remains

20g e a r e d t o t r a d i t i o n al students on a conventional

21n i n e - m o n t h a c a d e m i c calendar. The negotiated

22r u l e m a k i n g p r e s e n t s a good opportunity to determine

23t h e e x t e n t t o w h i c h , under the current statute,

24P e l l G r a n t d i s b u r s e ments can be made available

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1y e a r - r o u n d .

2 A n d f i n a l l y , we propose that the

3n e g o t i a t e d r u l e m a k i ng agenda involve 90/10 Rule.

4T h e C o m m i s s i o n ’ s f i nal report makes a number of

5p o i n t s t h a t s u p p o r t regulatory reform of the 90/10

6R u l e . T h e p r e a m b l e to the Commission’s report

7s t a t e s t h a t d i s t i n c tions based upon ownership

8s t r u c t u r e a r e i r r e l evant, except to an academic

9e s t a b l i s h m e n t p r e o c cupied with them, and that for-

10p r o f i t i n s t i t u t i o n s are one of the new paradigms

11t h a t h a v e d e v e l o p e d to adapt to the challenges that

12a r e a t t h e h e a r t o f the Commission’s concerns. The

13C h a m b e r w h o l e h e a r t e dly agrees.

14 I n a d d i t i o n , one of the central themes of

15t h e C o m m i s s i o n ’ s r e port is access to postsecondary

16e d u c a t i o n , h o w t o p romote it for under-served and

17n o n - t r a d i t i o n a l g r o ups, especially low-income,

18m i n o r i t y , a n d a d u l t students. The Commission

19f o c u s e s o n t h e p u r c hasing power of the Pell Grant,

20y e t i t n o t e s t h a t t he value of the Pell Grant can

21b e u n d e r c u t b y t u i t ion increases. All of these

22p o i n t s s u g g e s t t h a t reform of the regulations

23i m p l e m e n t i n g t h e 9 0 /10 Rule would further the goals

24o f t h e C o m m i s s i o n . Experience under the Rule shows

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1t h a t i t m e a s u r e s n o t institution integrity and

2q u a l i t y , b u t t h e s o cio-economic status of students,

3t h a t i s , h o w m u c h t hey qualify for need-based aid

4l i k e P e l l G r a n t s . The Rule thus incentivizes

5i n s t i t u t i o n s e i t h e r not to serve the most needy

6s t u d e n t s , o r t o r a i se their tuition, results that

7a r e c o n t r a r y t o a c h ieving the goals of access and

8a f f o r d a b i l i t y .

9 L e a v i n g t o the side the congressional

10d e b a t e o v e r r e p e a l of the 90/10 Rule, the

11D e p a r t m e n t c a n a n d should, in our view, revise its

12c u r r e n t r e g u l a t i o n s to lessen their

13c o u n t e r p r o d u c t i v e i mpact, and thus the degree to

14w h i c h t h e y s i n g l e o ut institutions on the basis of

15a n i r r e l e v a n t f a c t o r like ownership structure.

16T h e r e a r e a n u m b e r of anomalies in the current

17r e g u l a t i o n s t h a t i m pede access and affordability.

18T h e n e g o t i a t e d r u l e making offers an opportunity to

19c o r r e c t t h e s e p r o b l ems.

20 T h a n k y o u a gain for the opportunity to

21p r e s e n t o u r v i e w s o n the negotiated rulemaking that

22t h e D e p a r t m e n t i s p lanning. We do hope to work

23c l o s e l y w i t h t h e D e partment to make progress on

24t h e s e i m p o r t a n t i s s ues.

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1 Thank you.

2 D A V I D B E R G E RON: Thank you very much.

3 D A V I D B E R G E RON: Cynthia Littlefield.

4 C Y N T H I A L I T TLEFIELD: Good morning.

5 D A V I D B E R G E RON: Good morning.

6 C Y N T H I A L I T TLEFIELD: My name is Cynthia

7L i t t l e f i e l d . I a m the Director of Federal

8R e l a t i o n s o f t h e A s sociation of Jesuit Colleges and

9U n i v e r s i t i e s .

10 I n t h i s c a p acity we represent the 28

11J e s u i t c o l l e g e s a n d universities across the United

12S t a t e s , a n d w e a r e also affiliated with over 100

13i n t e r n a t i o n a l J e s u i t colleges and universities.

14 I m i g h t a d d that today I think it is

15r e m a r k a b l e t h a t o u r nation’s students have been

16p a r t i c i p a t i n g i n t h is process. I want to commend

17t h e m f o r t h e i r e f f o rts to come here today. I think

18t h a t i s t h e r i g h t t hing to do.

19 A J C U a p p r e c iates the opportunity to

20c o m m e n t b e f o r e t h e Department of Education,

21p a r t i c u l a r l y o n t h e implementation of ACG and SMART

22G r a n t s , b e c a u s e w e know that there is some

23c o n f u s i o n o n o u r c a mpuses across the country

24c o n c e r n i n g r e g u l a t o ry guidelines. Our main

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1p r i o r i t y i s t o e n s u re that regulatory complications

2f o r t h e A C G a n d S M A RT Grant programs do not

3i n t e r f e r e o r l i m i t student participation. AJCU

4h o p e s t h a t o u r c o m m ents will assist in these

5e f f o r t s .

6 T h e f i r s t g roup of issues are related to

7t h e d e f i n i t i o n o f “ academic year.” Recent

8c o l l e a g u e l e t t e r s h ave started to improve that

9d e f i n i t i o n , b u t c l a rification needs to be

10s u p p l e m e n t e d r e l a t e d to class progression. Several

11a r e a s o f c o n f u s i o n are the following:

12 N u m b e r o n e , the institutional definition

13o f “ c l a s s p r o g r e s s i on” does not always coincide

14w i t h t h e S t a f f o r d L oan definition of “academic

15y e a r . ”

16 N u m b e r t w o , refinement of the utilization

17o f n o n - c l a s s r o o m c r edits, i.e., advanced placement,

18i n t e r n a t i o n a l b a c c a laureates, and life learning

19c r e d i t s t o e n c o u r a g e advanced course work, and

20i n c l u d e f u l l e l i g i b ility for grant funding.

21 N u m b e r t h r e e, the encouragement defined by

22t h e r e g u l a t i o n s t o support two full years of study

23f o r t h e S M A R T G r a n t , as related to bachelor’s and

24m a s t e r ’ s p r o g r a m s , and students eligibly for the

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1a c c e l e r a t e d p r o g r a m s degree conferment.

2 T h e n e x t s e t of issues that we would like

3t o d i s c u s s a r e t h e transfer credits for transfer

4s t u d e n t s . T h e s e i s sues are similar to the first

5s e t o f i s s u e s , b u t they are complicated by the

6v a r i e t y o f e x t e r n a l factors related to transfers of

7c r e d i t , s u c h a s :

8 N u m b e r o n e , timing related to the posting

9o f t r a n s f e r c r e d i t varies by the completion of the

10n e c e s s a r y d o c u m e n t a tion. Class standing can be

11i m p a c t e d b y t h e l a t e arrival of this documentation,

12a n d c a u s e g r e a t c o m plications for the universities.

13 N u m b e r t w o , some internal and external

14t r a n s f e r s t u d e n t s w ill regress in their class

15s t a n d i n g d u e t o t h e new program academic

16r e q u i r e m e n t . W e n e ed to encourage transfers to the

17t a r g e t e d m a j o r w i t h out the risk of penalty due to

18r e g r e s s i o n .

19 A l s o , i f a student has received an ACG at

20a p r e v i o u s i n s t i t u t ion, does the new institution

21n e e d t o d o c u m e n t a rigorous high school curriculum?

22W e a s k t h a t q u e s t i o n.

23 N u m b e r t h r e e, the calculation of GPA, as

24r e l a t e d t o t r a n s f e r credits and international

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1s t u d y , n e e d s t o b e expanded to assist students in

2r e t a i n i n g e l i g i b i l i ty and foster exploration.

3 A n d f i n a l l y , number four, NSLDS procedures

4n e e d t o b e f u l l y d o cumented and integrated into the

5r e g u l a r t r a n s f e r m o nitoring process.

6 I t i s e s p e c ially true that additional

7e f f o r t s n e e d t o b e expanded related to the process

8o f a w a r d i n g t h e A C G . To encourage students and

9i n s t i t u t i o n s t o m a x imize the impact of the ACG,

10e a s y i d e n t i f i c a t i o n of eligible students need to be

11e s t a b l i s h e d . T h e p rocess of student self-

12i d e n t i f y i n g , o r t h e financial aid office being

13r e s p o n s i b l e f o r d o c umenting that information is

14s o m e w h a t f l a w e d . A centralized clearinghouse,

15p o s s i b l y , c o u l d b e responsible for determining that

16e l i g i b i l i t y t h a t w o uld best serve our students.

17 W i t h t h e i s sue of GPAs, it has been

18m e n t i o n e d e a r l i e r i n the transfer discussions,

19t h e r e a r e a d d i t i o n a l aspects of GPAs that need to

20b e e x p l o r e d . N u m b e r one, the exploration and

21e x p a n s i o n o f a c a d e m ic curriculum needs to be

22e n c o u r a g e d a n d n o t limited by GPA requirements.

23S t u d e n t s n e e d t o b e able to take demanding course

24w o r k w i t h o u t f e a r o f losing need-based funding.

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1T h i s i n c l u d e s t h e p roper utilization of pass/fail

2o p t i o n s i n s o m e c a s es and other similar programs.

3A n d n u m b e r t w o , t h e timing of the regulations of

4G P A s , a s r e l a t e d t o the disbursement of funds,

5n e e d s t o b e r e a s o n a ble and manageable.

6 T h e S M A R T G rants also have a student major

7r e q u i r e m e n t . W e h a ve suggested adding on a few of

8n e w , o t h e r r e q u i r e m ents that fall under the broader

9d e f i n i t i o n s , s c i e n c e, math, technology, et cetera,

10s u c h a s e n v i r o n m e n t al science, digital

11c o m m u n i c a t i o n s a n d multimedia technology,

12b i o p h y s i o l o g y , g e r o ntology, nutrition sciences,

13p s y c h o p h a r m a c o l o g y , anthropology, and physical

14a n t h r o p o l o g y , t o c i te but a few.

15 W e a l s o b e l ieve that clarity and expansion

16o f t h e d i s t i n c t i o n between intended declared majors

17a n d t h e r e q u i r e d p r ogression of course work between

18d o u b l e , t r i p l e m a j o rs is also critical for a smooth

19r u n n i n g p r o g r a m .

20 F o r f e d e r a l student loans, AJCU would not

21b e h e r e i f w e w o u l d not mention that our primary

22c o n c e r n h a s a l w a y s been to minimize student loan

23d e b t . W h i l e r e c e n t ly passed student loan interest

24r a t e s w i l l i n d e e d c ontribute to further debt burden

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1f o r o u r n a t i o n ’ s s t udents, we can try to minimize

2t h a t d e b t f o r s t u d e nts who are currently at risk.

3 A J C U i s s u p portive of simplifying the

4p r o c e s s f o r v a r i o u s repayment, deferment, and

5h a r d s h i p o p t i o n s f o r these impacted students, and

6w e w o u l d e n c o u r a g e that to be discussed in one of

7t h e n e g o t i a t e d r u l e making sessions.

8 W e g r e a t l y appreciate the opportunity to

9s p e a k h e r e t o d a y b e fore the Department of

10E d u c a t i o n . O u r a s s ociation has been active in this

11p r o c e s s , a n d w e a p p reciate Loyola University

12h o s t i n g o n e o f t h e hearings, in addition to two of

13o u r i n s t i t u t i o n s w h o have already testified,

14M a r q u e t t e U n i v e r s i t y and Loyola Chicago University.

15 A n d f i n a l l y , may I say that AJCU hopes

16t h a t w e c a n h a v e a n active participation in this

17w o n d e r f u l p r o c e s s c alled “negotiated rulemaking,”

18a n d I t h a n k y o u a l l today for listening to my

19c o m m e n t s , a n d f o r h aving us all here today after a

20l o n g n i g h t f o r a l l of us with limited sleep.

21 T h a n k y o u v ery much.

22 D A V I D B E R G E RON: Thank you, Cynthia.

23 W e a r e g o i n g to take a ten-minute break.

24A s w e a r e d o i n g t h a t, let me say two things. One

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1i s , C y n t h i a , w e a r e trying to answer the question

2a b o u t r e l i a n c e o n p rior institutions, we have said

3y o u c a n r e l y o n p r i or institutions for

4d e t e r m i n a t i o n o f s t udent’s eligibility for ACG, and

5t h e y c a n r e l y o n t h at for documentation, just so

6f o l k s k n o w t h a t . I , like Cynthia, have enjoyed the

7s t u d e n t s ’ c o m m e n t s , even though they are from the

8U n i v e r s i t y o f C o n n e cticut.

9 [Laughter.]

10 D A V I D B E R G E RON: Having graduated from the

11U n i v e r s i t y o f R h o d e Island, I always get concerned

12w h e n m y n e i g h b o r s f rom Connecticut come out in such

13n u m b e r s , i t s p e a k s so well.

14 O n e o f t h e things I have appreciated,

15t h o u g h , t h r o u g h o u t this process, is the comments of

16t h e s t u d e n t s , t h e y have been very helpful to us as

17w e h a v e t h o u g h t a b o ut the issues around student

18d e b t , a n d t h e y h a v e all been very well-spoken, and

19r e f l e c t v e r y w e l l o n our college students. So

20b e f o r e t h e y w e n t b a ck to the Northeast, I wanted to

21m a k e s u r e a n d c o m p l iment them. I know we will hear

22f r o m m o r e s t u d e n t s throughout the day.

23 W i t h t h a t , a ten-minute break.

241 D A V I D B E R G E RON: If you want to continue

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1t o c h a t , y o u c a n g o outside into the other room,

2b u t w e d o w a n t t o b e courteous to the folks coming

3t o t e s t i f y .

4 D A V I D B E R G E RON: Jim Tolgert.

5 JIM TOLGERT: Good morning.

6 M y n a m e i s Jim Tolgert, and I am here

7r e p r e s e n t i n g t h e C a reer College Association as the

8C h a i r m a n o f t h e B o a rd of Directors. However, my

9d a y j o b i s I a m t h e Chief Executive Officer of the

10E d u c a t i o n F u t u r e s G roup, an investor in private

11p o s t s e c o n d a r y e d u c a tion schools.

12 I t i s a p l e asure to present a summary of

13m y c o m m e n t s , w h i c h I have submitted also in

14w r i t i n g .

15 O n b e h a l f o f the Career College

16A s s o c i a t i o n , I w o u l d like to thank you for this

17o p p o r t u n i t y t o c o m m ent on the final report from the

18C o m m i s s i o n o n t h e F uture of Higher Education, and

19t h e a g e n d a f o r t h e upcoming negotiated rulemaking

20s e s s i o n s .

21 C C A i s a v o luntary membership organization

22o f p r i v a t e p o s t s e c o ndary educational institutions

23t h a t c o m p r i s e t h e f or-profit sector of higher

24e d u c a t i o n . C C A ’ s 1 ,400 members educate and support

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1n e a r l y 2 m i l l i o n s t udents each year for employment

2i n m o r e t h a n 2 0 0 o c cupational fields. All CCA

3m e m b e r s m u s t b e l i c ensed in the state in which they

4a r e l o c a t e d , a n d a c credited by a national or

5r e g i o n a l a c c r e d i t i n g agency recognized by the U.S.

6D e p a r t m e n t o f E d u c a tion.

7 T h e C o m m i s s ion on the Future of Higher

8E d u c a t i o n h a s p e r f o rmed a valuable service by

9e x a m i n i n g k e y i s s u e s related to how postsecondary

10e d u c a t i o n c a n b e t t e r address the needs of our

11n a t i o n i n t h e 2 1 s t C entury. The diverse points of

12v i e w p r e s e n t e d t o t he Commission and the frank

13d i a l o g u e a m o n g t h e Commission members produce a

14r e p o r t t h a t s h o u l d stimulate important improvements

15t o o u r h i g h e r e d u c a tion system. It takes common

16s e n s e , a s w e l l a s a market-based approach to higher

17e d u c a t i o n i n t h e b e st interests of students,

18e m p l o y e r s , a n d t a x p ayers.

19 T h e C o m m i s s ion’s recommendations coalesced

20a r o u n d t h e t h r e e b r oad themes that have been at the

21c e n t e r o f C C A ’ s l e g islative agenda for the last

22f o u r y e a r s : a c c e s s i bility, accountability, and

23a f f o r d a b i l i t y . T h e se themes are at the core of the

24m i s s i o n o f t h e c a r e er college sector.

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1 F i r s t , a c c e ssibility. As a group, we

2p r o v i d e a c c e s s t o c olleges for a disproportionate

3s h a r e o f m i n o r i t y a nd non-traditional students. We

4p r o m o t e t h e C o m m i s s ion’s recommendations to

5f a c i l i t a t e f u r t h e r higher education for these

6s t u d e n t s .

7 S e c o n d , C C A supports the Commission’s

8f i n d i n g s o n t h e n e e d for increased accountability

9a n d t r a n s p a r e n c y i n postsecondary education. We

10w e r e p l e a s e d t h a t C hairman Miller mentioned the

11i n s t i t u t i o n a l r e p o r t card that CCA proposed several

12y e a r s a g o a s o n e e x ample of what a good

13a c c o u n t a b i l i t y a n d consumer information piece could

14l o o k l i k e . C C A s u p ports the Commission’s

15s u g g e s t i o n t h a t i n s titutions report their retention

16a n d t h e i r j o b p l a c e ment numbers. This is a valid

17a c c o u n t a b i l i t y m e a s urement.

18 T h i r d , a f f o rdability. We were pleased

19t h a t t h e C o m m i s s i o n focused attention on the

20t r a n s f e r o f c r e d i t barriers students face. The

21D e p a r t m e n t o f E d u c a tion must address the

22d i s c r i m i n a t i o n t h a t students encounter when they

23s e e k t o t r a n s f e r c r edits from institutions that are

24n a t i o n a l l y a c c r e d i t ed to institutions that are

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1r e g i o n a l l y a c c r e d i t ed. Denials and deterrents to

2c r e d i t t r a n s f e r s a r e unfair to students, inhibit

3s t u d e n t c o m p l e t i o n , and drive up the cost of

4p o s t s e c o n d a r y e d u c a tion by forcing students to take

5a n d p a y f o r t h e s a m e course twice. This does not

6m a k e m e h a p p y a s a taxpayer or as a parent.

7 I n f o r m a l a t tempts to address this issue

8h a v e f a i l e d t o a d e q uately address this situation.

9B o t h t h e H o u s e a n d Senate address this issue in the

10r e a u t h o r i z a t i o n b i l ls, and we hope that when

11C o n g r e s s r e t u r n s t o the task of reauthorizing the

12H i g h e r E d u c a t i o n A c t, it will legislate in this

13a r e a . W e h o p e t h e Secretary will also explore

14o t h e r m e a n s t o p r o m ote fair and transparent

15t r a n s f e r o f c r e d i t policies.

16 T h e C a r e e r College Association agrees with

17t h e C o m m i s s i o n t h a t all stakeholders in higher

18e d u c a t i o n w o u l d b e n efit from better coordination

19b e t w e e n t h e n e e d s o f employers and educational

20i n s t i t u t i o n s . W e h ave for years worked closely

21w i t h t h e e m p l o y e r s in our communities to ensure

22t h a t o u r s t u d e n t s g raduate with the specific skill

23s e t s n e e d e d t o p r o g ress in their careers, and our

24i n s t i t u t i o n s a r e a b le to move quickly to respond to

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1m a r k e t n e e d s b y c r e ating new programs or revising

2c u r r e n t o n e s .

3 I f I m a y n o w address a few issues related

4t o t h e n e w i n t e r i m regulations. The Career College

5A s s o c i a t i o n i s p l e a sed to have new grant programs

6a v a i l a b l e t o s t u d e n ts. We understand the time

7c o n s t r a i n t s f a c i n g the Secretary in publishing

8i n t e r i m r e g u l a t i o n s , and look forward to the

9n e g o t i a t e d r u l e m a k i ng process to make some

10i m p r o v e m e n t t o t h e regulations.

11 W e u r g e t h e mandatory participation

12r e q u i r e m e n t s b e d r o pped for both the ACG and SMART

13G r a n t p r o g r a m s , C o n gress did not mandate

14p a r t i c i p a t i o n . W e believe the Department should

15t r e a t t h e s e t w o g r a nt programs in the same manner

16a s a l l o t h e r T i t l e IV HEA assistance programs by

17a l l o w i n g i n s t i t u t i o ns to choose whether or not to

18p a r t i c i p a t e . A d d i t ionally, we urge the Secretary

19t o r e c o n s i d e r t h e r egulatory restriction placed on

20t h e A C G t h a t l i m i t s them to degree-granting

21p r o g r a m s .

22 I n c l o s i n g , the Commission has given the

23h i g h e r e d u c a t i o n c o mmunity the beginnings of a

24r o a d m a p t o i m p r o v i n g the education marketplace. We

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1l o o k f o r w a r d t o w o r king with you, both in the

2u p c o m i n g n e g o t i a t e d rulemaking sessions and

3t h r o u g h o u t t h e f u t u re, to implement some of these

4p r o p o s a l s f o r t h e b enefit of students and the

5A m e r i c a n e c o n o m y .

6 Thank you.

7 D A V I D B E R G E RON: Thank you.

8 D A V I D B E R G E RON: Dallas Martin.

9 D A L L A S M A R T IN: David, Dan, good morning.

10 D A V I D B E R G E RON: Good morning.

11 D A N M A D Z E L A N: Good morning.

12 D A L L A S M A R T IN: As you know, my name is

13D a l l a s M a r t i n , a n d I am currently the President of

14t h e N a t i o n a l A s s o c i ation of Student Financial Aid

15A d m i n i s t r a t o r s .

16 I a p p e a r b e fore you today on behalf of the

17m o r e t h a n 3 , 0 0 0 p o s tsecondary educational

18i n s t i t u t i o n s a n d o t hers with related interests to

19o u r m e m b e r s o f N A S F AA to offer our suggestions for

20i s s u e s t h a t s h o u l d receive consideration during the

21D e p a r t m e n t o f E d u c a tion’s upcoming negotiated

22r u l e m a k i n g s e s s i o n , particularly as it relates to

23t h e i m p l e m e n t a t i o n of the Academic Competitiveness

24G r a n t a n d t h e N a t i o nal SMART Grant Program, as well

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1a s s o m e a d d i t i o n a l provisions that are included in

2t h e H i g h e r E d u c a t i o n Reconciliation Act of 2005.

3 L e t m e n o t e that we appreciate the

4D e p a r t m e n t ’ s s o l i c i tation of agenda items, and we

5b e l i e v e t h a t t h i s p rocess will yield regulations as

6i t h a s i n t h e p a s t that will help institutions to

7d e l i v e r s t u d e n t a i d funds to eligible students in a

8t i m e l y m a n n e r , f u l f illing the purposes of

9n e g o t i a t e d r u l e m a k i ng, and to develop procedures

10t h a t w o r k i n t h e i n stitutional setting and remain

11w i t h i n t h e s t a t u t o r y burdens. Further, we hope

12t h a t t h e D e p a r t m e n t will use the negotiated

13r u l e m a k i n g s t r u c t u r e to ensure that the concerns of

14a l l i n t e r e s t e d p a r t ies may be taken into account as

15t h e s e n e w p r o g r a m p rovisions are implemented.

16 W e w o u l d l i ke to offer the following

17l i s t i n g o f i t e m s f o r your considerations. Let me

18b e g i n w i t h t h e r e g u lations governing Academic

19C o m p e t i t i v e n e s s G r a nt and the National SMART Grant

20p r o g r a m s . N o t s u r p risingly, most of the questions

21t h a t w e h a v e r e c e i v ed from our members pertain to

22a c a d e m i c y e a r p r o g r ession, advanced placement

23c r e d i t s , a n d r i g o r o us secondary school program, but

24w e a r e a l s o n o w b e i ng asked more about transfer

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1s t u d e n t e l i g i b i l i t y and determination of the GPA in

2a v a r i e t y o f s i t u a t ions. We believe that these

3q u e s t i o n s i n p a r t i c ular are going to continue to

4a r i s e n o w t h a t w e h ave begun to implement the

5p r o g r a m s , p a r t i c u l a rly as we move into the second

6s e m e s t e r , o r s p r i n g terms, later this year. For

7t h i s r e a s o n , w e w o u ld hope that all of the ACG and

8S M A R T G r a n t P r o g r a m regulations would be open

9d u r i n g t h e t i m e o f the negotiations.

10 There a r e also other regulations under

11t h e H E R A A c t t h a t w e also have some concerns about,

12a n d t h e s e a r e t h e t opics that we would suggest be

13a l s o a d d e d t o t h e n egotiated rulemaking agenda.

14F i r s t , t h e G r a d P L U S Program, and particularly we

15a r e c o n c e r n e d a b o u t the issues of both entrance and

16e x i t l o a n c o u n s e l i n g, as well as what might be the

17a p p r o p r i a t e r e p a y m e nt period start date for

18s t u d e n t s w h o h a v e G rad PLUS loans, because it is

19m u c h d i f f e r e n t , o b v iously, with those students than

20i t i s w i t h t h e w a y we think of that program with

21t r a d i t i o n a l p a r e n t s .

22 A n o t h e r t o p ic is the telecommunications

23v e r s u s c o r r e s p o n d e n ce instruction. Given the many

24i n s t r u c t i o n a l v a r i a tions that exist today, as well

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1a s t h e v a r i o u s t e c h nologies that are in use, we

2b e l i e v e t h a t t h i s i s an area that needs to be very

3c a r e f u l l y e x a m i n e d , and the community input would

4b e i n v a l u a b l e . W e want to make certain that, first

5o f a l l , w e d o n o t u nnecessarily limit someone who

6h a s g o o d s u g g e s t i o n s and programs, but we also want

7t o e n s u r e t h a t t h e r e is also program integrity

8m a i n t a i n e d , r e g a r d l ess of telecommunications or

9c o r r e s p o n d e n c e i n s t ruction.

10 A n o t h e r t o p ic is the new loan discharges,

11p a r t i c u l a r l y t h e a p proach taken in the interim

12f i n a l r e g u l a t i o n s r egarding the requirement for

13o b t a i n i n g t h e d i s c h arge based upon the liability of

14i d e n t i t y t h e f t . T h is is an area that is new, it is

15i n c r e a s i n g , a n d i t is one that we think needs to be

16l o o k e d a t v e r y c a r e fully so that it is consistent

17w i t h o t h e r i n d u s t r y standards.

18 A n o t h e r t o p ic is the post-withdrawal and

19l a t e d i s b u r s e m e n t r equirements. We are

20p a r t i c u l a r l y c o n c e r ned about a number of issues

21h e r e , b u t o n e i s , “ Why are grant funds now subject

22t o t h e n e w c o n f i r m a tion requirement when we can

23f i n d n o r e f e r e n c e t o the grant program in the

24s t a t u t e i t s e l f ? ”

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1 I n a d d i t i o n to these and other topics, let

2m e a l s o g i v e y o u , i n the interest of time, two

3o t h e r b r o a d t o p i c s that are not part of the

4r e g u l a t i o n s , b u t t h at we had hoped would be on your

5a g e n d a . T h e f i r s t is the establishment of “safe

6h a r b o r ” l a n g u a g e f o r institutions. As you are all

7a w a r e , t h e i m p l e m e n tation of the HERA provisions

8o c c u r r e d i n a v e r y compressed timeframe. And while

9I w a n t t o e x p r e s s m y sincere appreciation to you

10a n d t o y o u r c o l l e a g ues at the Department for the

11e f f o r t s t h a t t h e y h ave made, and that you have

12e x p e n d e d i n t e r m s o f implementing these new grant

13p r o g r a m s , a n d t o d e velop these interim final

14r e g u l a t i o n s i n l e s s than eight months, I also would

15r e m i n d y o u t h a t o u r members, as well, have had to

16p r o c e e d i n i m p l e m e n ting these programs and making

17d e c i s i o n s b a s e d u p o n their reading of the statute,

18a n d w i t h l e s s t h a n complete regulatory guidance.

19G i v e n t h e f a c t t h a t I believe that everyone has

20p r o c e e d e d w i t h a g o od faith effort to make

21p r e l i m i n a r y d e c i s i o ns consistent with the reading

22o f t h e l a w , r e g u l a t ory language should be developed

23d u r i n g t h i s p r o c e s s to protect parties against

24e n f o r c e m e n t s t a n d a r ds that were not applicable or

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1a v a i l a b l e w h e n t h e s e actions were taken.

2 A s e c o n d b r oad topic that I would also

3h o p e t h a t y o u w o u l d consider that are not part of

4t h e c u r r e n t r e g u l a t ions, but we have heard many

5p e o p l e c o m m e n t o n t oday, and that would be to

6m o d i f y t h e r e p a y m e n t options for borrowers with

7s t u d e n t l o a n d e b t b urden. We would urge that the

8n e g o t i a t e d r u l e m a k i ng committees carefully examine

9r e f o r m s t h a t c a n b e made under current law with

10e x i s t i n g r e g u l a t i o n s to modify repayment options

11f o r b o r r o w e r s w i t h unmanageable student loan debt.

