From: Jason Lorgan, Nego�ator, Public Four-Year Ins�tu�ons of Higher Educa�on [Primary]

To: Program Integrity and Ins�tu�onal Quality Commitee 

Date: February 14, 2024

Re: Memo Regarding Cash Management- Books and Supplies 

I would like to submit the letter below for the committee’s consideration. The letter has 75 

signatures representing 61 institutions. To summarize, many institutions would like to maintain 

the ability to ensure all students begin the term with access to required textbooks as the 

default versus reverting to the default being that students start without access to their required 

content.

February 14, 2024

The Honorable Miguel Cardona Secretary

U.S. Department of Education

400 Maryland Ave., SW

Washington, DC 20202

Dear Secretary Cardona,

As representatives of American universities and colleges, we are alarmed to learn that the U.S. 

Department of Education (ED) is moving to curb access and affordability course materials 

programs such as Inclusive Access – which are highly effective offerings that provide low-cost, 

high-quality course materials to students at our nation's institutions of higher education, 

dramatically increase faculty and student choice, and deliver particularly strong benefits to low 

income and at-risk populations.

We request that you move quickly and decisively to protect and preserve these critically 

important options for course materials by retaining the current rules. Given many of the 

concerns raised during the negotiation sessions, we encourage the Department to consider this 

feedback in its next draft of language during this process.

By way of background, access and affordability programs such as Inclusive Access were 

developed by colleges and universities during the Obama-Biden administration when the 

Department of Education issued federal guidance creating an important mechanism for 

institutions of higher learning to include course material expenses as part of tuition and fees, 

with the caveat that those materials had to be offered to students at a cost below the 

competitive market rate. This move enabled low-income students to pay for course materials 
through their federal grants and loans–rather than going out of pocket–providing significant 

relief to those struggling to afford their degree.

In the years that followed the introduction of these programs, the positive impact has been 

nothing less than extraordinary. More than 1,900 colleges and universities (nearly 50%) from 

across the country now offer access and affordability programs based on the rules created 

during the Obama-Biden era.

The response from students has been extremely positive as well. In just one example, 83% of 

students surveyed at Norfolk State University said that such programs had a positive impact on 

their academic success, and 89% said that they would be likely to recommend the program to 

other students.

In terms of affordability, these programs have contributed to a dramatic 57% decline in student 

spending on course materials over the past decade, according to independent research group 

Student Watch. As part of that ongoing trend, students now spend an average of just $310 a 

year in the category, according to the 2023 Trends in College Pricing and Student Aid Report 

from the College Board.

While the benefits in terms of affordability are clear, students also always have the choice of 

opting out of the program and acquiring the course materials they need elsewhere.

In short, these programs are an essential tool for making higher education affordable to a 

broader range of Americans than ever before.

Additionally, these affordability and access programs accelerate student access to high-quality 

course materials, providing them seamlessly on or before the first day of class, and dramatically 

improve student outcomes and retention rates.

Programs providing early access to course materials have been shown to have particularly 

strong benefits for the most underserved student populations. In fact, recent independent 

academic research has shown substantial increases in course completion rates for at-risk 

groups, including Black students (up 21%), students over the age of 25 (up 6%), and female 

students (up 13%) who participate in these programs.

While there is no one-size fits all solution when it comes to course materials, these programs 

provide faculty and students with the option to choose high-quality materials at an affordable 

rate, while at the same time providing critically important support to at-risk groups.

The proposed regulation updates would effectively gut these programs by making it much more 

difficult for students to apply their federal student aid to course materials, undermining the 

successful legacy of a key Obama-Biden era campaign promise to bolster quality and 

affordability in higher education.
Affordability and access programs will, of course, continue to improve and evolve over time. 

We are committed to enhanced transparency and disclosure for students. But there is simply 

no good reason to threaten the extraordinary progress that these programs have made in 

terms of affordability and improved student outcomes over the past eight years.

As college administrators we urge ED to modify your proposed cash management regulation 

updates and retain the current regulations that make possible an important, successful course 

material access model that has demonstrated real positive outcomes for students.

