Washington Update: Higher Ed Policy, Regulations, and Insights:

Changing Higher Ed Podcast 182 with Host Dr. Drumm McNaughton and Guest Tom Netting

Transcript: Changing Higher Ed Podcast 182 with Host Dr. Drumm McNaughton and Guest Tom Netting

Drumm: Tom, welcome back to the show. It’s been far too long, my friend.

[00:00:04] Tom: Oh, it certainly has, and lots been going on, but Drumm, thanks for bringing me back. I’m happy to be here with you again.

[00:00:10] Drumm: Well, it’s really time for Washington Update because I’ll tell you, there are crazy things going on back in the Capitol, inside the Beltway and it’s spilling over into multiple States. But before we get there for the listeners who haven’t heard you on the show before, give us a little bit of background on who you are and where you got here.

[00:00:32] Tom: Sure. Tom Netting, an individual who’s been in higher education policy for over 30 years now. I started out on the side of accreditation for institutions of higher education. Leading into the ’92 reauthorization, I had visited over 100 schools. a national trade organization asked me to move over to become an advocate lobbyist, which I did headed into the ’92 reauthorization.

And it’s what I’ve now done as a passion for all of the ’92, ’98, 2008. And whenever we have our next reauthorization of the Higher Education Act, all of the negotiated rulemakings that have stemmed from the Higher Education Act, WIOA, and also any appropriations efforts that deal with higher ed policy.

[00:01:18] Drumm: It sounds to me you might know just a little bit about higher ed

[00:01:22] Tom: Maybe a little.

[00:01:23] Drumm: So. Well very good thank you. You know, every time we talk I learn new things from you which is fascinating for me always, and about your background I didn’t realize that you’d been involved with the HEA stuff for as long as you had.

[00:01:39] Tom: Yeah, it’s been a labor of love, but, yes, ’92 reauthorization forward, and one of the things that I hope we’ll talk about today is, the potential for at least introduction of some of the bills going into the next HEA reauthorization.

[00:01:52] Drumm: Well that would be really good because it’s been how many years since we reauthorized HEA?

[00:01:57] Tom: 2008, almost two full cycles beyond when it should have been.

[00:02:01] Drumm: And. We’ve had just a few things happen and change since then, haven’t we?

[00:02:09] Tom: Just a bit, you know, again, I think with distance education as well as a number of other things have changed quite considerably since that reauthorization, and, we’ve had two, like I said, two full cycles, 12 years of missed and we’re coming up on a third. So, yeah, there has been to be sure Drumm, as you well know, from some of our other conversations.

Yeah. There have been changes made specifically to the Higher Education Act 2019 with the FASFA Simplification Act, the last efforts of Senator Alexander before he left, not only the chairmanship, but the Hill. Which made significant changes to higher ed policy, and there have been other changes along the way, but in terms of a full review, comprehensive review, of the entire act and all of its titles, has not been done in quite some time, and there’s a need for it for everything from Title II and teacher education, Title IV and all the federal student financial aid issues, Title IX with campus security, and so much more.

[00:03:07] Drumm: Well, that’s a great segue into the regulatory front, because without the reauthorization of the HEA, it falls on the department and negotiating rulemaking to really make some determinations on what’s going to happen. So let’s jump right in on that.

[00:03:24] Tom: You couldn’t be more correct. Administrations on both sides of the aisle, when they’re in power have utilized their opportunities to look specifically at the regulations in lieu of statutory additional guidance and made changes. the Biden Harris administration has been very, very active and very busy and working from a negotiated rulemaking process that actually began back at the end of 2020. They preface it as their 2021 -2022 negotiated rulemaking, which brought us a whole set of regulations that went into effect this July 1st. Borrower defense to repayment, school closures and a number of other issues.