12A n d p a r t i c u l a r l y a m ongst those, I would mention the

13e c o n o m i c h a r d s h i p d eferment, to make certain that

14i s m o r e a c c e s s i b l e . There are other things in that

15a r e a t h a t w e s h o u l d look at, too, because this is

16a n a r e a o f i n c r e a s i ng concern to borrowers across

17t h e c o u n t r y , a n d c e rtainly will make a difference

18i n t e r m s o f t h e i r l ives and the future and well-

19b e i n g o f t h i s c o u n t ry.

20 I t h a n k y o u for your consideration of

21t h e s e r e c o m m e n d a t i o ns. We look forward to working

22w i t h y o u a n d p r o v i d ing you with any assistance

23t o d a y . A n d a g a i n , thank you for the opportunity to

24b e h e r e t o d a y .

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1 D A V I D B E R G E RON: I want to say, Dallas, as

2y o u a r e g o i n g b a c k to your seat, that we are aware

3t h a t w e n e e d t o d o work in the area of identity

4t h e f t . W h e n w e p u b lish the final rule, we made

5r e f e r e n c e t o t h a t , the desire on the part of the

6D e p a r t m e n t t o w o r k with the broader community to

7c o m e u p w i t h b e t t e r processes, and procedures, and

8r u l e s a r o u n d t h a t p articular provision of the HERA.

9 D A L L A S M A R T IN: And we appreciate that.

10 D A V I D B E R G E RON: Thank you, Dallas.

11 D A V I D B E R G E RON: Nikolai Blinow.

12 D A N M A D Z E L A N: We’ll come back.

13 D A V I D B E R G E RON: No, she is coming.

14 N I K O L A I B L I NOW: I am here.

15 H e l l o , m y n ame is Nikolai Blinow, and I am

16a s e n i o r a t S a l e m S tate College. I am also a

17f e a t u r e s e d i t o r f o r The Log, and a MASSPIRG

18v o l u n t e e r .

19 T h r o u g h o u t my years at Salem State

20C o l l e g e , I h a v e s e e n my tuition rates and fees

21r i s e , s p e c i f i c a l l y , the grant within my financial

22a i d p a c k a g e h a s s h r unk. Thus I, along with my

23f e l l o w s t u d e n t s , h a ve been forced to compensate by

24t a k i n g m o r e a n d m o r e student loans out, loans that

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1w i l l a f f e c t m y l i f e immediately upon my graduation

2a n d f o r y e a r s a f t e r wards.

3 A s a m e m b e r of a single parent household,

4t h e s e r i s i n g c o s t s have forced me to more or less

5s i g n m y l i f e a w a y t o college. From the beginning,

6I k n e w t h e r e w o u l d be no money for college. My

7f a t h e r r e m a r r i e d a n d stopped making financial

8c o n t r i b u t i o n s w h e n I was very young. My mother

9w o r k e d f o u r j o b s j u st to make rent and to buy food.

10T o g e t h e r , w e l i v e d in subsidized housing. Money

11w a s t i g h t a n d c o u l d not be used towards anything

12b u t t h e b a r e n e c e s s ities.

13 H o w e v e r , m y mother was always supportive

14o f m e g o i n g t o c o l l ege, no matter what the cost,

15a n d I a m s o t h a n k f u l for her support. She has

16m o t i v a t e d m e t o g e t a college degree, because she

17k n o w s t h a t h i g h e r e ducation offers me the

18o p p o r t u n i t y t o c h a n ge my social standing and will

19a l l o w m e t o p r o v i d e myself with a future that she

20d i d n o t h a v e f o r h e rself. The type of life that

21s h e w a n t s f o r m e i s modest. She just wants me to

22b e a b l e t o o w n m y o wn home, be able to take a

23v a c a t i o n e v e r y o n c e in a while, be able to afford a

24f a m i l y a n d p r o v i d e for them in the future, and to

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1h a v e t i m e t o b e i n v olved in my community, all

2t h i n g s t h a t s h e h a s not been able to have for

3h e r s e l f . I k n o w t h at with continued penny-pinching

4I w i l l m a k e i t , b u t I know I will need her cheering

5m e o n i n t h e b a c k g r ound to make it happen, to pay

6o f f m y d e b t , a n d t o get to where I want to be.

7 Y e t t h e r e a re many who are not as

8f o r t u n a t e a s I a m . How many aspiring college

9s t u d e n t s d o n ’ t h a v e a great parent pushing them

10f r o m b e h i n d ? H o w m any can’t see a way over the

11o b s t a c l e s o f f i n a n c ing and debt to decide that it

12i s w o r t h i t ? T h e h igh cost of college can be an

13i n t i m i d a t i n g t h i n g when you come from close to

14n o t h i n g . L o o k i n g b ack, I can easily see my mother

15a n d I m a k i n g d i f f e r ent choices, deciding that

16c o l l e g e w a s n o t i n my future.

17 I a m g r a t e f ul, despite the huge debt

18b u r d e n t h a t I w i l l carry, that we can still see a

19w a y f o r m e t o m a k e it. I think it is tragic that

20s o m a n y o t h e r s t u d e nts and families have a

21d i f f e r e n t p o i n t o f view.

22 W h i l e t h e D epartment of Education may not

23b e a b l e t o a l t e r c o llege expenses, you can make a

24d i f f e r e n c e b y a d o p t ing the five-point plan for

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1m a n a g e a b l e d e b t . A dopting this plan will make

2c o l l e g e l o a n s m o r e affordable, particularly for

3t h o s e o f u s f r o m l o w-income backgrounds with a lot

4o f d e m a n d s o n o u r p aychecks. By making these

5c h a n g e s , y o u c a n k e ep the path to college clear for

6s o m a n y o t h e r s . M o re people will be able to attend

7c o l l e g e a n d b e c o m e productive members of society,

8a n d t h a t i s t h e o r i ginal intent of the student loan

9p r o g r a m .

10 Thank you.

11 D A V I D B E R G E RON: Thank you.

12 D A V I D B E R G E RON: Benjamin Navon.

13 B E N J A M I N N A VON: I am Benjamin Navon. I

14a m h e r e r e p r e s e n t i n g Salem State College, The Salem

15S t a t e L o g , a n d M A S S PIRG.

16 G o o d m o r n i n g. I would like to thank you

17f o r t a k i n g t h e t i m e to consider this very important

18m a t t e r t o y o u n g v o t ers. I am here not only to

19r e p r e s e n t m y p l i g h t , but to express the concerns of

20m a n y o f m y p e e r s a t Salem State College and

21t h r o u g h o u t M a s s a c h u setts.

22 I a m c u r r e n tly the Editor in Chief of the

23s t u d e n t n e w s p a p e r . I take my responsibilities as a

24s t u d e n t l e a d e r s e r i ously, and I am constantly

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1s o l i c i t i n g t h e v i e w s and opinions of my peers. A

2r e s o u n d i n g c o n c e r n for all Massachusetts is the

3r i s i n g c o s t o f e d u c ation, coupled with the slashing

4o f s t u d e n t a i d b y p oliticians.

5 A c c o r d i n g t o Salem mayor, Kimberly

6D r i s k e l , M a s s a c h u s e tts is at the bottom of the

7b a r r e l w h e n i t c o m e s to funding state higher

8e d u c a t i o n . A s t h e Commonwealth cuts funding for

9s t u d e n t a i d i n i t i a t ives, more and more students are

10r e l y i n g o n g o v e r n m e nt and private loans to pay for

11c o l l e g e . B y t h e t i me students are ready to

12g r a d u a t e , t h e i n t e r est compounded on these loans

13c a n b e s u f f o c a t i n g .

14 W h e n I f i r s t matriculated to Salem State,

15I w a s a p p r e h e n s i v e about how I was going to be able

16t o a f f o r d t u i t i o n . Student loans enabled me to

17p u r s u e a d e g r e e , a n d for that I am thankful.

18H o w e v e r , a s I c o n c l ude this academic year, I

19f o r e s e e s i g n i f i c a n t hurdles that I will need to

20o v e r c o m e i n o r d e r t o be debt free.

21 I p l a n t o g raduate in May. Consequently,

22I h a v e b e e n e x p l o r i ng my options for life after

23c o l l e g e . I h a v e r e searched entry level jobs in my

24c h o s e n f i e l d o f j o u rnalism, and I find it

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1d i s h e a r t e n i n g t h a t a sizable amount of my post-tax

2s a l a r y w i l l b e a l l o cated to repay my student loans.

3C l e a r l y , t h e D e p a r t ment of Education is unable to

4s t e m t h e r i s i n g c o s t of higher education, but the

5g o v e r n m e n t c a n r e l i eve students of large loans by

6i m p l e m e n t i n g t h e f i ve-point plan for manageable

7d e b t .

8 B y a d o p t i n g these changes, more people

9w i l l b e a b l e t o a t t end college, and expand their

10m i n d s , a n d b e t t e r t heir future and that of this

11c o u n t r y . E d u c a t i o n is critically important to

12p r o m o t e a h e a l t h y a nd viable society.

13 Thank you.

14 D A V I D B E R G E RON: Thank you.

15 D A V I D B E R G E RON: Steven Boudreau.

16 S T E V E B O U D R EAU: Good morning.

17 M y n a m e i s Steven Boudreau, and I am here

18r e p r e s e n t i n g W o r c e s ter State College in

19M a s s a c h u s e t t s .

20 A s a c o l l e g e student, I am aware that

21s t u d e n t l o a n s h a v e become a great problem. As a

22s e n i o r a t W o r c e s t e r State College, I have noticed

23t h a t m a n y s t u d e n t s like myself are burdened with a

24g r e a t a m o u n t o f s t u dent debt.

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1 W o r c e s t e r S tate College is a mid-size

2s c h o o l , p r i m a r i l y c ommuters, and the majority of

3o u r s t u d e n t s c o m e f rom working class households.

4 I n b o t h m y experiences as a student and a

5m e m b e r o f s t u d e n t g overnment, I have come across of

6m y f e l l o w s t u d e n t s that are burdened by student

7d e b t . I n a n a t i o n where children are taught that

8t h e y c a n d o w h a t e v e r they want if they only have

9t h e d r i v e a n d t h e s kill, many prospective students

10a r e n o t r e a c h i n g t h eir potential due to lack of

11m o n e y .

12 I n o r d e r t o help keep the amounts of my

13l o a n s d o w n , I , l i k e many of my friends, have taken

14a v e r y r e a s o n a b l e s tep that is going to work well

15i n c o l l e g e . I , m y s elf, work about 27 hours a week

16o n a v e r a g e . T h i s m ay not seem like a great deal,

17b u t c o u p l e d w i t h 1 8 credit hours of classes and

18b e i n g i n v o l v e d i n s tudent government, I am now

19w o r k i n g 4 5 h o u r s o r more a week to graduate in

20d e b t .

21 I a s p i r e t o work in the television

22i n d u s t r y . I h a v e b een told that I can expect

23a n y w h e r e f r o m $ 2 0 - 2 5,000 a year for starting

24s a l a r y . I n t h e l a s t four years, I have accumulated

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1j u s t a b o u t $ 2 0 , 0 0 0 in student loans. When now

2c a l c u l a t i n g t a x e s a nd interest, I will be paying

3a n y w h e r e b e t w e e n 8 to 10 percent of my annual

4i n c o m e j u s t f o r t h e se loans.

5 A f t e r f o u r years of college, four years of

6h a r d w o r k , I w i l l b e considered just above the

7p o v e r t y l i n e a f t e r I have paid off my loan debt.

8T h e r e a r e m i l l i o n s of other students who are in the

9s a m e s i t u a t i o n I a m . My own finances aside, I am

10l u c k y . I c h o s e a c areer path where a four-year

11d e g r e e w i l l b e e n o u gh to get my foot in the door.

12I c a n n o t s a y t h e s a me for students in this country

13w h o h a v e c h o s e n t o become teachers, social workers,

14a n d v a r i o u s o t h e r t ypes of civil servants. Many of

15t h e m a r e t o l d t h e y need at least master’s degrees,

16a n d t h e y w i l l n o t b e making very much money after

17g r a d u a t i o n . T h e s e people who have chosen very

18n o b l e p r o f e s s i o n s a re underpaid as it is, then they

19a r e f o r c e d t o p a y a sizable percent of their income

20t o s t u d e n t l o a n s .

21 O n e o f m y c losest friends aspires to be a

22k i n d e r g a r t e n t e a c h e r. She is $30,000 in debt, and

23s h e s t i l l h a s g r a d school to look forward to. She

24n e e d s t o b e a b l e t o live after college, and not

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1c o n t i n u e t o b e a b u rden on her parents. The amount

2s h e w i l l b e p a y i n g in loans is amazing. At the

3r a t e t e a c h e r s a r e p aid and the lack of raises they

4r e c e i v e , m y f r i e n d will be in debt for many years

5t o c o m e . T h e a m o u n t of income that a person makes

6c u r r e n t l y h a s n o b e aring on the amount they are

7r e q u i r e d t o p a y b a c k or the size of their family,

8o r o t h e r g r e a t f i n a ncial obligations people have

9t h a t c a n d r a s t i c a l l y change the amount they are

10a b l e t o p a y - - a r e s t ill not considered, and hinders

11a p e r s o n ’ s p r o g r e s s in life.

12 A s l i f e c a n be unpredictable at best,

13t h e r e a r e m a n y p e o p le who can not pay back loans

14f o r o n e r e a s o n o r a nother. We are lucky enough to

15l i v e i n a n a t i o n t h at has concern for these people

16a n d h a s i n s t a l l e d t he hardship program, while a

17n o b l e i d e a , i t h a s flaws. The requirements to

18e n t e r t h e p r o g r a m a re strict, and there is far too

19m u c h r e d t a p e . W h e n a person is finally accepted

20i n t o t h e p r o g r a m , a ll the debt they have

21a c c u m u l a t e d i s h e l d for a period of time, although

22t h e i n t e r e s t i s s t i ll calculated. The people in

23t h i s p r o g r a m h a v e e ncountered some sort of personal

24p r o b l e m t h a t h a s b r ought them to hardship. Why

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1s h o u l d t h e y w a l k o u t of the program having left one

2p r o b l e m b e h i n d a n d finding another?

3 T h e p r i c e o f college is rising. This

4r a i s e s a n e w p r o b l e m; the very people that public

5c o l l e g e s a n d u n i v e r sities are meant to educate are

6t h e p e o p l e t h a t a r e becoming financially

7i n e l i g i b l e . A s t h e re are few people at Worcester

8S t a t e C o l l e g e w h o c an pay for their education, many

9o f u s a r e f o r c e d t o take loans. Any cuts in

10s t u d e n t l o a n p r o g r a ms cuts the number of working

11c l a s s f a m i l i e s w h o can afford to send their

12c h i l d r e n t o c o l l e g e .

13 W e a r e n o t here asking for a handout, and

14w e d o n ’ t w a n t c h a r i ty. We do realize that there

15a r e m a n y c h a n g e s t h at are going to be made today.

16A l l w e w a n t i s t o k now that, when we graduate, we

17c a n p a y b a c k o u r l o ans in a fair and reasonable

18m a n n e r .

19 Thank you.

20 D A V I D B E R G E RON: Thank you.

21 D A V I D B E R G E RON: Andrew Klimkowski.

22 A N D R E W K L I M KOWSKI: Good morning.

23 M y n a m e i s Andrew Klimkowski, from the

24R i c h a r d S t o c k t o n C o llege of New Jersey.

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1 T h a n k y o u f or affording me the opportunity

2t o s p e a k b e f o r e y o u today on the state of higher

3e d u c a t i o n i n A m e r i c a.

4 I a m a p o l i tical science student at the

5R i c h a r d S t o c k t o n C o llege of New Jersey. I serve on

6t h e g o v e r n i n g b o a r d of my institution as a student

7t r u s t e e . I h a v e w r itten higher education policy

8r e c o m m e n d a t i o n s f o r Governor Corzine as a member of

9t h e H i g h e r E d u c a t i o n Transition Policy Group.

10 I w i l l n o t e that my recommendation was to

11k e e p t u i t i o n a f f o r d able for all New Jersey college

12s t u d e n t s . G o v e r n o r Corzine, for reasons of his

13o w n , d i d n o t i m p l e m ent these recommendations, so I

14h a v e a p p r o a c h e d y o u today instead.

15 [Laughter.]

16 D A V I D B E R G E RON: As far as I know, I have

17n e v e r b e e n v o t e d f o r.

18 [Laughter.]

19 A N D R E W K L I M KOWSKI: Cuts to college

20b u d g e t s a t t h e s t a t e level, combined with cuts to

21s t u d e n t l o a n s a t t h e national level are putting the

22s q u e e z e o n s t u d e n t s from lower- and middle-income

23b a c k g r o u n d s t o g e t to college in New Jersey.

24 I f i t w e r e not for the fact that I am in

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1t h e N e w J e r s e y A i r National Guard, I simply would

2n o t h a v e t h e f i n a n c ial means to obtain a college

3d e g r e e . I g r e w u p in a farm in New Jersey and

4l e a r n e d a h a r d w o r k ethic, strong moral values, and

5a g r e a t e r u n d e r s t a n ding of society. While my

6g r a n d p a r e n t s w e r e i ll and could no longer continue

7f a r m i n g , t h e y b o u g h t a smaller farm for retirement.

8T h e y s o l d t h e i r f a r m to Chinese farmers who taught

9m e M a n d a r i n C h i n e s e . Growing up, globalization was

10a t m y d o o r s t e p .

11 I k n e w I w a nted to go to college; however,

12m y f a m i l y d i d n o t h ave the financial support for me

13t o g o . I r e s e a r c h e d every avenue for me to get on

14t h e r i g h t p a t h t o c ollege. In 2000, I joined the

15N e w J e r s e y A i r N a t i onal Guard. The state of New

16J e r s e y p a y s 1 0 0 p e r cent of undergraduate and

17g r a d u a t e e d u c a t i o n for our brave men and women in

18t h e N a t i o n a l G u a r d . While working toward my dream

19o f a c o l l e g e e d u c a t ion, my life significantly

20c h a n g e d o n S e p t e m b e r 11, 2001.

21 I w a s w o r k i ng at McGuire Air Force Base

22t h a t d a y - - I w i l l n e ver forget. I never felt so

23d e f e n s e l e s s . I h a v e since been activated twice,

24a n d p u l l e d o u t o f c ollege to serve our nation. I

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1a m a v e t e r a n o f O p e ration Enduring Freedom,

2O p e r a t i o n I r a q i F r e edom, and Operation Noble Eagle.

3I n t r a n s i t i o n i n g b a ck to college--I want to make a

4d i f f e r e n c e i n m y c o llege community, so I ran for

5t h e b o a r d o f t r u s t e es. As a stakeholder in higher

6e d u c a t i o n a n d a r e p resentative of all the talent

7c u r r e n t l y a t t e n d i n g Stockton, I am deeply concerned

8a b o u t o u r f u t u r e .

9 T h e A m e r i c a n higher education system is

10f a c i n g a s o c i a l s t r atification with the proportion

11o f l o w - i n c o m e a n d m iddle class students being

12r e p l a c e d m o r e a n d m ore by the sons and daughters of

13h i g h e r i n c o m e f a m i l ies. According to the Brookings

14I n s t i t u t e , t h e r e i s a 20 percent decline in state

15i n v e s t m e n t i n h i g h e r education for the past 25

16y e a r s , s o t u i t i o n a nd fees have risen dramatically.

17T h e t o p f a m i l y i n c o me quartiles have a 75 percent

18c h a n c e t o g o t o c o l lege, and the lowest families

19h a v e l e s s t h a n a 1 0 percent chance to attain a

20c o l l e g e d e g r e e . W e need to bridge the gap of

21s o c i a l a n d e c o n o m i c inequality that higher

22e d u c a t i o n i s p r o d u c ing in American society by

23i n c r e a s i n g a c c e s s a nd affordability for all

24A m e r i c a n s , r e g a r d l e ss of socio-economic background.

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1 I a l s o h a v e economic concerns. In Thomas

2F r i e d m a n ’ s b o o k “ T h e World is Flat,” he paints a

3c l e a r a n d v i v i d p i c ture of the global village. As

4a u t o m o t i v e , t e x t i l e , mill, and factory jobs

5i n c r e a s i n g l y g o o v e rseas, Americans must adapt and

6c h a n g e b y g o i n g b a c k to college to acquire new

7k n o w l e d g e s k i l l s a n d abilities to be competitive in

8t h i s g l o b a l e c o n o m y where human capital is

9c r i t i c a l .

10 C h i n a p r o d u ces 600,000 engineers, and

11A m e r i c a p r o d u c e s 7 0 ,000 engineering graduates. The

12U n i t e d S t a t e s h a s f allen behind the United Kingdom,

13S i n g a p o r e , F r a n c e , Ireland, South Korea, and other

14c o u n t r i e s i n t h e p r oportion of 24-year-olds with a

15c o l l e g e d e g r e e . A c cording to the American Council

16o n E d u c a t i o n , y o u n g er Americans are falling behind

17y o u n g p e o p l e o f o t h er nations in college enrollment

18a n d c o m p l e t i o n r a t e s.

19 W h i l e t h e U nited States is still a world

20l e a d e r i n a p r o p o r t ion of Americans ages 35-64 with

21a c o l l e g e d e g r e e , i t ranks seventh on this measure

22f o r 2 5 - 3 4 - y e a r - o l d s . In order for our nation to be

23c o m p e t i t i v e i n a g l obal village that transcends

24b o r d e r s , w e m u s t s e t a national vision to invest

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1m o r e f u n d i n g i n t o h igher education.

2 I w o u l d l i k e for you to take away from my

3s p e e c h f i v e a c t i o n items as recommendations to

4a d v a n c e h i g h e r e d u c ation in America.

5 A c t i o n i t e m number one, we need to

6i n c r e a s e a c c e s s a n d affordability. We need to

7b r i d g e t h e g a p o f s ocial stratification of low-

8i n c o m e m i d d l e c l a s s families. One set of measures

9t h a t t h e D e p a r t m e n t can take is to adopt a five-

10p o i n t p l a n f o r m a n a geable student loan debt that

11y o u h a v e h e a r d a b o u t from many students across the

12n a t i o n .

13 A c t i o n i t e m number two, we need to create

14a t w o - w a y p r o c e s s o f communicating to the American

15p e o p l e t h e v a l u e o f a college degree with the many

16s o c i e t a l b e n e f i t s t hat I have outlined. Right now,

17m o s t A m e r i c a n s s e e higher education as a road to a

18h i g h e r p a y c h e c k r a t her than a conduit for a better

19s o c i e t y . I u r g e y o u to fund stronger public

20e d u c a t i o n e f f o r t s s o that citizens and elected

21o f f i c i a l s m a k e b e t t er informed decisions to keep

22c o l l e g e o p p o r t u n i t y more fully funded.

23 A c t i o n i t e m number three, create national

24p r o g r a m s t o e a s e t h e transition of our veterans

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1r e t u r n i n g h o m e f r o m the global War on Terrorism so

2t h a t t h e y c a n f i t b ack into society and enroll in

3c o l l e g e s a n d u n i v e r sities. I fear that with post-

4t r a u m a t i c s t r e s s d i sorder veterans will not be able

5t o a t t a i n a c o l l e g e degree unless we raise it as a

6n a t i o n a l i s s u e . M a ny colleges and universities

7r e f u s e t o a c c e p t m i litary course work; therefore,

8m a n y v e t e r a n s h a v e to take course that they have

9a l r e a d y r e c e i v e d d u ring military training, which

10a d d s t o t h e b u r d e n of cost for military veterans.

11 A c t i o n i t e m number four, we must ensure

12t h a t p u b l i c t r u s t a nd accountability of the higher

13e d u c a t i o n s y s t e m w i th the American people. I am

14w o r k i n g o n a s t a t e w ide level to address

15a c c o u n t a b i l i t y p r o b lems in New Jersey. While I

16a p p r e c i a t e t h e D e p a rtment’s concern on this issue,

17I b e l i e v e t h e s e i s s ues can be taken care of

18l o c a l l y .

19 A c t i o n i t e m number five, we need to

20d e v e l o p s t r a t e g i c a nd short-term strategies for our

21n a t i o n t o b e c o m p e t itive in the knowledge-based

22g l o b a l e c o n o m y , i n c luding collaborations with the

23p r i v a t e s e c t o r a n d higher education. I know that

24y o u r r e c e n t l y f o r m e d Commission on the Future of

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1H i g h e r E d u c a t i o n i s tackling this question, and I

2l o o k f o r w a r d t o t h e initiatives that come forth

3f r o m t h e s e p r o p o s e d plans. However, I would

4c a u t i o n y o u t o n o t take a one-size-fits-all

5a p p r o a c h t o s t a n d a r dized testing as part of these

6i n i t i a t i v e s .

7 I n f u l f i l l i ng these initiatives, we will

8a d v a n c e s o c i a l a n d economic shortcomings that we

9a r e f a c i n g i n h i g h e r education. We will be a more

10e n g a g e d s o c i e t y ; w e will contribute to the economic

11p r o s p e r i t y o f o u r n ation, increase productivity,

12a n d b e e v e n m o r e c o mpetitive in the global economy.

13 T h a n k y o u f or your leadership and high

14r e s o l v e t o m a k i n g a difference for our nation. I

15h o p e m y c o m m e n t s t o day will help you in your

16d e c i s i o n - m a k i n g , a n d understanding of what college

17s t u d e n t s a r e f a c i n g . Thank you.

18 D A V I D B E R G E RON: Thank you, Andrew.

19 [Applause.]

20 D A V I D B E R G E RON: Andrea Kilroe.

21 A N D R E A K I L R OE: Good morning.

22 M y n a m e i s Andrea Kilroe. I am here from

23S a l e m S t a t e C o l l e g e ’s SGA Office.

24 I a m a s e n i or on the brink of graduation

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1t h i s s u m m e r , w i t h a bachelor of science in business

2w i t h a c o n c e n t r a t i o n on entrepreneurship.

3 W h i l e t h i s is a very exciting time for me,

4t h e c u l m i n a t i o n o f years of education, knowledge,

5a n d s k i l l s b e i n g u t ilized and exposed, I have to

6r u s h t o f i n d a j o b . My first job offer, I will

7h a v e t o t a k e , i n p r eparation to repay the

8o u t l a n d i s h l o a n s t h at I have accumulated.

9 F r o m o n e y e ar at the University of Vermont

10a n d f o u r a t S a l e m S tate College, I have accumulated

11l o a n s o f a p p r o x i m a t ely $60,000. My $60,000 in loan

12d e b t i s n o t a s s u b s tantial as others, but, for me,

13$ 6 0 , 0 0 0 i s d i s a p p o i nting and it is intimidating.

14 I h a v e b e e n working almost seven days a

15w e e k , t w o j o b s , f o r the last four years to pay for

16s c h o o l , h o u s i n g , a n d other necessities. That still

17w a s n o t e n o u g h , a n d I have to rely heavily on loans

18a n d f i n a n c i a l a i d . Working through college was

19b e n e f i c i a l o n m a n y levels, but it also limited my

20i n v o l v e m e n t i n e x t r acurricular activities.

21 A s a m e m b e r of SGA, I knew that I could

22n o t t a k e m o r e r e s p o nsibility, as my time was

23c o n s u m e d m o s t l y b y work and class. My

24p a r t i c i p a t i o n i n o t her groups was constrained, as I

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1o n l y h a d s o m u c h t i me to give. My college career

2w a s f u l l o f w o r r y a bout how I was going to finance

3m y n e x t s e m e s t e r , p ay for my books, and afford to

4l i v e .

5 T h e s t i g m a with college graduation is you

6a r e d o n e w i t h c o l l e ge. It is time to graduate,

7s t a r t a c a r e e r , s t a rt a family, and live a little;

8n o t f o r m e , a n d n o t for most other students. We

9a r e l o o k i n g a t e n t e ring job markets starting

10b e t w e e n $ 2 0 - 5 0 , 0 0 0 a year and paying loan debts, as

11w e l l a s g e t t i n g a f oothold in this world. For me,

12I a m e x p e c t i n g t o f ind a full-time job and keep one

13o f m y t w o c u r r e n t j obs just to pay off my loans.

14 U p o n g r a d u a tion, my hopes are to begin

15r a i s i n g c a p i t a l f o r my own business. I wanted a

16r e s t a u r a n t ; h o w e v e r , with my ominous loan

17r e p a y m e n t s , m y r e a s on for obtaining a college

18e d u c a t i o n , m y d r e a m , has to be postponed. Not just

19m y d r e a m s a r e a t s t ake, loans are affecting my

20f a m i l y , a s w e l l .

21 M y m o t h e r w as a child herself when she had

22m e , a n d d i d n o t h a v e the luxury to save for my

23f u t u r e . T o t h i s d a y, I cannot rely on my mother’s

24i n c o m e , a s s h e n o w has two more children, ages

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1s e v e n a n d e i g h t , t o send through college. She will

2n o t o n l y h a v e t h e a dvantage to plan in advance, but

3n o t h i n g s h e s a v e s w ill be enough. She will have to

4r e l y h e a v i l y o n l o a ns, as well. My brothers are

5g o i n g t o h a v e t o w o rk as extensively as I have to

6r e a l i z e t h e i r d e g r e e and their dreams.

