The Administration

    Community Letter on Proposed Visa Fee Increases (9/17/2018)

    On September 17, CGS joined the higher education community on comments and feedback submitted to the Department of Homeland Security around its proposed fee increases for the Student and Exchange Visitor Program (SEVP) calling attention to the potentially adverse impact on international students and faculty as well as U.S. institutions of higher education.

     

    Community Comments on Borrower Defense Rule (8/30/2018)

    On August 30, CGS signed on to comments from the higher education community sent to the Department of Education around its proposed final rule on borrower defenses to repayment. The letter specifically addresses proposed changes to the process for granting borrowers relief due to the closure of, or misrepresentations by, their institution. 

     

    CGS Comments on USAID Education Policy (8/2/2018)

    On August 2, CGS submitted comments and feedback to the U.S. Agency for International Development (USAID) around a set of questions posed at a discussion on the U.S. Government Basic Education Strategy and the impending USAID Education Policy. CGS provided several recommendations that USAID can implement with respect to this critical issue, including: strengthening the academic workforce; partnering with institutions to advance research; improving student support services; and bolstering connections with employers and industry.

     

    Community Letter on Proposed Changes to Visa Applications (5/14/2018)

    On May 14, CGS signed onto comments submitted by the higher education community to the State Department over its proposed changes to the application for nonimmigrant visas, including student visas, work visas, and tourist visas, which would require the reporting of five years of identifiers for social media platforms, previously used telephone numbers, email addresses, and international travel. The letter highlights the community’s concerns with the message this action would send to international scholars and the impact it would have on the ability of U.S. colleges and universities to attract the world’s top students and researchers.

     

    Community Letter to FBI Director on Higher Ed National Security Issues (4/24/2018)

    CGS signed onto a higher education community letter sent on April 24 to FBI Director Christopher Wray expressing concern over the disbanding of the National Security Higher Education Advisory Board (NSHEAB). The letter cites a recent congressional hearing regarding heightened security concerns around international students and theft of intellectual property. It also requests a meeting with relevant national security agencies to discuss national security issues that intersect with higher education.

     

    Community Letter on DACA Renewal Process (4/13/2018)

    CGS signed onto a higher education community letter sent on April 13 to the Homeland Security Secretary Kirstjen Nielsen expressing support for the Department of Homeland Security’s (DHS) effort to process renewal applications for current Deferred Action for Childhood Arrivals (DACA) registrants. The letter stresses the importance of expediting the process and encourages DHS to promptly review submissions that have recently expired or will expire in the coming days and weeks, to avoid a backlog of applications which may result in a loss of protections for DACA recipients whose status many soon lapse.

     

    Community Letter on Overtime Rule (9/25/2017)

    On September 25, CGS signed onto a community letter submitting comments to the Labor Department (DOL) regarding proposed changes to the Fair Labor Standards Act’s (FLSA) overtime pay requirements. The letter highlights the impact the proposed rule would have on postdoctoral researchers at institutions of higher education. CGS signed onto a similar set of comments to DOL in 2015. 

     

    Community Letter on Higher Ed Regulations (9/20/2017)

    On September 20, CGS signed onto a higher education community letter submitting comments to the Department of Education with respect to regulations that may be appropriate for repeal, replacement or modification. The letter highlighted recommendations made by a 2015 taskforce report, focusing on financial responsibility standards, return of Title IV funds, and state authorization. In August, CGS signed onto a similar letter, which provided recommendations on the negotiated rulemaking process, and also highlighted the 2015 report.  

     

    Comments to Education Department on NPSAS (9/7/2017)

    On September 7, CGS submitted comments and feedback to the Education Department regarding the 2017-18 National Postsecondary Student Aid Study Administrative Collection (NPSAS). The letter expressed appreciation that the department proposed differentiating between different segments of graduate and professional students, as well as for its proposal to provide more frequent results of its data collection. CGS also encouraged the department to clarify how forms of financial support, other than student loans, will be captured in this proposed data collection effort.

     

    Community Letters on DACA (August 2017)

    In late August, prior to a September 5th announcement by the administration,CGS signed onto two community letters to President Trump asking him to keep the Deferred Action for Childhood Arrivals (DACA) program in place and work with Congress on a long-term solution. 

     

    Community Letter to Department of Education on Executive Order 13781 (8/4/2017)

    On August 4, CGS signed onto a community letter offering comments to the Education Department with respect to Executive Order 13781 of March 13, 2017 (Comprehensive Plan for Reorganizing the Executive Branch). The letter focuses on the Department’s negotiated rulemaking process, providing a set of recommendations that can be used to amend or improve the current process. 

     

    Comments to Education Department on Plan to Reorganize the Executive Branch (8/2/2017)

    On August 2, CGS submitted feedback to the Department of Education regarding Executive Order 13781 of March 13, 2017 (Comprehensive Plan for Reorganizing the Executive Branch). The comments offered several suggestions on how the Department can better serve graduate students, including: better, more nuanced benchmarking; more transparent federal student loan information; simplified and equitable repayment options; and more relevant specified areas of national need in the Graduate Assistance in Areas of National Need (GAANN) program. 

     

    Community Letter on SHIPs for Graduate Students (7/12/2017)

    On July 12, CGS signed on a higher education community letter that responded to a “request for information” regarding reducing regulatory burdens imposed by the Patient Protection and Affordable Care Act & Improving Healthcare Choices To Empower Patients to Centers for Medicare & Medicaid Services (CMS). The letter requests that guidance be issued stating that institutions of higher education do not violate the Affordable Care Act (ACA) market rules if they subsidize their student health insurance plan (SHIP) coverage and will not be penalized for doing so.

     

    Comments Sent to CFPB on Student Loan Servicing Market Monitoring (04/24/2017)

    On April 24, CGS submitted comments to the Consumer Financial Protection Bureau (CFPB) regarding the agency’s proposed information collection activity, titled, “Student Loan Servicing Market Monitoring”, which looks to make student loan portfolio, performance, and repayment plan information more accessible and transparent. CGS urged the Bureau to be mindful of the information gap that exists in the data collection of graduate borrowers and encouraged CFPB not only to disaggregate by broad loan type, but also by degree type within graduate and professional programs (e.g., master’s, doctorates, and professionals).

     

    Community Letter to President Trump on the Impact of Immigration Ban on U.S. Science (1/31/2017)

    CGS has signed onto a community letter with 164 other higher education associations, scientific organizations and institutions of higher education, to President Donald Trump asking him to rescind Executive Order, Protecting the Nation from Foreign Terrorist Entry into the United States. The letter highlights the negative impact the Executive Order will have on the science and engineering capacity of the United States.

     

    Letter to Department of Homeland Security Regarding the Executive Order on Immigration (1/31/2017)

    CGS joined 46 other higher education associations on a letter to the Secretary of Homeland Security (DHS) John Kelly voicing the concerns of the higher education community with respect to how the administrations Executive Order, Protecting the Nation from Foreign Terrorist Entry into the United States, will affect institutions of higher education. The letter requests a meeting with the Department to discuss the concerns of the higher education community and offers to work with DHS to create policies that enhance our security without harming our ability to attract international students and scholars. 

     

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