On June 20, CCA submitted comments to the Department of Education on its Notice of Proposed Priorities and Definitions – Secretary’s Supplemental Priorities and Definitions on Evidence-Based Literacy, Education Choice, and Returning Education to the States [Docket ID ED-2025-OS-0020].
The comments read as follows:
Thank you for the opportunity to submit public comments on the Department of Education’s (Department) Notice of Proposed Priorities and Definitions – Secretary’s Supplemental Priorities and Definitions on Evidence-Based Literacy, Education Choice, and Returning Education to the States on behalf of Complete College America (CCA). CCA is a national nonprofit dedicated to increasing college completion rates and creating economic opportunity through postsecondary education.
At CCA, we strategize and implement our work through the CCA Alliance, comprising 53 members, including 44 states and territories, committed to promoting proven policies and evidence-based structural reforms that can improve student success. We agree with you that states and tribes must play a key role in “formulating, developing, and implementing policies that best serve students, families, and educators within their communities.” Allowing governors, state higher education agencies, state workforce development agencies or boards, and tribal agencies to compete for federal discretionary grants will open doors to critical funding for these entities and will greatly support students.
That said, we also recognize that student success must be a comprehensive endeavor. Federal funding must be directed to a variety of stakeholders who can develop and implement a range of interventions to support today’s students and ensure opportunities for college completion. We encourage the Department to develop grant competitions that recognize the role other entities, including postsecondary institutions of all types and nonprofit organizations, play in supporting student success. Therefore, we would propose expanding the priority to include a broader range of eligible entities. Postsecondary institutions and nonprofit organizations must be able to compete equally to carry out federal programs and projects.
In addition, removing the current priority, Increasing Postsecondary Education Access, Affordability, Completion, and Post-Enrollment Success, could significantly hinder opportunities to direct federal funds to support critical efforts in the states and at public postsecondary institutions, including community and technical colleges, to ensure postsecondary student success for those who need it. CCA recommends restoring that priority to increase student success nationwide. Federal funds must be used to support evidence-based programs with proven outcomes, with the goal of ensuring that all Americans have the opportunity to earn a degree or credential of value and have the necessary supports to do so.
We are happy to respond to any questions that you may have regarding the contents of this letter. Thank you for your consideration.