7 I a m h e r e o n behalf of my two brothers and

8t h e i r f u t u r e c o l l e g e career. I do not want them or

9a n y o t h e r s t u d e n t t o be limited in the knowledge,

10e x p e r i e n c e , a n d s k i lls that they can achieve

11b e c a u s e i t r e s u l t e d in too much of a financial

12b u r d e n . I w a n t a l l students to have the luxury of

13p a r t i c i p a t i n g i n c a mpus programs to make invaluable

14c o n n e c t i o n s a n d l e a rn how to create change. I want

15t h e s t u d e n t s i n c o l lege to have reassurance that

16t h e y h a v e t h e c u s h i on to wait for the right job,

17b e c a u s e t h e i r l o a n s are not looming so heavily on

18t h e i r c o n s c i e n c e .

19 R e p r e s e n t i n g myself, my brothers, and all

20s t u d e n t s , I a s k t h e government that is working on

21b e h a l f o f i t s p e o p l e to do something about the loan

22r e p a y m e n t s y s t e m . Adopt the five-point affordable

23e d u c a t i o n p r o g r a m . With these changes to the loan

24p r o g r a m s , s t u d e n t d ebt would be more bearable for

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1c u r r e n t a n d f u t u r e students. We are not looking

2f o r c h e a p e r c o l l e g e s and universities, but

3i m p r o v e m e n t .

4 T h a n k y o u , and I hope that you will adopt

5t h i s p r o g r a m .

6 D A V I D B E R G E RON: Thank you.

7 D A V I D B E R G E RON: Julia Benz.

8 JULIA BENZ: I am Julia Benz from the Ohio

9S t a t e U n i v e r s i t y .

10 W i t h m e i s Anna Griswald from Penn State

11U n i v e r s i t y .

12 W e a r e h e r e today representing the eastern

13h a l f o f t h e B i g T e n financial aid directors. You

14s a w s e v e r a l o f t h e m at the Chicago hearing. They

15w e r e r e p r e s e n t e d b y Susan Fischer and Dan Mann.

16T h e y s u b m i t t e d , a t that time, a document that you

17h a v e a s p a r t o f y o u r hearing.

18 T h e t w o o f us are here today to talk a

19l i t t l e b i t a b o u t t h e post-November 1 regulations,

20a n d m y c o m m e n t s t o d ay are focused on a positive

21d i r e c t i o n n e g o t i a t e d rulemaking could take for the

222 0 0 8 - 2 0 0 9 y e a r s a n d beyond.

23 T h e a m o u n t of funding currently found in

24a l l s t u d e n t a i d p r o grams is insufficient to meet

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1t h e n e e d s o f o u r s t udents. ACG and SMART Grants

2a r e a s t e p i n t h e r ight direction to help our

3n e e d i e s t s t u d e n t s w hile furthering the nation’s

4i n t e r e s t s i n p r o d u c ing qualified students in

5a c a d e m i c f i e l d s o f critical importance.

6 T h e S e c r e t a ry has acknowledged in her

7r e s p o n s e s t o c o m m e n ts made to the community between

8t h e i n t e r i m r u l e s a nd final rules published

9N o v e m b e r 1 , 2 0 0 6 , f or the 2006-2007 and the 2007-

102 0 0 8 y e a r s t h a t t h e administrative burden for

11i m p l e m e n t i n g t h e A C G and SMART Grant programs do

12n o t w a r r a n t a d d i t i o nal administrative cost

13a l l o w a n c e s , s i n c e t he programs are intended to

14p a r a l l e l t h e P e l l G rant Program in all aspects of

15i m p l e m e n t a t i o n .

16 M y r e c o m m e n dation is to follow through

17m o r e c l o s e l y o n t h i s concept of parallelism in

18o r d e r t o m a k e e l i g i bility for the new grant

19p r o g r a m s m o r e t r a n s parent and streamlined for

20s t u d e n t s . H a v e b o t h the ACG and SMART Grant share

21t h e s a m e r u l e s a s t he Pell Grant in two very simple

22a r e a s . F i r s t , a l l U.S. citizens and eligible non-

23c i t i z e n s q u a l i f y . Have continuing eligibility for

24t h e s e n e e d - b a s e d g r ant aid programs contingent on

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1s a t i s f a c t o r y a c a d e m ic progress standards set by

2s c h o o l s . T h e s e t w o small adjustments would go very

3f a r i n a l l o w i n g m o r e needy students to access the

4p r o g r a m s a n d t o e n s ure their continuing eligibility

5o n t h e i r d a t e o f g r aduation. Don’t implement more

6b a r r i e r s f o r n e e d y students to accomplish the

7u l t i m a t e g o a l o f g e tting the degree.

8 N o w A n n a w i ll talk.

9 A N N A G R I S W A LD: Thank you.

10 A n n a G r i s w a ld from Penn State. We

11a p p r e c i a t e t h e o p p o rtunity to be here today and

12o f f e r c o m m e n t s .

13 A s J u l i a m e ntioned, our colleagues in the

14B i g T e n i n s t i t u t i o n s have given some serious

15c o n s i d e r a t i o n t o a l l of the provisions that came

16o u t o f H E R A , s o w e appreciate the opportunity to

17s p e a k t o t h o s e .

18 W e r e p r e s e n t some half million students

19t h a t a r e e n r o l l e d c ollectively across the Big Ten

20i n s t i t u t i o n s , a n d w e administer, collectively, just

21o v e r $ 2 b i l l i o n i n federal student aid each year.

22 W h a t I w o u l d like to comment on, and to

23n o t b e t o o r e d u n d a n t, is many of the comments we

24h a v e h e a r d , e s p e c i a lly so well-stated by our

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1s t u d e n t s . S p e c i f i c ally, we acknowledge that,

2w i t h i n H E R A , w e d i d see an increase that will go

3i n t o e f f e c t t h i s n e xt year to the borrowing limits

4t o t h e f r e s h m a n a n d sophomore--the first two years

5o f s t u d e n t b o r r o w i n g. While we are appreciative of

6t h i s a n d a c k n o w l e d g e that is certainly a step in

7t h e r i g h t d i r e c t i o n , we believe this is

8i n s u f f i c i e n t a n d t h at much more needs to be done,

9a n d w e h o p e t h e D e p artment will take a lead in

10e n c o u r a g i n g t h e o p p ortunity for students to access

11l o w - i n t e r e s t l o a n s to a more sufficient degree.

12 W e a l s o n o t ed that the aggregate borrowing

13l i m i t s w i t h i n t h e f ederal loan program were not

14i n c r e a s e d c o n c u r r e n tly with the increase in the

15a n n u a l b o r r o w i n g l i mits, and we believe that this

16s h o u l d b e c o r r e c t e d , and that the aggregate limits

17a l s o i n c r e a s e d . A s we talk about student loans, we

18t a l k f i r s t ; h o w e v e r , about the extreme importance

19o f a c c e s s , e s p e c i a l ly for low-income students and

20m a n y m o d e r a t e - i n c o m e students today, the Pell Grant

21p r o g r a m i s a b s o l u t e ly essential for that. We would

22b e r e m i s s n o t t o s t ate very clearly our fundamental

23a n d p r i m a r y s u p p o r t for everything possible being

24d o n e t o s u p p o r t g r a nts, especially for low-income

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1s t u d e n t s .

2 R e a l i s t i c a l ly, though, we know that grants

3w i l l n o t e v e r b e a b le to address the full needs of

4s t u d e n t s . T o t h a t end, student loans are where we

5m u s t t u r n . T h i s i s not necessarily bad if a

6p r o g r a m i s c r a f t e d well. The concerns shared by my

7B i g T e n c o l l e a g u e s and many of my aid director

8c o l l e a g u e s a c r o s s t he country--and I would add that

9e a r l i e r t h i s y e a r , about 70 of us met to actually

10d i s c u s s t h i s v e r y i ssue and concern, and that is,

11g i v e n t h e i n a b i l i t y to borrow sufficient amounts of

12m o n e y t h r o u g h t h e f ederal loan program, that

13s t u d e n t s i n a l a r m i n gly large numbers are turning

14m o r e a n d m o r e o u t o f necessity to private education

15l o a n s . T h e s e a r e t ypically far more costly loans

16t o s t u d e n t s .

17 T h i s , I d o n ’t believe, was an intended

18m e t h o d o f p r o c e e d i n g with how students would

19f i n a n c e e d u c a t i o n , but, in fact, this has occurred.

20T h e r e a r e m a n y i n e q uities in allowing this approach

21t o c o n t i n u e , i n t h a t low-income students often are

22w i t h o u t s u f f i c i e n t family backing in terms of

23p a r e n t s b e i n g a b l e to serve as cosigners, or being

24c r e d i t - w o r t h y e n o u g h to borrow through these more

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1c o n s u m e r - b a s e d l o a n s.

2 T h e d i s c u s s ion that we had earlier this

3y e a r a m o n g a i d a d m i nistrators, hearing every day

4w h a t w e j u s t h e a r d from students here today, as we

5s a t a c r o s s t h e d e s k from them trying to piece it

6a l l t o g e t h e r , w e b e lieve that it is time and that

7i t i s p o s s i b l e f o r the country to offer one single

8l o a n s o u r c e . S t u d e nts are now borrowing from

9m u l t i p l e s o u r c e s t h at they have to repay. We

10b e l i e v e i t i s p o s s i ble to have one single loan

11p r o g r a m a c c e s s i b l e to all students, regardless of

12t h e i r c r e d i t r a t i n g or their parents’ ability to

13c o s i g n , a n d t h a t s u ch loans can be of a more

14r e a s o n a b l e i n t e r e s t rate.

15 T o c o m p l i m e nt that, knowing that

16s t u d e n t s - - a n d n o t t o encourage students to borrow

17m o r e , b u t k n o w i n g t hat is the necessity for many to

18c o m p l i m e n t t h i s a b i lity to borrow up to their need,

19m i n u s a n y o t h e r f i n ancial aid, we fully support

20w h a t w e h a v e h e a r d many of the students say today,

21t h a t t h e p r o j e c t o n student debt and its five-point

22p l a n f o r b a l a n c i n g the ability to borrow and access

23f u n d s , a l s o w i t h t h e ability to make reasonable

24r e p a y m e n t .

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1 S o , w i t h t h at, I will conclude my

2c o m m e n t s , a n d w e t h ank you again.

3 D A V I D B E R G E RON: Thank you.

4 T h e o n e c o m ment I want to make is that one

5t h i n g w e c a n ’ t d o w ith through regulations is

6c h a n g e u n d e r l y i n g l aw. So things like requirements

7t h a t s t u d e n t s m a i n t ain certain GPAs, that students

8a r e U . S . c i t i z e n s , in the cases of the ACG and

9N a t i o n a l S M A R T G r a n t, and loan limits are statutory

10p r o v i s i o n s , w h i c h w e cannot change through

11r e g u l a t i o n , j u s t s o people are aware.

12 A N N A G R I S W A LD: I think it is a matter of

13r e c o r d , i n t h e s p i r it of also giving input to other

14i s s u e s t h a t , h o p e f u lly, will find their way into

15r e a u t h o r i z a t i o n i n the future.

16 D A V I D B E R G E RON: We appreciate that. I

17j u s t w a n t e d t o m a k e sure that it was on the record

18t h a t w e d o n o t h a v e the authority to change statute

19b y r e g u l a t o r y a c t i o ns of the agency.

20 D A V I D B E R G E RON: Robin Polo.

21 ROBIN POLO: Good morning.

22 M y n a m e i s Robin Polo, and I am a

23s o p h o m o r e a t R u t g e r s University.

24 I w o u l d j u s t like to start out with

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1e x p r e s s i n g m y a p p r e ciation for you guys taking time

2o u t o f y o u r h e c t i c schedules to listen to our

3p e t i t i o n s i n r e g a r d to student loan debt.

4 I a m h e r e t oday not only to suggest

5m a n a g e a b l e a l t e r n a t ives to the current student loan

6d e b t p r o g r a m s , b u t to help you match a statistic to

7a f a c e . I a m t h e f irst in my family fortunate

8e n o u g h t o b e a t t h e university level, yet, on a

9d a i l y b a s i s , I s t r u ggle with the idea on how much

10s t u d e n t l o a n d e b t I am anticipating to graduate

11w i t h , a p p r o x i m a t e l y $50,000. This number shakes me

12s o m u c h t h a t I a m c onstantly considering dropping

13o u t o f s c h o o l , j u s t because I do not see how I can

14m a n a g e t h e s e l o a n s after graduation.

15 I , l i k e m a n y of us here today, fully

16s u p p o r t m y s e l f . I had it tough growing up, so my

17r e a l i t y i s t h a t I h ave no choice but to fund my

18e n t i r e e d u c a t i o n w i th student aid, mostly in the

19f o r m o f l o a n s .

20 S o , t o e d u c ate myself or not to educate

21m y s e l f ? T h i s i s a question that turns through the

22m i n d s o f h i g h s c h o o l seniors everywhere--the fact

23t h a t s t u d e n t s a r e u nable to pay for their higher

24e d u c a t i o n , a n d t h e fact that we will not be able to

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1m a n a g e g r a d u a t i n g w ithout outrageous debts prevents

2m i l l i o n s e v e r y y e a r from attending universities. I

3s t i l l a n s w e r t h i s q uestion by choosing to go to

4c o l l e g e d e s p i t e t h e burden.

5 H e r b e r t S p e ncer said, “The great aim of

6e d u c a t i o n i s n o t k n owledge, but action.” I believe

7t h i s 1 0 0 p e r c e n t . If I am denied or discouraged

8f i n a n c i a l l y t o t h e point that I, too, feel that

9t h e r e i s n o c h o i c e but to prematurely end my

10c o l l e g e e x p e r i e n c e , I might as well fall asleep and

11n e v e r w a k e u p . I w ill be giving up a dream of

12e q u a l i t y a n d j u s t i c e and other principles I care

13v e r y d e e p l y a b o u t , and I know that a college degree

14w i l l h e l p m e m a i n t a in that.

15 B u t h e r e I am, still in college. At

16R u t g e r s , I h a v e d e v eloped a deep passion for two

17t h i n g s : I w a n t t o help people, and I love the

18t h e a t e r a r t s . I w o uld love to go into education.

19I w o u l d l o v e t o g o overseas and teach English. I

20w o u l d l o v e t o t r a v e l to places whose communities

21a r e i n s e v e r e n e e d of aid and assistance, and that

22i n c l u d e s h e r e a s w e ll as abroad. I would love to

23u s e t h e a t e r a s a m e ans to influence the minds of

24t o d a y s o t h a t t h e y may look on social issues and

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1f i n d t h e m a s a l a r m i ng as they really are, as well

2a s h e l p p e o p l e f i n d compassion for those of us who

3a r e s u f f e r i n g t h e s e issues.

4 I w o u l d l o v e to teach in inner city

5s c h o o l s a n d i n s p i r e young people through the arts.

6I w o u l d l o v e t o h e l p mold the personalities of our

7f u t u r e g e n e r a t i o n s so that they may think in a way

8t h a t w o u l d b e n e f i t themselves and others without

9h a v i n g t o s a c r i f i c e their individuality or voice.

10I c o u l d g o i n a n y d irection, obviously, but then

11t h e r e i s t h e r e a l i t y of any one of these paths once

12I g r a d u a t e , t h e l o w starting salary and the high

13d e b t b u r d e n I w i l l carry.

14 T h e q u e s t i o n that I have not received an

15a n s w e r t o t h u s f a r is, “How I am going to be able

16t o t a k e p o s i t i v e a c tion in my society under these

17c i r c u m s t a n c e s ? ” C a n I afford to do it? Will I be

18c o n s u m e d w i t h d e b t , or will I be able to make it?

19R i g h t n o w , s o m e l o a ns can tie the monthly repayment

20t o m o n t h l y e a r n i n g s , but others don’t. Can I go in

21t h e d i r e c t i o n t h a t I want to go in, or will I have

22t o c h o o s e o t h e r w i s e ?

23 E v e n n o w , a s a full-time student, I have

24t o w o r k f u l l - t i m e o n top of the debt that I am

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1a c c u m u l a t i n g . T h i n k of how many students are in

2s i m i l a r p o s i t i o n s , and how much community

3i n v o l v e m e n t a n d p o t ential is being suppressed by

4t h o s e o f u s w h o h a v e the strength and the energy in

5t h e p r i m e o f o u r l i ves to accomplish great things,

6b u t n o t i m e i n w h i c h to do so.

7 I k n o w t h e U.S. Department of Education

8w a n t s t o p r o m o t e h i gher education and be

9e n c o u r a g i n g t o o u r future generation, but, right

10n o w , a l l t h e c u t b a c ks and rate hikes communicate

11t h e o p p o s i t e . T h e government is becoming an

12o b s t a c l e i n i t s e l f to our ability to succeed.

13 S o I a s k t h at you hear me out on these

14s u g g e s t i o n s . F i r s t of all, increase the

15a t t a i n a b i l i t y o f l o ans for those students who do

16n o t h a v e a n y o n e t o cosign for them. Lower the age

17f o r s t u d e n t s t o b e declared independent so their

18p a r e n t s ’ i n c o m e i s not factored into their aid

19p a c k a g e .

20 S e c o n d , a l l ow loans to be forgiven after

212 0 y e a r s i f b o r r o w e rs have met their contractual

22o b l i g a t i o n s . S o m e t imes borrowers won’t be earning

23t h e h i g h e r s a l a r i e s , and the loans simply should be

24f o r g i v e n w h e n t h a t happens.

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1 T h i r d , t a k e into consideration the field

2o f w o r k i n w h i c h a college graduate is going into

3a n d a d j u s t t h e l o a n payment according to their

4e x p e c t e d i n c o m e . M ake sure this provision is

5i n c l u d e d i n a l l t h e federal loan programs, not just

6o n e o r t w o .

7 I n c o n c l u s i on, by giving back to the

8s t u d e n t s t h r o u g h m o re manageable loan rules, we

9w i l l b e a b l e t o b e strong members of society, and

10w e w i l l b e a b l e t o think less about ourselves and

11m o r e a b o u t o t h e r s . I believe so strongly in

12e d u c a t i o n , a n d n o t only what it can do for me as an

13i n d i v i d u a l , b u t w h a t it can allow me to provide

14b a c k t o m y c o m m u n i t y. Help me, and I will help

15y o u .

16 Thank you.

17 D A V I D B E R G E RON: Thank you, Robin.

18 D A V I D B E R G E RON: Rosario Matos.

19 R O S A R I O M A T OS: Good morning.

20 M y n a m e i s Rosario Matos, and I am a

21s o p h o m o r e f r o m R u t g ers University in New Brunswick,

22N e w J e r s e y . I h a v e traveled all this way to urge

23t h e D e p a r t m e n t o f E ducation to do the right thing

24a n d e n s u r e t h a t l o a n repayment terms for college

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1s t u d e n t s a r e f a i r a nd manageable.

2 A s a y o u n g woman looking to the life ahead

3o f m e , a l i f e o f f i nancial struggle and loan

4r e p a y m e n t , I d e c i d e d to take action by first

5t e s t i f y i n g b e f o r e y ou today. Secondly, I volunteer

6o n c a m p u s t o g e t m y student government, student

7l e a d e r s , a n d o t h e r to get involved on campus around

8c o l l e g e a f f o r d a b i l i ty issues.

9 W e h a v e h e l d photo shoots throughout New

10J e r s e y o n p u b l i c c o llege campuses to create the New

11J e r s e y S t u d e n t D e b t Yearbook. It is a personal

12a c c o u n t o f h u n d r e d s of students from New Jersey who

13h a v e h a d l o a n d e b t and who think it is becoming

14u n a f f o r d a b l e . I h a ve only made one copy, but you

15c a n s e e i t a n d o v e r 4,000 other students at

16w w w . s t u d e n t d e b t a l e r t.com.

17 W e h a v e a l s o held numerous events, such as

18d e p a r t m e n t a w a r e n e s s informational sessions, and

19c o n d u c t e d e d i t o r i a l writing to local and statewide

20n e w s p a p e r s . A t t h e end of the semester, I am

21i n v i t i n g s e v e r a l l o cal political representatives to

22s p e a k a b o u t s t u d e n t loan debt on campus. This will

23n o t o n l y s h i n e m o r e light on the issue, but also

24e n c o u r a g e a n d i n c r e ase the political mindset on our

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1c o l l e g e c a m p u s e s .

2 P e r s o n a l l y , through my volunteering, I

3h a v e b e c o m e i n v o l v e d on a grander scale with New

4J e r s e y a n d f e d e r a l politics, because of how closely

5w e m u s t w o r k w i t h t hese institutions to get the

6c h a n g e w e s e e k . I have become a political animal.

7 [Laughter.]

8 R O S A R I O M A T OS: Just yesterday, I voted

9f o r t h e f i r s t t i m e . I don’t know how I would ever

10k n o w m y o w n p o w e r a s a citizen if it were not for

11t h e e x p e r i e n c e s I h ave gotten in college getting

12i n v o l v e d . N o o n e c an deny the importance of the

13c o l l e g e e x p e r i e n c e to the success of an individual

14a n d t h e e n v i r o n m e n t in which he or she lives.

15C o l l e g e s e x p o s e s t u dents to new perspectives as

16t h e y c o m e i n t o c o n t act with fellow students from

17a r o u n d t h e w o r l d . Universities provide the

18b r e e d i n g g r o u n d f o r intellectual pursuit and social

19a d v a n c e m e n t .

20 T h e s e a r e t he reasons why it is important

21f o r e v e r y p e r s o n t o have an equal opportunity to

22f u r t h e r t h e i r e d u c a tion. It is funny how

23u n i v e r s i t y s t u d e n t s can do so many things, but why

24i s i t h a r d f o r t h e average Joe Somebody to attain a

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1d e g r e e ?

2 A s a c o l l e g e student, I know all too well

3t h e p r e s s u r e i n v o l v ed in producing the thousands of

4d o l l a r s e a c h y e a r I need to pay for my education.

5T h i s p a s t y e a r , a s a work study student, I worked

6f i f t e e n - a n d - a - h a l f hours a week to ensure that I

7w o u l d h a v e e n o u g h m oney to pay for high-priced

8t e x t b o o k s , t r a i n t i ckets home, food, school

9s u p p l i e s , a n d o t h e r daily living expenses. I work

10h a r d d u r i n g t h e s u m mers to raise the money needed

11f o r t h i s c u r r e n t s e mester. Unfortunately, I have

12n o w a y t o c o m e u p w ith the additional $3,000 I need

13t o p a y f o r m y s p r i n g semester at Rutgers, taking

14o u t a n a d d i t i o n a l l oan is my only option.

15 I n t h e f u t u re, I want to see the world and

16s t u d y a n c i e n t p e o p l es as an archaeologist, because

17I t h i n k o n l y w i t h a solid understanding of our past

18c a n w e m o v e f o r w a r d in the most thoughtful way as a

19s o c i e t y . A r c h a e o l o gists don’t exactly bank the big

20b i l l s , a n d , o n t o p of this, many years of graduate

21a n d p o s t - g r a d u a t e s tudy are needed. This means

22m o r e m o n e y f o r s c h o ol and growing debt. Every day

23I w o n d e r i f I s h o u l d keep on the same track or just

24g i v e i t a l l u p b e c a use it is so expensive.

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1 M y r o o m m a t e , Mary Rose Bartholomay Fabara

2i s p u r s u i n g a c a r e e r in social work. We both know

3t h a t t h e t h o u s a n d s of dollars she owes in loans

4w i l l b e d i s a d v a n t a g eous, as social workers get only

5e n o u g h i n w a g e s t o scrape by. Adding large monthly

6p a y m e n t s , a l o n g w i t h low wages, will increase the

7s t r e s s l e v e l i n h e r life in the coming future, even

8a s s h e a c t s t o r e l i eve the stress of others. Mary

9R o s e m u s t , t o o , d e c ide if becoming a social worker

10i s w o r t h s u c h h i g h financial costs.

11 I t i s u n f a i r that the people we need in

12o u r s o c i e t y m o s t , s uch as teachers, social workers,

13a n d h u m a n i t a r i a n w o rkers are compelled to switch

14c a r e e r s b e c a u s e o f loan debt. Loans are an

15e s s e n t i a l m e a n s o f funding a college education, but

16t h e b e n e f i t s m i g h t be outweighed by the job acts,

17a s t h e y h i n d e r s t u d ents from going into the careers

18t h a t o u r s o c i e t y n e eds.

19 L o a n p a y m e n t options are limited. As it

20s t a n d s n o w , s o m e l o ans do not take into

21c o n s i d e r a t i o n c u r r e nt financial situation, nor

22f a m i l y s i t u a t i o n . Instead, the loan programs slam

23a b o r r o w e r w i t h a f lat 6.8 percent interest rate

24m o n t h s a f t e r c o l l e g e ends and must be paid. While

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1t h e b e s t s o l u t i o n t o this problem would be to

2i n c r e a s e f e d e r a l a i d programs like the Pell Grant,

3i t i s n o t p o s s i b l e for the Department of Education

4t o d o t h i s w i t h o u t congressional approval. What

5t h e D e p a r t m e n t o f E ducation can do is to adopt the

6f i v e - p o i n t p l a n b e i ng endorsed by the student

7g r o u p s , l i k e N e w J e rsey PIRG, across the nation.

8 W e s t u d e n t s need more incentives to

9c o n t i n u e o u r e d u c a t ion on the right track, such as

10m o n t h l y i n c o m e a n d family size being taken into

11a c c o u n t w h e n c a l c u l ating monthly payments. Please

12h e l p e n s u r e t h a t l o an repayment becomes fair and

13m o r e m a n a g e a b l e .

14 Thank you.

15 D A V I D B E R G E RON: Thank you.

16 D A V I D B E R G E RON: Michael Shawe.

17 M I C H A E L S H A WE: Hello.

18 I a m M i k e S hawe, and I am Rutgers

19U n i v e r s i t y s t u d e n t .

20 I w a n t t o b e a journalist. I want to be

21o n e o f t h o s e i n d e p e ndent investigative reporters

22w h o e x p o s e s c o r r u p t ion and reaffirms the American

23d e m o c r a c y , b u t I a m going to have great difficulty

24p u r s u i n g t h i s i m p o r tant profession, because, by the

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1t i m e I f i n i s h m y u n dergrad work, I will be over

2$ 3 5 , 0 0 0 i n d e b t , w i th approximately $20,000 of that

3b e i n g p r i v a t e l o a n s . I get no financial assistance

4f r o m m y f a m i l y , d e s pite the fact that their income

5c o u n t s t o w a r d t h e t ype of aid that I qualify for.

6I a m g o i n g t o b e d r owning in solitary debt.

7 L a s t y e a r , the state of New Jersey cut the

8R u t g e r s b u d g e t d r a s tically, giving up tuition and

9f e e s a n d f o r c i n g u s to rely even more heavily on

10l o a n s t o p a y f o r c o llege. At the same time,

11C o n g r e s s c u t t h e s t udent loan program by $12

12b i l l i o n . T h u s , i n New Jersey, it is becoming

13f i n a n c i a l l y i m p o s s i ble to even attempt to get where

14y o u w a n t t o b e t h r o ugh a college degree.

15 H i g h e r e d u c ation funding should be

16r e s t o r e d , a n d c o l l e ge loans should be made more

17a f f o r d a b l e f o r s e v e ral reasons. Higher education

18i s t h e b e s t w e a p o n against poverty. If you want to

19f i x p o v e r t y i n A m e r ica, then educate the poor.

20G i v e t h e m o p p o r t u n i ties to climb out of the

21h o p e l e s s c y c l e o f p overty and they will not

22d i s a p p o i n t . I f i t were not for the federal and

23s t a t e a i d t h a t I g e t, then students like me would

24n o t b e i n c o l l e g e , but that aid is not going as far

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1a s i t u s e d t o .

2 S e c o n d , a n educated and informed public is

3t h e g r e a t e s t w e a p o n against tyranny. If we allow

4t h e f e d e r a l f u n d i n g to erode further, the poor or

5e v e n m i d d l e c l a s s f amilies will be unable to attend

6c o l l e g e . A n d i f c o llege is only populated by a few

7r i c h p a t r o n s , t h e n that threatens one of the

8a s s u m p t i o n s o f o u r Founding Fathers to defend

9d e m o c r a c y , w h i c h i s that the masses be informed and

10e d u c a t e d .

11 I c a n n o t i m agine who I would be if it were

12n o t f o r t h e f a c t t h at I am in college and that I am

13a b l e t o t a k e a d v a n t age of all the resources there.

14I h a v e l e a r n e d t o r espect authority, but to also

15c h a l l e n g e i n j u s t i c e at every turn. I have become

16a n i n t e l l i g e n t , s e l f-sufficient participant in the

17c o m m u n i t y a n d t h e m arketplace. I have learned to

18r e a c h o u t , n o w t h a t I see that the American ideal

19o f e v e r y b o d y g e t t i n g equal chance to work towards

20s u c c e s s i s p o s s i b l e . College honestly and truly

21s a v e d m y l i f e . I h ave transformed from a silent

22v i c t i m i n t o a h a r d - working American who wants to

23g i v e b a c k .

