DISTANCE EDUCATION AND INNOVATION - INDUSTRY ADVISORY BOARD - ED CEBOT Public Comment

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