Department of Education Regulatory or Process Issues or Other Executive Branch Departments

On this page you will find comments or requests for action on established regulations, policies, processes, or other issues concerning student financial aid or other related areas of higher education.

NASFAA Joins Call on ED to Rescind DCL on Ending Racial Preferences, Requests Collaborative Process With Higher Education Community
February 25, 2025 - NASFAA sent a letter to ED asking it to rescind its recent Dear Colleague Letter, which told institutions to cease using "racial preferences" in admissions, financial aid, and other areas, or be at risk at losing federal funding.
NASFAA Presses New Administration to Extend GE/FVT Reporting Deadline to July 2025
January 29, 2025 - With a new presidential administration in office, NASFAA, along with over 50 higher education organizations, called on the Department of Education to extend the institutional reporting deadline for GE and FVT.
NASFAA's Comments on Loan Repayment Plan Interim Final Rule
December 17, 2024 - On Monday NASFAA submitted comments to the Department of Education (ED) on its plans to resurrect the Income-Contingent Repayment (ICR) and Pay as You Earn (PAYE) student loan repayment plans.
NASFAA Calls on ED to Extend GE and FVT Institutional Reporting Deadline to July 2025
December 13, 2024 - NASFAA, along with dozens of other higher education organizations, signed onto a letter calling on the Department of Education to extend the gainful employment (GE) and financial value transparency (FVT) institutional reporting deadline to July 2025.
NASFAA Calls on ED to Clarify and Provide Resources to Institutions on GE/FVT
November 12, 2024 - NASFAA signed onto a letter to the Department of Education outlining several issues institutions have faced as the institutional reporting requirements for gainful employment and financial value transparency deadline nears.
NASFAA Comments on Proposed R2T4, Distance Ed, and TRIO Regulations
August 26, 2024 - On Friday NASFAA submitted comments responding to ED's request for feedback on its proposed regulatory changes resulting from negotiations held earlier this year covering topics related to program integrity and institutional quality.
NASFAA Submits Comments on GE/FVT Reporting Requirements
June 17, 2024 - On Monday NASFAA submitted to the Department of Education (ED) its response to ED’s second request for comments on its Gainful Employment (GE) and Financial Value Transparency (FVT) institutional reporting requirements.
NASFAA Submits Comments on ED’s Student Loan Debt Relief Proposal
May 20, 2024 - On Friday NASFAA submitted comments to the Department of Education (ED) on its student loan debt relief proposal.
NASFAA Comments on Proposed Changes to IPEDS Reporting
May 10, 2024 - On Friday NASFAA submitted comments to the Department of Education (ED) in response to proposed changes to IPEDS data reporting.
NASFAA Shares Preview of Comments on ED’s Student Loan Debt Relief Proposal
May 8, 2024 - NASFAA is pleased to share a preview of comments it plans to submit to the Department of Education (ED) next week on its student loan debt relief proposal.
NASFAA Signs Onto Letter Requesting ED to Further Delay GE Reporting Requirements
April 24, 2024 - NASFAA signed onto a letter this week in response to the Department of Education's (ED) information collection request on gainful employment (GE) and financial value transparency (FVT) reporting requirements.
NASFAA Submits Comments on Proposed Gainful Employment and Financial Value Transparency Reporting Requirements
April 22, 2024 - On Monday NASFAA submitted to the Department of Education (ED) its comments on ED’s proposed Gainful Employment (GE) and Financial Value Transparency institutional reporting requirements.
NASFAA Asks ED to Delay Implementation of FVT and GE Reporting Requirement
March 15, 2024 - NASFAA signed onto a letter urging ED to delay reporting requirements, beyond the July 31, 2024 deadline, associated with the implementation of the department’s final rule for gainful employment (GE) and financial value transparency (FVT) framework.
NASFAA Submits Comments on ED Process for FSA ID Without SSN
February 26, 2024 - NASFAA submitted comments to the Department of Education (ED) related to its authentication process for individuals without a Social Security number (SSN) applying for an FSA ID.
NASFAA Asks ED for Burden Relief Due to Delayed FAFSA Rollout
December 12, 2023 - NASFAA sent a latter requesting the U.S. Department of Education (ED) reduce administrative burden on financial aid administrators during this final implementation phase of the FAFSA Simplification Act.
NASFAA Signs Letter Requesting Extension of Comment Period for Proposed Overtime Rule
October 12, 2023 - NASFAA, along with other higher education organizations, signed onto a letter to the Department of Labor requesting a 60-day extension to the comment period for a proposed overtime rule.
