Federal Policy
Outcomes Over Inputs
We believe the best policy approach regulates outcomes over inputs. With complete dedication to being the most student-centric university, WGU advocates for public policies that ensure academic quality and relevance, deliver accountability for student outcomes, increase transparency and safeguard taxpayer dollars. WGU regularly submits comments as part of the federal rulemaking process and works with policymakers to support legislation that improves educational outcomes.
WGU President Scott Pulsipher testifies before the U.S. House Committee on Education and the Workforce on Feb. 8, 2023.
Accountability for Student Outcomes
Equity in both access and attainment
The majority of today’s learners are part of a diverse group of individuals who often work at least part-time, pay for their own education, and/or care for families. They are not pursuing higher education for the coming-of-age experience; instead, they seek a path to economic prosperity, with the flexibility to learn on their own schedules. Unfortunately, many policies overlook this large population. WGU supports policies that help all students succeed, regardless of their background, location, or learning modality.
Improved completion rates
Students who do not complete a degree never realize the value gained from a credential and tend to be worse off than had they never started. Policies must incentivize innovation within institutions to support students throughout their educational programs.
Strong return on investment
The crippling level of student debt in this country is the symptom of a larger problem: Too many learning experiences are not designed to be affordable, and many are irrelevant to the needs of the workforce. Policies can incentivize institutions to better meet these needs and reduce costs by prioritizing credential relevance, program value, and data transparency.
Aligned with workforce needs
Employers need a skilled workforce that is well-equipped for today’s jobs. WGU programs are crafted with input from leading organizations to produce graduates with job-ready skills aligned with employer needs so they can contribute from day one.
Policy Engagement
Read about WGU's latest policy efforts.
WGU’s Response to Request for Information Regarding Ways to Support the Successful Completion and Submission of the 2025-2026 FAFSA Form (submitted September 13, 2024)
In August 2024, the Department of Education requested feedback on how to best support completion of the 2025-2026 FAFSA form. WGU identified several resources, tools, and changes that could improve the FAFSA completion process for students, financial aid administrators, and institutions.
WGU’s Public Comments on Program Integrity and Institutional Quality: Distance Education, Return of Title IV, HEA Funds, and Federal TRIO Programs (submitted August 23, 2024)
The Department of Education’s proposed regulations revise the definitions and reporting requirements for distance education, while also streamlining the process for Return to Title IV (R2T4) by requiring online institutions to take attendance and document withdrawals within 14 days of a student’s last attendance. WGU expressed support for measures focused on ensuring quality and transparency but raised concerns about the proposed rules’ emphasis on delivery mode rather than quality. The comments also recommended clarifications to the R2T4 provisions and called for a more thorough cost-benefit analysis before issuance of a final rule.
WGU’s Public Comments on Negotiated Rulemaking Committee; Public Hearing (submitted July 20, 2023)
In July 2023, the Department of Education announced plans to establish a negotiated rulemaking committee and solicited comments on the Secretary of Education’s ability to modify, waive, or compromise federal student loans. WGU’s comments indicated support for improved college affordability and transparency but expressed opposition to large-scale debt relief through administrative channels, advocating instead for legislative reform that could ensure lasting changes and accountability. WGU stated that widespread debt forgiveness could lead to unintended consequences, such as increased borrowing and taxpayer burden, and emphasized the importance of measures that hold institutions accountable and provide students with financial transparency.
WGU’s Public Comments on Financial Value Transparency and Gainful Employment (GE), Financial Responsibility, Administrative Capability, Certification Procedures, Ability to Benefit (ATB) (submitted June 20,2023)
Under this notice of proposed rulemaking, the Department of Education addressed five subjects: 1) financial value transparency and gainful employment, 2) financial responsibility, 3) administrative capability, 4) certification procedures, and 5) ability to benefit.
Financial Value Transparency and Gainful Employment:
Overall, WGU supported the Department’s goal of helping students make informed choices through increased institutional transparency and accountability. WGU offered several recommendations to help the Department achieve this goal. One of WGU’s recommendations, making transparency information available through the FAFSA portal, will be considered for addition in a future year, as the Department stated it would not be possible to incorporate the change to the 2024-25 FAFSA portal.