24 W h a t y o u g e t by investing federal dollars

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1i s r e a l r e s u l t s . Y ou have the chance to make this

2c o u n t r y b e t t e r b y s imply assisting students who are

3p a y i n g m o r e t h a n t h eir fair share of college

4t u i t i o n b y m a k i n g o ur loans more affordable. If

5y o u m a k e t h e s e r u l e changes, we will respond with

6h o p e , a n d b e l i e v e m e, we will not disappoint.

7 Thank you.

8 D A V I D B E R G E RON: Thank you.

9 D A V I D B E R G E RON: Andrew Friedson.

10 A N D R E W F R I E DSON: Good morning.

11 D A V I D B E R G E RON: Good morning.

12 A N D R E W F R I E DSON: My name is Andrew

13F r i e d s o n . I a m a j unior at the University of

14M a r y l a n d , C o l l e g e P ark.

15 G o o d m o r n i n g. Thank you for convening

16t h e s e h e a r i n g s o n h ow to make college affordable.

17I a p p r e c i a t e t h e o p portunity to bring testimony.

18 A s y o u k n o w , in February, Congress

19f i n a l i z e d p a s s a g e o f a bill that cuts almost $12

20b i l l i o n o f a i d f r o m the student loan programs.

21T h i s f u n d i n g c u t , a ccompanied by rising tuition,

22h a s m a d e i t i n c r e a s ing difficult for our generation

23t o p u r s u e h i g h e r e d ucation degrees.

24 A s t h e D i r e ctor of Governmental Affairs

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1f o r t h e S t u d e n t G o v ernment Association at the

2U n i v e r s i t y o f M a r y l and, College Park, I propose

3t h a t t h e U . S . D e p a r tment of Education negotiated

4r u l e m a k i n g p r o c e s s must aim to make student loan

5r e p a y m e n t r u l e s m o r e fair and manageable.

6 T h e w o r d “ u niversity” comes from the Latin

7“ u n i v e r s u s , ” w h i c h means “whole,” “aggregate,”

8“ e n t i r e . ” T o o o f t e n, we get so caught up in

9c u r r i c u l a r p u r s u i t s that we forget about how

10p i v o t a l c o - c u r r i c u l ar and extracurricular

11a c t i v i t i e s a r e t o o ne’s education. The idea of

12b e i n g w h o l e , o r w e l l-rounded, as we commonly say,

13i m p l i e s t h e o p p o r t u nity to engage in activities

14o u t s i d e o f , a n d a l o ngside, book and classroom

15a c t i v i t i e s . I n m y view, they are the very thing

16t h a t s e t s t h e u n d e r graduate college experience

17a p a r t f r o m s e c o n d a r y school graduate and post-

18g r a d u a t e e x p e r i e n c e s.

19 T h e r i s i n g costs and deepening debt are

20s t o p p i n g s t u d e n t s f rom these key opportunities.

21T a k e m y f r i e n d L y n n e, for instance. She attended

22A l b r i g h t C o l l e g e f o r a semester. Although Lynne

23l o v e d A l b r i g h t C o l l ege, its $36,000 and rising

24t u i t i o n p r o p o s e d s u ch a burden on her after

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1g r a d u a t i o n t h a t s h e decided to transfer to the

2U n i v e r s i t y o f M a r y l and. Several credits did not

3t r a n s f e r o v e r , s o n ow she is forced to take a

4s i g n i f i c a n t l y h e a v i er course load. She receives a

5S t a f f o r d L o a n , w h i c h does not cover her full

6t u i t i o n , a n d c a u s e d her to take out additional

7p r i v a t e l o a n s f o r h er to be able to stay in

8c o l l e g e .

9 A s i d e f r o m her six classes, Lynne is

10f o r c e d t o w o r k t w o jobs to cut her tuition costs

11a n d p u t h e r i n a p o sition to pay off her loans

12a f t e r g r a d u a t i o n . Needless to say, Lynne has no

13o p p o r t u n i t i e s t o e n gage in any extracurricular

14a c t i v i t i e s , a n d h a s a difficult time aggressively

15p u r s u i n g h e r a c a d e m ics because of how strapped she

16i s f o r t i m e a n d e n e rgy.

17 U n f o r t u n a t e ly, Lynne is not an exceptional

18c a s e a t a l l . C o u n t less students face the same

19c i r c u m s t a n c e s . M e a nwhile, at the same time Lynne

20i s s t r u g g l i n g , I h a ve taken full advantage of my

21c o l l e g e y e a r s b y w o rking hard in the classroom

22w h i l e p a r t i c i p a t i n g in numerous extracurricular

23a c t i v i t i e s . I c o u l d not imagine my time at the

24U n i v e r s i t y o f M a r y l and without the plethora of

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1e x t r a c u r r i c u l a r p o s sibilities readily available to

2m e .

3 A l o n g w i t h my participation in student

4g o v e r n m e n t , I a m a l so an active executive board

5m e m b e r o f a f r a t e r n ity, which has enabled me to

6b e c o m e C h i e f J u s t i c e of the entire Inter-fraternity

7C o u n c i l . I f o r m a l l y served on the Dean’s Student

8A d v i s o r y C o u n c i l f o r my college, where I met

9r e g u l a r l y w i t h t h e Assistant Dean to discuss how to

10b e t t e r t h e c o l l e g e for students. In that capacity,

11I a l s o s e r v e d o n t h e committee to select the

12c o m m e n c e m e n t s p e a k e r for fall graduation, and made

13r e c o m m e n d a t i o n s t o the Dean on how to appropriate

14t h e o v e r $ 3 0 0 , 0 0 0 - p lus technology fee money the

15c o l l e g e r e c e i v e s f r om the Provost.

16 A s a m e m b e r of the university senate last

17y e a r , I h a d t h e o p p ortunity to meet with faculty

18m e m b e r s , d e a n s , a n d administrators, including the

19u n i v e r s i t y P r e s i d e n t, Provost, and President’s

20C a b i n e t . T h e s e e x p eriences have allowed me the

21o p p o r t u n i t y t o p u r s ue my full educational

22p o t e n t i a l . T h e s e i nvaluable skills of interviewing

23a n d b e i n g i n t e r v i e w ed, meeting with and persuading

24a d m i n i s t r a t o r s a n d faculty, and even lobbying

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1b e f o r e y o u t o d a y a r e educational experiences which

2c a n n o t b e l e a r n e d i n a classroom, and simply cannot

3b e s u b s t i t u t e d .

4 U n f o r t u n a t e ly, over one-third of my

5c o h o r t s a r e m o r e l i ke Lynne and less like me.

6T h o u g h t h e y t a k e m y same midterm and final exams

7a n d h e a r t h e s a m e l ectures, they do not share my

8s a m e p e d a g o g i c a l o p portunities. The only

9d i f f e r e n c e i s t h a t I can afford the tuition bill

10a n d t h e y s i m p l y c a n not.

11 D u e t o l o a n debt, rather than learning

12t h e i r w a y t h r o u g h c ollege, these students are

13w o r k i n g t h e i r w a y t hrough it, and this is just

14s o m e t h i n g t h a t i s s ad. Work, of course, is not

15a l w a y s a b a d t h i n g ; however, I strongly believe

16t h a t u n i v e r s i t y s t u dents, the best and brightest of

17o u r y o u n g a d u l t p o p ulation, should have the

18m o b i l i t y t o d e c i d e where, and whether, they will

19w o r k .

20 F o r i n s t a n c e, the past three jobs I have

21t a k e n w e r e a s a n i n tern in the Maryland House of

22D e l e g a t e s a s a d e p u ty field director of a local

23c a m p a i g n , a n d a s a congressional intern in the

24W h i p ’ s o f f i c e . T h e ability to take advantage of

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1t h e s e u n p a i d i n t e r n ships has given me more than

2j u s t w o r k e x p e r i e n c e or something to put on my

3r e s u m e . I n f a c t , I walk away from these

4e x p e r i e n c e s w i t h s k ills, connections, and a

5c o n s t a n t l y r e n e w i n g passion for civil service. The

6s a m e s k i l l s , c o n n e c tions, and deepening social

7c o m m i t m e n t a r e m o s t likely not earned by the large

8n u m b e r o f s t u d e n t s working 30-plus hours a week

9j u s t t o m i n i m i z e t h eir loan debt.

10 M o s t d i s h e a rtening to me, perhaps, is the

11n u m b e r o f y o u n g p e o ple who could be at the

12U n i v e r s i t y o f M a r y l and or similar schools, but

13c a n n o t a f f o r d t o d o so because of the high cost.

14A m o n g t h e 4 0 0 , 0 0 0 c ollege eligible high school

15g r a d u a t e s w h o a r e f orced not to attend college are

16m a n y b r i g h t i n d i v i d uals who could be my classmates.

17R e g r e t t a b l y , I w i l l never have the privilege to

18m e e t , s t u d y , a n d w o rk with these bright

19i n d i v i d u a l s . C o u n t less students, those who could

20b e t h e n e x t u n i v e r s ity president, the next editor

21o f t h e c a m p u s n e w s p aper, or, eventually, a

22s c i e n t i s t , s u r g e o n , entrepreneur, or politician

23l a c k t h e o p p o r t u n i t y to reach their full potential.

24 A l t h o u g h m y hopes for change may seem

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1s e l f l e s s , I m u s t a d mit that I plan to attend law

2s c h o o l , a n d t h a t I will need to take out loans to

3p a y f o r i t . H o w e v e r, I also have other goals that

4c o n f l i c t w i t h t h i s one, given the current loan

5r e p a y m e n t r u l e s . I would like to work in the

6p u b l i c s e c t o r a t s o me point after pursuing a law

7d e g r e e . I h a v e c o n templated applying for Teach for

8A m e r i c a , w o r k i n g a t a non-profit, or perhaps

9w o r k i n g f o r , o r a s , a public defender.

10 A l t h o u g h p r ograms like Teach for America

11o f f e r a s t i p e n d f o r graduate school or professional

12s c h o o l , t h e y d o n o t mitigate the incredible burden

13t h a t d e b t w i l l c a u s e. Working at a non-profit or

14w i t h a p u b l i c d e f e n der will fail to put me in a

15r e a l i s t i c p o s i t i o n to pay off my loans.

16 W e n e e d t o fix our system so we are not

17d i s c o u r a g i n g p a r t i c ipation in public sector jobs,

18b u t a r e e n c o u r a g i n g and promoting it. A young

19p a s s i o n a t e p e r s o n s hould never be denied the

20a b i l i t y t o g i v e b a c k to society because of his or

21h e r l o a n d e b t .

22 I r e c o g n i z e that the Department lacks the

23a b i l i t y t o o v e r t u r n the Budget Reconciliation Plan

24p a s s e d b y C o n g r e s s in February, which would be a

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1h u g e s t e p i n m a k i n g loans more manageable.

2H o w e v e r , t h e r e a r e still changes within the scope

3o f t h e D e p a r t m e n t ’ s power that can be made to the

4s t u d e n t l o a n r e p a y m ent program that will reduce the

5h a r d s h i p s p l a c e d o n borrowers. I urge the United

6S t a t e s D e p a r t m e n t o f Education to adopt the five-

7p o i n t p l a n f o r m a n a geable student loan debt. We

8m u s t v i e w o u r e d u c a tional system, both K-12 and

9h i g h e r e d u c a t i o n , a s the greatest education that

10o u r s o c i e t y c a n m a k e in its future. Better than

11b o n d s , a n d s t o c k s , and real estate, attaining a

12c o l l e g e d e g r e e i s t he best way to ensure that the

13f u t u r e o f o u r n a t i o n is secure.

14 T h e s t u d e n t loan program has helped

15m i l l i o n s o f s t u d e n t s get to that future, but it is

16s t a r t i n g t o h a v e d e trimental consequences. In

17o r d e r t o h a v e a r e t urn on the education investment

18f o r w h i c h t h e s t u d e nt loan program was designed, we

19m u s t a l l o w b o r r o w e r s a chance to repay their loans

20a n d g i v e b a c k t o s o ciety in a fair and manageable

21f a s h i o n . I f o n l y w e could accomplish that, all of

22s o c i e t y s u c c e e d s .

23 I a p p r e c i a t e you giving me the opportunity

24t o s p e a k o n t h i s i m portant issue, and your

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1u n d e r s t a n d i n g t h a t we need to improve the current

2l o a n d e b t s i t u a t i o n . Thank you.

3 D A V I D B E R G E RON: Thank you.

4 D A N M A D Z E L A N: Thank you.

5 D A V I D B E R G E RON: Emma Simpson.

6 E M M A S I M P S O N: Good morning.

7 M y n a m e i s Emma Simpson, and I am the

8P r e s i d e n t o f t h e S t udent Body at the University of

9M a r y l a n d , C o l l e g e P ark, the state’s flagship

10i n s t i t u t i o n .

11 B e f o r e I b e gin, I would like to thank you

12f o r h a v i n g t h i s h e a ring this morning. I knew that

13I w a l k e d i n t o t h e r ight place and I am testifying

14t o t h e r i g h t g r o u p when, on the wall, the mission

15s a y s t h a t i t i s h e r e to create equal access to

16e d u c a t i o n .

17 M a k i n g t w o - year and four-year institutions

18a c c e s s i b l e t o a l l s tudents is critical. An

19e d u c a t e d w o r k f o r c e has been credited for much of

20o u r c o u n t r y ’ s e c o n o mic prosperity over the past

21c e n t u r y . F o r M a r y l and, in particular, a 2001 study

22s h o w e d t h a t t h e U n i versity System of Maryland,

23w h i c h i n c l u d e s 1 1 p ublic institutions, is

24r e s p o n s i b l e f o r b i l lions of dollars in additional

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1s t a t e r e v e n u e d u e t o graduates’ increased earnings.

2I a m s u r e y o u h a v e heard those numbers before, and

3m o s t p e o p l e c a n p r o bably agree on the importance of

4h i g h e r e d u c a t i o n . Instead, it comes down to a

5n u m b e r s i s s u e .

6 A s I p r o c e e d with my testimony, I want to

7s t r e s s t h a t h i g h e r education is an investment. The

8m o r e m o n e y t h a t i s put in now, the more it will pay

9o f f i n t h e l o n g r u n . A 2005 study titled “The

10V a l u e o f H i g h e r E d u cation: Individual and Societal

11B e n e f i t s ” d o c u m e n t s the numerous individual,

12c o m m u n i t y , a n d g e n e ral societal benefits associated

13w i t h a n e d u c a t e d w o rk force. For example,

14i n v e s t i n g i n t o d a y ’ s students is likely to increase

15t h e p r o b a b i l i t y t h a t their own children will go to

16c o l l e g e a n d i n c r e a s e the economy’s output and

17i n c o m e w h e n t h e y e n ter the work force themselves.

18 I f , h o w e v e r , the cost of a college

19e d u c a t i o n b e c o m e s t oo burdensome, I fear we will

20s e e n e g a t i v e c o n s e q uences. For one thing, I am

21c o n c e r n e d i t w i l l l ead to a substantial decrease in

22p u b l i c s e r v i c e . P e rsonally, I am in the

23I n t e r n a t i o n a l D e v e l opment and Conflict Management

24P r o g r a m a t t h e U n i v ersity of Maryland, with a group

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1o f m y t h r e e p e e r s t hat highly value public service,

2b u t I h a v e b e e n d i s appointed as senior year goes

3o n , a n d a s f r i e n d s are searching for jobs, to hear

4h o w m a n y o f t h e m t a lk about finding the highest

5p a i d j o b s s o t h a t t hey can pay off their loans.

6 M y b o y f r i e n d serves as a perfect example.

7F o r t h e p a s t t h r e e years, he has talked about going

8i n t o p u b l i c i n t e r e s t work, but now, as he is

9p l a n n i n g t o t a k e o n tons of loans for law school,

10h e h a s t o l d m e r e c e ntly that public interest law is

11n o t p r o f i t a b l e e n o u gh to pay off loans and raise a

12f a m i l y .

13 I a m a l s o c oncerned that, with tuition

14r a t e s o n t h e r i s e , the share of income put towards

15d e b t p a y m e n t s w i l l become too great and leave many

16r e c e n t g r a d u a t e s i n poor financial situations. My

17p a r e n t s d i d n o t p a y off their student loans until

18t h e y w e r e w e l l i n t o their 40s, the result of paying

19f o r f o u r y e a r s o f c ollege, professional school and,

20o f c o u r s e , k i d s . A side from $1,000 they managed to

21s t a s h a w a y f o r m e , and $1,000 for each of my

22s i b l i n g s w h e n w e w e re born, my parents did not have

23t h e c h a n c e t o i n v e s t until they were in their 50s.

24T h i s i s d a n g e r o u s f or an ownership society.

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1 B e f o r e I c o nclude, I would like to provide

2a b r i e f o v e r v i e w o f the situation at Maryland. Over

3t h e p a s t f e w y e a r s , tuition has increased by 44

4p e r c e n t . I n o n e y e ar alone, there was a tuition

5i n c r e a s e a t t h e s t a rt of the academic year, and

6t h e n o n e h a l f w a y t h rough the year. A girl living

7o n m y f l o o r h a d t o move back to her parents’ house

8t o a f f o r d s c h o o l , a nd a second one on my hall had

9t o d r o p o u t c o m p l e t ely because of cost.

10 W h i l e w e a r e still a state school, and

11c o n s i d e r a b l y m o r e a ffordable than private schools,

12n o p a r e n t c a n c a l l it cheap. College Park’s

13t u i t i o n , t e x t b o o k p rices, mandatory fees, and room

14a n d b o a r d n o w a m o u n t to $20,303 per year for in-

15s t a t e s t u d e n t s , a n d $33,742 per year for out-of-

16s t a t e s t u d e n t s . F o r parents of in-state students,

17o u r u n i v e r s i t y i s p robably the best option, yet

18t h a t i s s t i l l a p r i ce tag of $82,000 for four

19y e a r s . L o a n s a r e n ecessary for many students to

20c o v e r t h e c o s t s , y e t we are all taught about the

21d a n g e r s o f b e i n g i n debt.

22 T o a v o i d m a ssive amounts of debt when they

23g r a d u a t e , m a n y s t u d ents work one or two jobs during

24t h e s c h o o l y e a r . W hile there is conflicting

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1r e s e a r c h o n t h e a c t ual impact of employment on

2a c a d e m i c a c h i e v e m e n t, there is an important

3d i f f e r e n c e t o n o t e in the types of employment.

4 T h i s y e a r I am serving as the Student Body

5P r e s i d e n t , a r o l e t hat takes 30-50 hours a week.

6I t i s a n e x t r e m e l y stressful role, and I do not get

7p a i d , b u t m y p o s i t i on will pay off endlessly with

8t h e s k i l l s I h a v e a cquired and the experiences I

9b r i n g t o t h e t a b l e . For students who are forced to

10f i n d p a i d w o r k , t h e re are few paying jobs that will

11g i v e t h e m t h e l e g u p in the career field. The

12s t u d e n t w i t h a j o b at the campus recreation center

13o r t h e d i n i n g h a l l will not compare to the student

14w h o h a s a n u n p a i d i nternship at the Smithsonian

15I n s t i t u t i o n o r a n u ndergraduate research position

16w i t h a p r o f e s s o r .

17 I h a v e b e e n an undergraduate teaching

18a s s i s t a n t f o r t w o g overnment courses. I have co-

19t a u g h t a f r e s h m a n i ntroductory course for two

20y e a r s . I w a s a p o l icy intern at an advocacy

21o r g a n i z a t i o n i n W a s hington, D.C. I was the

22P r e s i d e n t o f t h e S t udent Global AIDS Campaign on

23c a m p u s f o r t w o y e a r s, and I served on the National

24S t e e r i n g C o m m i t t e e . I was the Vice President of

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1A c a d e m i c A f f a i r s f o r the SGA, and now I am the

2S t u d e n t B o d y P r e s i d ent. These are educational and

3l e a d e r s h i p o p p o r t u n ities I have had because I have

4n o t h a d t o p a y f o r college and because my parents

5c o u l d a f f o r d t h e c o sts of education.

6 F o r m a n y s t udents, however, these

7o p p o r t u n i t i e s a r e n ot available. We pride

8o u r s e l v e s o n p r o v i d ing equal opportunities, but I

9c a n r e c o g n i z e t h e t remendous privileges I have had

10b e c a u s e o f m y a b i l i ty to go through college without

11m o u n t i n g d e b t , a n d my ability to take on unpaid

12p o s i t i o n s .

13 T h u s , I a m here today not to advocate on

14m y b e h a l f , b u t o n b ehalf of the 10,000 or so

15s t u d e n t s a t M a r y l a n d who will graduate with debt.

16I u r g e y o u t o s u p p o rt the five-point plan for

17m a k i n g t h e c o s t o f college more manageable. It

18w i l l h a v e a n i n c r e d ible impact on these 10,000

19s t u d e n t s a t M a r y l a n d, the students at numerous

20o t h e r i n s t i t u t i o n s , and society at large.

21 Thank you.

22 D A V I D B E R G E RON: Thank you, Emma.

23 W i t h t h a t , we have concluded the list of

24w i t n e s s e s t h a t w e h ave for this morning. We will

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1r e c o n v e n e a t q u a r t e r to 1:00? 1:00? 1:00.

2 I a m l o o k i n g at my director over in the

3c o r n e r . T h a n k y o u , Mary.

4 D A N M A D Z E L A N: Always check with the boss.

5 D A V I D B E R G E RON: So we will reconvene at

61 : 0 0 . T h a n k y o u a l l.

7 [ R e c e s s f o r lunch at 11:54 a.m.]

8

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1 A F TERNOON SESSION

2 [1:05 p.m.]

3 D A V I D B E R G E RON: We are going to get

4s t a r t e d i n j u s t a m inute. Actually, we are about

5t h r e e m i n u t e s l a t e , which I hate to be three

6m i n u t e s l a t e w h e n w e start the afternoon, but I

7t h i n k w e a r e g o i n g to be fine.

8 W e h a v e w i t nesses signed up until about

93 : 5 0 a t t h i s p o i n t , so we actually may be done by

104 : 0 0 , w h i c h , i f y o u asked me at the start of the

11d a y i f w o u l d g e t t h at point by that time--but we

12w i l l b e p r e t t y c l o s e, I think, to completing at the

13e n d o f t h e d a y .

14 O u r f i r s t w itness this afternoon is going

15t o b e C o n s t a n t i n e C urris.

16 C O N S T A N T I N E CURRIS: Thank you very much.

17 I a m p l e a s e d, as President of the American

18A s s o c i a t i o n o f S t a t e Colleges and Universities to

19h a v e t h i s o p p o r t u n i ty to comment on several issues

20o f m a j o r c o n c e r n t o our membership, which includes

214 3 0 p u b l i c c o l l e g e s and universities and higher

22e d u c a t i o n s y s t e m s .

23 P r i o r t o a s suming the ASCU presidency in

241 9 9 9 , I h a d t h e p r i vilege to serve as a university

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1p r e s i d e n t a t t h r e e institutions, beginning in 1973.

2D u r i n g m y 3 3 y e a r s in higher education, many

3c h a n g e s , m a n y o f t h em good, have occurred, but none

4h a s b e e n m o r e d a m a g ing to students and their

5f a m i l i e s , a n d , I b e lieve, to the nation as a whole,

6t h e n t h e e x t r a o r d i n ary rise in student

7i n d e b t e d n e s s .

8 T o d a y , t h a t indebtedness retards our

9l o n g s t a n d i n g g o a l o f ensuring access and

10o p p o r t u n i t y , a s w e l l as impacting the career

11c h o i c e s a n d e c o n o m i c opportunities for our

12g r a d u a t e s . W e h a v e created a new debtor class, our

13g r a d u a t e s , a n d i t s ranks are swelling.

14 T h e c a u s e s for this unfortunate

15d e v e l o p m e n t a r e m a n y, and there is no single or

16s i m p l e s o l u t i o n , b u t several of the steps to

17a d d r e s s t h e p r o b l e m of excessive, onerous

18i n d e b t e d n e s s c a n b e addressed by the United States

19D e p a r t m e n t o f E d u c a tion through these negotiated

20r u l e m a k i n g p r o c e d u r es and the decisions that will

21f o l l o w .

22 O n e o f A S C U ’s major concerns on behalf of

23b o r r o w e r s i n t h e l o an program is the lack of

24r e p a y m e n t p r o v i s i o n s that allow borrowers maximum

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1f l e x i b i l i t y r e l a t i v e to their incomes and the size

2o f t h e i r d e b t . W e understand that, while graduates

3f r o m t h e p a s t f i v e years have, on average,

4e x p e r i e n c e d e x t r a o r dinary difficulty in repaying

5t h e i r l o a n s . N e v e r theless, as college costs,

6a m o u n t s b o r r o w e d , a nd interest rates have recently

7i n c r e a s e d a n d a r e i ncreasing, a growing proportion

8o f b o r r o w e r s w i l l n ot be able to manage their debt

9u n d e r t r a d i t i o n a l r epayment plans.

10 W e c a l l a t t ention to the proposals of the

11p r o j e c t o n s t u d e n t debt to make loan repayment more

12m a n a g e a b l e a n d e q u i table. We believe that the

13i n c o m e - c o n t i n g e n t r epayment program and economic

14h a r d s h i p d e f e r m e n t s are solutions that should be

15w i d e l y a n d e a s i l y a vailable for borrowers whose

16d e b t - t o - i n c o m e r a t i o has made it impossible for

17t h e m t o r e p a y o n m o re traditional amortization

18p l a n s . W e u r g e t h e Department to work with the

19h i g h e r e d u c a t i o n a n d lending communities to make

20i n f o r m a t i o n a b o u t t hese additional repayment plans

21m o r e w i d e l y a v a i l a b le.

22 S e c o n d l y , a s you may know, ASCU has

23e n d o r s e d t h e r e c o m m endations of the Secretary’s

24C o m m i s s i o n o n t h e F uture of Higher Education. We

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1a r e c o m m i t t e d t o a c countability to the public as

2e m p h a s i z e d i n t h e C ommission Report. That report

3c l e a r l y a s s e r t s t h a t continued public support is

4n o t a u t o m a t i c , b u t would be contingent upon our

5r e s p o n s i v e n e s s t o t he educational needs of our

6f e l l o w c i t i z e n s , a n d our assistance to the states

7a n d t h e n a t i o n i n t his critical time of economic

8a n d s o c i a l r e a d j u s t ment.

9 R e g a r d l e s s of the data system used to

10c o l l e c t i n f o r m a t i o n about our students and our

11i n s t i t u t i o n s , w e s t rongly urge the Department to

12m a k e m u c h n e e d e d c h anges to the outcomes data now

13c o l l e c t e d i n t h e f o rm of graduation rates. The

14d e f i n i t i o n o f g r a d u ation rates mandated in the

15s t a t u t e s a n d r e g u l a tions is outmoded, and has been

16o v e r t a k e n b y c h a n g i ng student populations. The

17n u m b e r o f p a r t - t i m e and older students on our

18c a m p u s e s h a s g r o w n considerably during the last

19g e n e r a t i o n . A t t h e same time, alternative

20a t t e n d a n c e p a t t e r n s related to life and career

21c h o i c e s h a v e e m e r g e d, giving rise to terms such as

22“ s t o p p i n g o u t , ” a n d to patterns such as students

23a t t a i n i n g a s s o c i a t e degrees after they completed

24t h e i r b a c c a l a u r e a t e . What is currently collected

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1h a s v i r t u a l l y n o v a lidity and, in truth, its

2p u b l i c a t i o n m i s l e a d s the public.

3 W e b e l i e v e the Department has the

4n e c e s s a r y a u t h o r i t y to modify its current

5r e q u i r e m e n t s f o r i n stitutional reporting in this

6a r e a , a n d s t i l l m e e t the minimum requirements of

7t h e s t a t u t e a n d r e g ulations. ASCU believes that

8c o l l e g e s a n d u n i v e r sities have a responsibility to

9c o m m u n i c a t e c l e a r l y and effectively about their

10s t e w a r d s h i p o f t h e public’s investment in them.

11P o l i c y m a k e r s a n d t h e general public need better

12d a t a a n d m o r e m e a n i ngful information, not simply

13m o r e d a t a .

14 A S C U s u p p o r ts amendments to the Higher

15E d u c a t i o n A c t t h a t would require public disclosure

16a n d d i s s e m i n a t i o n o f findings from final

17a c c r e d i t a t i o n r e p o r ts. Additionally, ASCU

18e n c o u r a g e s t h e r e g i onal accrediting agencies to

19b r o a d l y c o m m u n i c a t e their initiatives in assessing

20s t u d e n t l e a r n i n g . As you may know, ASCU, in

21c o l l a b o r a t i o n w i t h our sister association has

22e m b r a c e d a v o l u n t a r y institution accountability

23p r o j e c t t o m e a s u r e student learning in the context

24o f w h a t w e a d d i n t erms of value, and how we can

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1s t r e n g t h e n t h e u n d e rgraduate process.