NASFAA Submits Comments to ED on Burdensome Information Collections
August 14, 2023 - NASFAA submitted comments to the U.S. Department of Education (ED) on identifying burden across ED's Information Collection Requests.
NASFAA Comments on Proposed Federal Work-Study Reporting
July 12, 2023 - NASFAA submitted comments to the U.S. Department of Education (ED) on ED’s proposed information collection on institutional reporting of Federal Work-Study (FWS) wages for Student Aid Index (SAI) calculation.
NASFAA Comments on Gainful Employment, Administrative Capability, Ability to Benefit
June 20, 2023 - NASFAA submitted comments to the Department of Education on its proposed rules forfinancial value transparency and gainful employment, financial responsibility, administrativecapability, certification procedures, and ability to benefit.
NASFAA Comments on Proposed Federal Work-Study Information Collection
May 15, 2023 - NASFAA submitted comments to the Department of Education (ED) on its proposed information collection for student work-study earnings.
NASFAA Submits Written Comments on ED’s Intent to Establish Negotiated Rulemaking
April 25, 2023 - NASFAA submitted written comments to ED in response to a recent notice of intent to establish a negotiated rulemaking committee to cover topics such as return to Title IV funds (R2T4), third-party servicers, accreditation, cash management, and more.
NASFAA Submits Comments on Updated Third-Party Servicer Guidance
March 30, 2023 - NASFAA questioned ED’s decision to change the regulatory definition of third-party servicer through guidance, and warned that the inclusion of so many new outside entities in the definition risks essential service providers leaving the marketplace.
NASFAA Signs Letter to ED on Third-Party Servicers
March 29, 2023 - NASFAA signed onto a letter to the Department of Education (ED) addressing the Dear Colleague Letter that outlines ED’s proposed expansion of the definition for when an outside contractor is a “third-party servicer."
NASFAA Comments on Proposed Low-Financial-Value Programs List
February 10, 2023 - NASFAA stressed in its response to ED’s request the need to tread carefully in light of the potential impact such a list could have on programs.
NASFAA Submits Comments to ED on Proposed New IDR Plan
February 10, 2023 - NASFAA acknowledged the need for a strong safety net for student loan borrowers but cautioned that back-end loan forgiveness should not be a substitute for up-front grants.
NASFAA Signs Letter to VA on Enrollment Management System Transition
December 13, 2022 - NASFAA signed on to a letter sent by the American Council on Education urging the Department Veterans Affairs (VA) to delay the transition to a new enrollment management system for certifying GI bill benefits. The Education Service announced earlier ...
NASFAA Submits Comments to FSA on Draft Strategic Plan
September 29, 2022 - On Wednesday NASFAA submitted comments to Federal Student Aid (FSA) Chief Operating Officer Richard Cordray on FSA’s Draft Strategic Plan for 2023-27.
NASFAA Letter to ED on Partnership Challenges
September 7, 2022 - NASFAA in a letter to both ED and FSA is calling on the department to meet with NASFAA’s leadership to better coordinate on partnership initiatives that will address ongoing operational challenges that are negatively impacting schools and students.
NASFAA Comments on ED Proposed Rule on Prison Education Programs, 90/10 Rule, Changes of Ownership
August 26, 2022 - NASFAA commended ED and negotiators on reaching consensus on prison education programs. Comments included several operational questions for all three topics proposed in the draft regulations.
NASFAA Signs Letter Urging the Department of Education to Extend PSLF Waiver
August 18, 2022 - NASFAA signed onto a letter urging Secretary Miguel Cardona to extend the Public Service Loan Forgiveness (PSLF) waiver, which expires in October.
NASFAA Comments on ED’s Affordability and Student Loans Regulatory Package
August 12, 2022 - NASFAA submitted comments to ED on its proposed regulatory changes to borrower defense to repayment; pre-dispute arbitration and class action waivers; student loan interest capitalization; loan discharges for total and permanent disability...
NASFAA Signs Brief Arguing That Race-Conscious Admissions Is Protected by the First Amendment
August 2, 2022 - NASFAA, along with 39 other higher education organizations, signed an amicus brief arguing that admissions officers considering race in college applications are protected by the First Amendment.
NASFAA Comments on ED's Datasets RFI
June 3, 2022 - NASFAA's comments on the request for information regarding datasets by the U.S. Department of Education, urging FSA to publicly share more available data at more predictable intervals.
