Comment on FR Doc # 2026-13248
Anonymous AnonymousOtherIndividual
Summary: Christopher Adams, a study abroad program administrator, expresses concern that rescinding regulations without clear replacement guardrails could harm transparency and academic autonomy. He urges the Department of Education to pair any deregulation with specific commitments to multi-year planning, peer review, equity for smaller institutions, and measurable outcomes.
To the Department of Education:
As a study abroad program administrator, I support reducing unnecessary burden, but I am concerned that rescinding program-specific regulations without clear replacement guardrails will reduce transparency, predictability, and academic autonomy.
Predictability and Planning: Study abroad and language programs require multi-year planning. Please commit to publishing multi-year priority frameworks and standardized selection criteria/weights at least 6–12 months before competitions to allow institutions—especially smaller ones—to plan responsibly.
Governance and Peer Review: The notice suggests pursuing “non-grant options” (e.g., contracts, subgrants) to eliminate peer review and indirect costs. If ED adopts these mechanisms, please preserve external peer input, publish scopes of work for comment, and codify safeguards for academic independence and innovation that have long underpinned Title VI and Fulbright-Hays.
Equity for Smaller Institutions: Flexibility can unintentionally favor well-resourced applicants. Please detail how ED will ensure equitable access for community colleges and minority-serving institutions, including capacity-building supports and transparent scoring rubrics.
Outcomes and Accountability: Please specify measurable outcomes for language proficiency, access for underrepresented students, and institutional diversity, and commit to annual public reporting so stakeholders can assess whether deregulation improves results.
Flexibility is valuable, but it should not come at the expense of the program’s core academic mission or equitable participation. I urge ED to pair any deregulation with strong transparency, peer engagement, and equity safeguards.
Sincerely, Christopher Adams