2 T h e D e p a r t m ent has announced that the

3f i r s t p a n e l o f n e g o tiated rulemaking will be on the

4A c a d e m i c C o m p e t i t i v eness Grant and the National

5S M A R T G r a n t P r o g r a m . ASCU has joined with the

6U n i v e r s i t y o f N e w Y ork in submitting recommended

7i m p r o v e m e n t s t o t h e final regulations, and we

8b e l i e v e t h o s e c o m m e nts should inform the discussion

9o f t h e f i r s t p a n e l , and have proposed in a separate

10l e t t e r t h a t M r . G e o rge Chin, University Director of

11S t u d e n t F i n a n c i a l A id at SUNY be selected as one of

12t h e n e g o t i a t o r s . W e support the Department’s

13e f f o r t s t o i m p l e m e n t the programs quickly and with

14n e e d e d r e v i s i o n s , a s those that we have proposed.

15 L a s t l y , w e commend to the Department’s

16r e c o m m e n d a t i o n s f r o m the Commission on the Future

17o f H i g h e r E d u c a t i o n , calling for significant

18i n c r e a s e s i n a p p r o p riations for the Pell Grant

19P r o g r a m a n d f o r r e s tructuring student aid programs

20t o f o c u s r e s o u r c e s on assisting those students with

21s e r i o u s f i n a n c i a l n eed.

22 I a p p r e c i a t e the opportunity to share

23t h e s e c o n c e r n s w i t h you, and pledge our continued

24c o n s t r u c t i v e e n g a g e ment. Thank you.

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11 DAVID BERGERON: Thank you.

2 D A V I D B E R G E RON: Dina Zarella.

3 DINA ZARELLA: Good afternoon.

4 My name is Dina Zarella. I am a social worker at

5the National Association of Social Workers, and serve there

6as a senior field organizer in our Government Relations and

7Political Action Department.

8 NASW is pleased to submit comments to the

9Department of Education regarding this negotiated

10rulemaking. Founded in 1955, NASW seeks to enhance the

11well being of individuals, families, and communities

12through its work and advocacy. NASW has long advocated for

13client’s rights, self-determination, and client-centered

14care.

15 NASW urges you to address the issue of fair

16student loan repayment. Reducing debt burden is both an

17area where you have the authority to regulate, and it is an

18issue that your Commission on the Future of Higher

19Education identified as a priority.

20 As the world’s largest association of

21professional social workers, with 150,000, NASW has members

22across the United States who struggle to maintain their

23social work careers while repaying their burdensome loan

24debt.

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1 Social workers enter the profession to make a

2difference in their communities, but too many of them have

3to move away from this career in order to pay for their

4schooling and raise their families. Social workers

5experience loan debt in a way many other advanced degree

6professionals do not. For many social work jobs, you need

7a master’s degree to even qualify. Bachelor’s level social

8workers in a study for 2004 and 2005 were shown to have an

9average loan debt of $18,609, master’s level had an average

10loan debt of $26,777, and doctoral level social workers

11have an average loan debt of $32,841.

12 In 2001, the median salary of social workers with

132-4 years of experience was only $35,600. Over 20 percent

14of social workers make less than $30,000 a year. As you

15can see, comfortably repaying loans well over $18,000 is

16quite difficult for new and experienced social works who

17may make less money than most equally educated

18professionals in much more lucrative careers. Social

19workers provide services to people of all income ranges and

20in all communities across the country. If we want to

21maintain a high level of training for these crucial

22professionals, we need to find ways to remove the barrier

23of burdensome loan debt so that they can serve their client

24base.

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1 Unfortunately, the tools that are supposed to

2assist borrowers with payments on federal loans are

3inadequate, confusing, and inconsistent--too often

4providing the wrong incentives. Without improved

5protections for borrowers, the nation may see an increase

6in default and bankruptcies, rather than an increase in

7more productive graduates who can contribute fully to

8society.

9 After four years of undergraduate studies and two

10years of graduate studies, I entered the social work

11workforce with over $40,000 in loan debt and a starting

12salary of $22,000 a year. With interest over ten years, I

13would pay double that amount back. I lived in Philadelphia

14at the time, and my monthly $600 loan debt payments ate up

15half of my take home salary. It was difficult to find

16adequate housing and to cover my basic needs on the

17remaining $600 per month. Within six months, I moved back

18in with my parents in Chicago to restart my job search

19process. My first job in Chicago paid slightly more, at

20$25,000 a year. I lived at home for several months before

21I was able to afford a studio apartment. I am one of the

22fortunate ones, because my parents were able to help

23support me during my early career, but for too many social

24workers, particularly mid-career returning social workers,

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1this is not possible.

2 Over the years, NASW has collected stories from

3social workers who are desperately trying to repay their

4loans, and I have a few of them here I want to share.

5 “The $700 a month that my wife and I paid to the

6government for our student loans and will pay over the next

730 years is money that inhibits us from living better lives

8for us and our own children. This is true even as we help

9many others to live better lives. My wife and I both have

10master’s degrees, and we both rehabilitate people with a

11degree of measurable success, and we still, for example,

12live in a mobile home with our three children. We didn’t

13get the degrees in order to get a better financial life.

14We got the degrees in our fields of expertise in order to

15help make the world a better place.”

16 Another social worker says:

17 “I am a child welfare social worker at a child

18family and services agency. I received my MSW, master’s

19degree in social work, in 1997 from Howard University. My

20student loan debt is now up to over $70,000, and I am

21struggling to repay.”

22 A licensed social worker in the state of West

23Virginia talks about having worked in the field for 13

24years, and then completing her MSW degree. Social workers

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1work in many fields and many different positions, and I

2don’t know any social worker, be it a child welfare worker,

3or geriatric worker, hospital social worker, et cetera, who

4makes enough money to easily pay back the loans they have

5incurred to further their education.

6 “I know that I am going to have a loan balance of

7$20-30,000 to pay off when I graduate next May from my

8program, and I will not make enough money to adequately

9address my bills, but I still plan on working in the field.”

10 Another social worker talks about being a

11graduate of Temple University:

12 “I completed the social work program in 2002 and

13earned a BSW, a bachelor’s in social work degree. I have

14worked in the child welfare system for four years, and am

15currently seeking assistance with loan forgiveness programs

16as I am struggling to pay my student loan. I have been

17accepted into a master’s program to obtain my MSW, but am

18putting that off due to my current loans.”

19 As you can hear from these individual stories,

20these are the types of people we want and need to be

21serving our children, our parents, and our communities.

22They will better be able to do so if provided reasonable

23loan repayment options.

24 NASW concurs with the five-point plan presented

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1to the Department of Education in May, including limiting

2student loan payments to a reasonable percentage of income

3to 10 percent, and never more than 15 percent of income,

4recognizing that borrowers with children have less income

5available for student loan payments, preventing added

6interest from making the problem even worse when borrowers

7face hardship situations, canceling remaining debts when

8borrowers have made income payments for 20 years, and

9simplifying the process of applying for hardship deferrals.

10 NASW urges you to include these proposals in the

11upcoming negotiated rulemaking. Our nation’s economic

12future depends on the education of our citizenry, and

13student loans have become an embedded part of the financing

14system for training beyond high school. Given the

15important role of loans in making it possible to attend and

16complete college, it is incumbent upon us to ensure that

17loan repayments are not unfairly excessive. If NASW may be

18of additional assistance, please do not hesitate to contact

19me.

20 Thank you so much for allowing me to present this

21testimony and for examining this critical issue.

22 DAVID BERGERON: Thank you.

23 D A V I D B E R G E RON: Brandon Lozeau.

24 BRANDON LOZEAU: Hello. I would like to thank

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1you for letting us come today.

2 My name is Brandon Lozeau. I am a student at the

3University of Massachusetts at Dartmouth, and I am a senior

4double majoring in political science and French, with a

5minor in economics, and also working on a certificate in

6international marketing in French.

7 My family and I are all too familiar with student

8loans and the financial burden that they are placing on my

9future and the futures of so many other students who can’t

10afford to self-finance a postsecondary education. As

11difficult as carrying debt is for me, it is more

12unfortunate that there are thousands of families out there

13who do not have the financial means of even sending their

14child to a college or university. The U.S. Government and

15the Department of Education must work harder and implement

16policies that will allow for easier loan repayment and more

17affordable access to higher education in this country.

18 I will be graduating from my university with more

19than $50,000 in student loans, and I actually plan on going

20to grad school, which is going to cost me another $30,000.

21The interest rates on my loans have added more than $5,000

22to the amount that I must repay when I exit school. For

23years, I have been interested in government and the public

24sector, because I have come to realize how much government

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1affects the daily lives of millions of people in this

2country every day. I feel as though my knowledge and

3skills would be so useful in the public arena, but the fact

4remains that I will not be able to afford to take a job

5that I would love because of the financial constraints that

6student loans have placed on me over the last three-and-a-

7half years in matriculation.

8 Just the other day, I read an article that

9stated, “The average annual starting salaries for students

10graduating with a four-year degree in political science

11have increased only one percent in the last year, to a

12little more than $33,000 a year.” If one subtracts housing

13costs, transportation costs, and other survival costs,

14there isn’t much left over to pay off the crippling student

15loans. It seems our system for paying for college is now

16actively discouraging the next generation from using our

17skills to get involved and give back to the community. I

18think that runs against what a college degree should be

19about.

20 In America, we put so much emphasis on attending

21colleges and universities after attending secondary school

22because it is supposed to be the gateway to opportunity and

23advancement for our country as a whole. Like so many other

24things, actions speak louder than words. Every student

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1should have equal access to higher education in this

2country. The Department of Education can provide student

3loan repayment incentives to enter jobs that do not

4necessarily attain high salaries, but are a great social

5benefit, like teachers, social workers, and positions in

6other public service sectors. And, of course, you can

7adopt the five-point plan for manageable debt that is

8promoted by many student groups here today and other

9coalition organizations.

10 In the realm of education, not enough emphasis is

11placed on the importance of higher education and making it

12a universal right. Every child in the United States has

13the right to a K-12 education, but there should be a

14similar guarantee for higher education, as well. Attending

15a college or university should be something students see as

16a natural next step in their development as a human being.

17A person who wants to better him or herself, their career

18opportunities, and their country by taking full advantage

19of all the educational opportunities that this country has

20to offer, should not view entrance into the realm of higher

21education as financial suicide.

22 So many potential students could enter higher

23education with more aid in the form of grants, repayment

24incentives, and lower interest rates on student loans. I

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1strongly encourage the Department of Education to implement

2policies that will grant the opportunity of a higher

3education to all who want one, not to just those who can

4afford one.

5 Thank you for your time.

6 DAVID BERGERON: Thank you, Brandon.

7 D A V I D B E R G E RON: Nick Nuar--did I get anywhere

8close to right with your name?

9 NICK NUAR: Pretty close.

10 Hi, I am Nick Nuar. I am here from Rutgers

11University in Camden, coming on behalf of NJPIRG, and with

12the support of the Student Government Association.

13 I am here to testify on the value of higher

14education funding, what it means to me, and what it means

15to the future.

16 This Administration and the President have a

17vision when it comes to education. President Bush has

18referred to reading as the new civil right. He understands

19the impact of strong thinkers, accountable education, and

20empowered market participants for the future of our country.

21 There is a lot of positive talk, and we are here

22today to suggest that you follow up with the right actions.

23Many of us are concerned that the recent congressional cuts

24to higher education loan programs are not a step in the

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1right direction. With globalization, especially, it is

2important for America to have citizens that understand and

3can compete in the global economy.

4 The past 200 years have been good to the United

5States of America; however, we must work hard, think

6creatively, and face emerging challenges to continue to

7prosper. Getting more people into college and graduated is

8the best chance we have for our country to remain durable.

9 My college story begins years ago. When I

10started school, I had some family support. My family could

11not continue to help me out after my first year at school,

12and the financial aid I could qualify for was not enough.

13I had to drop out at the beginning of my second year. I

14worked full-time as a mechanic, a tow truck driver, and at

15an insurance company. The next year I tried working full-

16time while going to school. I have friends who have pulled

17this feat off, but for me it did not work, and my health

18suffered. In the end, it was not sensible to make money or

19progress through school. I ended up moving back in with my

20father and going to Rutgers in Camden. I have worked hard

21and persevered, and now, several more years than I planned

22on, I have $30,000 in debt, but I also have a physics

23degree.

24 My education has been great. Thanks to the

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1knowledge I learned and encouragement from professors, I

2recently presented a poster at the American Association of

3Physics Teachers. It was about 3-D scanners in high

4schools as a fun way to interest kids in math and physics

5concepts. A professor there asked me to modify my system

6so that I could do a scan for armor dynamics, a new kind of

7lightweight body armor that will protect troops and

8civilians. I am still looking for a full-time job, and

9this is a positive development for my career. Beyond my

10career, many will benefit from this innovation.

11 I am convinced that physics has taught me how to

12think keenly and solve hard problems. It is probably the

13most difficult thing that I have done and, to me, a proper

14right of manhood. As a result, I am ready to take on some

15of the big challenges American society will be facing.

16 But you don’t need a physics degree to recognize

17that the 21st Century is being driven by productivity gains,

18new medicines, energy-efficient technology, and other

19innovations, like 3-D scanners. These are all possible

20because of the educated pool of talent that we can draw on.

21The future depends on solving hard technical problems and

22backing it up with feasible political solutions.

23 Many high profile economists, like Samuel Keynes,

24disagree on the specific role that government should play

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1and the ideal size of the government. They seem to be

2unanimous, however, in the long-term economic benefits of

3education. In its cost benefit analysis--if you will bear

4with me as I share some very basic numbers, not as nuanced

5as the Department already has, I am sure. The Texas

6Commission on Higher Education, in its cost benefit

7analysis, found a thirteen-fold return when the Texas

8government invests extra dollars in college education.

9 When I consider all the other benefits like the

10internal freedom of graduates, also that we become more

11informed and engaged citizens, that we make local economies

12stronger, and that we build a stronger tax base for federal

13and state budgets through our income. I am even more

14firmly in my belief that one place where the government

15should invest is education.

16 Please enhance our investment by making

17universities more accessible and costs more manageable.

18Thank you for your time.

19 DAVID BERGERON: Thank you.

20 D A V I D B E R G E RON: Kerrin Forgette.

21 KERRIN FORGETTE: My name is Kerrin Forgette, and

22I am here on behalf of MassPIRG at the University of

23Massachusetts, Dartmouth.

24 I am just beginning to figure out what the rest

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1of my life might look like, and, although it is sad to say,

2money is a huge factor in the decisions that I make.

3 Ever since I can remember, it was always

4understood that I would go to college. It was also

5understood that, unless I won the lottery, or an equivalent

6in scholarships, I would be attending a state school. I

7could not understand why I should have to go to such an

8expensive school and start my life with thousands of

9dollars of debt. So I opted to go to the least expensive

10school that would suit my needs. After only a year of that

11my parents could not afford the costs, so we took out

12student loans. My plan had backfired. I barely had one

13foot into the so-called “real world,” and I already owed

14money, and I would owe a lot more before I would graduate.

15 My whole life I watched my parents struggle

16through their debt. I don’t even think student loans were

17a factor in the money that they owed, which really scares

18me. Their debt is just from the everyday living expenses

19of raising a family. By the time I am their age, I will

20probably be burdened by the same expenses, plus the cost of

21my schooling. I don’t want to have to fight through my

22life to pay off the money I owe, and I know they don’t want

23that for me, either. I also know it pains them that I had

24to take out loans for college because of their current

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1experiences with debt.

2 This thought plagues me every time I think about

3career choices. I really wanted to be a teacher for a long

4time, and I still do, but I want to teach because I love

5the idea of talking about what I know for a living. I want

6others to hear my ideas, and I want to influence people in

7some way.

8 But the truth is I won’t make a high salary as a

9teacher, and I have to balance my deep debt from college I

10will carry against that reality. So now I am not sure what

11to do with my life. I don’t want to enter a career I am

12not crazy about, but I don’t want to have a job I love with

13nothing to show for it.

14 I know I am not the only one with these thoughts,

15and that is a big problem. This country needs teachers and

16other public service workers to sustain itself. If it is

17not economically possible to go into these fields, then our

18whole society suffers.

19 I read an article saying that education is a

20right and not a privilege, and this really caught my

21attention. Anyone should be able to learn in college if

22they so choose to; it should not be reserved to those who

23can afford to pay the most. But I understand, like

24everything else in the world today, college costs money. I

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1also understand that there is nothing the Department of

2Education can do about the rising cost of higher education,

3but there is something you can do to help students deal

4with this cost. You can adopt the five-point plan to help

5ease the burden many are facing now, and countless others

6are doomed to face.

7 I strongly agree that a person’s income should be

8taken into account when determining loan repayment. Those

9people who are brave enough to enter a field of education,

10social work, and other public service jobs should be able

11to do those jobs without the constant burden of debt. Of

12course, these loans need to be repaid in a reasonable

13amount of time, but if you are not making enough to pay

14them back, then everyone involved suffers.

15 Also, graduates with children should not have to

16choose between giving their children what they need and

17paying off their college loans. It costs a lot of money

18these days to raise a family, and this should definitely be

19taken into consideration.

20 So I ask you to keep these ideas in mind when you

21are making your decisions. Please keep students like me in

22mind. The five-point plan is just a small step to

23improving the cost of higher education, but it is an

24absolutely indispensable step that must be taken.

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1 Thank you.

2 DAVID BERGERON: Thank you.

3 D A V I D B E R G E RON: Sandrae Ban.

4 SANDRAE BAN: Good afternoon.

5 My name is Sandrae Ban, I have traveled from

6North Shore Community College in Lynn, Massachusetts, to

7speak to you today.

8 It is my honor to represent in the future of the

9best country on earth. How did the U.S.A. get to become

10the best? It was apparently the work of great business

11leaders, scientists, politicians, and philosophers. Their

12contributions are studied and taught by the best

13universities not only here, but worldwide, but that legacy

14is getting lost.

15 We have brilliant minds that are going to waste

16on a daily basis due to the high cost of college. Our

17colleges could develop the next Albert Einstein, Thomas

18Jefferson, or great person of the century, but the next

19generation is opting out of college instead.

20 As a people, we cherish the special moment when

21our children reach the pinnacle of educational success. We

22smile with joy as they stand at graduation, degree in hand.

23That degree means so much more than a bigger paycheck, it

24signifies the hope of everyone that our future will be

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1brighter and stronger because we trained the next

2generation to take our society further.

3 So many parents and students dream of such

4events. So many parents and students do what they can to

5make this hope a reality, but guess what? A four-year

6college is too expensive. Parents and students have to

7take more and more loans to pay for it. Even though a

8four-year degree is a path to independence and optimism, it

9has become financially easier to start a job after leaving

10high school rather than enrolling in a four-year college.

11 More and more students who make it through coming

12 to a college like North Shore don’t have the resources to

13 continue further. The fact that students have to take so

14 much debt is a huge problem. I am here to tell you that

15 the reality of taking too much debt stops parents and

16 families from considering a four-year college, and this

17 stops hope and inspiration towards a better tomorrow.

18 A nation without relatively easy access to a

19higher education is a nation without hope, a nation heading

20for failure. With the current world order, can we afford

21for our children to fail? We are all here with one aim,

22one goal, one destiny.

23 This event reminds me of the pilgrims that

24arrived in Virginia in 1607. They all had enormous

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1problems, and they looked to the North for hope. Their

2cries were heard and addressed collectively. From such

3acknowledgment evolved the “land of the free, and the home

4of the brave.” Can you imagine what we can achieve if our

5cries are heard and addressed in the same manner? The

6result would be the fastest growing country in relation to

7educational, social, political, and economic advancement.

8 My mom is the main breadwinner of the household.

9I can remember vividly applying for financial aid this

10semester, which I was denied, because she made too much

11money in 2004. However, in the process of applying, she

12was diagnosed with lymphoma cancer, which reduced the

13family income drastically. The fact that I was not able to

14attain financial aid, which would make my expenses more

15bearable, could easily deter my motivation in regards to

16pursuing a higher education.

17 Among us, there are countless people who decide

18to terminate their education hopes after receiving the

19horrifying news from the Department of Education. It is

20unfortunate, and this cannot be over emphasized, that the

21tools that are supposed to assist borrowers with payments

22on federal loans are inadequate, confusing, and

23inconsistent.

24 One approach to make access to higher education

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1easier is to make loan repayment easier and more

2affordable. Earlier this year, Congress went in the wrong

3direction by making student loans more expensive. In

4contrast, the Department of Education can give us back a

5little hope by enacting the five-point plan to make student

6loan more affordable. When I look forward, I see the

7emblem with the Department of Education, and I see a green

8tree, which simply means we should flourish, and with the

9current debt, it is almost impossible for this generation

10to flourish. So I am asking you to please just consider

11what we have to say.

12 Thank you very much.

13 DAVID BERGERON: Thank you.

14 D A V I D B E R G E RON: Sarah Flanagan.

15 SARAH FLANAGAN: Thank you.

16 I am Sarah Flanagan, Vice President for

17Government Relations and Policy Development of the National

18Association of Independent Colleges and Universities.

19 The approximately 1,000 NAICU members nationwide

20reflect the diversity of private, not-for-profit higher

21education in the United States. Our members include

22traditional liberal arts colleges, major research

23universities, church and faith-related institutions,

24historically Black colleges and universities, Hispanic-

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1serving institutions, women’s colleges, performing and

2visual arts institutions, two-year colleges, and schools of

3law, medicine, engineering, business, and other professions.

4 Our institutions vary greatly in the missions

5that they serve, but we are united in our commitment to

6quality and student success. We educate more than 20

7percent of college students, while awarding 30 percent of

8all degrees. Since 1976, NAICU has represented our

9institutions on public policy with the federal government.

10Throughout our history, we have been closely engaged with

11legislation affecting programs under the Higher Education

12Act, and with the regulatory process that governs these

13programs. We have participated in all past negotiated

14rulemaking sessions, and welcome the opportunity to be part

15of the upcoming meetings.

16 Our policy work has focused on two things of

17particular relevance today: one, providing students with

18access to the college of their choice; and two, taking

19appropriate regulation that is sensitive to the diversity

20and independence of our institutions while addressing

21legitimate public policy needs.

22 We understand that the purpose of the public

23hearings, which are concluding today, and NAICU has had at

24least two staff at each of those hearings, is to identify

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1agenda items for the negotiated rulemaking session that

2will begin in December. Clearly, there are many

3implementation questions related to the newly enacted HERA,

4particularly around Academic Competitiveness and SMART

5Grants and loan program changes that should be addressed in

6these sessions. These questions should dominate the

7negotiated rulemaking because they will lay the foundation

8for the operation of two new significant sources of grant

9aid for students.

10 It is somewhat less clear to us which of the many

11other topics raised in previous hearings are appropriately

12addressed in the upcoming negotiated rulemaking session.

13This is particularly true in those areas such as

14accreditation and transfer credit where Congress has

15discussed various changes, but has not yet amended the law.

16We would echo the advice that has been given in previous

17hearings, that negotiated rulemaking not be initiated in

18these areas until after Congress has completed

19reauthorization of the Higher Education Act.

20 Because accreditation is of particular interest

21to our member institutions, I want to make a few comments

22about our perspective in that area. Because no changes in

23the accreditation law have been made since 1998, it is not

24clear exactly what would be covered in the negotiated

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1rulemaking session on this topic. However, should such a

2session be held, we would urge that it not be used

3primarily to impose regulatory uniformity in areas such as

4the evaluation of student learning outcomes.

5 Accreditation is a uniquely American institution.

6In most other nations, quality reviews are generally

7conducted by centralized government authorities. The

8tradition of institutional autonomy by the United States

9called for a different approach. It has an approach that

10has been highly successful over the years, and one that

11Europe is now trying to duplicate. It has a lot of

12diversity in institutions to flourish, and it has helped

13make American higher education the standard for the world.

14 As Duke University President Richard Broadhead

15pointed out in a recent column in The Washington Post,

16“High-rated officials in Asia continue to respect and

17admire the creativity of the American system.” Broadhead

18acknowledges that American higher education must improve,

19as we all do, but observes that making ourselves over in

20the image of an imagined rival won’t be the formula for

21success. Even as we correct real deficiencies, we need to

22recognize and nurture the strengths that are so evident to

23others.

24 It is important to recognize that colleges and

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1universities are interested in ensuring their students

2learning. As one would expect in a system as diverse as

3our own, they are undertaking a variety of assessment

4methods. Perhaps one of the most unusual and intense

5efforts has been launched by Alverno College in Wisconsin,

6recently highlighted in “Inside Higher Education.” They

7have abandoned grades many years ago in favor of

8integrating assessment into every element of the curriculum.

9 The Alverno system, and other innovative

10assessment systems, would never withstand reforms made in

11the name of accountability that call for standard measures

12that allow for easy comparison of institutions that are not

13alike. The drive to explore and innovate, the very

14qualities that led to the development of the now highly

15touted Collegiate Learning Assessment would be killed on

16the vine through such efforts.

17 Accreditors have already been pushing

18institutions to demonstrate how well they are achieving

19their missions based on current statutory requirements

20enacted in 1992 and strengthened in 1998. These efforts

21need to be allowed to grow and develop, not to be

22suffocated in an effort to achieve measurable and

23comparable outcomes.

24 Accreditation has been used successfully by the

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1federal government for more than a generation to ensure

2quality and diversity of educational product, without

3inappropriate federal intrusion into matters of curriculum.

4In this sense, accreditation has served as a barrier to

5federal control. We encourage you to continue this past

6practice of limited federal regulation over accreditation

7to ensure that accreditation not become a tool for federal

8intervention.

9 This is not just a belief in the central premise

10that accreditation is first and foremost a system of peer

11review. We also believe that excessive federal control of

12accreditation would lead to a decline in the variation of

13excellence that is the hallmark of American Education.

14 Thank you for allowing me to make these remarks

15on behalf of American Independent Higher Education. We

16look forward to the formal negotiated rulemaking sessions

17in the weeks ahead.

18 DAVID BERGERON: Thank you.

19 D A V I D B E R G E RON: Lamar Thorpe.

20 LAMAR THORPE: Well, I have to say, welcome to

21the people from out of Washington, D.C. Thank you for

22coming down and supporting this good cause.

23 Thank you, members, for the opportunity to be

24here today.

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1 My name is Lamar Thorpe. I am five-year veteran

2of the United States Navy, and a senior double majoring in

3sociology and women’s studies at George Washington

4University. Currently, I am also the Student Association

5President, representing undergraduates, graduates, law,

6medical, and professional students on all three of our

7major campuses. I am a native of Los Angeles, California,

8and graduated high school in 1999.

9 Today, I praise God every day for the opportunity

10that so many people in my community did not have, a chance

11to enter higher education. When my peers and I graduated

12in 1999, most of us did not think about college loans,

13application fees, or deadlines. Why? It is quite simple,

14because there were always jobs that target--the military

15recruiters were always in our neighborhood, and the local

16community college, which most of us couldn’t finish anyway,

17never said, “no.” The idea of higher education was far

18beyond our reach and not a reality.

19 Recently, we all had the right to be upset with

20John Kerry’s botched joke, specifically saying that those

21who don’t get a good education end up in Iraq, but we were

22upset for the wrong reasons. We should have been upset for

23the fact that what he said actually has some truth to it.

24I personally did not go to Iraq, but I did join the

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1military because I had no other place to go after I failed

2out of my community college and could not find a job at the

3local grocery story, because my reading and writings skills

4were at a seventh grade level.

5 Many of the young men and women who I graduated

6with enlisted in the Marine Corps. Most of them are still

7there today, and some of them are in Iraq, never given the

8chance at higher education.

9 My message is very simple. We all need to focus

10on providing access and affordability to our children.

11These are not students, and they are not just pupils, and I

12think we forget that sometimes. These are our children.

13 The number that joined the military end up in

14prison or with few opportunities are not statistics,

15either; they are our children, whether they are Black,

16White, Asian, Middle Eastern, Latino, or whatever category

17they fit in. We are failing them by increasing student

18loan interest rates, as the Congress did this past January,

19and cutting back on funding for financial aid programs. We

20are failing them by not increasing grant or aid, by not

21expanding forgiveness in loans.

22 As a veteran, I am entitled to the Montgomery

23G.I. Bill, as most of you know, but there are many

24misconceptions about the G.I. Bill itself. I am always

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1amazed that people believe that I get a free ride for

2college because I did five years in the Navy, and because

3of the G.I. Bill, but I don’t. Although I am grateful for

4the G.I. Bill, $8,000 a year does not cover my $48,000

5tuition bill. I rely heavily on Pell Grants, Stafford

6Loans, and low interest rates, and other various forms of

7financial aid, so those have always been important to me.

8 The five-point recommendations that were put

9forth by the Committee are great and I support them, but

10please focus on expanding higher education access, on

11improving student preparation, addressing non-academic

12barriers, and significantly increasing grant aid to low-

13income students.

14 Thank you for your time.

15 DAVID BERGERON: Thank you.

16 D A V I D B E R G E RON: Jarrett Kealey.

17 JARRETT KEALEY: Thank you for convening these

18hearings, and thank you for the opportunity to speak.

