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To Rep. McKeon on Title IV policies and practices

July 20, 2001

July 20, 2001

The Honorable Howard "Buck" McKeon
U.S. House of Representatives
2232 Rayburn House Office Building
Washington, DC 20515

Dear Mr. Chairman:

On behalf of the National Association of College and University Business Officers (NACUBO), I would like to thank you for your efforts to improve the federal student aid programs. NACUBO’s members, the chief financial and business officers, represent more than 2,100 colleges and universities. Our strong interest is derived from the business officer’s responsibility for managing the Title IV funds. We applaud your leadership for launching the Fed.Up initiative. NACUBO’s specific recommendations for improvements to the Title IV rules are enclosed.

For many years, we have commented on legislative and regulatory proposals, participated in negotiated rulemaking, and met with Department of Education officials on Title IV policies and practices. We have become increasingly disheartened by the expansion of the federal student aid regulations as well as the growth in complexity of the rules every campus faces. While the negotiated rulemaking process has vastly improved the quality of proposed rules issued by the Department of Education, the process needs further refinement. Key stakeholder groups need to be consulted prior to the promulgation of guidance, including preambles and other forms of subregulatory guidance.

The complex and unduly burdensome Title IV regulations need to be streamlined to help institutions effectively and efficiently manage the federal student aid programs. Regulating to the lowest common denominator is not the most productive way to manage these programs. We recognize the government’s need to protect the federal funds, but this must be balanced with an informed and reasoned approach to the regulated community. Given the diversity of colleges and universities, their missions and the students they serve, greater flexibility will enhance program administration and improve access for millions of low-income students.

NACUBO worked closely with the American Council on Education and other higher education associations on extensive comments detailing a number of suggestions. We strongly support the recommendations in the June 21st letter and concur with our colleagues that in addition to amending specific statutory and regulatory provisions, changes need to be made in the regulatory process.

We thank you for your leadership and commitment to improving the federal student aid program and reducing the regulatory burden on students and institutions. We look forward to working with you in seeking common sense solutions to bring about meaningful regulatory relief.


Christine E. Larger
Vice President, Public Policy and
Government Relations