Dear Speaker Ryan, Majority Leader McCarthy, Minority Leader Pelosi, and Minority Whip Hoyer:
On behalf of the Association of Governing Boards of Universities and Colleges (AGB), I write to comment on H.R. 4508, the Promoting Real Opportunity, Success, and Prosperity through Education Reform Act (PROSPER)—a bill that would reauthorize the Higher Education Act of 1965.
AGB is the premier organization centered on governance in higher education, serving over 1,300 member boards representing 1,900 colleges, universities, and institutionally related foundations that are comprised of over 40,000 board members and senior administrators. Governing board members serve as institutional fiduciaries, entrusted with the legal authority to establish and oversee all major policies, including oversight of institutional mission, academic quality, and financial health. This means that boards have responsibilities for the stewardship and protection of their institutions’ human, physical, and financial assets, and hold these assets in trust for both current and future generations.
Governing board members, as fiduciaries of their institutions, will be pleased that H.R. 4508 contains several recommendations that will simplify and streamline federal mandates and regulations. Based on recommendations from the 2015 Task Force on Federal Regulation of Higher Education, the bill will lower administrative costs that can be passed on to students by reducing unnecessary and duplicative regulations. Our members will also be pleased with provisions that incentivize Pell recipients to complete their degrees in a timely manner, that simplify the federal aid application process, that eliminate origination fees on student loans, and that authorize institutions to limit student borrowing.
However, several sections of the bill will give institutional fiduciaries pause. We are deeply concerned to see the end of the subsidized student loan program and the elimination of Supplemental Educational Opportunity Grants and the public service loan forgiveness program. These changes will have a substantially negative impact on low-income students by raising their cost of college and their amount of student debt. In addition, graduate students would face new loan limits—cutting off the access of low-income students to potentially high-earning areas of study—and lose eligibility for the work-study program.
The bill would also expand eligibility for student aid to short-term programs. While this has the possibility to benefit many students, the bill simultaneously relaxes the requirements that prevent fraud and abuse in the Title IV federal aid programs. In addition, the bill would require minority-serving institutions to meet a graduation rate threshold in order to be eligible for certain grants. This would disadvantage these schools which often enroll some of the hardest to serve students.
As noted above, there is much to applaud in H.R. 4508, but there are also major policy changes in the bill that should have included sufficient debate and discussion. While AGB stands ready to work with you to ensure that the reauthorization of the Higher Education Act achieves what is necessary for the benefit of our nation’s students and help sustain the vital federal role in our nation’s system of postsecondary education, we cannot support H.R. 4508 in its current form.