Negotiated Rulemaking Public Hearing Afternoon Session April 28, 2025

Good afternoon. Welcome back from lunch. We'll get right started with our next comment. As a reminder, please come up to the podium. Give your name your affiliation. And then I'll let you know you have 3ÿmin. Pers you. Is it, is it on? There we go. Okay. You have 3ÿmin. Thank you. Good afternoon. My name is Persis You and I'm the deputy executive director and managing council of student bar protection center. We stand in strong opposition to the Trump administration's attempt to implement project 2,025. Which calls for gutting and comparing payment options and eliminating public service loan forgiveness. Let's be clear. The Trump administration's assault on IDR and yes left isn't reform. It's retaliation. These actions would force nurses, features, veterans, and others who have dedicated their careers to serve our communities. To choose between pain their monthly student loan bills and putting food on their table. Borrowers everywhere would be prepared further into debt while relief is pushed further out of reach. Congress passed the income pension repayment statute with a clear goal to prevent student debt from becoming a life sentence. Despite attempts by right wing groups to rewrite history, it is clear that Congress intended ICR to include cancellation after no more than 25 years. For 30 years, administrations of both parties have refined protections to keep ours out of delinquency, default, and a lifetime of death. But for too long, government mismanagement and student loan industry abuses made existing IDR options more of a debt trap, allowing balances to balloon and failing to provide the financial relief borrowers need. These historic failures led the Biden administration to create the saving on a valuable education plan. I proudly served as a primary legal aid negotiator on the rulemaking committee, which created the safe plan. Joining these negotiations, borrowers provided heartbreaking testimony about the inability to afford the rent, pay for critical medical care, and cover other basic necessities. The resulting safe plan with proponents of project, 2,000, and 25 is too generous, was pegged to the amount it would reduce food insecurity. It would cut monthly payments in half for many borrowers, protected borrowers from runaway balances. An expedited debt relief for borrowers with low balances. Student loan delinquencies are now skyrocketing with nearly 4 million bars behind on their own payments. But instead of defending affordable payment options, this administration has forced millions in to remain in economic limbo. As borrowers face, a looming default cliff. This administration plans to start ripping vital social security benefits from millions of seniors and bars with disabilities. Instead of helping millions of bars who have been failed by this broken student loan system, it's eliminating what few safeguards exist to help them. Instead of strengthening public service loan forgiveness and ensuring public service workers, get the relief they are entitled to, this administration plans to illegally weapon Yes, in order to publish public service workers employed at organizations. We're engaged in work that is not in line with President Trump's agenda. These efforts will ultimately threaten critical public service fields and harm our most vulnerable communities. 20 second. For these reasons, we strongly oppose any efforts that would force working families to pay even more on their monthly student loan bills and deprive borrowers of critical cancellation. Thank you for your comment. Daniel Carter. Good afternoon. Good afternoon. My name is S. Daniel Carter, President of Safe Campuses LLC, a campus safety consultant from Georgia. With 3 decades of experience in campus safety and security, I am grateful for the opportunity to speak today about the CLERY Act regulations and their vital role in protecting students and ensuring institutional accountability. For context the CLERY Act is a federal law under Title 4 of the Higher Education Act. It requires colleges and universities to report campus crime data, maintain security policies, and alert the campus community about ongoing threats. This includes issuing annual security reports, keeping a daily crime log and providing timely warnings, measures that promote transparency and safety on campuses nationwide and protect taxpayer investment. The CLERY EGG regulations provide critical clarity that enable institutions to meet their statutory obligations effectively. For instance, they defined key terms like campus security authority. Interpretations that are not arbitrary but necessary to implement the statutes broad mandates. They also detail how to compile crime statistics and maintain logs, ensuring consistent, accurate reporting across institutions. If the department is considering evaluating these regulations, I urge cost. The regulations are essential tools for compliance carefully aligned with the statute's purpose. It would be prudent to differ any evaluation and to looking receive the thorough thoughtful attention it deserves. Campus safety is a nuanced and dynamic issue and rust changes could create confusion. Finally, if the department opts for negotiated rulemaking on CLERY Act issues, I strongly recommend including relevant practitioners and experts as non-f Federal negotiators. Campus safety professionals compliance officers and victim advocates bring invaluable real-world insights. Having served as a non federal negotiator 3 times, 1999, 2,009, 2,014. I can attest that this collaborative process mandated by the Higher Education Act encourages, ensures regulations are practical, effective, and responsive to institutional challenges. Closing. The CLERY Act regulations are indispensable tools for compliance and safe. They are not mere additions but necessary implementations of the statute's framework. Developed for a collaborative, expert informed process. Any review should be measured, prioritizing clarity, caution, and collaboration to preserve their effectiveness. I encourage the department to uphold these principles and address these critical issues. Thank you for your time. And one