Financial Responsibility:
WGU suggested two adjustments to the proposed financial responsibility modifications that would reduce institutional burdens while still protecting students. These recommendations pertained to institutional reporting and events that trigger Department action. The Department incorporated both adjustments into the final rule.
Administrative Capability:
WGU expressed a commitment to the proper administration of its programs and services under the new rules. However, two recommendations were made: 1) delaying full implementation of administrative capability requirements until July 1, 2025, and 2) extending the placement timeline for clinical or externship opportunities to 90 days to address issues that could arise during the placement process. The Department declined to incorporate either recommendation into the final rule.
Certification Procedures:
WGU urged the Department to withdraw proposed rules that could arguably undermine State Authorization Reciprocity Agreements (SARA) and reduce access to education. WGU highlighted the benefits of SARA in expanding student access to higher education and protecting students through uniform eligibility requirements. The Department’s final rule kept SARA intact and provided acknowledgment of students who live in one state but plan to work in another.
Ability to Benefit:
WGU admissions criteria include high school graduation or the equivalent and WGU is, therefore, not currently involved with the Ability to Benefit (ATB) process. WGU provided general support for the Department’s proposed changes, stating the new rules will clarify and simplify the ATB process for both states and institutions.
WGU’s Public Comments on Agency Information Collection Activities; Comment Request; 2024-2025 Free Application for Federal Student Aid (FAFSA®) (submitted May 22, 2023)
WGU provided feedback on the 2024-2025 FAFSA, supporting efforts to simplify the form but expressing concerns about the removal of the housing choice question. WGU stated that this omission complicates the estimation of student costs and urged the Department of Education to reinstate the question.
Summary: https://www.federalregister.gov/documents/2023/03/23/2023-06169/agency-information-collection-activities-comment-request-2024-2025-free-application-for-federal
WGU’s Public Comments on Requirements and Responsibilities for Third-Party Servicers and Institutions (submitted March 30, 2023)
In February 2023, the Department of Education released a Dear Colleague Letter (DCL) that expanded the definition of a Third-Party Servicer (TPS). WGU expressed concerns that this new definition includes entities not traditionally subject to TPS requirements, which could overwhelm institutions. WGU also cautioned that the expanded definitions could divert focus from student outcomes, create heavy administrative burdens, and limit innovation and partnerships. To mitigate these risks, WGU urged the Department to rescind the DCL and engage in a more formal process to revise TPS requirements. On May 16, 2023, the Department issued another DCL that removed the effective date of the previous letter and indicated plans to issue final revisions at a future date. In July 2024, the Department announced that further regulatory promulgation of third-party servicers would take place through formal negotiated rulemaking, and in October 2024, it was announced that the DCL would be rescinded.
WGU’s Comments on Improving Income-Driven Repayment for the William D. Ford Federal Direct Loan Program (submitted February 10, 2023)
WGU provided input on the Department of Education’s proposed rulemaking on Income-Driven Repayment, which included the introduction of the SAVE Plan for student borrowers. WGU backed aspects of the proposal aimed at simplifying and standardizing repayment rules, eliminating negative amortization, and reducing complexity for borrowers. However, WGU did not fully endorse the proposed rulemaking due to significant financial implications for taxpayers. WGU stressed the importance of a reasonable and lasting approach to regulation that removes confusion and makes the financial aid process less burdensome.
WGU’s Response to Request for Information on Public Transparency for Low-Financial-Value Postsecondary Programs (submitted February 10, 2023)
The Department of Education requested feedback on how to identify low-value postsecondary programs. In its response, WGU noted that the value offered by programs and institutions varies significantly, but this information is not readily available to students. WGU stated that increased transparency would help students make better-informed decisions and encourage institutions to focus on value. An ROI metric, for example, could help students assess the value of pursuing a program. WGU also recommended providing students with financial value information and student outcomes data before enrollment and suggested basing financial aid allocations on the value an institution provides.
To find out what is being done to close the digital divide in your state, reach out to our Government Relations representatives.
