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End of TPS Expansion Comment Period
What insights do we have on next steps to fix this mess?
Phil Hill
March 31, 2023
You may have already noticed, but we are in the middle of a rebranding of PhilOnEdTech and MindWires. Expect an announcement next week, but in the meantime I’ll share that adding a CNAME record to a naked domain can kill your company email and calendaring. Who knew? Well, I do now.
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On to the update.
This afternoon is the end of the public commenting period for the Dear Colleague Letter (DCL 23-03) that expands the definition of third-party services (TPS). Pencils down.
Since last week’s post, there has been a barrage of public comments submitted. From 64 to 670+ comments that have been posted to the site, and a total of 1,082 comments submitted as of last night (there tends to be a one week lag between comment submission and final posting). No, my time in New Orleans for Ellucian Live 23 was not conducive to coding the additional responses, so there is no statistical update to share.
Any Changes?
There is nothing I have seen, however, that suggests a groundswell of commentary supporting the new guidance. In fact, it is hard to find groups or even individuals outside of the Department of Education or Century Foundation or Arnold Ventures that don’t recognize the mistakes made by this DCL. There are some, but not many. We’ll at least scan the additional comments to see if there are any new patterns and let you know.
Of course, this is not a voting game - the point at least initially is that the higher ed community is overwhelmingly against DCL 23-03. And not all comments carry the same weight. There one comment worth highlighting.
ACE Wisdom
The American Council of Education (ACE), which appears to have been the primary influence on ED delaying the effective date of the guidance, is unequivocal in its final comments [emphasis added]: