U.S. Department of Education, Program Integrity and Institutional Quality Committee Negotiated 1

Rulemaking Summary of Session Three– March 4-7, 2024

U.S. Department of Education

Program Integrity and Institutional Quality

Negotiated Rulemaking

Meeting Summary – Session 3

March 4-7, 2024

Welcome

Federal Mediation and Conciliation Service Facilitator welcomed the Non-federal, Federal, and public to 

Session 3 of the Department of Education negotiated rulemaking for developing proposed regulations 

regarding Program Integrity and Institutional Quality. 

Introductions

Roll Call of Record was conducted.

Membership

The following individuals are the Members of the Program Integrity and Institutional Quality Negotiated 

Rulemaking Committee: 

Community of Interest Primary Negotiator Alternate Negotiator

Business Officers from Institutions 

of Higher Education

Joe Weglarz, Marist College Dom Chase, Ivy Tech Community 

College of Indiana

Civil Rights Organizations and 

Consumer Advocates

Carolyn Fast, The Century 

Foundation

Magin Misael Sanchez, UnidosUS

Financial Aid Administrators JoEllen Price, San Jacinto College Zack Goodwin, University of Nevada, 

Las Vegas

Historically Black Colleges and 

Universities, Tribal Colleges and 

Universities and Minority-Serving 

Institutions (institutions of higher 

education eligible to receive 

Federal Assistance under title III, 

parts A and F, and title V of the 

HEA)

Dr. Charles B. W. Prince, Dillard 

University

D’Angelo Sands, Texas A&M Corpus 

Christi
U.S. Department of Education, Program Integrity and Institutional Quality Committee Negotiated 2

Rulemaking Summary of Session Three– March 4-7, 2024

Institutional Accrediting Agencies 

Recognized by the Secretary

Jamienne S. Studley, WASC College 

and University Commission

Michale McComis, Accrediting 

Commission of Career Schools, and 

Colleges

Legal Assistance Organization Robyn Smith, Legal Aid Foundation 

of Los Angeles, and National 

Consumer Law Center

Sophie Laing, Pine Tree Legal 

Assistance

Private Nonprofit Institutions of 

Higher Education

Erika Linden, Des Moines University Scott Dolan, Excelsior University

Programmatic accrediting agencies 

recognized by the Secretary, to 

include State Agencies recognized for 

approval of nurse education

Dr. Laura Raser King, Council on 

Education for Public Health

Amy Ackerson, Missouri State Board 

of Nursing

Proprietary Institutions of Higher 

Education

Jillian Klein, Strategic Education, Inc. 

(SEI)

David Cohen, Five Towns College –

APC Board of Directors

Public Four-Year Institutions of 

Higher Education

Jason Lorgan, University of 

California, Davis

Alyssa Dobson, Slippery Rock 

University 

Public Two-Year Institutions of 

Higher Education

Jo Alice Blondin, Clark State College Michael Cioce, Rowan College at 

Burlington County

State Attorneys General Diana Hooley, Massachusetts 

Attorneys General Office

Vacant

State Officials, including State higher 

education executive officers, State 

authorizing agencies, and State 

regulators of institutions of higher 

education.

John Ware, Ohio State Board of 

Career Colleges, and Schools

Robert Anderson, State Higher 

Education Executive Officers 

Association

Student or borrowers, including 

currently enrolled borrowers, or 

groups representing them

Jessica Morales, American University 

Washington School of Law

Emmett Blaney, Young Invincibles

U.S Military Service Members, 

Veterans, or groups representing 

them

Barmak Nassirian, Veterans 

Education Success

Ashlynne Haycock-Lohmann, Tragedy 

Assistance Program for Survivors

Federal Negotiator Gregory Martin

David Musser

Herman Bounds
U.S. Department of Education, Program Integrity and Institutional Quality Committee Negotiated 3

Rulemaking Summary of Session Three– March 4-7, 2024

Agenda

The committee reviewed and discussed the issues one at a time throughout the Session. The nonfederal negotiators had submitted their counter proposals and rationales to the Department between 

Session 2 and 3 for consideration. The Department reviewed the proposals and then provided updated 

proposed regulatory text in advance of Session 3 on the following but did not reach consensus on the 

following topics:

- Withdraws and Return of Title IV Funds (R2T4)

- Distance Education

- State Authorization

- Cash Management

- Accreditation

The TRIO subcommittee presented a unanimous recommendation for the full committee to accept and 

reach consensus on the Departments regulatory text proposal for changes to three (3) TRIO programs as 

follows:

• Talent Search program

• Upward Bound program

• Educational Opportunity Centers program

The full committee reached consensus on the Departments proposed regulatory text related to TRIO. 

Public Comment

The Committee provided opportunity for public comment at the end of each day except for the final day.

Next Steps

FMCS will distribute this final summary document. This concluded the negotiations piece the of the 

rulemaking on Program Integrity and Institution. The Department will proceed with the next phase of 

the rulemaking process.