U.S. DEPARTMENT OF EDUCATION
PUBLIC COMMENT COUNCIL EXCHANGE BOARD OF TRADE
DISTANCE EDUCATION AND INNOVATION Docket ID: ED-2018-OPE-0076-0845 Public Comment by the Council Exchange Board of Trade
Karl Cureton, Executive Chairman Council Exchange Board of Trade nmtc@council.exchange The purpose of these distance education and innovation regulations is to reduce barriers to innovation in the way institutions deliver educational materials and opportunities to students, and assess their knowledge and understanding, while providing reasonable safeguards to limit the risks to students and taxpayers.
DOCKET ID: ED-2018-OPE-0076-0845
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PUBLIC COMMENT
DISTANCE EDUCATION AND INNOVATION - INDUSTRY ADVISORY BOARD COUNCIL EXCHANGE BOARD OF TRADE SUBMITTED BY KARL CURETON EXECUTIVE CHAIRMAN
Comment on Proposed Regulation to provide
CEBOT is an employer organization focused on
flexibility to institutions to modify their
policies that drive evidence based outcomes. This
curriculum at the recommendations of
proposed change in regulation would converge the
industry advisory boards and without relying
needs of the employer and the needs of graduates
on a traditional faculty-led decision-making process: This public comment directly addresses and affirms the decisions made by the Secretary of the U.S. Department of Education (ED) to propose ruling to amend regulations issued under the Higher Education Act of 1965, as amended (HEA). The Secretary proposes to provide flexibility to institutions to modify their curriculum at the recommendations of industry advisory boards and without relying on a traditional faculty-led decisionmaking process. The Council Exchange Board of Trade (CEBOT) represents the now over 65,000 minority technology companies located in the U.S. doing business around the world. It is well documented that the information communications and technology industry (ICT) has a great demand for well trained employees.
who may be hired. It will also signal to Higher Education decision makers that ED is encouraging better communications with industry stakeholders that bring industry standards and industryrecognized credentialing into curriculum development practices. This becomes relevant when considering Title IV funding. "Title IV of the Higher Education Act (HEA) authorizes programs that provide financial aid to students to assist them in obtaining a postsecondary education at certain institutions of higher education (IHEs). These IHEs include public, private nonprofit, and proprietary institutions. For students attending such institutions to be able to receive Title IV assistance, an institution must meet basic criteria, including offeringat least one eligible program of education(e.g.,programs leading to a degree or preparing a student for gainful employment in a recognized occupation)." See (1) link below.
1. https://fas.org/sgp/crs/misc/R43159.pdf
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DOCKET ID: ED-2018-OPE-0076-0845
PUBLIC COMMENT
According to the above referenced Congressional
acceptance of transfer credits, use of prior learning
Research Report, "Institutional Eligibility for
assessment or other non-traditional methods of
Participation in Title IV Student Financial Aid
providing academic credit. The current regulation
Programs - Updated February 14, 2019" these Title IV
also does not address the internship or externship
requirements are intended to provide a balance
portion of a program. ED proposes to clarify that
between consumer protection, quality assurance,
institutions utilizing written arrangements may align
along with oversight and compliance in
or modify their curriculum in order to meet the
postsecondary education providers participating
recommendations or requirements of industry
in Title IV student aid programs. The amended HEA
advisory boards or industry-recognized credentialing
§ 668.5 to increase the institutional flexibility will
bodies.
allow institutions of higher education an opportunity to provide timely relevant educational
ED also proposes to clarify the calculation for
program offerings and allow institutions to modify
determining the percentage of the program that is
their curriculum at the recommendations of
provided by an ineligible institution or organization
industry advisory boards. This proposed ruling will
under § 668.5(c) in paragraph (g). The number of
also provide an opportunity for credentialing bodies
semester, trimester, or quarter credit hours, clock
like CEBOT an opportunity to augment the post-
hours, or the equivalent that are provided by the
secondary education process.
ineligible organization or organizations would be divided by the total number of semester, trimester,
Industry may be provided a financial incentive to
or quarter credit hours, clock hours, or the
participate in campaigns that may include
equivalent required for completion of the program.
marketing activities, such as the broad
A course would be considered to be provided by an
dissemination of informational brochures or the
ineligible institution or organization if the
collection of contact information. This activity can
contracted organization with which the institution
receive incentive compensation according to the
has a written arrangement has authority over the
Congressional Research Report. It is encouraging
design, administration, or instruction in the course.
that ED is focused on workforce readiness and there is a hope that IHEs consider how they augment their
CEBOT recognizes that this flexibility will allow IHEs
respective Program Participation Agreement (PPA).
an opportunity to better attract and retain students who are focused on becoming more attractive to
The current § 668.5 regulation establishes a
employers. Industry certifications and internships
framework for written arrangements between two
provide a valued experience for student participants
eligible institutions or written arrangements
and from CEBOT research studies technology
between an eligible institution and an ineligible
employers are more apt to hire graduates with
institution or organization to provide part of an
relevant work experience. CEBOT also concurs that
educational program. This section does not address
the proposed revisions to § 668.5 would better
workforce responsiveness or the methodology for
facilitate educational innovations and allow
calculating the portion of a program offered by an
institutions increased flexibility in partnering with
ineligible institution or organization.
entities to provide critical workforce training that may be beyond the capability of institutions to offer
Additionally, it does not address an institution's
on their own.
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DOCKET ID: ED-2018-OPE-0076-0845
PUBLIC COMMENT
CEBOT is an industry association that researches and implements solution-oriented initiatives grounded in a design-based research methodology. CEBOT is focused on increasing the number of cybersecurity professionals in the public and private sectors by leveraging the collective capabilities of minority technology companies, historically black colleges and universities, government agencies along with non-profit organizations and community partners.
Karl Cureton, Executive Chairman Council Exchange Board of Trade nmtc@council.exchange www.council.exchange