But more recently, they completed the second half, if you will, of those regulatory revisions, which included many, many key areas, of changes. One is a new set of oversight for all institutions of higher education deemed as financial value transparency, which is an offshoot, if you will, of the gainful employment regulations that are specific eligibility rules structured for private for-profit institutions and other portions of the higher education community with programs below the associate’s degree level.

[00:04:42] Drumm: So just so that I’ve got this right and everybody pretty much knows about gainful employment. So, this financial value transparency has been extended to all institutions. Is that correct?

[00:04:57] Tom: That’s correct. All institutions and their programs. This is again a major step towards consumer information and awareness of higher education by the Biden Harris administration. You now have essentially what they call the non-GE eligible entities and programs. Which are still going to be reviewed and have the same calculations and computations of their programs with respect to debt to earnings and with respect to the earnings potential of individuals graduating from those programs with respect to other individuals with only a high school diploma.

Or with only individuals with only other levels of educational attainment. What will be done is that information, while not impacting the future eligibility, will be part of a website very similar to or akin to what is right now, the scorecard or college navigator and probably be updated in house there. But this does present information to the consumer on all programs across all institutions for the first time in a way that may be a little different than what they’ve seen with the college scorecard and the navigator.

[00:06:13] Drumm: So, this is in effect now?

[00:06:16] Tom: This is in effect now, but will not become reality until July 1 of 2024. Keep in mind under the way in which regulations have to be developed under Title IV, they must be published in final form by November 1st of the preceding year, to go into effect July 1 of the subsequent year. Now, the reality of that, Drumm, is that it means that a lot of this information will only start to be calculated and brought forward next year.

So it’ll literally be 20 25 or 2026 before this data on all institutions and all programs starts to become publicly, of value and presented, but the eligibility criterion under gainful employment will start July 1 of next year for eligibility purposes and again, first assessment will be 2025 and then second assessment 2026.

[00:07:12] Drumm: Well, you and I have been talking back and forth for a long period of time I don’t want to say years, but it probably has been. About extending gainful employment to all institutions. It sounds like that’s exactly what is happening but the question i have is does this information have to be submitted to the department or is it just put it up on your website or a combination thereof.

[00:07:38] Tom: It’s a combination thereof. The department is the one responsible for doing the calculation. The presentation of the information on the department’s website will be their own. There are some responsibilities potentially for institutions that are the non-GE category to report some of this information to students under certain parameters.

Again, limitations on what those are all programs that are in the undergraduate level will not have to report these to their student populations, even if they have a fail, meaning they’re below one or the other of the triggers, but other entities and other institutions will. So there are some differences, obviously, between eligible or ineligible, but this is a half-step, Drumm, that really put the rest of the higher education community, that are not subject to the gainful employment eligibility criterion, on notice that there is still concern about the quality and benchmarks with regard to the use of federal funds for all institutions.

[00:08:41] Drumm: To me. It makes really good sense. In fact, I was just reading something in the wall street journal about education, go figure the journal, totally business, talking about education. I believe it was one of the former secretaries of the treasury he was talking about how higher ed needs more regulation to focus on outcomes and this sounds like, you know governance and outcomes, this sounds like a good step in that direction.

[00:09:12] Tom: Very well could be. Again, some people, it’s interesting you brought up outcomes, some people throughout the negotiations and through time immemorial have suggested that outcomes may be a better assessment than looking at the fiscal issues that are proposed under gainful employment. You also have to take into consideration many of the institutions across all sectors.

Wanted recognition for population served and other challenges. There are a number of characteristics that play into the educational programs themselves as well as the student populations that are attempting to enter into those programs. And there are programs that this doesn’t seem to fit real well with. Think of our teachers, think of our social workers, think of so many different groups of important, highly important educational programs that may never be the ones that are going to see a significant increase in their earnings based on their loan requirements when they were in school. But nevertheless, I’m certain nobody argues against wanting more quality teachers, nor any more quality health professionals to help us make it through so many different issues and including mental health issues and, as well as obviously physical. So, you know that there are a number of discussions around these proposals that have gone on for, literally over a decade, almost two now, and will continue as we look at these proposals.

