Comments are Due Wednesday, September 23rd
Last week, the U.S. Department of Education (ED) proposed changes to its rules that would undermine community colleges’ ability to serve students using federal funds. The proposal includes changes to the rules for competitive and formula grants that community colleges receive directly from ED (such as TRIO, Strengthening Institutions Program, and Child Care Access Means Parents in School), and changes to the rules for State-administered formula grants that states pass through to community colleges (such as Perkins Career and Technical Education and Adult Basic Education (ABE) funds).
What Would the New Department of Education Rules Do?
The rules would allow discretionary grants to be terminated “for convenience.” In other words, a grant could be cancelled in the middle of a budget period at the whim of any administration. In addition, when a college has a multi-year grant, continuation of those grants would no longer receive priority over new grants, and decisions about whether a grant would be continued could occur at any time during the fiscal year (in other words, there could be a break in between the current grant period expiring and knowing whether or not you can continue the funded work).
The rules also would allow ED to prioritize applications that ask for lower - or no - indirect costs. Competitive preference points would be able to be given to applicants who either propose to use an indirect cost rate that is lower than their approved negotiated rate for their entire grant period or who use the de minimis indirect cost rate. This could put colleges that have fewer resources - such as many rural colleges - at a disadvantage.
The proposal would also add language restricting how grantees could select their project participants and their project staff – removing previous requirements that incentivized grantees to consider factors to ensure equity and a range of experiences and perspectives. In addition, all grantees would be required to demonstrate they have policies protecting freedom of speech, inquiry, and press.
For community colleges that get formula funds from their states, such as Perkins Career and Technical Education and Adult Basic Education (ABE) funds, compliance with Executive Orders would now be required, as it already is for competitive grants from the Department of Education.
Community colleges may also see additional criteria in grant applications that are aligned with workforce outcomes, and they will be provided more specific parameters for evidence requirements in grant proposals. Finally, the Department of Education would stop announcing grant competitions in the Federal Register so community college staff would need to monitor grants.gov as it does for other agency grant announcements.
It is critical that community colleges, trustees, and other stakeholders submit comments and talk to their members of Congress to explain the impact these proposals would have on being able to serve students and communities in a consistent and predictable way.
The comment deadline is Wednesday, September 23rd.
Take Action Now!
View the ACCT created sample comment template that your community college can customize with your individual circumstances and submit here.
Amanda Fuchs Miller is the President of Seventh Street Strategies
