Department of Education Delays Implementation of Third-Party Servicers Guidance

4/14/2023

WIH

Earlier this week, the Department of Education (Department) announced that the agency is delaying the effective date of updated guidance on third-party servicers. The updated guidance clarifies when companies and others who provide recruitment services to institutions of higher education will fall into the third-party servicers category. “Specifically, [the Department] will delay the effective date of the guidance letter, and the September 1, 2023, date will no longer be in effect. The effective date of the revised final guidance letter will be at least six months after its publication, to allow institutions and companies to meet any reporting requirements. Deadlines for audit and contractual requirements will follow in fiscal years that begin after the effective date for the reporting requirements.

The announcement lists several activities that it does not consider to be third-party servicer relationships:

Study abroad programs.
Recruitment of foreign students not eligible for Title IV aid.
Clinical or externship opportunities that meet requirements under existing regulations because they are closely monitored by qualified personnel at an institution.
Course-sharing consortia and arrangements between Title IV-eligible institutions to share employees to teach courses or process financial aid.
Local police departments helping to compile and analyze crime statistics, unless they write or file a report on behalf of an institution for compliance purposes.

CGS and the broader higher education community have been active on this issue and recently sent a letter to Secretary of Education Miguel Cardona concerning the proposed changes to the guidance.

Senate Democrats Request Increased Funding for Office of Federal Student Aid

Earlier this week, Senator Elizabeth Warren (D-MA) and 16 other Senators sent a letter to the Senate Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies regarding the need to increase funding for the Department of Education’s Office of Federal Student Aid (FSA). In the letter, Senator Warren and her colleagues request an appropriation of $2.7 billion for FSA for fiscal year 2024. This increase in funding will assist with the implementation of reforms to the student loan system, including improvements to the Public Service Loan Forgiveness (PSLF) program and a new income-driven repayment (IDR) plan for borrowers.

The Senators write in the letter, “FSA’s responsibilities have increased to protect students and borrowers, but its federal funding has remained stagnant. The lack of adequate resources creates more barriers for students to continue their education. We believe this funding request is needed to provide FSA with the resources it needs to fulfill its goal of ensuring that all eligible students and families can access federal student grants, loans, and work-study funds to pursue education and training beyond high school.”

In February 2023, CGS submitted comments to the Department of Education concerning proposed changes to the IDR plan.

Important Announcements from the National Science Foundation

In the last two weeks, the National Science Foundation issued programmatic and award announcements of importance to the graduate education community.

Dear Colleague Letter: Computer and Information Science and Engineering Graduate Fellowships
- The Dear Colleague Letter invites applications for individuals who intend to apply to doctoral degree-granting programs in Computer and Information Science and Engineering disciplines for matriculation in Fall 2024 or Fall 2025. NSF expects that 70 individuals will be selected with three years of financial support. For each of the three years of support, a $37,000 stipend and $16,000 cost-of-education allowance will be awarded to the graduate degree-granting institution of higher education for each Fellow who will use the support in a fellowship year.

Dear Colleague Letter: Catalyzing Institutional Change to Support Greater Equity, Inclusion, and Access in STEM Academic Careers and Advanced Degree Attainment
- The Dear Colleague Letter seeks to advance the racial, ethnic, and gender diversity of the student graduating with STEM doctoral degrees through two institutional change programs at NSF such as the Alliances for Graduate Education and the Professoriate (AGEP) program and the Organizational Change for Gender Equity in STEM Academic Professions (ADVANCE) program. The AGEP program supports alliances among institutions of higher education to design and implement strategies that increase the number of historically underrepresented STEM faculty and promote systemic change, and the ADVANCE program supports systemic change projects to enhance gender equity and inclusion for STEM faculty. A webinar on this Dear Colleague Letter will be held on April 27, 2023, 3:00-4:30pm EDT. Register for the webinar here.

National Science Foundation Virtual Grants Conference
- NSF will be hosting a virtual grants conference, to be held during the week of June 5, 2023. Registration will open on Wednesday, May 10 at 12PM EDT. The NSF Grants Conference is designed to give new faculty, researchers, and administrators key insights into a wide range of current issues at NSF. NSF staff will provide up-to-date information about policies and procedures, specific funding opportunities and answer attendee questions. Highlights of the conference will include:
  - New programs and initiatives
  - Proposal preparation
  - NSF’s merit review process
  - NSF directorate sessions
  - Award management topics
  - Conflict of interest policies
  - NSF systems updates

Important Changes Coming to the Fulbright-Hays Selection Process

The Department of Education (Department) recently issued an amended federal register notice for the Fulbright-Hays Doctoral Dissertation Research Abroad Fellowship Program. According to the notice, the Department of Education is “amending the selection criterion and the selection criteria point allocations in the Notice Inviting Applications for FY2023 and extending the deadline date for transmittal of applications until April 28, 2023.” According to a recent article in Inside Higher Ed, this amended selection process is in response to lawsuits filed by applicants to the program.

For the Fiscal Year 2023 application for awards, the Department allowed one point at most in the selection process for proficiency in one or more languages other than English or the applicant’s native language. The lawsuit stated that the rule for the program penalizes students whose native language is the same as what is spoken in the country where they want to conduct their research.