last note, I would second the request of the gentleman earlier outside the negotiated rule making process for some clarity on the timelines for the Stop Campus H. Thank you. Thank you for your comment. Elizabeth Tang. We have 3ÿmin. Hi, my name is Elizabeth Tang and I'm here to ask you not to make any changes that undermine or cancel critical programs. Like public service loan forgiveness and income driven repayment, including pay as you are. I'm a child of immigrants. I was lucky enough to receive both merit and need-based scholarships to attend college. After college, I spent 2 years working at a nonprofit advocating against gender-based violence in India, earning a salary of $15 in total over those 2 years. When I returned to the US and started a duel to read program, including a law degree, I had to take out more than $300 in federal loans to pay for it. Since graduating. I've been practicing as a civil rights attorney at a nonprofit organization advocating on behalf of survivors of gender based violence. My work has included educating students and workers about their rights. Advocating for stronger laws and regulations against gender-based violence, including here at the Department of Education. And litigation against schools and government bodies that violate those rights. I could not have done any of this work without IVR and the promise of PSLA. When I started my career, my salary was $50,000 a year, despite having 3 degrees, including 2 advanced degrees. IDR was allowed me to afford to live in DC at all. Today I've made nearly 90 payments toward the 120 payments required for loan cancellation under PSLS. Yeah, my total balance remains over $300,000 and in fact it's only increased. There's simply no way I could ever pay this off without IDR. My economic security and that of my future child was due in July. Depends critically on the continued existence of IDR and PSLF. Now it is true I could switch to a corporate lodge off with an astronomically higher salary, helping corporations accumulate more profit. But I have no desire to do so. I know that my wife on passion is fighting systemic injustice for people who live at the margins of society. At the same time, I know the SIRK reality is that if the department or Congress chooses to gut IDR, I will not be able to afford to pay 50% or 70% of my take home pay toward my student loan. And if you were Congress decides that you got TSLF, I will be locked in a catastrophic lifetime cycle of debt. That will drastically limit and for close choices and possibilities not only for me but also for my future child. And this is the case for millions of students across the country. I remember in college how 1 billion dollar corporations avidly recruited on campus. I too explore, but ultimately rejected one of these high paying jobs. But today a full 50% of my college is graduating class will take lucrative careers in finance consulting and technology. And 74% of my law school will take a lucrative career at a corporate law firm. Less than 11% of my law school would choose public interest. That number will only plummet further if you take away IDR and PSLS. How do you and PSL are not just programs that support the livelihood of public interest workers like myself. They're also investments in our nation's public interest programs, public education, lifesaving healthcare, pro bono legal services, and other vital programs that serve millions of people across these seconds. Preserving IDR and PSLA. It's far bigger than the people testifying in this room today. It is about investing in the future sustainability and vitality of this country. It is undeniably a moral decision and I hope you make the right one. Thank you. Thank you for your comments. Clinton walls. Hi. My name is Clint. 20ÿmin. Thanks. I'm Dr. Quentin Walls. I have no fancy affiliation aside from just being a student loan borrower who has over half a million dollars in student loan debt and 9 years and 8 months into the PSLF program. So. If we look back at this in 1,965, the original HGA passed. And out of that we got GBL, which in the 90 developed into FFPL, which would be scrapped for the FDLP and under all these repayment programs, we got IVR and then we got the broader based IDR, which had pay and then had repay and has ICR and then say repay turned into save and now save doesn't exist basically. Anyway, we got this out of its soup and my idea on or my opinion on all of this is that The student loan system has become very fragmented and I can as a physician who works in hospitals and I'm used to HCAPS and HIPAA and and all of the alphabet soup of that world. I appreciate the effort to try to reform this world. I appreciate the effort to try to reform this to streamline things. But the simple I kind of feel like we look at this whole situation here. After 6 decades of this process. We come to a pretty good. Program in the 2010. Pay was working well. The powers that be that could have challenged the repayment terms under pay did not choose to do so and actually that's not past the statute of limitations. Repay was created just the back fill in an arbitrary cutoff date that was created under pay and essentially had very similar terms, 90% of the terms were similar. And that was kind of trucking along fine until prior administration decided to rock the vote. And I'm not here to talk about prior administration rocking the boat, but I feel like moving forward, you're looking for solutions. I feel like if we look at what was previously created. You could, there's an opportunity here to. Create an a unified repayment plan that would apply to everyone that takes the best of the terms of pay and repay that we're not challenged, a 10% cap on discretionary income for the payment amount. You could look at what Congress passed with IVR that said that a 25 year repayment term would be the max. Combine those things, make it apply to all borrowers, and you have a very simple, straightforward. Every borrower knows what they're getting themselves into. Every bower is eligible for the same thing, kind of program, which hopefully is what you're looking to do. The only other thing I would say is public service loan forgiveness. If I'm being