But yes, the ability to have all programs at least start to take this into consideration and also outcomes, I think, is a very valuable step forward. I obviously have a little bit of a bias that as long as it’s all sectors and all institutions.

[00:10:59] Drumm: I agree I think that’s that is the right way to do it. Moving on, what else is going on the regulatory front.

[00:11:07] Tom: Well, we talked about a lot about the value, transparency and gainful employment. There was another whole large set of regulations that literally just barely met that master calendar deadline of November 1st, which included major changes to the financial responsibility, administrative capability, certification procedures, and ability to benefit regulations.

Now that’s a mouthful in and of itself.

[00:11:31] Drumm: I can’t say it again.

[00:11:33] Tom: But the regulations that are part of those four packages are equally as comprehensive and intense. The financial responsibility and administrative capability, as the names would imply, look at the overall health and structure of each institution, based on a number of triggers that, are all based not only around financial issues, but also around how the programs are functioning at an institution. The mandatory and discretionary triggers that the secretary has at her or his disposal, are important and they have beefed up those, specifically the department, and they’ve made reference to this on many occasions, have put a focus on concerns around institutions that could be getting closer to risk, or closer to closure.

So a lot of the regulations are designed to try and highlight sooner rather than later by the department, as well as accreditors and the states, the triad, the potential risk associated with a school closure or even in some instances, mergers and attempts potentially to move from one set of recognition criteria to another to alleviate opportunities for some of those regulations to be applied to them. From the department standpoint, moving from for profit to a nonprofit status is of concern to them. So they tightened up some of the requirements of “yes, you can still do that, but you’re not going to get out from under some of the prior regulatory overhangs until the complete transition is complete and you show us as well that the transition is a full transition and not a Potemkin village where you only see the front end, but not the back end.”

There are a number of other key changes that have been highlighted. One of them that is getting a great deal of focus is on what everybody’s now calling the “100 percent rule”. It’s a proposal under the program participation agreements where entities that are required by a state toprovide education for professional certification or licensure at a specific number of hours, clock hours, that they can only, they going forward starting July 1, 2024, if you are providing that program, you can only provide that program with Title IV eligibility, if you meet the exact number of hours. There was the ability to use what they called the “150 percent rule” where institutions could provide training beyond the stated goal or the stated number by the state, pardon the state comment, but it’s important to note that this has implications and consequences for many programs, not only in allied health, But certainly in beauty and wellness, as well as other types of programs. And the department did make some caveats for, if you’re on a border state, and you’re trying to grapple with two states with two different sets of hours, but this one’s caused a lot of problems and a lot of concerns. We still don’t know the full impact of it, but that’ll carry over in discussions about what’s happened legislatively when we get to that. Another major issue, crisis averted with regard to concerns around distance education and the N. C. Sarah reciprocity agreements.

[00:14:57] Drumm: Yeah. I wanted to get into that one.

[00:14:59] Tom: There was concern, that the reciprocity agreements would potentially be undermined by efforts within the regulatory regime to focus on, areas of consumer information and consumer protection. as well as issues around licensure and certification once again. Fortunately the department made it very clear that they are not intending to step on the toes of reciprocity agreements. So the work with N. C. Sarah is and the, hard work of those compacts and that overall compact and being a part of N. C. Sarah remains. There are still some issues around provision within N. C. The regulations that requires all online entities to either know and share which states they do or don’t have the ability for an individual to meet the state licensure requirements.

So that’s going to take some administrative burden, and there is, probably still not a lot of what most of the community would have liked in that area, but obviously it’s a give and take. There are so many others transcripts and the fact that now all institutions are required to provide transcripts to individuals upon request, and cannot withhold them for cash balances against the institution.

