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

Rulemaking Summary of Session Two – February 5-8, 2024

U.S. Department of Education

Program Integrity and Institutional Quality

Negotiated Rulemaking

Meeting Summary – Session 2

February 5-8, 2024

Welcome

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

Session 2 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 

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

Rulemaking Summary of Session Two – February 5-8, 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 Two – February 5-8, 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 1 and Session 2 for consideration. The Department reviewed the proposals and then provided 

updated proposed regulatory text in advance of Session 2 on the following:

- Cash Management

- State Authorization

- Distance Education

- Withdraws and Return of Title IV Funds (R2T4)

- Accreditation

Temperature checks were conducted on each issue to ascertain the amount of support or dissent on 

each issue/proposal. Temperature checks are not consensus.

Public Comment

The Committee provided opportunity for public comment at the end of each day. Public comment was 

received on all four days of the session. 

Next Meeting

The next meeting will be held via Zoom Gov March 4-7, 2024. 

Next Steps

FMCS will distribute a final summary and final agenda to the negotiators. Any information that 

members want to share with the Department, or the Committee as a whole, should be sent to the 

facilitators by COB on February 14, 2024. Additionally, any questions members have may be directed to 

the facilitators.

Committee members will communicate with others within their communities of interest to inform and 

get feedback from them.

Addendum

U.S. Department of Education 

Federal TRIO Program Subcommittee

Meeting Summary of Session 2 

February 9, 2024

Welcome

Federal Mediation and Conciliation Service Facilitators, Krystil Smith and Cynthia Jeffries, welcomed the 

subcommittee members back for Session 2, the final Session on the Federal Trio Program 
U.S. Department of Education, Program Integrity and Institutional Quality Committee Negotiated 4

Rulemaking Summary of Session Two – February 5-8, 2024

subcommittee.

Roll Call of Record

FMCS conducted roll call of members. 

Community of Interest Member

Institutions of Higher Education D’Angelo Sands

Current of former participants in a 

Federal TRIO Program

Wade Williams

Secondary Schools, including local 

educational agencies with 

secondary schools

Geoff Garner

Organizations, including 

community-based organizations 

with experience in serving 

disadvantaged

Emalyn Lapus

State officials, including State 

Higher Education Executive 

Officers, State Authorizing 

Agencies, and State Regulators of 

Institutions of Higher Education

Michael P. Meotti

Department of Education, Office of 

Policy, Planning, and Innovation 

within the Office of Postsecondary 

Education

Aaron Washington, Subcommittee 

leader

Department of Education, Higher 

Education Programs, office within 

the Office of Postsecondary 

Education

Gaby Watts
U.S. Department of Education, Program Integrity and Institutional Quality Committee Negotiated 5

Rulemaking Summary of Session Two – February 5-8, 2024

Department of Education, Office of 

General Counsel

Hannah Hodel

Agenda

• Talent Search program

• Upward Bound program

• Educational Opportunity Centers program

The Department had resubmitted their original regulatory text proposal, after having considered the 

subcommittee members counter proposal submitted in Session 1, in advance of the sub-committee 

meeting. 

Following discussion, the subcommittee reached agreement for support of the Departments original 

proposal, which will be presented to the main negotiating committee for discussion and consensus 

action in the March session.

Next Steps

The subcommittee will provide a version of their recommendation to FMCS for distribution by February 

23, 2024.

FMCS will distribute the recommendation to the Department of Education and the main negotiating 

committee prior to the start of the March Session. 

The subcommittee will be scheduled to present their recommendation to the main committee during 

the March session.

Adjournment

The subcommittee adjourned at 12:00pm ET.