UPCEA Issues Comments on Proposed Negotiated Rulemaking September 2018
UPCEA recently commented on the vast undertaking of the rulemaking committee that was proposed by the Department of Education. We find that the proposed depth and breadth of the topics, and the amount of time provided to the committee, coupled with the complexity of those topics and the limited amount of seats at the table to be substantial. We believe this undertaking may be too weighty to truly seeking solutions to these complicated issues. A lack of consensus, as the Department knows, will default to the Department’s rewriting of the rules. Our first major recommendation would be that you break apart many or all of these 12 major issues into their own negotiated rulemaking committees, to provide the proper expertise, and deep analysis, time, and conversations that these complex and sensitive issues require.
Placing careful attention on protecting students from predatory practices should be the goal of many of the changes that are being considered, combined with protecting institutional autonomy and encouraging educational access and quality.
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UPCEA Policy Committee
Kristen Brown, University of Louisville, Chair
Bridget Beville, University of Phoenix
Corina Caraccioli, Loyola University New Orleans
Abram Hedtke, St. Cloud State University
George Irvine, University of Delaware
Craig Wilson, University of Arizona
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