Another heavy focus on high school diplomas when an institution that or the department feels that there is rise to check the validity of the high school. Keep in mind that’s another caveat, so a lot of these are nuance that I can’t go into, or we’d spend the whole time just going through one issue at a time, but there’s a lot, there’s a lot of meat on those verbal regulatory bones that the institutions are now coming to grips with. As you can imagine, there’s a number of webinars being hosted by all of the national trade groups, as well as the department itself, to try and bring additional clarity to these provisions. And that will continue as we get into now through July 1 of next year.

[00:16:58] Drumm: Thank you for that quick wrap up. That was very good. I’m glad we had a chance to unpack that just a little bit. I do want to get into one other regulatory thing. A lot of news has been out there with respect to Title IX and 1st. So it’s not going to be in the, in the federal register.

[00:17:19] Tom: Hold on. Not true. Not true. Title IX, by its very statement, Title IX is not Title IV. Only Title IV regulations are subject to the Master Calendar.

[00:17:29] Drumm: Oh, I

[00:17:30] Tom: So the Title IX regulations do go into effect. again, therein lies one of the significant differences. So, the changes that are being brought about by Title IX, will go into effect, once published in the Federal Register in their final form.

That’s why you see continued focus on not only those that have already come out, but the huge comprehensive package that everybody is waiting and working towards as well and actions being taken by Congress around those particular provisions, yet again as well.

[00:18:03] Drumm: That’s interesting. So i’m guessing and you know just for my own clarification edification Title IV is about funding, so the publishing in the Federal register Is that because of the funding aspect of it?

[00:18:18] Tom: No, it’s because all government regulations have to be published in their final form as part of just the overall process. but there are distinctions and differences. Yes. Title IV, as it’s referred to, is where all of the Federal administration of the grants and loan programs resides within the Higher Education Act.

Title II is teacher education and training. So you have a lot of the issues there. You have Titles V, VI, and VII that speaks specifically to, other aspects of grant and assistance for the HBCUs, the Hispanic minority serving institutions and others. And then obviously Title IX, which speaks to everything from athletics, major tip of the hat to the protections for women’s in sports, as well as all of the campus security proposals. And it’s that Title IX bill that has all of the changes that have already come about with regards to LBGT Q plus communities. But now we’re waiting on the major set of revisions for all of the Issues related to bullying, cyber bullying, as well as the multitude of other protections for various different communities based on race, gender, and so many other issues, and truly just the basic campus protections of everything from fire to other issues.

[00:19:38] Drumm: Are you hearing major changes are going to happen. I know you’ve got your ear to the pulse on this one.

[00:19:44] Tom: Absolutely. Again, one of the pendulum swings is always around some of the issues around Title IX, in particular the concerns about protection for victims of rape and assault and other types of horrific circumstances, as well as the protection for the accused and that process. And there are differences of opinions and with regards tothe level and type of protection for both sides. There are areas of agreement, like you don’t want those individuals in the same classroom, but how do you determine and make sure that the campus life of one or both individuals is not mitigated by proximity to the other. So there are a lot of real things and real hearty issues that have been addressed under Title IX multiple times, and as different administrations come in, they like to look at those and, back to that pendulum swing, it seems that under Democrats that the rights of the accuser are put first and foremost. When it is under Republican control the rights of the accused are sometimes given greater deference than the accuser group would like. So trying to find that balance, and I’m being obviously overly broad in putting those two groups in different pockets because obviously people have their own opinions, but overall, that’s the way it seems to break down. And so the pendulum swings when the administrations swing.

[00:21:20] Drumm: Well, it’s just like the whole communications issue around the Israel Hamas conflict. It doesn’t matter what you say, you’re always going to have somebody angry at you.