honest, I think it should be outside the scope of. What's being considered right now because it was created by an act of Congress and by being created by an act of Congress, executive action and the action of the Department of Education should not be able to modify that. And a lot of people have been relying on that for a decade of their lives like myself. Thank you for your time. Thank you for your comments. Matiana Nichols. Marilyn Hammer. You have 3ÿmin. Thank you. My name is Marylyn Hammer and I'm the president CEO of Champion College Solutions, Champion Empowerment Institute and champion for success. And my passion for this industry comes from growing up in an abusive home in Montana where it was pretty rough and I figured out early on that education was my ticket to freedom. And so I, enrolled in classes, advanced classes early on, and I graduated from college when I was 19 years old. And that allowed me to break away from the generations of abuse that had gone in my family. And in 1988, January, I was hired as 1st full-time default manager in the history of the country. The 1st language about default management was Appendix D and that was written by me with some of the Department of Education officials. And that was mandatory. Language from 1989 to 1996. When it was rewritten and just sub part in. I was one of the negotiators I've negotiated many times and I've helped to contribute to every higher education loss since 1,988. So I have extensive knowledge of the business. My oldest company is 35 years old and we've been to the top management for 35 years. So during that time. What I have discovered is that there's basically 3 categories of people who either pay or default. There's a percentage that will always pay. There's a percentage that will never pay. And then there's a big bucket in between. And those are the people where we can make a difference. Those are the people that just need some extra hand holding. And based on the, criterion for. Qualifying for these loans. The more, the more you qualify, the lower the income and they often come from welfare recipient backgrounds where nobody's ever had a checking account. And so what what's happened over the years is complexity is the enemy of execution. And it's become way too complex for most of the people who qualify for the biggest amounts of loans. So that's something that I feel that we can address. The solutions and repayment should reduce the debt. Which has been a huge problem. It should support higher education and it should empower people who otherwise would never have a chance to build a credit. Portfolio that can truly change somebody's life not just in student loans but in what it can do for them down the road when they have a credit file. So the components of it that are important are that it must be affordable. And that's the most complex part of this is what is affordable. So you have to take into consideration. 20 seconds if the payments are affordable, if it pays down the principal and if there's, if the loan forgiveness is affordable. And so I think through a combination of changing what we have, incorporating more of the standard repayment program where there's where it's predictable, we can get there time. Thank you. Thank you. For your comments. Melissa Byrne. Hi, my name's Liz. I'm going to be the 45 million. I am a borrower and I'm here today because There's a bunch of billionaires in America including Linda who is at this agency who lied to everybody about a golden age in America but really they just like a guild of Asian America. We're not here today because you guys actually want to help borrowers to hear because people like James care more about. Loan companies and the people that are profiting off us. You don't care about the fact that they've been defunding higher education for the last 40, 50 years so that we have a loan based system as opposed to a free higher education system that's public. So we're here because you guys want to hurt. Borrowers, you want to hurt future students and I think that's despicable. There's nothing American about coming here and saying like we're gonna hurt you and we're gonna harm you. The best you guys could do for student loan years is nothing. If you just kept things as status quo, we can hopefully in 4 years be able to clean up the mess that you and your doge rows are doing to people. And it's disgusting and it's horrible. Right now you fired the people that could actually help student loan borrowers. And for some reason, you've kept around other people who don't want to actually help borrowers. And you all, people like James on the outside who are on the outside the last 4 years. You brought it all the way to the Supreme Court over the contract for Mohila to harm borrowers and all of a sudden now you just slash contracts every single day as if there's nothing to do with contracts. So let's be clear what you guys care about today is hurting borrowers is burning down the American dream because you would rather kids who are born poor and middle class wipe the stews and people that are born of fluent. Wipe the rings of Linda McMea. It is time for these billionaires. Just to go flow on their yachts in the Mediterranean and leave. The workings of America to people who actually care about each other and it is shameful and anybody here who works to hurt student loan borrowers. Hey on you. Game on everybody who wants to hurt borrowers per students, families. And I hope every single day of your lives you feel guilt and shame for hurting everybody. And you have a chance today to leave here after listening to borrowers and say, you know what, the Doge Road, Elon, Trump, they're all full of fit and I'm gonna turn my life around and I'm gonna help borrowers. I'm gonna help students. Or you can choose to say buck Americans, we're just going to help the few become super wealthier than they already are. Get on a rocket ship with Elon and go to Mars second. And so in closing, literally just do nothing for the next 3 and a half years. That's the best you can do for borrowers. Otherwise, just know. Thank you. For your comments. Amelia Marcado. Hello. My name is Amelia Ricotto. I am a 30 year medical student at Baylor