NASFAA Joins Community Letter Raising Concerns Regarding Changes to 85-15 Rule
March 22, 2022 - NASFAA joined a letter along with more than a dozen organizations raising concerns regarding the Department of Veterans Affairs’ recent announcement of key changes to the 85-15 rule, specifically changes in the requirements for a 35% exemption.
NASFAA Submits Comments to ED on Proposed Changes to Quarterly HEERF Report
March 14, 2022 - NASFAA submitted comments to the Department of Education (ED) on Monday, March 14 on its proposed changes to the Higher Education Emergency Relief Fund (HEERF) Quarterly Budget and Expenditures Report (QBER)
NASFAA Urges Department of Education to Extend Verification Waiver
February 15, 2022 - NASFAA, NCAN, and TICAS in a letter to President Joe Biden requested that the Department of Education extend, for the 2022-23 award year, the verification waivers granted for the 2021-22 award year.
NASFAA Urges ED to Not Require Annual Student Loan Acknowledgment for All Schools
December 8, 2021 - In a letter to Department of Education (ED) Undersecretary James Kvaal this week, NASFAA asked the department to consider making the Annual Student Loan Acknowledgement (ASLA) available to institutions for voluntary adoption.
NASFAA Joins Higher Ed Stakeholders in Letter to ED on Resumption of Student Loan Repayment
November 17, 2021 - NASFAA has joined a group of higher education stakeholders in urging Education Secretary Miguel Cardona to provide more concrete details concerning the department’s efforts to seamlessly transition student loan borrowers back into repayment.
NASFAA Submits Comments to Negotiated Rulemaking Committee on 90/10 Rule
November 3, 2021 - NASFAA submitted comments to the Department of Education (ED) on Student Assistance General Provisions — Non-Title IV Revenue Requirements (90/10) in response to its recent notice announcing upcoming negotiated rulemaking on this topic.
NASFAA Submits Comments to ED on PSLF program
September 24, 2021 - In this letter response to a recent request for information from ED, NASFAA shared results of a recent survey of financial aid administrators who found Public Service Loan Forgiveness (PSLF) outreach, publicity, and communication to be inadequate.
Verification Letter to Department of Education
September 7, 2021 - Written on behalf of NASFAA and NCAN, this letter expresses disappointment in the Department of Education’s (ED) failure to extend, for the 2022-23 award year, the verification waivers granted in GEN-21-05 for the 2021-22 award year.
NASFAA Submits Comments on Revised HEERF Annual Data Collection Form
August 23, 2021 - NASFAA and NACUBO submitted joint comments to the Department of Education (ED) on its proposed revision to the Higher Education Emergency Relief Fund (HEERF) annual data collection form.
NASFAA Joins ACE in Submitting HEERF Annual Reporting Comments
August 23, 2021 - NASFAA joined ACE and several other higher education associations in a letter to the Department of Education this week on its proposed revision to the Higher Education Emergency Relief Fund (HEERF) annual data collection form.
NACUBO and NASFAA comments on FSA Sampling Request: 2021 Compliance Supplement
June 14, 2021 - NASFAA joined NACUBO in a letter to Federal Student Aid (FSA) Chief Operating Officer Richard Cordray regarding FSA’s proposed changes to the 2021 Office of Management and Budget (OMB) Compliance Supplement.
NASFAA Joins Effort Providing Recommendations for Transitioning Millions of Borrowers Back Into Repayment
March 16, 2021 - NASFAA joined a handful of other higher education groups in a letter to the Department of Education detailing recommendations so borrowers are smoothly and successfully transitioned back into repayment.
NASFAA, NCAN Urge ED to Implement Changes to FAFSA Swiftly
March 2, 2021 - NASFAA joined a letter with NCAN urging the Department of Education and newly appointed Education Secretary Miguel Cardona expressing the importance of implementing the changes made to the FAFSA in an efficient and timely manner.
Request for Meeting on Section 117 Reporting Requirements
February 11, 2021 - NASFAA joins a letter to Acting Education Secretary Philip Rosenfelt requesting a meeting to clarify the obligations of colleges and universities under Section 117 of the Higher Education Act, which deals with foreign gift and contract reporting.
NASFAA Joins Community Comments on Section 117
December 14, 2020 - NASFAA joined a group of higher ed associations in submitting comments & a legal memo. to ED in response to the notification of interpretation & request for comments on ED's enforcement authority for failure to adequately report under Section 117.
Higher Ed Groups Urge ED to Extend Repayment Relief Through Sept. 2021
November 2, 2020 - Amid the COVID-19 crisis, NASFAA, TICAS, and ACE sent a letter to ED Secretary Betsy DeVos urging the administration to extend borrower protection provisions.