[00:21:31] Tom: Well, and I try and walk that fine line, but yes, unfortunately, it does seem like, we’re picking sides no matter what we say these days. And that’s as a personal aside is unfortunate because as a lobbyist, you’d like to think, or and I think in my brain, what I want to work towards is resolution of things regardless of sides and try and find the middle ground that works towards the best possible solution. So again, sorry for the aside. One more thing on the regulatory front, Drumm, before we potentially move over to the legislative side and more of that polarization to a great degree. One of the things the department did host yesterday was a organizational webinar that shared with lead organizations the fact that they are getting very close to putting forward the 2024 2025 awards year FAFSA. The application documentation that all schools across all sectors have been waiting for, for quite some time. The department had said that they had hoped to have it out by early December, it was originally supposed to come out in the past in June or July, but because of changes to the FASFA simplification law, in 2019 that fully implemented this year, it’s taken a while to make the form what it needs to be. It will be out for all institutions by December 31st, so obviously all schools will be looking for that and the department believe they’ve made a lot of changes in the update that I was privy to yesterday. It does look like it will be worth the wait in terms of a lot of what they have done with the form, with the back end to the form, and the processing and the like. So, when next we talk, hopefully that will either be eminent or already in the hands of students as well as the schools and processing aid for individuals moving into next year.

[00:23:20] Drumm: Let’s, let’s hope that it isn’t as bad a rollout as it was for Obamacare.

[00:23:24] Tom: That’s one of the things that they actually discussed in general form and they believe they have it on lockdown quite well.

[00:23:31] Drumm: Good. Good. Swapping sides of the the DC Capital area. Let’s move to the Hill. What’s going on up there?

[00:23:40] Tom: Nothing. It’s been really quiet up there.

[00:23:43] Drumm: Oh good. Well, I guess we can wrap up then

[00:23:46] Tom: I hope you detected the sarcasm in that statement.

[00:23:48] Drumm: Oh, yes.

[00:23:50] Tom: So much. Let’s start with a real quick encapsulation of just this week. Back to, unfortunately, the war the Palestinian organizations of Hamas. There were two hearings this week alone on how to protect students on our campuses across the country. When we have individuals on both sides, but predominantly a focus in the hearings was on, Palestinian statements and, potential harm of, Israeli Jewish individuals. We saw a number of circumstances on college campuses that were noted where individuals of the Jewish community were literally having to hide and sequester in places for fear of life. Or other options of concern. So there’s movement on Capitol Hill to try and see what can be done to address that. and it’s a focus of the HEA reauthorization as well. One of the things that I’ll talk about here in a minute when I talk about the six areas of HEA, focus that the House is going to be moving forward on some legislation.

One of them is foreign influence, and part of both of those hearings was directly related to whether or not some of the Palestinian groups have targeted the opportunity to utilize campus settings, to fund, opportunities to, promote anti Semitism. And there is a growing concern that on both sides, we need to make better care and comfort, with regard to how the FBI and others, as well as the school themselves, monitor, I don’t want to use the word police, but monitor, the efforts of our college campuses and the organizations that are on them. While at the same time, recognizing and appreciating the fact that our college campuses have always been a bastion for the ability for individuals to learn and, be exposed to new things. Obviously they are balancing the desire for those opportunities with also the protection of the students and the belief, and then again, that harm is not part of any groups, or shouldn’t be a part of any groups, community, much less the schools.

In the broader context, appropriations is on the forefront. We witnessed this week the prevention of the shutdown that would have been today as we look at this on a Friday. And the ability for that legislation to be moved forward. And at the same time, they are working on the individual appropriations bills for the fiscal year that began, October 1st.

[00:26:23] Drumm: So what else, what else is new?

[00:26:25] Tom: Time immemorial.

Yeah, Congress hasn’t seemed to hit those deadlines for literally a decade now. But within those, there are some key important issues, not only the establishment of the maximum PELL, other grant programs, the interest rate for student loans and the like. But more and more there have also been the additions of what they call riders. Which are, attempts to legislate on an appropriations bill or, prevent the use of funds on an appropriation bill is more apt. Several of those that were brought forward in the House, discussions of the higher ed bill, which is labor, health and human services and education, all of education. It’s the huge domestic bill that is focused on every year. But within higher ed, there were several key amendments, what they call the Confucius Amendment, which going back to foreign influence, is the attempts to prevent, the federal government and others from China and elsewhere from impacting influencing our college campuses here in the United States.