College of Medicine in Houston. Currently and turning with the American College of Physicians in DC. Thank you for this opportunity to speak about PSLF today. Like many students, I research financial aid options before curriculum or faculty to student ratios. When applying to medical school and this approach helped me secure full tuition scholarship at Baylor. They'll still graduate with that from living expenses. I am incredibly lucky though. Many of my classmates from undergrad had to accept their only admission offer from medical schools charging over $70,000 annually, accumulating over $280,000 in tuition debt alone. And these costs are unfortunately changing medicine. A 2,023 survey found that one in 4 medical students consider quitting and 61% plan to pursue careers that do not involve patient care. For those that remain, many choose lucrative specialties or wealthy areas just to manage debt. I'm avoiding public institutions entirely. Rural families, working-class communities and veterans suffer as a result. The PSLO provides that critical bridge, allowing physicians to serve vulnerable populations while maintaining financial stability. During my clinical rotations, I've witnessed firsthand that public service hospitals are where we help America's most vulnerable. I've seen the Gust and Wars of Humanity and Houston's beloved Ben Tob, our community safety net hospital where no one is turned away. I will never forget caring for an incarcerated woman giving birth completely alone with no family or support allowed. I held her hand throughout her delivery. And when the nurse asked for the baby's name, my patient turned to me, looked at my badge and quietly read my 1st name, Amelia. And this wasn't gratitude. It simply revealed how little kindness she had experienced in her life. And the simple act of holding her hand the most basic form of human compassion prompted her to name her baby after me and it shows how really she had been treated with basic dignity. This moment shows what public service medicine offers the opportunity to be present for society's most marginalized. Treating them with the humanity everyone deserves. Student deaths should not force physicians away from these essential settings towards higher paying private facilities serving only those who can afford care. Yes. PSLF provides a clear compact, commit a decade to serving your community and receive student debt relief. It upholds service and responsibility, which are values that transcend political divides and unite us as Americans. I urge you to strengthen and protect this vital program that represents the best of who we are as a nation. Thank you. Thank you. For your comments. Catherine, Jim Boris. I apologize if I massacre then. We have 3ÿmin. Good afternoon. My name is Katharine Gamborees and I'm the Government Relations Manager at the American Association of Community Colleges. ACC will submit detailed comments on the role making process next week, but today we would like to highlight 4 key areas that we urge the department to look at. As you put together your role making agenda. First, st we share the department's goal of streamlining and improving existing Title 4 processes to promote innovation and student success. To that end, we encourage the department to revisit the regulations around return of Title 4 funds. While the rules were improved during the last round of negotiated rulemaking, they remain needlessly complicated, burdensome and time consuming. They're simplified. Second, our member colleges continue to tell us. That approval of program participation agreements, re-certification, and program review procedures are extremely burdensome and time intensive. Collectively, they stifled the ability of community colleges to be nimble and to adopt a changing workforce and student needs. Well, the department, we urge the department rather to systematically review the regulatory framework in these areas. To decrease institutional burden in by reducing overlap. Next, we access the department's help in combating fraudulent students. You stolen identities to access and steel financial aid refunds. This is an issue that greatly impacts community colleges because of our low tuition. Our colleges continue to vote significant resources to identifying fraudulent students. Often partnering with expensive vendors and to date, we have received very little material or technical support from the department. They are then left on the hook for any stolen funds as part of our T. 4. We urge you to consider this problem during negotiated role making. Excuse me. Finally, as the department waste changes to existing income driven repayment plans. Or due to craft policies that consider the experiences of low-balanced community college borrowers. Only 12% of our students borrow and they borrow significantly lower amounts than other types of students. They are more likely to be low income and face greater obstacles to repayment. To that end, we asked the department to consider a shorter timeline to forgiveness under IDR for small-balanced borrowers. Thank you for the opportunity to share these topics and we look forward to working with you on these and other issues throughout the world making process. Thank you for your comments. Did Latiana Nichols do show up? No. At this time, are there any of you in the audience who have not already spoken that would like to come up and make a public comment? Going one? Going twice? Once again, I'd like to acknowledge and thanks for the team members we have, Yeah. Conference team, event things, technical assistance, logistics, our staff and all in the office of secondary education. There were a number of logistic and technical Thank you. I did confirm every way with many details. Without your, this would not be possible. We have a deputy under Secretary and. Good. It's very fun. Doing that. We thank you. Team for your hard work dedication to make this event. And from the bottom of my heart and hard hard hard hard hard hard hard hard hard hard hard hard hard hard. Okay. Thank you and our virtual public on behalf of the entire Department of Education team. We thank you for your comments and joining us today. Thank you for your feedback.