Short-Term Pell Expansion
While Pell Grants can currently be used for programs lasting 15 weeks or more, pending legislation would extend Pell eligibility to programs of at least eight weeks. Proponents of short-term Pell believe the added financial support can help more students obtain valuable, career-relevant skills. However, there is also concern that shorter programs are prime targets for bad actors, who will develop programs that do not translate to increased income or career success.
WGU’s Public Comments on Institutional Eligibility, Student Assistance General Provisions, and Federal Pell Grant Program (submitted August 26, 2022)
The Department of Education requested comments on prison education programs, the 90/10 rule for calculating revenue, and changes in ownership. WGU expressed support for expanding Pell Grant eligibility within the prison system to help incarcerated individuals access education and gain life-changing opportunities. WGU also supported proposed modifications to the change of ownership rules, particularly the updated definition of "nonprofit institution." WGU did not comment on the 90/10 rule, as this rule only applies to proprietary institutions.
WGU’s Public Comments on Student Assistance General Provisions, Federal Perkins Loan Program, Federal Family Education Loan Program, and William D. Ford Federal Direct Loan Program (submitted August 12, 2022)
In this notice of proposed rulemaking, the Department of Education requested comments on several topics: borrower defense to repayment, interest capitalization, public service loan forgiveness (PSLF), and student loan discharges due to total and permanent disability, school closures, and false certification. Regarding borrower defense to repayment, WGU expressed support for allowing borrowers to file claims when they have been wronged by an institution. WGU emphasized that this process should be transparent and afford institutions the opportunity to respond to these claims. Additionally, WGU backed the elimination of non-statutory student loan interest capitalization and supported many of the proposed changes to the PSLF program.
WGU’s Response to the National Telecommunications and Information Administration’s Request for Comment on the Infrastructure Investment and Jobs Act Implementation (submitted February 4, 2022)
The National Telecommunications and Information Administration (NTIA) requested feedback on broadband implementation efforts. In response, WGU highlighted the digital divide's impact on education, especially during the COVID-19 pandemic, and advocates for higher education's role in broadband access programs. WGU also emphasized the importance of including higher education institutions as subgrantees and partners in state broadband plans to ensure access, adoption, affordability, digital equity, and inclusion. WGU also stressed the need to ensure that State Digital Equity Plans align with broader goals in education, workforce development, and essential services.
WGU’s Response to Request for Information Regarding the Public Service Loan Forgiveness (PSLF) Program (submitted September 23, 2021)
WGU offered feedback on the PSLF Program, pointing out its underutilization and suggesting improvements. WGU noted that the program is underused due to its complexity and restricted eligibility criteria. Additionally, the application and certification processes are cumbersome and would benefit from clearer instructions. WGU recommended increasing awareness, simplifying the rules, making processes more user-friendly, and expanding eligibility.
WGU’s Public Comments on Administrative Priority and Definitions for Discretionary Grant Programs (submitted October 7, 2020)
In response to the COVID-19 pandemic, the Department of Education proposed a priority for grant applications aimed at building capacity for remote learning. The focus areas included technology utilization and access, personalized learning, and performance-based assessments that promote competency-based education (CBE). The proposal also included potential definitions for remote learning, CBE, and interoperable credentials. WGU supported the proposed definitions for CBE and interoperable credentials and suggested that references to short-term credentials be reframed to certificates or micro- and stackable credentials.
WGU’s Public Comments on Distance Education and Innovation (submitted May 4, 2020)
Western Governors University (WGU) supported the U.S. Department of Education's proposed rules on Distance Education and Innovation, emphasizing the importance of regulatory clarity, flexibility, and shared accountability among federal, state, and accrediting bodies. WGU commended the revised definitions and standards for academic engagement, credit hour, and distance education, while advocating for institutional flexibility in financial aid delivery models. The university also supported provisions for timely program approval, clear compliance standards, and streamlined certification procedures. WGU recommended allowing early adoption of the final regulations before July 1, 2021.