There were other provisions that dealt specifically with issues around those regulations that we just talked about. There was a provision that was brought forward by Burgess Owens, as the subcommittee chairman on higher ed in the workforce, to prevent the 90-10 rule that went into effect July 1st of this year. Part of that regulatory package that was done last year, from being forwarded. It got to the rules committee in the House where they decided not to make it an order. Part of the reason for that was, as I understand it, because of the scoring, the financial scoring associated with it. And also, matters of timing.

So that proposal specifically related to the proprietary community didn’t get through. A proposal broader, for all communities, was the issue related to that 100 percent rule that I was alluding to earlier. Provision was brought forward by Lloyd Smucker from Pennsylvania, at the behest of many different groups, but specifically, education with regards to allied health and more specifically, even to beauty and wellness. I know the individuals that actually brought it forward on behalf of their students and then their state and it moved from there, but that provision made it through the rules committee and actually was supported by voice vote where it would prohibit if it were made final law,to have the Department of Education implement that 100 percent rule. Now, the reality was, that provision got through, and before they even got to vote on the final bill, the House had slated two other appropriations bills for final votes on final passage. Neither one of those happened, because Republicans on their own side of the aisle, used the votes on those two bills to show their frustration with the passage of the broader continuing resolution, which protects the federal government from closure between now and January and February based on the ladder approach. Long winded way of saying that they literally pulled the labor HHS and education appropriations bills from the floor, having completed the negotiations on it, because they didn’t want another appropriations bill going down to defeat on the House floor by their own party.

So as we sit here,that bill is now awaiting potential consideration after Thanksgiving. We’ll see what happens. It would still have to go through the Senate and obviously the Democratic controlled Senate has other views and other opinions, not likely to be accepting of either of those provisions probably will be of the foreign provisions with regard to Confucius institutions, but we’ll have to wait and see. A long winded way of saying that there is still a great deal of tumult around the fiscal bills in both the House and the Senate and with the pushback on the continuing resolution to January and February, we will continue to see that play out over at least the next 2 to 3 months.

[00:30:30] Drumm: So let’s quickly, cause we’re running out of time. Let’s quickly touch on the, the six bills for the HEA. You know, Instead of doing a omnibus, they’re putting them piecemeal out there, which in today’s climate we are, probably make sense. Let’s go through those quickly.

[00:30:48] Tom: Sure. real quick. And again, we owe the Workforce Innovation and Opportunity Act is also being constructed by the House committee. You will likely see that comprehensive, one single comprehensive bill, come out before the end of the year. But at the same time, Dr Fox, as well as Mr. Owens, the subcommittee chairman, Dr Fox, the full committee chairwoman for the education and the workforce committee. Have notified everybody that they’re looking to move portions of the HEA, for the reasons that we already discussed. It’s been way too long since many of the important issues within the Higher Education Act have had a retooling or an update. Which is hence what reauthorizations are supposed to be all about.

So they’ve noticed the communities that there’s going to be essentially six different bills. The first one, as I alluded to earlier, is, foreign, intervention. the second one is Title II. Obviously, Title II, as I said earlier, is teaching and all of the issues around teaching. The third is on student loans. That is a comprehensive chunk in and of itself, not, you know, Title IV will be part of that, but there’s also other parts of it that will come in other of the silos that I’m going to allude to or the bills that I’m going to allude to. But under student loans, you can rest assure the discussions around one loan, for, income based repayment and one loan for using the normal customary repayment options are things that the Republicans have proposed in the past. there will be, I think, modifications to that. How we address interest rates, how we address repayment, all will be part of that, as well as the administration and delivery, because keep in mind, there’s A lot of concern about as we transition back to loan repayments, what the department is doing and what, in some people’s views, the department is not doing, to protect and make that transition, once again, hopefully as smooth as possible, while protecting borrowers, but also protecting the federal fiscal interest.

