NASFAA Submits Comments on Accreditation, Innovation, and Modernization NPRM
NASFAA is pleased to share its comments on the Department of Education's (ED) Accreditation, Innovation, and Modernization (AIM) Notice of Proposed Rulemaking (NPRM), which proposes changes to the regulations governing accrediting agencies.
NASFAA's comments focus on proposed §602.17(a)(3)(ii), which would require accrediting agencies to review an institution's practices and capabilities regarding the administration of student aid programs. NASFAA recommends that ED remove this provision, arguing that it exceeds the department's statutory authority, extends accreditor responsibility beyond the scope of accreditor expertise, and duplicates oversight functions that the Higher Education Act assigns to the Department of Education within the program integrity triad. The comments urge ED to apply its own deregulatory principles by eliminating a review that duplicates the department's existing oversight of Title IV administrative capability, rather than shifting that responsibility to accreditors.
In addition to these comments, NASFAA also signed onto a letter by the American Council on Education (ACE) responding to the proposed rule. The letter supports several provisions of the rule, including: flexibility for institutions to switch accreditors, expedited initial accreditation approval, and access to Title IV funds during arbitration and judicial review. These comments also raise concerns about new requirements, regulatory burden, institutional autonomy, and peer review. Additionally, the letter urges ED to allow for more time to conduct the negotiated rulemaking process.
Publication Date: 9/22/2026