19 My name is Jarrett Kealey, and I am a senior at

20Marymount University in Arlington, Virginia. I am here

21today not only to express my own views, but on behalf of

22Marymount students as their Student Body President.

23 I am very fortunate. I am the first in my family

24to attend college, and I am getting a quality education.

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1Scholarships and financial aid have helped make it possible

2for me to pursue my dream of obtaining a college degree. I

3am here to speak about the critical importance of financial

4aid to millions of students like me.

5 For many first generation students, the reality

6of achieving a college education is not easy. I personally

7have found it necessary to take out more loans each year,

8while I have seen my grant aid remain stagnant. You may be

9saying to yourself, “Jarrett chose a private university

10knowing that the tuition would be high. He could have

11gotten a good education at less cost at a public college,”

12and you would be right. I did know that private college

13tuition would be higher, but I wanted the small classes and

14personal attention that a place like Marymount delivers.

15Some students need this kind of environment to succeed, and

16are intimidated by large public universities.

17 It is also important to note that public colleges

18in many states, including Virginia, cannot accommodate all

19of the students who are seeking higher education. Private

20institutions like Marymount help to ensure that all

21college-bound students have access to quality higher

22education.

23 Access to higher education must be expanded, and

24one key to access is affordability. It is incumbent upon

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1colleges and universities to hold the line on tuition

2costs, while providing quality programs and services, and

3it is incumbent upon our government to ensure that the

4funds and programs are available to assist deserving

5students who want to become leaders of our society.

6 We always hear that colleges and universities

7produce leaders, and that is true, but it is important to

8note that higher education also produces people who serve.

9At Marymount, for example, a large percentage of the

10students are preparing for careers in nursing, teaching,

11counseling, and public safety. These graduates will meet

12critical needs in our society, and their chosen

13professions, unfortunately, do not generate high salaries.

14We should all be concerned about making college affordable

15for individuals who want to pursue these types of service

16careers, and for future workers and leaders in every field.

17 My own career goal includes working in student

18affairs in a higher education setting. I want to be able

19to work with young adults in some of the most important

20years of their lives, but I worry about whether I will be

21able to repay my loans, whether I will be able to go to

22graduate school. I find myself asking, “Do I want to take

23on more debt in order to attend graduate school?” I

24sometimes wonder whether I should consider a higher paying

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1career, but no, I want to make a difference in the lives of

2college students, and to do that, I will need the help that

3strong financial aid programs provide.

4 In 2005, 71 percent of Marymount University

5graduates had student loan debt, and the average loan

6balance was $24,950. And to think that many of these

7people have begun careers as teachers, nurses, and police

8officers. I wonder how difficult it will be for them to

9continue on the path of service while repaying their

10college loans.

11 Students need more grant aid, and graduates need

12loan repayment programs that take into account the post-

13college income level. Such programs would encourage young

14people to pursue service careers and make it fiscally

15feasible for them to do so.

16 In closing, I believe that the proposed five-

17point plan would greatly benefit America’s students and, in

18the end, we would all benefit from the great leaders and

19citizens that a quality college education produces.

20 Thank you for the opportunity to speak.

21 DAVID BERGERON: Thank you.

22 D A V I D B E R G E RON: Matthew Johnson.

23 MATTHEW JOHNSON: Good afternoon, everyone.

24 My name is Matthew Johnson. I am a junior

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1journalism student at the University of Maryland. I

2currently have a 3.84 GPA on 76 credits, and I am applying

3for the prestigious Harry S. Truman Scholarship, which has

4a public service requirement if I receive it.

5Additionally, I am an educator, I tutor at Adelphi

6Elementary, and I tutor for the Athletic Department at

7Maryland.

8 Now, I will admit, I am a little better off than

9some of the thousands upon thousands of college students

10who are struggling with high tuition costs and boring

11classes. I was fortunate enough to get my entire year paid

12for because I fought hard and won two journalism

13scholarships and got my FAFSA form in early. However, the

14same cannot be said for my previous two years, where I was

15forced to take out several loans, and am now stuck trying

16to figure out how to consolidate them so that I can save

17some money.

18 I really don’t want to be in debt. I don’t want

19to have that lingering in my mind when I am deciding my

20future. Almost my entire life is devoted to some type of

21service or another, whether it is Marymount PIRG--I am

22involved in a lot of student groups and other outside

23projects--and whatever fortune is thrown my way, I try to

24give at least some of it back, just in general. What’s

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1left over is devoted to a princess in China, who I hope to

2marry some time after getting my bachelor’s. We are trying

3to go to graduate school in the same region in the world,

4it’s pretty complicated. Thank God for the Internet, right?

5 Now, I really hope I win the Truman Scholarship

6because I don’t think I will be going to graduate school on

7loans. I might be the most educated man in debtor’s

8prison, but that isn’t very satisfying.

9 Now, when I was in high school, I wanted to go to

10Harvard, but one day it occurred to me, probably around the

11time I was receiving ten college solicitations a week, but

12none from Ivy League schools, that Harvard was out of my

13mother’s price range, and I would not be going despite my

144.0 and multitude of extracurricular activities. Why did

15my mother ever decide to become a teacher? Why did my dad

16decide to become an alcoholic and stop working and sending

17child support? Why is college so expensive? All of this

18was running through my head, even at that age.

19 The lucky thing is I am an only child. My mother

20could not afford to send more than one kid to college on a

21teacher’s salary, but she did whatever she could to send me

22something and I owe everything to her. She had loans of

23her own to pay back to UMBC, not to mention house and car

24payments, things like that. So when I heard, I think, last

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1year, that Congress voted to cut $12 billion from aid, it

2makes me wonder whether our government wants us to be

3educated out of this generation. I feel that they are

4threatened by a smart, young generation that could expose

5their corruption and oust them from power.

6 It is like we are only born to work for Wal-Mart

7unless our parents make six figures. This is not the

8America we sell to tourists and travel guides. America is

9the land of opportunity to those people, a place where

10anyone, poor or rich, Black, Brown, or White, can achieve

11their wildest dreams. Now, I hope that you will keep at

12least some of those dreams alive by supporting the five-

13point plan for manageable student loan debt.

14 Thank you.

15 DAVID BERGERON: Thank you.

16 D A V I D B E R G E RON: Scott Peach.

17 SCOTT PEACH: Hello, my name is Scott Peach, and

18I am a senior political science major at the University of

19New Hampshire.

20 First of all, I would like to thank you for

21hearing the student voice when deciding our future.

22Unfortunately, not all of those who run our government are

23listening to us, the students, which is why we are in dire

24need of your help.

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1 Attaining a college degree, I am sure, as you

2know, is becoming increasingly difficult, if not

3impossible, for more and more students. With the $12

4billion slashes to financial aid, tuition costs rising with

5no end in sight, the expanding emphasis on loans, and the

6ridiculous interest rates, many students are dismissing

7college as an option in their future.

8 At UNH in 2004 and 2005, 72 percent of students

9graduated with loan debt, at an average of $21,459. For

10me, I will be graduating with around $25,000 in debt. In

11April of 2007, I will be applying for the Peace Corps in

12hopes to leave for South America right after I graduate.

13 So what will my reward be for attending college

14and helping others in need? Well, it will be that $25,000

15bill waiting for me when I return home, along with the

16interest rates that will add on to that, a bill that will

17force me to work one or two other jobs, along with the

18profession that I choose.

19 Working excessive hours at two or three jobs to

20keep up with loans and the rising cost of living was not

21what I imagined when I was applying for college. I had

22imagined expanded opportunities, freedom to choose my

23profession, and eventually being able to follow my

24passions. Nowadays, it seems that attending college is

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1closing the doors to opportunity instead of opening them.

2My strongest passions in life are activism, grassroots

3organizing, and helping others better their living

4situations.

5 Now, we all know that these things pay next to

6nothing, and, with my loans and high interest rates, I am

7not even sure if I will be able to pursue my passions, all

8because I went to college, all because I wanted to better

9my education and to better my chances in the workforce. So

10what does this mean for our society?

11 Well, if things continue down this road, there

12will be less teachers, less social workers, and less

13college graduates. How did we get to a place in America

14where only the super rich can attend college while they try

15and send us poor folk off to war? So, when you are all

16deciding our future, I hope you will remember us, the

17students, and the hardships that we face every step of the

18way of the college experience.

19 I thank you again for giving us the chance to

20express our grievances with the whole system. Thank you.

21 DAVID BERGERON: Thank you, Scott.

22 D A V I D B E R G E RON: Shelley Saunders.

23 SHELLEY SAUNDERS: Good afternoon.

24 My name is Shelley Saunders, and I am the Vice

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1President of Strategic Services with American Student

2Assistance. I am here today on behalf of ASA and my fellow

3guarantors in the National Association of Student Loan

4Administrators.

5 NASLA is a private, non-profit, voluntary

6membership organization that represents the interests of

7guarantors. NASLA is organized to ensure consistent and

8reliable delivery of student loan services to America’s

9students, parents, and postsecondary institutions. NASLA

10is committed to working cooperatively with all

11postsecondary industry participants and representative

12organizations in fulfilling the promise of educational

13access and choice.

14 Over the last several years, many factors have

15impacted student loan borrowing, including the rising cost

16of education, increasing borrower indebtedness, and the

17rapid growth of private loan borrowing, and the popularity

18of loan consolidation. These changes underscore the need

19to review several areas of potential improvement, several

20of which I will describe in a brief moment, and the

21additional details, which are in the written testimony that

22I just gave you.

23 Because of the importance of these turns and

24changes to student loan borrowing, and the fact that FFELP

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1is, by far, the largest source of federal student aid,

2NASLA believes that it is important that guarantors

3participate as both a lead and a backup negotiator on the

4loan issues team in the negotiated rulemaking process.

5 A core focus of guarantors is to maximize the

6success of borrowers in repaying their loans. As an

7administrator of the FFELP, a guarantor works closely with

8the Department, students and families, schools, lenders,

9and loan servicers throughout the life of the loan.

10Inclusion of a guarantor voice in the negotiations will

11promote broad-based, well-informed rules.

12 NASLA proposes the following list of issues for

13negotiation for both the FFELP and Direct Loan Program:

14 First, simplification of obtaining and granting

15deferments. NASLA feels that the process of a borrower

16obtaining a deferment from more than one loan holder is

17unnecessarily cumbersome and could be streamlined. NASLA

18recommends changes to the regulations that would permit a

19lender to grant any type of deferment to a borrower who has

20another loan deferred for the same timeframe and the same

21reason by another holder. The lender could use NSLDS or

22another authoritative database to determine that the

23borrower is in deferment status for a particular reason and

24a particular timeframe.

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1 With respect to access to economic hardship

2deferment, the overly complicated process of applying for

3an economic hardship deferment results in the

4underutilization of the deferment entitlement, and makes it

5much more attractive for the lender to offer a less

6beneficial, particularly in the long run, discretionary

7forbearance.

8 We recommend that Congress reevaluate the HEA

9provisions to simplify the eligibility criteria. In the

10meantime, we suggest that the Secretary exercise her

11authority to simplify existing regulations. In particular,

12we would like the Secretary to examine the eligibility

13criterion that allows a borrower to qualify for the

14deferment if the borrower is receiving or has received

15payments under a federal or state public assistance

16program. The Department should consider developing a

17comprehensive list of federal and state qualifying public

18assistance programs, and placing that list on a Web site to

19enable loan holders to consider the eligibility of all

20applicants for the deferment in a consistent manner.

21 In addition, we would like the Secretary to allow

22the lender to use either the borrower’s original loan debt

23or current outstanding balance, whichever is more

24beneficial to the borrower, in determining a borrower’s

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1eligibility for the economic hardship deferment on the

2basis of the borrower’s dept-to-income ratio.

3 While various repayment options exist in the

4federal loan programs, the effectiveness of those options

5is limited, especially with the increasing debt burden

6experienced by student borrowers. Although borrowers have

7an income-based, income-sensitive repayment option, this

8option does not take into account other debt or family

9size, or prevent situations in which a loan balance is

10increasing, even if payments are being made. We feel that

11these factors should be considerations in determining a

12borrower’s repayment amount.

13 With respect to utilization of a discretionary

14forbearance, forbearance can be a useful tool in preventing

15default; however, guarantors are finding that there is

16little they can do for a borrower to resolve mid- to late-

17stage delinquencies and prevent defaults because of the

18heavy use of discretionary forbearance early in loan

19repayment. More care should be taken to ensure that the

20application of forbearance, and the subsequent interest

21that accrues and is capitalized, does not impair the

22borrower’s long-term ability to achieve successful

23repayment.

24 We also recommend that the Department reevaluate

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1exit-counseling requirements to include the new graduate

2and professional Grad PLUS for borrowers, as well as

3borrowers who are exiting school who have obtained in-

4school consolidation loans. Providing exit counseling for

5all student loan borrowers is extremely important to ensure

6that they have the information necessary to make informed

7choices that impact subsequent life decisions, and to allow

8them to establish successful repayment habits and lifelong

9fiscal responsibility.

10 With respect to financial literacy, the Treasury

11Department and Congress have indicated that a lack of

12financial literacy is a significant issue in the U.S., and

13have gone so far as to establish financial literacy month

14annually in April.

15 NASLA strongly advocates developing a financial

16literacy program that is available as an elective course to

17all students attending secondary and postsecondary

18institutions. Such programs would assist students in

19achieving the level of financial literacy necessary to

20succeed.

21 With respect to total and permanent disability

22discharge requirements, the conditional discharge

23provisions have been in place since 2002. NASLA feels that

24a sufficient amount of time has passed for the Department

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1to take a step back and review and evaluate the conditional

2discharge process. While we understand the Department’s

3obligation to protect the integrity of the discharge

4program and not allow for abuse or fraud, we are not

5convinced that the current process is as streamlined and

6efficient as it could be. The current process is

7duplicative and redundant, and we feel a more definite

8separation of duties between the Department and guarantee

9agencies is needed.

10 We assert that guarantors should be allowed to do

11the job they were charged with, determining borrower

12eligibility. On the other hand, if the analysis

13demonstrates the value of the current process, then we

14suggest the following revisions to current regulations:

15 We request that the Secretary reconsider

16simplifying the eligibility requirements of a disability

17discharge. While we understand that the Department’s

18position is not to rely on disability determinations made

19by other agencies, such as the Social Security

20Administration, as these determinations are less stringent,

21we feel there is validity to reevaluating this position.

22We understand that, when receiving SSA disability benefits,

23if a borrower’s condition improves, the agency stops

24providing benefits. However, the Social Security

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1Administration’s definition of disability could be used to

2place a borrower in the first year of conditional status

3where, in part, the borrower’s annual earnings and

4continued disability status is monitored and re-verified

5for an additional two-year period.

6 Additionally, a borrower in a conditional

7discharge status should be permitted to make loan payments

8and resolve delinquency or default status, if possible,

9prior to a final discharge determination. The Department’s

10premise that a borrower who is able to make a loan payment

11during a period of conditional discharge is unlikely to be

12truly, totally, and permanently disabled is unfair to

13disadvantaged individuals.

14 Additionally, taking the issue of the disparity

15between the standard for meeting the definition of

16“disability” between the HEA and the Social Security

17Administration a step further, the Department’s policy that

18allows it to garnish disability benefits is a policy that

19ought to be rescinded. Borrowers whose disability payments

20are garnished are frequently in the most extreme financial

21circumstances, and resolutions of garnishment complaints

22are difficult, if not impossible to resolve.

23 Lastly, current regulations state that a

24discharge of a loan based on the death of a borrower or a

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1student in the case of a PLUS loan must be based on an

2original or certified copy of the death certificate. We

3recommend that regulations be revised so that if one loan

4holder obtains an original or certified copy of the death

5certificate, other holders are allowed to discharge the

6deceased borrower’s loans based on the same death

7certificate.

8 In conclusion, NASLA appreciates the Department’s

9consideration of this testimony and offers itself as a

10resource to the Department on these and other issues.

11Thank you.

12 DAVID BERGERON: Thank you.

13 D A V I D B E R G E RON: Ellen Frishberg.

14 ELLEN FRISHBERG: Thank you. It is really nice

15to be here among all of these students. It makes me feel

16like I am back at work.

17 I have spent 30 years in a financial aid career.

18This has been a really exciting year for us because we have

19a new grant program. We have not implemented a new grant

20program in a very long time, and it has been a really good

21feeling to be able to offer new grants to students this

22year.

23 I have three things that I want to mention here

24today. While I know that they may be statutory rather than

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1regulatory, I know that you have the ability to influence

2the statute, as well, so I would like to talk to those

3three points.

4 The first one has to do with those new grants.

5When we evaluated our student population, we thought that

6we really had a significant group of students, because we

7do teach all the STEM courses where I work. What we

8discovered, in fact, is that 18 percent of our students who

9would have been eligible for National SMART were eliminated

10because they were permanent residents. These are students

11who will become citizens, but because they are 17 and

12cannot become citizens yet, or they are 18 and they are

13juniors and they have not had time to go through that

14process, they have lost out on significant grant funding.

15 It was very disconcerting to us--it was a very

16happy occurrence to find out that, in fact, we had so many

17students who are new immigrants to this country, who have

18taken up being excellent in those subjects, in engineering

19and in technologies, but that we would not be able to help

20with additional grant funding. So if there is any way we

21can change that statute to include other than just citizens

22in permanent residence, which we include for all other

23programs, that would be a wonderful boon to the promise of

24the American Dream.

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1 I, too, along with the students, support the

2five-point plan, but that is not why I am here. But I do

3support it, partially because I am a student loan repayer

4myself, and also because I have two teenage children who

5are about start applying to college--it is kind of scary.

6 The thing that I most want to talk about, though,

7is the Spellings Commission, and how they found that

8students see paying for college as an unattainable task.

9The misinformation that is out there in the community about

10what college costs is pretty much the norm. Even in rich

11communities in Maryland people think that there are very

12few options out there and that it is going to cost $40,000

13a year to go to school, which we all know is not true, but,

14in fact, people don’t see the options.

15 So I think it is time that we start thinking

16outside of the box, in terms of the system that we use to

17determine a family’s need for financial aid, and get

18outside of the system that was designed by the College

19Scholarship Service back in 1954 to serve a very elite

20group of schools that has now become embedded in the Higher

21Education Act. That system had an elaborate application

22form with a lot of confusing and arcane questions, and

23those financial aid programs, because of the application,

24are not reaching poorer first generation college students

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1and their families. And I know this because I was a first

2generation college student--quite a few years ago, but I

3was a first generation college student, and I didn’t know

4about the form and the programs, and I know that is still

5the case.

6 We also know from the data that it is ten times

7more likely that you will get a BA if you come from the

8highest income quintile than if you come from a family from

9the lowest income quintile, all other things being equal,

10that’s grade point average and SAT scores, and that is

11pretty damning on this nation and the promise.

12 So money would help, of course, money always

13helps, but the process of applying is also part of the

14problem. So I propose a process that would improve

15awareness of the options that are available, and ease

16delivery without a large federal cost. Every year, in the

17mail, you get from the Social Security Administration, a

18statement of your year’s previous earnings, and that is

19taken from data that the Social Security Administration

20gets. That document lays out how much you can expect to

21receive in Social Security benefits when you retire. It is

22a government form, it is filled with basic verifiable and

23free information, and it tells a story. People read it and

24they say, “Oh, no, I will never be able to retire at that

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1rate,” or they say, “I think I am going to start saving for

2retirement.” It gives them some incentive to act. And, as

3citizens, you have information and you can act on it, you

4can work or you can save, or you can decide, “No, I can

5live on that.” So why not clone this type of statement and

6use it to tell families a different type of story?

7 How about a story about how much financial aid

8one of their family members could receive if they went to

9college now, or even in ten years in the future? You could

10use the same data that the Social Security Administration

11uses to generate these reports, based on who earns income.

12And each year families could be asked, when they file their

13taxes, if they would like a college benefits statement, we

14can even give it a federal name.

15 [Laughter.]

16 ELLEN FRISHBERG: The data could then be

17transmitted to the Department of Education, which would, on

18the basis of earned income information alone, generate a

19statement that would say, “You are eligible for X number of

20Pell Grant dollars, student loan dollars,” and even, if you

21know the residency, state aid money, because much of that

22is formula driven.

23 It could illustrate different scenarios of how

24much aid a student in a family could receive, based on

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1different costs of schools, so that you would take care of

2the issues of segments. And that way a family could learn

3when their children are young that either they won’t

4qualify for need-based dollars or, more importantly, that

5they will qualify for all of the money that they need, and

6then they can act on that information. They can encourage

7their kids to go to school, they can plan a savings

8strategy, they can motivate them and make them think that

9college is possible.

10 You could also do this with people who don’t have

11taxable income, but are recipients of untaxed federal or

12state benefits like SSI or TANF. The agency that they work

13with, we just send their names in with their information

14and they could request a similar statement, and then the

15application becomes easy. When a family member decides to

16go to college, you fill in the back with the schools you

17plan to attend, you send it to a processor, and then they

18send back-verified eligibility information to the school.

19 I know that some of my colleagues are going to be

20shocked by the idea that we could take such subtle

21information as the need analysis calculation and do it

22based on a couple of data elements, but we toss out

23complexity to reach a reality. The system we have is

24complicated, the Commission said so it is flawed. The

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1analysis currently is based on income, not on true wealth.

2Families’ most significant assets, their homes and their

3retirement accounts, don’t count in the current system, so

4why put a complex application in front, as a barrier, to

5college attendance? Why not make it a piece of information

6that people have?

7 Congress could design a formula that would use

8actual income, and the data reported on the tax return may

9give some other indicators of a proxy for wealth, so that

10you can determine need. You just use that as an index so

11that it does not cost anymore to distribute financial aid.

12The present system we have is imperfect, it’s complicated.

13This may not be perfect, some colleges may still want more

14information, but it certainly would get more information

15out to people, and it is simplicity, and it would be a

16statement to get people to enroll.

17 The last issue I wanted to mention is that we are

18under a lot of pressure to spend our Perkins Loan funds on

19campus. We have had a number of years where variables have

20mitigated against that. Perkins Loans were higher interest

21rate than Direct Loans, so students were turning them down

22to take Direct Loans. Consolidation loans have increased

23repayments significantly, so we are trying to figure out

24ways to make a sustainable level of repayment. Right now,

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1the regulations don’t allow us to keep cash on hand, and

2yet we are trying to figure out ways to level out our

3repayments.

4 There is also some threat of losing those

5dollars, and since we are all looking for new grant money,

6it would be our hope that if, in fact, we ever ended the

7Perkins Loan Program because we want to get to simplicity

8of one loan, that you would all institutions that have

9managed these programs for 30 or 40 years to keep the

10corpus of the repayments, turn it into endowed scholarship

11funds that we can then offer to needy students as grants.

12 I thank you very much for your attention.

13 DAVID BERGERON: Crystal Calarusso.

14 CRYSTAL CALARUSSO: Good afternoon.

15 My name is Crystal Calarusso, and I am the

16Academic Director of the National Association of Schools of

17Public Affairs and Administration.

18 We are the specialized professional accreditor of

19the master of public administration, the master of public

20policy, and other professional degrees for public service

21at the graduate level.

22 I appreciate the opportunity to speak with you

23today from the perspective of a specialized, professional

24accreditor.

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1 NASPA is also a voluntary accreditor. A

2voluntary accreditation process denotes that our graduate

3programs seek accreditation for reasons other than federal

4funding or obtaining professional licensor for graduates.

5Graduate programs specifically participate in our

6accreditation process for three main reasons: to facilitate

7quality improvement within the program, to join the

8national peer review community that makes policy for the

9MPA and MPP degrees, and to provide an extreme signal of

10their commitment to assessment and improvement.

11 Our programs, and those of many other

12professional accreditors, have a distinct and established

13voluntary commitment to quality assurance and assessment.

14NASPA is not a Title IV gatekeeper, but changes in policies

15regarding the national governance structure of

16accreditation will affect our practice.

17 Recent policy suggestions from the Commission on

18the Future of Higher Education regarding national data

19systems and accreditation reforms could have some

20unintended impacts on the systems of quality assurance for

21programs. Communications from the Commission have affirmed

22that diversity of programs is a strength of American

23postsecondary education. However, some policy

24recommendations may have the potential to homogenize

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1program assessment, specifically in the case of

2professional programs. If not carefully designed, some

3national data system and accreditation reform efforts could

4effectively move the policymaking focus for professional

5degrees away from the professions, where the knowledge and

6expertise to address quality within their own context

7resides, and into a national system that provides a basic

8template for all, but a good fit for few.

9 To maintain the hallmark diversity of

10professional education, the profession should be recognized

11for their valuable role as a public in determining the

12style and scope of assessment. In fact, only the idea of

13increased accountability to the public is mentioned.

14Professional accreditors frequently ask, “Which public?”

15We have an established responsibility not only to students

16making a buying decision, but also very importantly to the

17professions we serve.

18 Professional accrediting bodies have provided a

19valuable service, not only to students seeking degrees, but

20also to the professions and to the public at large by

21ensuring that we will have competent nurses, lawyers,

22engineers, and other professionals to lead our communities.

23This is accomplished through a variety of both outcomes and

24input standards appropriate to prepare students for

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1practice in a given profession.

2 Comparability data, both quantitative and

3qualitative are useful to the consumer of the education

4product. However, data recommendations and assessment

5requirements not designed by the profession, or not based

6on quality indicators specific to that profession can lead

7to rankings and decisions that are marginally relevant to

8program quality. Popular indicators, for better or worse,

9can have the effect of motivating policy and curriculum

10shifts within individual programs, as programs attempt to

11compete for the best students.

12 If these decisions are based on indicators that

13carry little relevance to program mission, national

14assessment requirements and data systems that include

15professional programs may have the unintended consequence

16of slowing improvement and development of professional

17programs. It could impede the very innovation that the

18Commission seeks to support.

19 To avoid these unintended consequences from the

20results of the negotiated rulemaking process, and to

21respect the diversity of programs and accreditors, I hope

22the Department of Education will consider including a

23representative from specialized professional accreditation

24on commissions and rulemaking bodies wherever possible. I

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1also hope that the process will move forward with the goal

2of recognizing the value of program diversity, allowing the

3professions to determine, with their many publics, the

4types of assessments to perform, and the information to

5present to the public.

6 Thank you.

7 DAVID BERGERON: Thank you.

8 D A V I D B E R G E RON: Nick Christianson.

9 NICK CHRISTIANSON: Thank you very much for

10allowing me to testify on the issue of student debt. It is

11not every day that we, as students, are granted the

12opportunity to share our side of the story with our

13government, and I can tell you, as you can see, we have a

14lot to say on this and many other issues.

15 My name is Nick Christianson. I am a senior at

16the University of New Hampshire, and I study politics and

17justice studies. My experience dealing with debt from

18student loans, at this point, is very limited, although I

19know that will certainly change the day I graduate.

20 Back when I was applying to colleges and

21universities across the country four years ago, after being

22rejected by my top choice, I narrowed it down to American

23University, here in Washington, D.C., and the University of

24New Hampshire. Both of these schools fit my requirement of

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1being close to national politics, but when I received my

2financial aid packages from each institution, I could not

3really afford either of them. So I went to the one that my

4family would have the least trouble financing, which was,

5naturally, the state school, albeit the second most

6expensive state school in the country.

7 My dad was a journalist and my mom was a school

8counselor, until we opened our small retail shop in North

9Hampton, Massachusetts the year I went off to college,

10where they now both work full-time. I was fortunate enough

11to have most of my college expenses paid for by my parents

12each year, and I know that many do not have that financial

13support, but my family learned that a small business is

14neither cheap to start up, nor quickly profitable, so I

15will be on my own to pay off the loans I took out to get my

16education.

17 The national average loan debt for a four-year

18state college is $18,000. The average student loan debt in

19New Hampshire is $24,000. Many of my friends will have

20$30,000 or more of debt. Luckily for me, I will only have

21close to the national average of $18,000, plus interest, to

22pay back. Although, thinking about that, it sounds pretty

23ridiculous for me to say, “only $18,000,” especially

24considering that I am looking for a career in non-profit

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1advocacy organizations, or as a political campaign

2organizer, neither is known for its salary, particularly

3for those of us just starting out.

4 The same goes for many other professions, like

5teachers or social workers, as many have mentioned today,

6and for no reason that I can comprehend, the cost for the

7education to learn the skills and knowledge that these jobs

8require is hardly paid off by accepting the position in

9these incredibly important fields. Student loan repayments

10become a burden that so many of us will have to factor into

11our major life decisions. What job can I afford to take?

12Where can I afford to live? When can I afford to start a

13family? These questions become amplified by anxiety when

14the everyday costs of living accrue to form a barrier of

15payments and bills. Student debt is just a beginning, and

16it is a shame that it exists at all.

17 Having taken out $18,000 in loans, people tell me

18that I better be smart enough to have a plan to pay them

19back. Well, I don’t have a plan, few students do when they

20graduate, and I do know that a plan has been suggested to

21you containing five core points lessening the financial

22burdens for those of us who may be hamstrung by our student

23debt.