NASFAA Urges Treasury, IRS to Ensure CARES Act Emergency Aid to Students Is Non-Taxable
April 16, 2020 - NASFAA joined NACUBO and other organizations in a letter to the Department of Treasury and the Internal Revenue Service, urging them to ensure emergency grant aid to students is treated as a non-taxable qualified disaster relief payment.
NASFAA Asks ED for Flexibility in Verification Due to COVID-19 Disruptions
April 3, 2020 - NASFAA joined NCAN and NACAC in a letter to the Department of Education (ED) asking for financial aid verification flexibility amid the coronavirus global pandemic.
NASFAA Responds to ED Request for Comment on Improving PSLF Application and Certification Forms
March 30, 2020 - NASFAA submitted comments to the Department of Education suggesting ways to improve the proposed combined Public Service Loan Forgiveness Application and Certification form.
Higher Education Community Urges ED to Delay Action on Foreign Gifts ICR During COVID-19 Outbreak
March 25, 2020 - NASFAA joined dozens of other organizations urging the Department of Education to delay any further action on the proposed Section 117 foreign gifts and contracts information collection request during the coronavirus outbreak.
NASFAA Urges Congress to Provide Relief to Student Loan Borrowers Amid Coronavirus Outbreak
March 20, 2020 - NASFAA joined the American Council on Education and the Institute for College Access and Success in a letter to lawmakers, urging them to provide immediate relief to student loan borrowers during the coronavirus outbreak.
NASFAA Joins Higher Education Community in Comments on ED Foreign Gift Reporting Requirements
March 12, 2020 - NASFAA signed on to a letter Wednesday commenting on the Department of Education’s (ED) proposed information collection request (ICR) for foreign gift reporting that it published in the Federal Register on February 10.
NASFAA Joins Other Organizations in Criticizing ED’s Foreign Gifts Reporting Guidance
November 7, 2019 - NASFAA, along with 29 other higher education organizations, on Tuesday signed on to a letter offering comments about the Department of Education’s (ED) proposed rules on foreign gift reporting requirements.
NASFAA Submits Letter of Support for Information Sharing Between DoD and ED
May 14, 2019 - NASFAA submitted comments in support of the Department of Defense's proposed systems modifications.
NASFAA Signs on to Letter on Proposed Changes to Public Charge Policy
December 11, 2018 - NASFAA joined more than two dozen other organizations in signing on to a letter sent to the Department of Homeland Security, raising concern over the proposed rule on inadmissibility of immigrants and non-immigrants on public charge grounds.
NASFAA, ACE Urge ED to Delay a Recall of Perkins Funds and Reimburse Cancellations
October 11, 2018 - NASFAA and the American Council on Education (ACE) wrote to the Department of Education (ED) last week urging it to publicly announce its intentions to resume reimbursing institutions for cancelled Perkins Loans, which it has failed to do since fisca...
NASFAA Submits Bankruptcy Comments
May 23, 2018 - NASFAA submitted comments to the Department of Education (ED) in response to a Request for Information concerning ED's guidance pertaining to student loan bankruptcy filings.
Higher Education Community Letter to DHS on Timely DACA Processing
April 13, 2018 - NASFAA joined a higher education community letter to the Department of Homeland Security to emphasize the importance of timely processing all DACA renewal applications.
NASFAA Submits Letter on PTAC Data-Sharing Guidance
March 9, 2018 - Last year, ED's Privacy and Technical Assistance Center released verbal guidance on the sharing of FAFSA data. This new guidance prohibits students from authorizing financial aid offices to release FAFSA information to approved entities.
NASFAA Urges ED to Resolve & Issue Privacy Guidance Quickly
November 17, 2017 - NASFAA, along with several partner organizations, sent a letter to the Department of Education (ED) about verbal guidance given by ED's Privacy and Technical Assistance Center (PTAC) that has upended many years of common practice.
NASFAA Submits Comments on Burdensome Regulations
September 19, 2017 - NAFSAA submitted to the Department of Education (ED) comments on areas of regulation that need revision, per a June 22 request in the Federal Register.
NASFAA Letter Encourages ED to Improve Efficiency, Accountability
August 4, 2017 - NASFAA in a letter sent on Friday encouraged the Department of Education (ED) to take steps to improve its efficiency, efficacy, and accountability with key stakeholders, including looking at new ways ED could engage with institutions and financial a
Higher Education Community Comments to the Agency Reform Taskforce
August 4, 2017 - NASFAA joined comments led by the American Council of Education submitted to the Department of Education's Agency Reform Taskforce in response to a request for feedback on how to improve ED's efficiency, effectiveness, and accountability.
