From: Jason Lorgan, Negotiator, Public Four-Year Institutions of Higher Education [Primary]

 Alyssa Dobson, Negotiator, Public Four-Year Institutions of Higher Education [Alternate]

 Michael Cioce, Negotiator, Public Two-Year Institutions of Higher Education [Alternate]

To: Program Integrity and Institutional Quality Committee 

Date: March 5, 2024

Re: Memo Regarding Cash Management- Books and Supplies 

We would like to submit the letter below for the committee’s consideration as we attempt to 

reach consensus. This letter has been signed by eight Higher Education Associations. We 

believe this letter demonstrates the concerns that institutions have about the current language 

being discussed.

March 5, 2024

The Honorable James Kvaal 

Under Secretary of Education 

U.S. Department of Education 

400 Maryland Ave, SW 

Washington, D.C. 20002 

Dear Mr. Kvaal:

We write to express concerns about the Department of Education’s proposal to revise current 

federal cash management regulations to restrict institutions’ ability to ensure students receive lowcost textbooks and supplies through affordable access programs. We believe such a regulatory 

change would ultimately undermine our shared goals to improve affordability and raise student 

outcomes in higher education. 

The cost of higher education remains a leading concern for many, and the Biden Administration has 

been working to identify new solutions to help mitigate costs for students. However, this particular

proposal would compromise the successful structure of affordable access programs, leading to 

dramatically higher course materials prices and reducing timely access to textbooks and supplies, 

with the greatest harm coming to underserved and disadvantaged students. 

During the decade leading up to 2016, the cost of books and course materials for college courses 

increased by 88 percent. The Obama-Biden Administration recognized the need for a better 

solution and approved cash management regulations to allow institutions, when disbursing Title IV 

funds, to automatically provide course materials to students, as long as the materials were offered 

below competitive market rates and students had the choice to opt-out. Today, more than 1,500 

institutions nationwide offer affordable access programs to help students save money on textbooks 

and course materials. 
The opt-out structure underpinning these access programs has allowed publishers the economies 

of scale necessary to offer bulk discounts that would otherwise not be available to students. As a 

result, affordable access programs have been credited with helping to bring down student spending 

on course materials by an astounding 57 percent in less than a decade and most programs offer 

better terms and features than found in the retail marketplace, including free access each term 

through the add/drop period. 

Millions of college students across the country benefit from the cost savings, ease of access, and 

convenience offered by access programs. According to independent research, the average student 

spent $285 on course materials in the 2022-2023 academic year – that’s a 60% drop from 2007, 

when the average student spent more than $700 on course materials. Recognizing the value and 

savings afforded by access programs, several student body governments at institutions like CSU 

Long Beach and UNC Charlotte have taken action to formally endorse access programs.

Access programs can have a direct positive impact on students’ academic performance, increasing 

course completion rates and raising academic outcomes. The premise is simple: when students

automatically have the materials they need on or before the first day of class, they perform better in 

class. A recent student survey confirmed more than three-quarters (83%) of students believe 

access programs had a positive impact on their academic success. Further, independent research

found these programs are especially beneficial to underserved students; access programs resulted 

in substantial increases in course completion rates for at-risk groups, including Black students and 

students over the age of 25. 

As leaders in higher education, we recognize access programs help lower course materials costs, 

make it easier than ever for students to have all the materials they need on or before the first day of 

class, and can contribute to better academic outcomes – particularly among nontraditional and 

disadvantaged students. 

Instead of advancing regulations that could have unintended consequences for college costs and 

make it more difficult for students to succeed academically, we strongly urge the Department of 

Education to preserve the existing structure of access programs while working with institutions and 

stakeholders to advance commonsense modifications that enhance transparency and protections 

for students. Any regulatory actions must not compromise the integrity of access programs nor

harm institutions’ ability to continue offering these convenient, popular, and affordable programs.

Thank you for taking our concerns into consideration as you continue this important higher 

education rulemaking effort. 

Sincerely, 

American Association of Community Colleges

Association of Community College Trustees

EDUCAUSE

National Association of College and University Business Officers
National Association of College Auxiliary Services

National Association of College Stores

Rebuilding America's Middle Class

Unizin