24 I know this five-point plan for manageable

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1student loan debt will not get me out of the red, nor will

2it lower tuition costs or raise funding for grants, but the

3plan certainly serves to round off the rough edges in the

4student loan program, and it is a plan that you can put

5into action now, because the truth is, despite what people

6say, student debt is not a question of stupidity versus

7planning. We are forced to take on these costs to complete

8our educations, and we invest in our educations for the

9very reason that we are planning for our future. There are

10so many valuable skills for life and career that can only

11be learned and perfected at college. Unfortunately, they

12are all too frequently accompanied by something else that

13can only be found at college, student debt for life.

14 I thank you again for taking the time to consider

15my story and others, and I strongly urge you to help

16students repay their loans successfully and fairly by

17adopting the five-point plan for manageable student loan

18debt that has been presented.

19 DAVID BERGERON: Thank you.

20 D A V I D B E R G E RON: Anthony Daniels.

21 ANTHONY DANIELS: Thank you.

22 My name is Anthony Daniels. Thank you for

23allowing me the time to testify today.

24 DAVID BERGERON: Are you picking that up in the

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1back?

2 COURT REPORTER: Not really.

3 DAVID BERGERON: We need you a little closer to

4the mike for our transcriber.

5 ANTHONY DANIELS: My name is Anthony Daniels. I

6want to thank you for allowing me the time to testify on

7behalf of me and my colleagues.

8 Thank you for convening these hearings about how

9to make college affordable. I am both professionally and

10personally concerned about the issue for management of

11student loan repayment rules.

12 Professionally, I serve as the Chairperson of the

13National Education Association Student Program, where I

14represent over 60,000 college students over 1,100

15universities across the nation preparing for careers in

16education.

17 The rising levels of student loan debt threatens

18their ability to pursue successful careers in education

19without being committed to lengthy student loans plagued by

20rising interest rates. We are all concerned about the

21levels of student loan debt. As a recent graduate with an

22outstanding level of student loan debt, I am affected

23personally by the costs and concerns of the repayment plan.

24 I received my bachelor’s degree in elementary

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1education in the spring of 2005 from Alabama University,

2and I am currently pursuing a master’s degree in special

3education at that same institution. As I completed my

4bachelor’s degree in four years, I find myself in over

5$30,000 in loan repayment debt. At that time I wondered,

6“Could I possibly survive as a first-year teacher off of

7$28,000 in Alabama?” I even asked myself, “Was college the

8best way to go, or should I have looked for a regular job?”

9Working a regular job did not seem so bad after all. At

10least I would be making a better living without the stress

11of loan repayments, but the decision had been made. I had

12to look at the situation I was in after graduation. I

13looked at my $30,000 of debt, extremely low teaching

14salary, and decided that my only option was to further my

15education so I will be able to get more money.

16 I saw this as my best option, because having just

17finished my student teaching two weeks earlier, I could not

18see how I could possible afford to travel to another state

19for an interview or pay relocation fees should I actually

20have been offered a job.

21 Folks, the teaching profession is a calling. I

22went into teaching because it was the most rewarding

23profession in the world. There was nothing more exciting

24than helping students discover things that fascinate, and

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1nothing is more rewarding than seeing a child grasp an idea

2and develop an idea of his or her own. But how can I

3purchase a car or a home when I am in debt over $30,000?

4This is a major concern of all of my colleagues.

5 More than 8 million postsecondary students

6receive student aid, with 30 percent of this support coming

7from the federal government. In the next decade,

8undergraduate enrollment in colleges and universities will

9increase by 14 percent, with 80 percent of these new

10students coming from minority backgrounds, and 1 in 5

11living in poverty. Federal aid is already insufficient to

12allow us to want to pursue higher education to do so.

13 Recent studies have indicated that typical

14student borrowers leave school with almost $20,000 in debt,

15and that many young Americans face such significant college

16debt that they will defer home ownership and starting a

17family. Students are not able to take careers in teaching,

18social work, or other public interest fields.

19 I have attached to my written testimony a table

20taken from the state higher education project report,

21“Paying Back, Not Giving Back: Student Debt’s Negative

22Impact on the Public Service Center Career Opportunities.”

23The table shows the percentage of college students who

24would have manageable debt if they took a teaching job in

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1the state. Nationally, nearly a quarter of the graduates

2from public four-year institutions would have unmanageable

3debt on a starting teacher’s salary, and figures rising to

4almost 40 percent of the graduates from private

5institutions. Higher education remains a critical

6investment for young people to make it themselves, for

7families to make a success of their children, and for the

8nature to make it in the future.

9 Current projections are that financial barriers

10will prevent 4.4 million high school graduates from

11attending a four-year public institution over the next

12decade, and will prevent another 2 million high school

13graduates from attending college at all. I recognize that

14this is a complicated problem, and that much of the

15responsibilities lie within the purview of the President,

16Congress, and states.

17 Folks, the federal government has not been doing

18its part to help make college affordable. Last February,

19Congress passed a measure that removed almost $12 billion

20from the student aid programs, and in the first year of the

212007 budget, the President proposed $1.2 billion in

22additional cuts from the higher education program. The

23latest cuts have further exacerbated the affordability of

24college education, leaving many lower income students

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1unable to complete their education. As we look for a

2solution to this problem, we are proud of the

3recommendations in the recent report of the Secretary’s

4Commission on the Future of Higher Education to highlight

5access and affordability, especially the recommendation to

6increase the nation’s commitment to the need-based aid.

7 However, as NEA President Weaver said, “To give

8the proposal teeth, we need a commitment from lawmakers to

9provide adequate funding.” In order to meet broader higher

10education goals, NEA also calls for improving student

11preparation and providing more high schools with programs

12on adolescent literacy and dropout prevention, as well as

13counseling, smaller learning communities, and expansion of

14the AP courses.

15 President of the National Council of Higher

16Education added, “The benefit of higher education are much

17more than bigger paychecks for the graduate or a stronger

18economy, higher education is the key to promoting an

19informed citizenry and protecting our democratic society.”

20 NEA hopes to continue working with the Department

21in this area, and looks forward to the next spring summit

22on higher education announced in Secretary Spellings’

23speech last September. The Department can do its part on

24the issue by taking some concrete steps, but it cannot do

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1it alone. The NEA will be working to increase grant aid

2and other student aid programs in order to increase college

3affordability.

4 As Chair of the NEA Student Program, I pledge to

5contribute to that effort. Cutting interest rates in half

6for student and parent loans, as well as increasing grant

7aid are important steps toward reversing the recent cuts of

8higher education assistance. One step the Department can

9take is to make changes in loan repayment terms that will

10provide more fair and manageable circumstances for college

11graduates once they begin loan repayments. This will be a

12welcome result from the round of negotiated rulemaking.

13 I thank you for your time, and I look forward to

14continuing to develop the development of this process.

15Thank you.

16 DAVID BERGERON: Thank you.

17 We are going to take a ten-minute break. Then we

18will reconvene at quarter till 3:00.

19 Thank you.

20 [Brief recess.]

21 DAVID BERGERON: Okay, we’re going to reconvene.

22 Our next witness is David Baime.

23 Good afternoon, David.

24 DAVID BAIME: Good afternoon. This is a little

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1bit like being on trial, here.

2 My name is David Baime. I am Vice President for

3Government Relations for the American Association of

4Community Colleges, and we represent virtually all, or over

595 percent, of all the nation’s two-year public

6institutions of higher education. We also have, as an

7affiliated council, the Student Association for Community

8College Students.

9 I would like to thank you for convening this

10group and for giving me a chance to speak.

11 I did want to inform you that my organization

12will be submitting nominations for two individuals in the

13negotiated rulemaking process, and, in general, I would say

14that the reason why we like to have people involved in the

15neg. reg. process, as we have a number of times in the

16past, is because our student financial aid officers are

17sometimes less resourceful than we would like them to be,

18and the administrative burden issues are perhaps more

19important for our colleges than they are for other sectors

20of institutions.

21 I want to just talk very briefly about two major

22issues that were raised in the notice about these sessions.

23First relates to the Spellings Commission Report and the

24issue about whether or not some of the recommendations of

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1that report ought to be incorporated into the neg. reg.

2process, and my organization’s general perspective that

3that’s not a good idea. The recommendations in the Report

4are very far reaching, have a lot of policy implications,

5and these are the kinds of issues that are best mediated

6and decided upon in the Congress rather than through the

7regulatory process. I think in some areas it would be

8possible to create or adopt some of the Spellings

9Commission recommendations by the regulatory process, but

10we don’t think that it is a good idea. Negotiated

11rulemaking, and rulemaking in general, is a fairly closed

12process once the negotiators are selected, and we think

13that in a more open process of legislative process, it is

14probably a better venue for deciding these. And also,

15particularly in the area of outcomes, these are very

16complicated and very contentious that, again, we think

17would be better off discussed at a different level.

18 I want to just mention that the negotiations over

19the Student Right to Know Law, and implementation of that

20took a number of regulatory revisions, and quite a long

21time at the negotiated rulemaking table. So that is just

22an example of what you might be getting into if you decide

23to move forward, say, in the area of student outcomes and

24Student Right to Know by the regulatory process.

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1 Another area that relates to the Spellings

2Commission report is accreditation. We have the same

3caution to you as we do about, more generally, the

4Spellings Commission recommendations. Accreditation,

5statutory language, particularly the standards of

6recognition for the agencies, have been subject to a lot of

7discussion, and negotiation, and parsing of language in the

8legislative process, and, in general, it has been my

9organization’s position that the regulatory process should

10hew as closely as possible to the statutory language. For

11that reason, we see going off into new areas of regulation

12of accreditation without statutory--a premature direction--

13it is probably a bad idea, given the sensitivity that our

14presidents have to the accreditation process, and the

15implications it has for their institutional operations. So

16that is just very briefly about the Spellings Commission

17Report.

18 We did want to talk a minute about the Academic

19Competitiveness Grants, where we will be explicitly

20nominating a negotiator. We would like to be involved with

21this because of its importance to our students. I just

22mentioned for your information, generally, that our

23campuses have told us that the numbers of students who are

24coming in with ACG eligibility are lower than they would

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1have expected them to be or would like them to be. Some of

2our narrower issues are related to transcripts--these are

3all things that we did mention in our comments in August,

4but just quickly--in terms of the transcripts that are

5required for documentation of the completion of the

6rigorous course of study at the secondary level, many of

7our colleges don’t collect transcripts. That is not

8because they are not interested in the academic

9qualifications of their students; it is just that they use

10up-front diagnostic testing for them rather than their

11transcripts. So this is a significant additional

12regulatory burden for them in many cases, when they have to

13go back and procure the transcripts.

14 Another point on the rigorous secondary school

15program, I just wanted to point out to you that the dual or

16concurrent enrollment programs are growing across the

17country, over 75 percent of community colleges offer them

18now with their high schools. They are designed to

19encourage students to pursue a postsecondary education, to

20get them oriented towards college and making them really

21see and feel that college is an option for them. So, to

22the extent that they are designed specifically to motivate

23students to go on to postsecondary education and achieve in

24it, we would just recommend that you look at those

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1carefully as you consider approving the secondary programs

2for ACG eligibility.

3 The last item on the Academic Competitiveness

4Grants I wanted to mention, and you will notice that we do

5remain very concerned about the decision department to not

6allow certificate students for eligibility. The impact on

7our students is perhaps not as great as you might think it

8would be. There is sometimes a perception that there are

9just scores of certificate programs offered at our

10colleges. In fact, there is fewer than one certificate

11award for every associate’s degree that our colleges grant,

12so it is not like there is a huge proliferation of them.

13Many of our certificate students do go on to get an AA

14degree, and then go on to get the BA degree. But most

15importantly, we are absolutely convinced that the statute

16makes those programs eligible, and it bothers us when we

17believe that the statute is not observed, particularly when

18it is to such detriment to our colleges.

19 Finally, I just want to mention that the project

20on students’ debt recommendations are something that are

21looked at favorably. Our students, obviously, have lower

22debt levels than students attending four-year colleges, but

23for the over 20 percent of our students that do have debt,

24the debt is over $6,000 now, on average, and debt burden is

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1a big issue for our students. Our students have had

2relatively high default rates in the past compared to other

3sectors, so we are very interested in these issues and

4trying to look at ways to ameliorate repayment burdens for

5our lower income students.

6 Thank you.

7 DAVID BERGERON: Thank you, David.

8 D A V I D B E R G E RON: Barbara Salt. Barbara, you

9have been very patient.

10 BARBARA SALT: Oh, thank you.

11 I want to thank you for your attentiveness and

12patience through a long day, as well.

13 I am Barbara Salt, a Ph.D. social worker, a

14recent 2003 Ph.D. graduate of the Catholic University of

15America. I am a member of the National Association of

16Social Workers, and Senior Program Associate for the

17Institute for the Advancement of Social Work Research.

18 I speak today from personal experience as a late

19career returnee to higher education to pursue a doctorate

20in social work. This testimony addresses several issues,

21which that decision has made on my current and retirement

22financial status.

23 First, I want to note that my early career was

24facilitated by a government funded resource no longer

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1available, but which was important in setting me and others

2on a course of public service and, I believe, has provided

3to this government a substantial return on its investment.

4 The now defunct National Institutes of Mental

5Health Grants of the 1960s provided tuition and living

6expenses to build the workforce necessary to launch the War

7on Poverty. This child of a railroader and factory worker

8would not otherwise have been able to attend graduate

9professional school of social work at that time. I am

10eternally grateful for the privilege, and regret that this

11opportunity is no longer available to others like me, nor

12to the profession. I believe that this also is a loss to

13our nation’s service provider workforce.

14 Regarding student loan repayment, I want to

15encourage regulation, indeed, future legislation, as well,

16that would reduce the burden of higher education to social

17workers who serve this country’s abused and neglected

18children, its mentally ill homeless, its returning

19traumatized veterans, and its elderly citizens navigating

20complex medical care systems at a time when their cognitive

21abilities are declining or impacted by serious health

22debilitation.

23 I want to raise another issue that merits

24attention. Not only does the returning mid-life or later

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1career student thus enter a time of considerable tuition

2outlay and reduced income, whether attending school full-

3or part-time, this absence from the full-time workforce

4adds a further burden to retirement income. Reduced income

5during these later years of schooling impacts the level of

6Social Security income. Mid- and late-life students, known

7as the sandwich generation, often also face support for

8their children’s schooling, as well as support for their

9elderly parents in assisted living facilities or nursing

10homes.

11 In my case, I found that, as an only child, my

12parental care responsibilities preclude my working full-

13time at the very time when my income should be highest to

14maximize my own retirement Social Security income. In

15addition, upon graduation three years ago, after four years

16of no earned income, I had incurred almost $40,000 in

17student loans, so you can see the impact on retirement

18income.

19 Most private social agencies do not have programs

20to support advanced education. Burgeoning social work

21education programs have created a deficit in doctoral-level

22social work faculty. Despite that, entering doctoral

23faculty in the field face salaries well below mid- to late-

24career incomes in the practice arena. Thus, one who seeks

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1to serve the profession through research and educating

2future generations faces not only reduced incomes, but also

3burdensome student loans, as well as a reduced base on

4which the retirement funding of both private and Social

5Security is predicated.

6 While I do not wish to imply that I am

7impoverished, I do want to emphasize that the service of

8social workers to our nation’s most vulnerable, where work,

9at times, involves high personal safety risk, should be

10supported by governmental recognition of this value to our

11country through the forgiveness of student loans for

12providing service, education, and research.

13 I am providing information to link to additional

14information on the burden of student loans to social

15workers in my written testimony. We have also heard that

16from the NASW. I have in my written testimony two

17websites, one of which provides information about loan debt

18in proportion to social work salaries by state. It should

19be noted that starting salaries in a master’s and doctor of

20social work faculty appointments are well below that of

21senior social work practice salaries in federal agencies.

22That is, beginning social work faculty may be $45-55,000,

23which is, if you worked through a fair career, you are

24probably a little bit beyond that, so you are taking a cut

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1just to move into the education workforce. Another website

2is on the need for loan forgiveness for social workers, and

3that gives a number of personal examples that you heard

4earlier in earlier testimony.

5 I basically want to conclude by thanking you

6again for your attention, and for addressing this part of

7the solution to meeting the needs of social work first

8responders to our citizens in need. Thank you.

9 DAVID BERGERON: Thank you, Barbara.

10 D A V I D B E R G E RON: Roger Williams. Good

11afternoon, Roger. You have been another patient soul.

12 ROGER WILLIAMS: Indeed. Well, no one has been

13more patient than the three of you, and you are to be

14commended for it.

15 My name is Roger Williams. I am the Executive

16Director of the Accrediting Council for Continuing

17Education and Training, ACCET, it goes by the acronym,

18ACCET. We accredit approximately 243 institutions that

19operate about 650 schools across the country, and a few

20overseas. I am also the Chair of the Council of Recognized

21National Accrediting Agencies, which consists of six

22agencies. The vast majority of the schools accredited,

23about 3,100 in number, are in the proprietary sector, and

24range from certificate level up through the master’s degree.

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1 A counterpoint to David’s comment to you all

2suggesting caution, I would suggest that you need to throw

3caution to the wind, and I truly believe that negotiated

4rulemaking is appropriate in this case. In fact, if you

5look back at the last two HEAs, which the last one is so

6far back, we can hardly remember it anymore, a great deal

7of patience has been demonstrated, and perhaps too much.

8 When I reflect back on one of the issues that I

9would like to touch on, which is accountability, recalling

10that, in 1992, when the recognition criteria, for the first

11time, included outcomes on it--in 1998, and I speak from

12some experience, I served at the negotiated rulemaking at

13the time, and would never submit myself to that again, but

14it is commendable work, of course--that recognition

15criteria was moved up to number one. And yet, here we are,

16in 2006, still talking about pilots, and models, and things

17that we are going to do, and it makes me wonder how either

18Congress or the Department of Education has been that

19patient.

20 From ACCET’s perspective, we created a set of

21outcome policies back in 1990, primarily focusing on

22completion of placement. Prior to which, there was a

23single standard in ACCET that had placement listed and the

24word “optional” next to it, which is rather odd, when you

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1think that the vast majority of ours are vocational

2programs. It wasn’t until 1997 that we finally passed

3benchmarks, and we have utilized those benchmarks.

4 We even have a subcommittee of the Commission

5called the Completion of Placement Subcommittee that helps

6to focus on those particular outcomes. We have benchmarks

7of 77 percent placement, and 67 percent completion, and we

8have found those very important tools. They aren’t--and I

9think outcomes, in general, are not simply about trying to

10find what the institution does, but rather inspiring them,

11and inspiring often requires some difficult decisions.

12 In fact, we place a number of institutions on

13“show cause” each year as a consequence of not meeting

14those benchmarks. Many programs are removed because they

15can’t demonstrate that they are really productive. So we

16really believe that outcomes are a very important measure.

17 While it is perhaps in the vocational area, and

18it is simple to look at the training-related job

19placements, it is difficult for us to understand why those

20wouldn’t be used for associate degrees, as well. We have

21occupational associate degrees, and most certainly would

22think are fully applicable to them.

23 With regard to completion, which I think is going

24to be a very tempting outcome that many people will not

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1look past, in the coming of the negotiated rulemaking, and

2I hope that is not the case, because, while I believe

3certainly that retention, completion, and graduation rates

4are very important, if they are left to stand on their own

5without further outcomes, either in terms of job placement

6rates or in terms of learning outcomes, particularly those

7that might actually have some quantifiability to them, much

8as I know that word upsets people, I think we are going to

9be in even greater danger of grade inflation, because if

10you push with an incentive on completion rates, you are

11going to push the process for people to do things that,

12perhaps, they would not ordinarily do. While there isn’t

13much talk about it, save the occasional article in The

14Chronicle about grade inflation, I think it is a very

15serious problem that no one has bothered to look at very

16carefully.

17 So, relative to outcomes, in general, I think the

18time is long overdue, and we really need to get serious

19about it, and may even take some radical approach in

20negotiated rulemaking. I hope it will provide some of that.

21 With regard to transparency, again, if you

22reflect back in the late 1980s and early 1990s, for the

23Department of Education to even get a letter of

24accreditation, it had to subpoena accrediting agencies. I

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1have distinct recollections back in those times, and the

21992 regulations really were an improvement on that. It

3pushed us all, which is probably a theme here--it requires

4some pushing occasionally, to get the agencies to begin

5publishing information. ACCET publishes some of the

6actions that the Commission takes—“final actions,” of

7course, is really the keyword on our website.

8 We send all of our letters out, the actual

9letters themselves--out to the state agencies and to the

10U.S. Department of Education. We also include “show cause”

11action, which some would call “probation,” others,

12“warning.” It is not a requirement, but we do believe that

13is an important component of communication out to the

14federal and the state so they have a better picture of what

15status an institution is run with accreditation at any

16given time.

17 Having said all that, and really being a believer

18in transparency, I do worry that there are those who are

19suggesting disseminating team reports, which I think would

20be a disaster. The peer review process does require a

21certain level of comfort that requires a certain level of

22respect--confidentiality between accrediting agency and the

23institution. If you remove that, I do believe that the

24peer review process would begin to collapse, because you

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1will end up with reports that people know are going to be

2published, and therefore will be more filled with

3platitudes and anecdotes than any helpful information, and

4I would warn against taking that approach.

5 The last issue is relative to transfer of credit.

6I served with the CHEA Committee back in, I think, around

71990, working on what became a framework for transfer of

8credit, which I think is a very commendable piece. It has

9the great pitfall, of course, of not having any teeth in

10it, and that is, of course, similarly found in our

11recognition criteria. While I am not at all in favor of

12forcing institutions to merely accept transfer of credit,

13the fact of the matter is that there are very serious

14implications to the current system. It is often argued

15that it is too expensive, and I find that rather odd from

16the fact that tuition rates are what they are. I have two

17kids in college as I speak, so I am speaking with great

18authority here.

19 I would note, incidentally, that my kids’ current

20student fees are what I used to pay for tuition back in the

211960s and 1970s. If cost is really the factor that is

22holding back transfer of credit, I would suggest that

23somebody should look at fees, perhaps, as a way to get

24around that. But the biggest issue, really, I think, is

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1one of providing an incentive that says, “This is

2important.” And probably the only way that will take place

3is if, in the recognition criteria, it says that

4institutions must indeed craft and publish whatever their

5transfer of credit policy is. At least it would be seen,

6and I think that would be an important step forward.

7 Finally, I think it is very important to take

8note that accreditation really holds great promise, and I

9think it doesn’t quite realize that promise, often, because

10it tends to be a bit timid. I think it is a great

11enterprise. I think that the real measure of accreditation

12is not the fact that an institution, or an agency, rather,

13has prestigious institutions with great reputations. The

14real question is, “Is it because of accreditation?” I

15think if we really want accreditation to do its job better,

16we need to challenge accreditation to do a little better

17job.

18 Thank you very much.

19 DAVID BERGERON: Thank you.

20 D A V I D B E R G E RON: Devin Ellis.

21 DEVIN ELLIS: Good afternoon.

221 T h a n k y o u a ll very much for hearing from

23u s t o d a y .

24 M y n a m e i s Devin Ellis. I am a first-year

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1m a s t e r ’ s i n p u b l i c policy student at the University

2o f M a r y l a n d , C o l l e g e Park, and I am also the

3D i r e c t o r o f A c a d e m i c Affairs for the University of

4M a r y l a n d S y s t e m S t u dent Council, which represents

5a l l o f t h a t s t a t e ’ s public higher education

6i n s t i t u t i o n s .

7 I w a s g o i n g to read from this, but I see

8t h a t y o u a r e o u t o f coffee, so I will just try and

9c o m e t o t h e p o i n t .

10 D A V I D B E R G E RON: We know where to get more.

11 DEVIN ELLIS: As a first-year master’s in

12p u b l i c p o l i c y s t u d e nt at a public higher education

13i n s t i t u t i o n , I h a v e already incurred almost $18,000

14i n l o a n d e b t , a n d I do not anticipate that I will

15m a k e i t t h r o u g h t h e remainder of my program without

16i n c u r r i n g m o r e .

17 Y o u h a v e h e ard from a lot of undergraduate

18s t u d e n t s t h i s m o r n i ng and this afternoon, and also

19s o m e g r a d u a t e s , a s well, but I wanted to emphasize

20t h e f a c t t h a t t h e d ebt burden problem is a plight

21t h a t i s s h a r e d b y g raduate students, as well. And

22I d o n ’ t n e e d t o t e l l you that this applies

23p a r t i c u l a r l y t o t h o se graduate students who seek to

24u s e t h e i r h i g h e r e d ucation for public service, or

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1f o r w o r k i n t h e p r i vate or the public sector, which

2d o e s n o t p a y w e l l e nough to make taking on tens of

3t h o u s a n d s d o l l a r s o f debt an attractive prospect.

4 S o c i a l w o r k ers, nurses, educators, and

5a l s o m a n y o t h e r g r a duate degree-holding

6p r o f e s s i o n a l s w h o w ork in the public arena cannot

7e x p e c t t o m a k e t h e kind of salaries that doctors

8a n d l a w y e r s h a v e t r aditionally been able to make in

9t h e p r i v a t e a r e n a t hat is used as an excuse to

10o f f s e t t h e c o s t o f attaining a graduate degree.

11 I , m y s e l f , am not looking forward to the

12b e g i n n i n g o f m y i n t erest payments, because, seeking

13t o g o i n t o t h e f i e l d where I will most likely be

14e m p l o y e d a s a p u b l i c servant, I don’t need to tell

15a n y o f y o u t o d a y t h at the federal government is not

16k n o w n f o r i t s l a v i s h pay packages. I think that it

17i s v i t a l l y i m p o r t a n t that the Department, in

18s e e k i n g t o f u l f i l l the mission that has been

19s p e l l e d o u t , o f m a k ing public and private higher

20e d u c a t i o n i n t h i s c ountry accountable to the public

21b y p r o d u c i n g m o r e , better highly educated

22p r o f e s s i o n a l s i n e n gineering, in the sciences, in

23l e a d e r s h i p , a n d i n academia, that steps be

24u n d e r t a k e n t o m a k e that possible for people.

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1 I a m v e r y m uch in favor of the five-point

2p l a n t h a t y o u h a v e heard about today. I think most

3o f i t s p r o v i s i o n s v ery soundly support lightening

4t h e d e b t b u r d e n o n students, graduate as well as

5u n d e r g r a d u a t e , b u t I think that the federal

6g o v e r n m e n t a l s o h a s to undertake longer term

7t h i n k i n g a b o u t t h i s issue.

8 I w o u l d l i k e to share with you very

9b r i e f l y , t o h i g h l i g ht my concern, a couple of

10s t a t i s t i c s f r o m m y own campus, the University of

11M a r y l a n d , C o l l e g e P ark, which has over 10,000

12g r a d u a t e s t u d e n t s d istributed across its

13d e p a r t m e n t s .

14 I n 1 9 9 9 a n d 2000, the University of

15M a r y l a n d c o n d u c t e d a survey of all of its graduate

16s t u d e n t s , i n w h i c h one of the series of questions

17t h a t t h e y a s k e d c o n cerned debt and affordability.

18W h e n a s k e d i f t h e y thought that they would incur

19d e b t i n t h e c o u r s e of their degree, 1 in 4

20r e s p o n d e n t s t o t h e survey believed that they would

21n e e d l o a n s o f $ 2 0 , 0 00 or more in the course of

22t h e i r e d u c a t i o n , a n d only 2 in 5 believed that they

23c o u l d c o m p l e t e t h e i r degree with no recourse to

24l o a n s .

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1 W h e n s t u d e n ts were asked to rank their

2m o s t i m p o r t a n t s o u r ce of funding for their

3e d u c a t i o n , l o a n s c a me in fourth out of thirteen

4c a t e g o r i e s , b e a t o u t only by university

5a s s i s t a n t s h i p s , f e l lowships, and income from

6o u t s i d e e m p l o y m e n t .

7 W h e n g r a d u a te students were asked to list

8t h e g r e a t e s t o b s t a c le to their academic progress,

9f i n a n c i a l d i f f i c u l t ies was the single largest

10c a t e g o r y , w i t h o v e r 60 percent of respondents

11l i s t i n g t h a t a s t h e greatest obstacle to their

12c o m p l e t i o n o f t h e i r degree.

13 C o n t r a r y t o what our automatic assumptions

14m i g h t b e i n t h i n k i n g about the distribution of

15g r a d u a t e s t u d e n t p o pulation at a large public

16u n i v e r s i t y , t h e s i n gle largest percentage of

17r e s p o n d e n t s t o t h i s survey were actually from

18e n g i n e e r i n g , c o m p u t er, and the life sciences, the

19s e c o n d l a r g e s t c a t e gory were from the social

20s c i e n c e s a n d e d u c a t ion, the third were from

21b u s i n e s s a n d m a n a g e ment and the humanities, and

22t h e n i t g o e s d o w n s teeply from there.

23 S o , b e a r i n g that in mind, I would like to

24c l o s e b y u r g i n g y o u all to recommend and support

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1t h e f i v e - p o i n t p l a n that you have heard about

2t o d a y , a n d a l s o s t r ongly encourage the Department

3t o i n c l u d e s t u d e n t s in any future neg. reg. process

4t h a t i s u n d e r t a k e n .