NASFAA Requests Reprieve and Review of VONF Requirements, Data in Letter to ED
July 28, 2017 - NASFAA urged the Department of Education to press pause on the “burdensome” Internal Revenue Service (IRS) Verification of Nonfiling (VONF) requirements for independent students and families that do not file a federal tax return.
NASFAA Requests School, Borrower Protections in Perkins Wind Down
June 12, 2017 - NASFAA on June 12 sent a letter to the Department of Education asking for certain procedures to assist institutions and borrowers during the wind down of the Federal Perkins Loan Program.
NASFAA Submits Year-Round Pell Implementation Letter
May 5, 2017 - NASFAA, on May 5, submitted a letter to the Department of Education expressing support and excitement for the reinstatement of year-round Pell and offering assistance with the interpretation and implementation of the program.
NASFAA Urges ED to Restore DRT, Ease Administrative Burdens Caused by Outage
March 14, 2017 - NASFAA on Tuesday sent a letter to the Department of Education urging the Department to take immediate steps to ease application and verification burdens caused by the sudden outage of the IRS Data Retrieval Tool (DRT).
NASFAA Submits Comments to ED on PSLF Application and Revised Employer Certification Form
February 10, 2017 - NASFAA submitted comments to ED on its newly created Public Service Loan Forgiveness Application and revised Employer Certification Form.
NASFAA Requests Relief on Verification of Non-Filing Requirement
December 15, 2016 - NASFAA sent a letter requesting a waiver of the Verification of Non-Filing requirement for non tax filers who are selected for verification if the applicant does not meet the registration requirements for the IRS Get Transcript Online functionality.
NASFAA Sends Public Service Loan Forgiveness Letter to ED
October 25, 2016 - NASFAA sent a letter to the Department of Education requesting information about Public Service Loan Forgiveness (PSLF) and the number of borrowers expected to benefit from forgiveness of their remaining unpaid balances in 2017.
NASFAA Submits Comments on ED's Generic Clearance for Federal Student Aid Customer Satisfaction Surveys and Focus Groups
July 28, 2016 - This week, NASFAA submitted written comments to the Department of Education (ED) on its Generic Clearance for Federal Student Aid Customer Satisfaction Surveys and Focus Groups Master Plan.
NASFAA Comments to FCC on TCPA Rulemaking
June 21, 2016 - NASFAA submits comments to the FCC regarding rulemaking on a recent TCPA amendment regarding debt collection and autodialing.
NASFAA Letter Urges ED, White House, to Facilitate Burden Reduction
December 17, 2015 - NASFAA on December 16, 2015 sent a letter urging policymakers to allow institutions to redirect resources that may be freed up by burden reduction to best address the needs of their students.
NASFAA Joins NACUBO Letter to Halt Implementation of VA Tuition Offset Policy
April 9, 2012 - NASFAA joined NACUBO and 12 other associations in signing onto a letter urging the U.S. Department of Veterans Affairs (VA) to halt the reinstatement of a policy that would offset veteran debts against Post-9/11 G.I. Bill tuition and fee payments.
NASFAA Urges Action on Student Health Insurance Regulations
March 2, 2012 - NASFAA joined the American Council on Education (ACE) to urge the Department of Health and Human Services (HHS) to immediately issue the final version of student health insurance coverage regulations or delay the regulation.
NASFAA Letter to ED on 12 Semester Pell Grant Limit
February 23, 2012 - NASFAA President Justin Draeger urges Education Secretary Duncan to hold schools harmless for any inadvertent Pell Grant overpayments made to students who the Department of Education doesn't properly identify as having reached the new 12 semester ...
NASFAA Joins Higher Ed Groups to Oppose State Authorization Regulations
March 2, 2011 - NASFAA joined 60 other higher education associations and accrediting organizations to oppose the state authorization regulations included in the Oct. 29, 2010 final program integrity regulations.
Letter Opposing Federal Definition of a Credit Hour
February 18, 2011 - NASFAA joined more than 70 other higher education associations, including accreditors, to urge the U.S. Department of Education to rescind the federal definition of a credit hour included in the program integrity final regulations.
NASFAA Asks ED to Encourage Sufficient Resources for Aid Offices
August 5, 2010 - NASFAA writes U.S. Department of Education Undersecretary Martha Kanter to request assistance in ensuring campus financial aid offices have sufficient resources to effectively serve students.

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