Respectfully,

75 Signatories, representing 61 Institutions

(See the full list of Signatories below)

Higher Education Professionals at Four Year Institutions:

Russell Weldon, Auburn University

Sandra Hope, Professor, Microbiology & Molecular Biology, Brigham Young University

Marie C. Pizzorno Ph.D., Professor of Biology, Bucknell University

Kimberly Yates, Assistant Director – Course Materials, Central Michigan University

Barry Waters, Central Michigan University

John A. Marohn, Professor, Cornell University

Tigran Abrahamyan, PhD, Florida International University (FIU)

David R. Decker, Franklin University President, Franklin University

Kathleen Hutcheson, Lab Supervisor, Staff, Georgia Southern University

Derick Robertson Director of Retail, Georgia Southern University

Carrie Rose, Bookstore Manager, Grove City College

Jacklyn Downing, Kutztown University of Pennsylvania

Dr. Andrew Steele, Associate Professor, Chemistry, School of Natural Sciences and 

Mathematics, Lenoir Rhyne University

Dr. Eric Terry, Associate Professor, Miami Dade College

Thania Rios, Miami Dade College

Tina Kuhn, Miami Dade College

Shahrooz Moosavizadeh, Professor, Director of the Spartans All Inclusive Learning (SAIL)

Program, Norfolk State University

Amy Barnsley, Professor, Mathematics, Northern Michigan University

Jennifer Kelly, Executive Director University Affairs, Northwestern State University

Briana Salas, Associate Professor, Our Lady of the Lake University

Daryoush Tahmassebi, Purdue University Fort Wayne
Jeff Laborda, Associate Professor, Natural Science Dept., State College of Florida, ManateeSarasota

Scott Chapman, Book Division Manager, UCLA Store, University of California Los Angeles 

(UCLA)

Melvin Beck, University of Memphis

Eric Parsons, Director of Undergraduate Studies, Department of Economics, University of 

Missouri

Dr. Mike Moore, Affiliate Research Assistant Professor, University of New Hampshire

Christina Green, University of North Georgia

Timothy Barnett, University of South Carolina

Jerry Carroll Director of Contract and Retail Services, University of South Carolina Upstate

Betty Phillips, Course Materials Manager, University of Tennessee

Lee Murphy, Distinguished Lecturer, Department of Nutrition, University of Tennessee –

Knoxville

Lindsay Mahony, University of Tennessee, Knoxville

Dr. Matthew Pamental, Senior Lecturer, Department of Philosophy, University of 

Tennessee-Knoxville

Michelle Childs, The University of Tennessee

Shirley Streeter, Assistant Director, Volbooks, University of Tennessee

A. Vaish, University of Virginia

Juno A. Farnsworth, Assistant Professor, Vincennes University

Alyson Froehlich; Assistant Professor, Higher Ed Instructional Consultant; University of Utah

Randy Simmons, Utah State University

Linne Marsh, Utah Tech University

Dr. Danny Walker, Assistant Professor, Chair of Philosophy & Arts, Wilmington University

Higher Education Professionals at Two-Year, Community College, and Technical Schools:

Gena Britt, Ph.D., Professor of Psychology, Brightpoint Community College

Christopher Walsh, Anne Arundel Community College

William Hoover, MD Science Coordinator for Allied Health Sciences, Bunker Hill Community 

College

Noah Channell, Bookstore Manager, Coastal Alabama Community College

Thomas Feather, Assistant Administrator Bookstore, Community College of Rhode Island

Greg Morris, Senior Vice Provost Academic Services, Dallas College

Emily Fulgham-Clay, Professional Development Coordinator, Delgado Community College

Herman Calzadillas, Dean of Prof Tech, Everett Community College

Richard H. Turner, AVP Academic Operations, Florida State College at Jacksonville

Ray Lambert Director of Business and Auxiliary Services, Greenville Technical College

Dr. William Easterwood, Hinds Community College

Donald Parker, Inclusive Access Coordinator, Houston Community College

Doug Sutton, Coordinator of Online Course Materials ICCOC, Iowa Community College 

Online Consortium

Johnette McKown, President, McLennan Community College
Jimilea Jansson, Bookstore Manager, NOC Bookstore, Northern Oklahoma College

Roger Yohe, Ph.D., Vice President of Academic Innovation and Strategy, Palm Beach State 

College

Dr. Scott Zimmer, Paradise Valley Community College

Michael Cioce, Rowan College at Burlington County

Dr. Laurel Williamson, Deputy Chancellor & President, San Jacinto College

Niki Whiteside, Assistant Vice Chancellor for Instructional Innovation & Support, San Jacinto 

College

Louis Moritz - Manager of Administrative Services, Tri-County Technical College

Josh Wrightson, Bookstore Manager, Tri-County Technical College

Beth Dunn, Triton College

Glenn Jablonski, Mathematics Instructor, Triton College

College and University Signatories:

Anoka Ramsey Community College

Cornell University

Eastern Iowa Community College

Florida International University

Kennebec Valley Community College

North Carolina Central University

University of Virginia

Waukesha County Technical College

Bookstore Professionals:

Jon Bibo, Independent College Bookstore Association

Kevin Taylor, Bookstore Manager, SGA Bookstore (Serving Slippery Rock University)