5 T h a n k y o u v ery much for you time.

6 D A V I D B E R G E RON: Thank you.

7 W h e n w e c o n duct a negotiated rulemaking,

8i t i s a s t a t u t o r y r equirement that we include

9s t u d e n t s . S o e v e n if we didn’t want to, we would

10h a v e t o .

11 [Laughter.]

12 D A V I D B E R G E RON: And from all of the

13c o m m e n t s t h a t w e h a ve heard from students over the

14c o u r s e o f t h e s e h e a rings, any of us who would have

15t h o u g h t a b o u t n o t i ncluding students have long

16s i n c e t h r o w n t h a t n otion out the window.

17 W e t h a n k y o u. And also, my niece is a

18m e d i c a l s t u d e n t a t Johns Hopkins, and her brother

19w a s j u s t a c c e p t e d t o medical school this week. So

20m y n i e c e a n d n e p h e w are both going to medical

21s c h o o l , a n d t h e y w o uld take issue with issues that

22w o u l d b e c o n c e r n e d about student debt for medical

23s t u d e n t s , a s w e l l , out of graduate students.

24 D A V I D B E R G E RON: Sarah Levin.

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1 SARAH LEVIN: Hi, I am Sarah Levin. I am

2h e r e o n b e h a l f o f E lizabeth Marques, who is

3P r e s i d e n t o f t h e L a boratory Institute of

4M e r c h a n d i s i n g . S h e wanted to be here and she

5c o u l d n ’ t , w h i c h i s why I am, clearly, here.

6 I a m h e r e t o talk about the standards for

7d e t e r m i n i n g t h e f i n ancial viability of college.

8T h e t h i r d c o m m i t t e e on the negotiated rulemaking

9p r o c e s s w i l l c o n s i d er these institution eligibility

10i s s u e s , a n d w e r e c o mmend that this third committee

11r e v i e w t h e p r o c e s s under which there are exceptions

12t h a t i n s t i t u t i o n s c an prove their financial

13s t a b i l i t y .

14 T h e D e p a r t m ent of Education should,

15i n d e e d , s e t s t r i c t standards to ensure the

16f i n a n c i a l h e a l t h o f an institution. We encourage

17r i g o r o u s f i n a n c i a l guidelines to protect our

18s t u d e n t s a n d o u r c o llege communities, but we do not

19a g r e e t h a t t h e s e s t andards are infallible. While

20t h e D e p a r t m e n t ’ s c u rrent standards most often

21i n d i c a t e a c o l l e g e ’ s financial stature accurately,

22t h e r e a r e i n h e r e n t faults and flaws in the ratio

23t e s t i n g t h a t u n f a i r ly burden colleges that are,

24i n d e e d , f i n a n c i a l l y sound.

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1 C u r r e n t l y , the Department determines

2f i n a n c i a l v i a b i l i t y through ratios calculated using

3t h e f i n a n c i a l s t a t e ment data using GAAP, or

4g e n e r a l l y a c c e p t e d accounting principles. While

5t h e s e s t a t e m e n t s p r epared by GAAP generally

6i n d i c a t e t h e f i n a n c ial status of an institution,

7t h e y d o i n c l u d e u n f air biases against institutions

8t h a t h o l d a p p r e c i a t ed real property assets. With

9t h i s i n m i n d , t h e D epartment should consider giving

10t h e S e c r e t a r y d i s c r etion of reviewing and taking

11i n t o c o n s i d e r a t i o n the fair market value of these

12a s s e t s .

13 C o l l e g e s m a y be financially stable, while

14f a i l i n g t h e r a t i o t est using the GAAP-based

15f i n a n c i a l v a l u e s . GAAP does not adequately value

16a p p r e c i a t e d a s s e t s . Since assets are reported at

17b o o k v a l u e , b o o k v a lue does not always represent

18t h e f a i r m a r k e t v a l ue of an asset in cases where

19r e a l p r o p e r t y h a s s ignificantly appreciated over

20t i m e , t h e G A A P s t a n dards present a severe

21u n d e r v a l u a t i o n o f t he asset.

22 F o r e x a m p l e , at LIM, a building they

23p u r c h a s e d w a s v a l u e d at $500,000; they purchased

24t h a t i n 1 9 6 4 . R i g h t now, it is valued at between

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1$ 1 8 - a n d $ 2 0 m i l l i o n, and on the books for GAAP

2s t a n d a r d s i t i s o n l y valued at $100,000, which is a

3s e v e r e u n d e r v a l u a t i on.

4 I n t h e s e e x traordinary circumstances where

5G A A P - b a s e d f i n a n c i a l statements exponentially

6u n d e r v a l u e a s s e t s , the Secretary and the Department

7o f E d u c a t i o n s h o u l d have the discretion to review

8t h e s e c a s e s a n d t o grant exemptions to the ratio

9t e s t . I t i s d e t r i m ental for the financially secure

10i n s t i t u t i o n s t o o b t ain these costly letters of

11c r e d i t i n o r d e r t o maintain financial aid for their

12n e e d y s t u d e n t s .

13 C u r r e n t l y , if an institution fails the

14r e q u i r e d r a t i o t e s t s using the GAAP standards, it

15c a n r e m a i n f u l l y c e rtified by making available a

16l e t t e r o f c r e d i t i n the amount of 50 percent of the

17s t u d e n t a i d p r o v i d e d. Also, an institution can be

18p r o v i s i o n a l l y c e r t i fied by making a letter of

19c r e d i t i n t h e a m o u n t of 10 percent of student aid

20a v a i l a b l e . W e s u g g est that the Secretary of the

21D e p a r t m e n t o f E d u c a tion have the discretion to

22a l l o w a n i n s t i t u t i o n to remain fully certified by

23p r o v i d i n g a l e t t e r of credit in the amount less

24t h a n 5 0 p e r c e n t a f t er reviewing a full review of

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1t h e i n s t i t u t i o n ’ s f inancial statements using the

2c u r r e n t f a i r m a r k e t value of the assets of the

3i n s t i t u t i o n . W e a r e not suggesting changing the

4r e g u l a t i o n s o r a l l o wing financially unstable

5i n s t i t u t i o n s t o h a r m students’ educations, but we

6a r e a d v o c a t i n g t h a t the negotiated rulemaking

7c o m m i t t e e h a v e t h e opportunity to discuss these

8s t a n d a r d s , a n d r e c o mmend that both the Department

9o f E d u c a t i o n a n d t h e Secretary have the ability to

10c o n s i d e r , a n d h a v e the discretion to review, these

11e x c e p t i o n a l c a s e s .

12 T h a n k y o u f or your time.

13 D A V I D B E R G E RON: Thank you.

14 D A V I D B E R G E RON: Jennifer Pae.

15 J E N N I F E R P A E: Speaking of students on the

16c o m m i t t e e s , m y n a m e is Jennifer Pae, and I am the

17e l e c t e d P r e s i d e n t o f the United States Students

18A s s o c i a t i o n . W e a r e the country’s oldest and

19l a r g e s t n a t i o n a l s t udent association, representing

20m i l l i o n s o f s t u d e n t s nationwide.

21 A s a c o a l i t ion of student governments and

22s t a t e w i d e s t u d e n t a ssociations, we are here today,

23a g a i n , f r o m B e r k e l e y, and Chicago, and Orlando to

24o n c e a g a i n e x p r e s s our concerns in high hopes that

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1t h e D e p a r t m e n t w i l l adopt for the negotiated

2r u l e m a k i n g p r o c e s s .

3 A s s t u d e n t s have organized across the

4c o u n t r y f o r t h i s y e ar’s midterm elections, they

5h a v e u s e d i s s u e s s u ch as divestment from higher

6e d u c a t i o n a s a d r i v ing force to turn out to the

7p o l l s . I n t h e p a s t two months, USSA has registered

8m o r e t h a n 4 0 , 0 0 0 s t udents in five targeted states,

9a n d s o m a n y s t u d e n t s turned out in record numbers

10o v e r t h e 2 0 0 2 n u m b e rs. The University of Michigan

11a t A n n A r b o r - - t h e y stated their numbers were over

121 6 0 p e r c e n t .

13 T o d a y ’ s s t u dents are committed to securing

14a c c e s s t o h i g h e r e d ucation, and we urge you to

15c o n s i d e r w a y s t o r e duce student debt burdens,

16i n c r e a s e g r a n t a i d , and increase access to higher

17e d u c a t i o n a s y o u b e gin negotiated rulemaking. The

18n e w l y c r e a t e d A C G a nd SMART Grants can provide an

19a d d i t i o n a l 5 0 0 , 0 0 0 students with funds necessary to

20p u r s u e a c o l l e g e d e gree, but existing regulations

21h a v e m a d e t h e g r a n t s confusing to students, and

22d i f f i c u l t t o a l l o c a te for financial aid

23a d m i n i s t r a t o r s . A t a time when it has become more

24d i f f i c u l t t o a c c e s s higher education due to costs

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1a n d o p p o r t u n i t y , w e should be providing these

2g r a n t s f o r t h e m o s t needy students in order to

3a c h i e v e s u c c e s s i n this country.

4 I n a d d i t i o n , restricting these grants to

5o n l y f u l l - t i m e c o l l ege students who recently

6g r a d u a t e d h i g h s c h o ol excludes many non-traditional

7s t u d e n t s a n d p a r t - t ime students. As our

8o r g a n i z a t i o n r e p r e s ents millions of students across

9t h e c o u n t r y , t h e s e grants clearly do not create

10a c c e s s f o r t h e m . F urthermore, students who are

11e l i g i b l e f o r t h e P e ll Grant, but are not

12r e c i p i e n t s , s h o u l d be allowed to receive these

13g r a n t s . T h e c u r r e n t regulations only allow Pell

14G r a n t r e c i p i e n t s t o benefit from this award. While

15w e a p p l a u d t h e D e p a rtment for creating these new

16g r a n t s , w e h o p e t h a t you will consider amending the

17r e g u l a t i o n s t o e n s u re that more students have the

18o p p o r t u n i t y t o r e c e ive them.

19 A n a d d i t i o n al concern for students include

20t h e n e e d t o m a k e c o llege more affordable, of

21c o u r s e , b y l i m i t i n g student loan repayments to a

22r e a s o n a b l e p e r c e n t a ge of a borrower’s income.

23R e c e n t g r a d u a t e s w h o pursue careers as teachers or

24i n t h e n o n - p r o f i t s ector will have the ability to

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1s u c c e s s f u l l y m a n a g e their student loan repayments.

2W e w o u l d a l s o l i k e the Department to recognize that

3b o r r o w e r s w i t h c h i l dren have less income available

4f o r s t u d e n t l o a n p a yments. Family status should be

5t a k e n i n t o a c c o u n t when determining their loan

6r e p a y m e n t s .

7 F i n a l l y , w e urge the Department to protect

8s t u d e n t b o r r o w e r s f rom high interest charges when

9t h e y f a c e h a r d s h i p situations. Due to the recent

10c u t s i n t h e s t u d e n t loan program, students are

11f a c i n g m u c h h i g h e r burdens, and we must ensure that

12s t u d e n t s a r e p r o t e c ted from unmanageable levels of

13d e b t . I t i s i m p o r t ant for students to not only be

14a b l e t o a f f o r d t h e repayments of their loans, but

15t h e r e s h o u l d b e s a f eguards in place to help them in

16t i m e s o f f i n a n c i a l instability.

17 R e s e a r c h s h ows that 40 percent of students

18d o n o t p u r s u e g r a d u ate school because of their

19s t u d e n t l o a n d e b t . Each year, millions of

20g r a d u a t e s d e l a y s o m e of life’s most important

21d e c i s i o n s , a s y o u m ay know, including purchasing a

22h o m e , g e t t i n g m a r r i ed, and starting a family simply

23b e c a u s e t h e y a r e b u rdened with student loan debt.

24 A s c o l l e g e costs continue to skyrocket,

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1t h e a v e r a g e f a m i l y is continually finding it harder

2t o a f f o r d c o l l e g e . Just yesterday, while I was in

3t h e s t a t e o f M i c h i g an, they passed an extremely

4h a r m f u l b a l l o t i n i t iative, similar to a proposition

5i n C a l i f o r n i a t e n y ears ago, which has dramatically

6a f f e c t e d t h e h i g h e r education system, which will

7e l i m i n a t e A f f i r m a t i ve Action programs, not only in

8e d u c a t i o n , b u t t h e job market, as well.

9U n f o r t u n a t e l y , t h i s will target many first

10g e n e r a t i o n , l o w - i n c ome students of color, and will

11c l o s e t h e d o o r s o f higher education for many

12q u a l i f i e d i n d i v i d u a ls. We must provide for the

13s u c c e s s o f t o d a y ’ s students, and for future

14s t u d e n t s , i n o r d e r for our country to succeed in a

15g l o b a l e c o n o m y , e s p ecially for those that have the

16m o s t p o t e n t i a l .

17 T h e S p e l l i n gs Commission Report concluded

18t h a t 9 0 p e r c e n t o f the fastest-growing jobs in the

19n e w i n f o r m a t i o n a n d service economy would require a

20p o s t s e c o n d a r y d e g r e e. If our nation intends to

21c o m p e t e i n t h i s c h a nging global economy, we need an

22e d u c a t e d w o r k f o r c e , and, sadly, many of those

23s t u d e n t s w h o a r e s h ut out from pursuing a higher

24e d u c a t i o n a r e l o w - i ncome and minority students.

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1 W e u r g e f o r the Department to provide a

2h i g h e r e d u c a t i o n a l system that is affordable and

3a c c e s s i b l e t o a l l . Twenty years ago, anyone who

4w a n t e d t o p u r s u e a college degree was granted that

5o p p o r t u n i t y . U n f o r tunately, students today do not

6h a v e t h a t l u x u r y . Millions of students are working

7f u l l - t i m e , r a i s i n g families, and drowning in

8u n m a n a g e a b l e d e b t , just to put themselves through

9s c h o o l .

10 I n c r e a s i n g grant aid and making loans more

11m a n a g e a b l e w i l l a l l ow more students an opportunity

12t o a c c e s s t h e d o o r s of higher education. While we

13k n o w t h a t i t i s n o t within the Department’s

14j u r i s d i c t i o n t o i n c rease appropriations for these

15f e d e r a l p r o g r a m s , w e ask that you do whatever you

16c a n t o m a k e c o l l e g e a reality for students across

17t h e c o u n t r y , a n d n o t simply a dream.

18 W e a r e e a g e r to work with the Department,

19a n d t r u l y r e p r e s e n t students from across the

20c o u n t r y t h r o u g h o u t the negotiated rulemaking

21p r o c e s s a n d t h e t a b le, as we have in the past. So,

22l o o k f o r w a r d t o o u r nominations, not only for

23m y s e l f a n d t h e V i c e President, but our Legislative

24D i r e c t o r . A n d w e h ope through all the testimonies

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1f o r t h e C o m m i s s i o n on the Future of Higher

2E d u c a t i o n , a s w e l l as these public hearings for the

3D e p a r t m e n t , t h a t y o u take these testimonials to

4h e a r t , b e c a u s e t h e y are true stories of what is

5g o i n g o n i n t o d a y ’ s higher educational system.

6 T h a n k y o u f or the time and the

7o p p o r t u n i t y , a n d w e look forward to talking to you

8a g a i n s o o n .

9 D A V I D B E R G E RON: Thank you, Jennifer.

10 I w o u l d n o t e, as I said earlier, we can’t

11c h a n g e s t a t u t e ; f u l l-time is a requirement of the

12s t a t u t e f o r A c a d e m i c Competitiveness Grants and

13N a t i o n a l S M A R T G r a n ts. We did make a change in the

14f i n a l r u l e t o a d d r e ss one of your issues related to

15P e l l r e c i p i e n t s .

16 D A V I D B E R G E RON: Jesse Fenner.

17 J E S S E C . F E NNER: Good afternoon.

18 D A V I D B E R G E RON: Good afternoon.

19 J E S S E C . F E NNER: My name is Jesse Fenner,

20a n d I a m a n a l u m n u s of the Upward Bound Program

21f r o m t h e U n i v e r s i t y of Chicago, and I am here today

22t o v o i c e m y s u p p o r t for Upward Bound, and to ask

23t h a t t h e D e p a r t m e n t ensure that its proposed

24p r i o r i t i e s t a k e i n t o account, reflect upon, three

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1t h i n g s t h a t I t h i n k make the Upward Bound Program

2t h a t I p a r t i c i p a t e d in a successful program.

3 T h o s e t h r e e things are: establishing

4t r u s t , a p a r t n e r s h i p, and a safe haven. Many

5U p w a r d B o u n d p a r t i c ipants or potential Upward Bound

6p a r t i c i p a n t s h a v e , at some point in their life--

7t h e y h a v e b e e n f a i l ed, either by schools that did

8n o t a d e q u a t e l y p r e p are them for high school and

9c o l l e g e , b y f a m i l y that did not adequately support

10t h e m i n t h e i r e n d e a vors, or by their community that

11f a i l e d t o p r o v i d e t hem with safe schools or safe

12n e i g h b o r h o o d s .

13 T h e s e t h i n g s create barriers to reaching

14o u t t o s t u d e n t s . I don’t think that the Upward

15B o u n d P r o g r a m n e e d s any more barriers. I would ask

16t h a t t h e D e p a r t m e n t make sure that its proposed

17p r i o r i t i e s g i v e t h e Upward Bound Program the

18f l e x i b i l i t y n o t o n l y to reach out to the students

19w h o f a l l w i t h i n t h e four corners of your proposed

20p r i o r i t i e s , b u t t h o se students who come to Upward

21B o u n d .

22 I w a s o n e o f the students. I wasn’t a

23p o o r s t u d e n t , I w a s just poor. There were a lot of

24f a c t o r s p u l l i n g a t me, and pulling at my family.

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1A m o n g m y b r o t h e r s a nd sisters, there are six of us.

2A l l o f u s w e r e e x c e llent students up through the

3e i g h t h g r a d e , b u t t hree dropped out of high school,

4t w o g r a d u a t e d f r o m high school with no college, and

5t h e n m y s e l f . W i t h partnership with Upward Bound, I

6w a s a b l e t o g o t o H arvard University, and am now an

7a t t o r n e y t o d a y .

8 S o I t h i n k that Upward Bound--in the

9p r o g r a m t h a t I p a r t icipated in, it has to engage in

10a t r u s t - b u i l d i n g p r ocess with the participants, and

11i t n e e d s t h e f l e x i b ility to do that. I think,

12b e c a u s e o f t h a t , t h at the students or the

13p a r t i c i p a n t s w h o c o me to the program won’t

14n e c e s s a r i l y f i t i n the four corners of the proposed

15p r i o r i t i e s , a n d I w ould ask for flexibility in

16t h a t .

17 T h e s e c o n d thing is partnership. I was

18a b l e t o a c h i e v e t h e things that I was able to

19a c h i e v e i n p a r t n e r s hip with Upward Bound, and I

20w o u l d a s k t h a t t h e proposed priorities enable all

21p a r t i c i p a n t s , a l l s tudents enrolled in Upward

22B o u n d , t o b e f u l l p artners with Upward Bound in

23m a p p i n g t h e i r e d u c a tional achievement. I don’t

24k n o w w h a t I w o u l d h ave done if I were in a control

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1g r o u p . I d o n ’ t t h i nk I would be standing here

2t o d a y , b u t I w o u l d ask that the Department include

3s o m e f l e x i b i l i t y t h at, if a student wants to be a

4f u l l p a r t n e r w i t h U pward Bound, that they are not

5r e j e c t e d , a n d t h a t they are able to get the

6r e s o u r c e s t h a t t h e y request.

7 A n d t h e l a s t thing, a safe haven. I know

8m y n e i g h b o r h o o d w a s not safe. I spent as much time

9a s I c o u l d a t U p w a r d Bound and, at times, I brought

10p e o p l e w i t h m e w h o were there, and none of them got

11r e j e c t e d ; n o n e o f t hem were asked what their grade

12p o i n t a v e r a g e w a s , what their test scores were,

13t h e y w e r e j u s t p r o v ided with help. I would ask

14t h a t t h e D e p a r t m e n t , in its proposed priorities for

15U p w a r d B o u n d , e n s u r e that the program remains

16i n c l u s i v e , t h a t i t is not restrictive or exclusive,

17a n d t h a t t h e s t u d e n ts who come to seek help from

18t h e p r o g r a m c a n a c t ually get it.

19 Thank you.

20 D A V I D B E R G E RON: Thank you.

21 D A V I D B E R G E RON: Alys Cohen. How are you?

22 ALYS COHEN: I am great, and I am

23i m p r e s s e d t h a t y o u pronounced my name correctly.

24 D A V I D B E R G E RON: It’s been one of those

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1d a y s t h a t I h a v e h a d good success and bad success

2w i t h p r o n o u n c i n g n a mes, but thank you. You are our

3l a s t s c h e d u l e d w i t n ess. There may be others that

4m a y w a n t t o s a y s o m ething, but they are not on our

5l i s t .

6 D A N M A D Z E L A N: So take your time.

7 D A V I D B E R G E RON: Take your time. You have

8h a l f a n h o u r .

9 ALYS COHEN: I am Alys Cohen. I am a

10s t a f f a t t o r n e y a t t he National Consumer Law Center.

11 T w e n t y y e a r s ago, I was a member of NYPIRG

12a n d U S S A , s o I w o u l d like to associate myself with

13a l l t h o s e s t u d e n t s who made wonderful remarks

14t o d a y .

15 A s a p u b l i c interest lawyer, I will be

16p a y i n g b a c k m y s t u d ent debt until my three and

17f o u r - y e a r - o l d a r e s tarting to enter college, and I

18a m t h e s i s t e r o f a social worker.

19 B u t t o d a y , I am here on behalf of members

20o f t h e l e g a l a s s i s t ance community who represent

21l o w - i n c o m e s t u d e n t s and borrowers. We support the

22l a w y e r s a n d t h e b o r rowers directly in their effort

23t o d e a l w i t h t h e i r student loan problems, and we

24g e t c a l l s e v e r y w e e k from lawyers, and not all

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1b o r r o w e r s h a v e l a w y ers, trying to parse through the

2s i t u a t i o n s t h a t t h e ir clients have. Most of the

3t i m e t h e a n s w e r i s , “The regulations don’t go far

4e n o u g h f o r y o u r c l i ent.”

5 L e t m e t a l k about some of those regulatory

6i s s u e s . W e u r g e y o u to address the issue of

7s t u d e n t l o a n r e p a y m ent burdens in the negotiated

8r u l e m a k i n g . D e b t h as become a primary way that

9A m e r i c a n s p a y f o r c ollege. Borrowers are

10i n c r e a s i n g l y , t h r o u gh no fault of their own, faced

11w i t h p a y m e n t s t h a t are simply unaffordable. It is

12i m p o r t a n t f o r s t u d e nts to understand the importance

13o f f u l f i l l i n g t h e i r obligations; however, these

14o b l i g a t i o n s m u s t b e balanced against other

15i m p o r t a n t i n t e r e s t s , including encouraging access

16t o e d u c a t i o n a n d p r oviding relief for vulnerable

17b o r r o w e r s a n d v i c t i ms of fraud.

18 U n f o r t u n a t e ly, the current federal

19p r o t e c t i o n s a r e p o o rly designed, and fail to

20p r o v i d e a f u n c t i o n a l safety net for student loan

21b o r r o w e r s . F o r t u n a tely, you have the legal

22a u t h o r i t y t o i m p r o v e their safety through the

23u p c o m i n g r u l e m a k i n g . We ask you to adopt the five-

24p o i n t p l a n , a b o u t w hich you know very much, and we

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1e s p e c i a l l y a s k y o u to give special consideration to

2s o m e a d d i t i o n a l r e c ommendations that particularly

3a f f e c t t h e l o w e s t i ncome borrowers.

4 N u m b e r o n e , we ask you to expand the

5a v a i l a b i l i t y o f i n c ome-contingent repayment plans

6b y o f f e r i n g t h e s e p lans through rehabilitation, in

7a d d i t i o n t o c o n s o l i dation, and by allowing

8b o r r o w e r s i n d e f a u l t to reconsolidate defaulted,

9D i r e c t , a n d F F E L c o nsolidation loans in order to

10a c c e s s t h e I C R P .

11 N u m b e r t w o , we ask you to strengthen the

12s a f e t y n e t f o r t h e most vulnerable borrowers by

13t y i n g t h e d e f i n i t i o n of disability for purposes of

14c a n c e l i n g l o a n s t o the standards set by the Social

15S e c u r i t y A d m i n i s t r a tion, by restoring the seven-

16y e a r g r o u n d s f o r d i scharging student loans in

17b a n k r u p t c y , a n d b y repealing the bankruptcy non-

18d i s c h a r g a b i l i t y p r o visions that apply to private

19l o a n s .

20 N u m b e r t h r e e, we ask you to develop and

21s u p p o r t p r o g r a m s t h at can provide objective, in-

22d e p t h a s s i s t a n c e t o borrowers experiencing problems

23w i t h s t u d e n t l o a n d ebt.

24 N u m b e r f o u r , improve monitoring of private

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1c o l l e c t i o n a g e n c y a ctivity, and relieve other

2c o l l e c t i o n b u r d e n s by only charging collection fees

3t h a t a r e b o n a f i d e and reasonable by re-imposing a

4s t a t u t e o f l i m i t a t i ons for student loan

5c o l l e c t i o n s , a n d b y creating a rigorous training

6p r o g r a m f o r c o l l e c t ors that includes regular

7o v e r s i g h t a n d a n a c cessible system to handle

8b o r r o w e r c o m p l a i n t s .

9 A n d n u m b e r five, since it is a companion

10t o t h e f i v e - p o i n t p lan, ensure that borrowers can

11e n f o r c e t h e i r r i g h t s by creating an explicit

12p r i v a t e r i g h t o f a c tion to enforce key provisions

13o f t h e H i g h e r E d u c a tion Act. As a former

14g o v e r n m e n t l a w y e r m yself, I appreciate the power of

15g o v e r n m e n t e n f o r c e m ent, but there is nothing like a

16p r i v a t e c a u s e o f a c tion to get actors to do the

17r i g h t t h i n g .

18 O n e o t h e r t hing that is not on here that I

19w o u l d l i k e t o a d d . Right now, in Congress, they

20a r e l o o k i n g a t F H A modernization. What they are

21t r y i n g t o d o i s m a k e the FHA program for low-income

22h o m e o w n e r s b e r e l e v ant. The biggest challenge to

23t h a t i s t h e a b u s e i n the private loan market. As

24t h e p r i v a t e l o a n s e xpand in the student loan

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1m a r k e t , I d o n ’ t w a n t to see the same thing happen

2b e c a u s e o f t h e h e a v iness, and the complexity, and

3t h e l i m i t a t i o n s o f the government student loan

4p r o g r a m s .

5 O n t h e s u b j ect of who participates in the

6r u l e m a k i n g , w e n o m i nate Deanne Loonin, staff

7a t t o r n e y w i t h N C L C , and Bob Shireman, Executive

8D i r e c t o r o f t h e P r o ject on Student Debt, to

9r e p r e s e n t l e g a l a i d organizations and their low-

10i n c o m e c l i e n t s i n t he upcoming negotiated

11r u l e m a k i n g p r o c e s s . We appreciate the

12c o n s i d e r a t i o n o f o u r nomination.

13 W h e n I w a s coming in here today, I came to

14t h e f i r s t b u i l d i n g with the little red school house

15a n d i t s a i d , “ D o o r closed. Try the next entrance.”

16A n d I c a m e t o t h e n ext door and it said, “Door

17c l o s e d . T r y t h e n e xt entrance.” I hope that we

18w o n ’ t h a v e a l o t o f doors closed for those that are

19t r y i n g t o b e t t e r t h emselves.

20 Thank you.

21 D A V I D B E R G E RON: Thank you.

22 T h a t i s t h e last witness we have

23s c h e d u l e d . W e w i l l stay here for the next 25

24m i n u t e s i f t h e r e a r e other people who want to say

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1s o m e t h i n g .

2 B u t w h i l e t here is no one here at the

3m i c r o p h o n e t o d o t h at, let me just say--I have said

4m y t h a n k s t o s t u d e n ts at various times during the

5d a y . A s w e h a v e g o ne around the country, we have

6b e e n t r e m e n d o u s l y i mpressed by our students. They

7h a v e p r o v i d e d , i n e very case, something unique and

8s p e c i a l a s s o c i a t e d with that particular student,

9b u t a l s o , t h e y h a v e spoken for their friends and

10c o l l e a g u e s o n t h e c ampuses, and we have appreciated

11t h a t . I a p p r e c i a t e everybody’s patience who stayed

12a l l d a y t o d a y , a n d there have been a number of you

13l i s t e n i n g w i t h u s a s we have listened to testimony.

14 S o , w i t h t h at, we are just going to sit

15h e r e a n d h a n g o u t f or the next 24 minutes, unless

16t h e r e a r e o t h e r s . If there are others that are

17h e r e t h a t w a n t t o s peak, they can do that.

18 D A N M A D Z E L A N: We are considering this

19o p e n m i k e t i m e .

20 [ O p e n m i c r o phone from 3:38 to 4:00 p.m.]

21 [ W h e r e u p o n , at 4:00 p.m., the hearing was

22a d j o u r n e d . ]
23

24

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