| The Department of Education has proposed a new accountability rule under AHEAD that would measure the value of undergraduate certificate programs using a flawed earnings comparison based on American Community Survey data. As written, the proposal unfairly compares career education graduates against a benchmark that already includes individuals with vocational and trade certificates, creating a misleading and legally questionable standard.
CECU has prepared a template comment letter outlining major concerns with the proposed rule and recommending key adjustments before any accountability consequences are implemented. The issues raised are especially relevant to cosmetology, personal care, culinary, medical assisting, and other short-term certificate programs, particularly those serving women and students in lower-wage regions.
We strongly encourage institutions and stakeholders to submit public comments. Individualized comments carry far more weight than identical submissions. While you may use the template as a starting point, it is critical to customize your response with institution-specific examples, student outcomes, operational impacts, regional considerations, and workforce realities.
Comments that include unique experiences, data, anecdotes, or examples of increased costs, reduced access, workforce barriers, or student impact are especially valuable in strengthening the public record.
Review the template comment letter HERE.
Review our Guide to Submitting Comments HERE.
The Department needs to hear directly from institutions and stakeholders affected by this proposal. High-quality, unique comments will be essential in shaping the final rule.
Contact us with any questions by emailing Jordan Wicker, SVP for Legislative and Regulatory Affairs at Jordan.wicker@career.org.
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