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Initial View of Public Comments
If public comments held much weight, ED would change course
Phil Hill
March 24, 2023
Its’ been a busy week, with our Monday webinar on TPS guidance and the Tuesday news that Pearson was selling its OPM business. The EdTech industry in general, and the OPM market in particular, is not boring these days.
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On to the update.
The written public comment period on the bundled services exception review (whether to change or rescind the guidance that enables OPM tuition revenue sharing) closed a week ago, and the public comment period on the TPS guidance expansion closes on March 30th. Comments are not posted immediately on the regulations.gov site, but we should have enough comments to get a sense of the feedback being given on these two crucial EdTech regulatory guidance letters.
Note that this is not truly a voting scheme, but the numbers are significant enough to share the relative numbers.
The following will likely be updated and appear in a free blog post later this month, but I wanted to share initial results with premium subscribers.
Bundled Services Exception
We reviewed 250 public comments regarding the question of whether the US Department of Education (ED) should rescind the 2011 guidance, which would eliminate tuition revenue-sharing agreements, at least for OPM companies. I believe there are or will be another 20 comments to add to this mix within a few days.
We coded the comments as either Against keeping the 2011 guidance (and therefore rescinding that guidance and eliminating rev share), For keeping the 2011 guidance, or Neutral. While there are some questions about how much community organizing encouraged people to comment, the results were still surprising to me. Roughly 9% of comments are Against, 84% are For, and 7% were Neutral. You can find the comments here.