WGU’s Public Comments on Federal Perkins Loan Program, Federal Work-Study Programs, Federal Supplemental Educational Opportunity Grant Program, Federal Family Education Loan Program, William D. Ford Federal Direct Loan Program, Teacher Education Assistance for College and Higher Education Grant Program, Federal Pell Grant Program, Leveraging Educational Assistance Partnership Program, and Gaining Early Awareness and Readiness for Undergraduate Programs (submitted January 9, 2020)
WGU expressed its full support for the proposed TEACH Grant program regulations, which simplify requirements, improve transparency, and establish reconsideration processes for grant-to-loan conversions. WGU expected the new regulations to reduce inappropriate debt and align with Congress's legislative intent.
WGU’s Public Comments on Negotiated Rulemaking Committee; Public Hearings (submitted September 14, 2018)
In July 2018, the Department of Education announced plans to establish a negotiated rulemaking committee and requested comments on the core functions of accreditation and access to high-quality, innovative programs. WGU’s response recommended more support for innovative learning models, uniform accountability standards across delivery methods, and the inclusion of quality assurance entities in the accreditation process. WGU also stressed the need to update the Higher Education Act to align with technological advancements and to ensure affordability, access, and workforce readiness.
WGU’s Public Comments on Program Integrity: Gainful Employment (submitted September 13, 2018)
WGU commented on the Department of Education’s proposal to replace gainful employment regulations with a process that would update the College Scorecard, or another online tool, to offer program-level outcomes for all higher education programs participating in Title IV. WGU’s letter emphasized the need for better accountability measures for all Title IV eligible institutions, stating that current gainful employment regulations lack appropriate levels of accountability. It highlighted WGU’s competency-based education model and advocated for public policy that advances quality, access, affordability, and transparency. The letter suggests using loan repayment rates and publishing graduation rates and median earnings to improve accountability and aid student decision-making.
WGU’s Public Comments on Evaluation of Existing Regulations (submitted September 26, 2017)
These written comments are an extended version of a public statement given in response to the Department of Education’s request for suggestions on higher education regulations that might be suitable for repeal, replacement, or modification. Highlighting WGU’s Responsible Borrowing Initiative, we encouraged the Department to maintain its Experimental Sites Initiative and advocated for regulations that reduce student loan debt and improve the efficiency of financial aid distribution.
WGU’s Public Comments on Program Integrity and Improvement (submitted August 24, 2016)
This notice of proposed rulemaking set forth the criteria for eligibility in Title IV financial aid programs. Additionally, it outlined the necessary disclosures for students enrolled in distance education and correspondence courses. While WGU endorsed state reciprocity agreements, it expressed concerns regarding the proposed state authorization regulations for distance education providers.
WGU’s Public Comments on Teacher Preparation Issues (submitted May 2, 2016)
WGU responded to the Department of Education’s proposed rule on teacher preparation accountability, expressing concerns that online institutions are judged differently from traditional colleges, risking biased evaluations and data issues. WGU noted that the system could result in inconsistent state ratings, unfairly impacting distance education programs’ TEACH grant eligibility. They urged the withdrawal of the proposal and suggested collaborating with Congress for fair accountability measures.
WGU President Testifies Before Congress on Higher Ed’s Path Forward
On Feb. 8, 2023, WGU President Scott Pulsipher was invited to testify before the U.S. House of Representatives Committee on Education and the Workforce on the topic of “American Education in Crisis.” As part of his testimony, President Pulsipher outlined three deliverables upon which higher education should focus:
- Higher education should be accessible, traversable, and equitable. Our current system is leaving human potential on the table and is failing to serve as a catalyst for human progress. While many colleges and universities are innovating to create pathways to opportunity that are accessible to all, equity gaps stubbornly remain.
- Higher education must create value for students. The current state of higher education is perhaps best summarized by the Postsecondary Value Commission, supported by the Gates Foundation and the Institute for Higher Education Policy. Their study found that 650 institutions serving approximately 1.5 million students do not provide their students with a minimum economic return after accounting for the cost of attendance.
- Higher education must meet the needs of the workforce. As an extension of providing individuals a pathway to opportunity, a secondary benefit is realized: Workforce needs become aligned with talent supply.
As part of his testimony before the committee, President Pulsipher submitted a detailed written plan for how to make this shift, including policy recommendations. Those written remarks are available for download as a white paper.
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