There will be another whole, proposal on institutional accountability and focused on issues related to everything from, as you would imagine, accreditation, those outcomes, notions that you discussed and we discussed earlier, with regard to educational delivery. I think will be paramount to that, as will risk sharing, the Republicans are thinking very highly of the responsibility of institutions with fiscal issues. And then the others are, one on campus safety, so again, Title IX. Another on workforce and innovation, as the name would imply, that’s where I think you’re going to see the short term PELL proposal discussed and other issues around, again, providing new opportunities for distance education and the ways in which that delivery mechanism goes.

So we’ve got multiple bills getting ready to come out, staggered over the course of probably the remainder of this year and into next year. All of which will be subject to the reviews of all the communities. The reality is, to be, to put a bow on this, is that while they may get through the House floor, they’re probably not going to go much further than that with a Democratic Senate. But they’re looking to put some markers down and they’re also looking to put some legislation out that they believe is the focus of where higher ed should be going moving forward.

[00:34:04] Drumm: Well as as always it is jam packed whenever we have a chance to chat and we’ve said we need to do this every three months and I think we need to schedule that to do it three months because there’s just way too much to talk about.

[00:34:18] Tom: Yeah, and I probably missed half of the things that I was hoping to cover, but, you know, again, I hope I touched on enough.

[00:34:24] Drumm: Oh very much so thank you. Three takeaways the president’s need to you know just keep on their radar at this point

[00:34:32] Tom: I’m going to go off script on one of these, but it’s been one that I’ve had concerns about before, cyber security. You, as institutions, are responsible for the FTC safeguard rules that have gone into effect. There are additional changes that are going to be promoted by the Department of Education. Work please, please, please with your it departments to make sure that you are on top of all of the IT requirements of these various groups. It is much more expansive than it was under just the original Graham Leach Bliley Act. That’s number one. Number two, take very seriously all of these regulatory changes and spend some time with your financial aid departments and others looking at the implications for, in particular, the most recent proposals that have been put forward with regard to financial responsibility and administrative capability. They impact all institutions, not just subsets of institutions. And last but not least, when the Title IX regulations come out, obviously, we will all be having to look in greater detail at what is there.

 Real quick bonus one, we are watching very carefully the efforts of the department under borrower defense to repayment. All institutions are starting to see more borrower defense to repayment claims. When you receive a notice from the department that you have claims, take the opportunity, even though they say it is at your leisure or at your will, to do a review of each of those individual students proposals or claims. Don’t take that lightly. Do the review. Make sure that you know, the substance of those claims, because some of them may not be as substantial as others.

[00:36:10] Drumm: Tom, that’s great, that’s a great list thank you. What’s next for you other than you know the usual?

[00:36:18] Tom: Just time on task. Again, a lot of these bills are, you know me, I’m a wonk, so I’m looking forward to, as funny as that may sound for some, seeing what the Republicans are going to put forward, having had discussions with both Democrats and Republicans, as all of these proposals continue to go through, and also looking not only to the conclusion next month of the debt relief negotiations, providing additional waivers for the secretary, but also the new rounds of negotiated rulemaking coming next year that will focus on R2T4, return of Title IV funds, cash management, as well as accreditation, state authorization, and a couple of other issues as well.

So it’s never a dull moment, Drumm.

[00:37:01] Drumm: I, yeah, definitely not a dull moment. Tom, thanks so much for being on the show, it’s been great to have you back and now let’s not make it quite so long next time

[00:37:11] Tom: Right there with you, and again, thank you so much for the opportunity to share with you and with your vast membership. and I’m here any time my friend,

[00:37:19] Drumm: Sounds good. Take care, brother.

[00:37:21] Tom: You too.