Written by: Cody Brumfield
Published: 07/23/2008

Education Department Fails to Gain Emergency Clearance for Transfer Survey

Last week, the Under Secretary's Office at the U.S. Department of Education announced a major survey of Pell Grant recipients who transferred between colleges. In a federal register notice, The Department indicated that it had sought emergency clearance from The Office of Management and Budget to perform the survey starting July 17th, only one day after the date of publication of the notice.

AACRAO immediately registered its opposition to the approval of the Department's attempt to circumvent the regular clearance process in a letter to the Office of Information and Regulatory Affairs at the OMB. The Association's objections to the effort were shared by a number of other higher education groups, which submitted a similar letter to OMB requesting that the emergency clearance be denied. The group, which included AACRAO, pointed out that there was "no additional benefit to be derived from the unnecessary 'emergency' designation." In addition, the letter argued, precluding public comment would be unwise considering the complex and varied institutional policies on transfer and the differing perspectives of colleges, students, and government officials.

As of now, the OMB has refused to approve the Department's emergency request. The request has been amended by the Department to allow an additional week of consideration by the OMB. However, it appears that the data collection clearance process will most likely follow the normal procedures, and provide all affected groups to share their views. Should the Department choose to move forward with the survey, AACRAO would welcome the opportunity to submit formal comments and help develop a survey that facilitates an unbiased examination of credit transfer.