Bartending, Books, Bocce, and Bills: Government Relations with Scott and Mike

In this episode, AACRAO’s Director of Government Relations Scott Filter and Associate Director for Public Policy, Mike Bilfinger follow-up on their recent government relations webinar. You’ll hear aboutook us on a journey deeper the most recent changes to Duration of Status, which affects international students, and the work of the Accreditation, Innovation, and Modernization or AIM Committee, introduce a lot of changes affecting transfer credit. Be sure to mark your calendars for their next webinar on November 11, and they’ll be back on the pod in December for another debrief.

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Hi, everybody. Welcome to another episode of Heard. In this conversation, ACR's own Scott Filter and Mike Bilfinger joined us for a debrief and deep dive into their most recent government relations webinar. Scott is the director of government relations for ACRO and Mike is the associate director for public policy, and they took us on a journey deeper into the weeds of the most recent changes to duration of status, which affects international students and the work of the Accreditation, Innovation and Modernization or AIMM Committee, which busted out a bunch of changes affecting transfer credit. Scott starts with an introduction of who he is and his journey to his role at ACR and some of his side hustles. Scott and Mike are both remarkable, and I'm so glad they could join us. Be sure to mark your calendars for their next webinar on November 11th, that's Veterans Day, and they'll be back on the pod in December for another debrief. All right, let's get started. Hi, everybody. Welcome to another episode of Heard. I'm Ingrid Nuttall.-- I'm Tashawna-- Curtis, and Portia Lamar is not with us today. Unfortunately, she had a family commitment. We miss her. We're thinking of her. But joining us on the pod today, uh, we have a very special guest, one return guest, Mike, we'll, we'll introduce you, but like, congratulations on your second appearance on Heard. But we have joining us Scott Filter, director of government relations for ACR, and Mike Bilfinger, associate director of public policy for ACR. Scott, and Mike, thank you so much for joining us on. Thanks for having me. I'm super excited for my first podcast. Yay. Is this your first podcast ever? No, I did one other at a previous job, but this is definitely my, the, the most centered I've had where I was kind of the subject, uh, of it. It is like when the pod drops, there's going to be like a glow that happens that emits from it, like on LinkedIn and stuff when we share it. Um, it's interesting when that happens. So, just a little background, I know you talked about this in the webinar, but this idea came up out of, um, last year, Mike was on the pod and we did an overview of sort of like what had come to pass, um, legislatively in the last year. And it was so rich with content that I know is really important to everyone. That we talked about how we can keep this going as a regular thing and landed on, you all are doing some webinars which we're going to talk to and having the opportunity to do some regular follow-up with you after your government relations webinar. So, so this is your first but not last time, um, and we're really excited and grateful to have the opportunity to do this with you regularly. So, for um your first visit, Scott, we, we always ask people to introduce themselves, help the audience a little bit about themselves, maybe go a little bit deeper about who you are, where you come from, and what you do before we get started. So can you let everybody know who you are? Yeah, I can give you both a professional and a personal introduction. Um, I'll start personal. Um, I am, in my mid-forties. I was born in Michigan, grew up in Florida. I moved to Washington DC immediately after undergraduate because I had this deep desire to work in politics. Um, so I moved to Washington DC and then realized immediately how little those people make. And didn't do it, uh, until now. Uh, so it was an interesting transition for me, but I have now been in Washington DC, uh, for 24 years, uh, as of last week. Um, it is a city that I, I love. It is a vibrant city with lots to do. Uh, so I love Washington DC. Uh, my biggest hobbies, uh, as you can probably see by the bookshelf over my shoulder here that the, the listeners cannot see, I have tons and tons of books. I love to read. I'm a voracious reader. Uh, in college, I worked at a Barnes and Noble and bought tons and tons of books that I, years later, I had to get rid of over a bedbug issue, but I've started rebuilding my collection. Um, I read something like 100 to 120 books a year. Uh, so I am always reading, I always read multiple books at a time. Um, I love to travel. Um, I try to go internationally once or twice a year. I love domestic travel. Um, as much as I love Washington DC, I also love being on an airplane going somewhere new and exciting. Um, I'm a proud, as I announced at the annual meeting, I'm a proud cat dad of a cat named Titus, and Um, again, the listeners won't meet Titus because, uh, this is a visual thing, but at some point he always shows up during, uh, uh, webinars and Zoom meetings to, to see why he's not being paid attention to. Uh, but he is now 915, and he's the sweetest thing, gives me lots of affection. Um, two other things you should know about me, in my spare time, I'm a bartender. Um, I have worked in the bar. I have worked in the bar industry now for 16 years. Um, it is a very kind of divey bar that has very basic drinks, uh, but it is my social outlet that I do. Um, and then the other thing I'm known for is, uh, in 2010, I helped start a, uh, LGBTQ sports, social sports league called Stonewall Sports. Um, it started with like a kickball league, a bocce league, and a, a dodgeball league. And it has now grown into almost 30 cities nationwide. Um, it's probably the largest, uh, or maybe the second largest LGBTQ social sports league in the country. Um, I'm not in charge and I don't need it anymore. Uh, but I do still play bocce, uh, which is about the energy level I have at some days, um, at my mid-40s age range. Um, so that's who I am personally. Professionally, um, I fell into my career. Um, growing up in Orlando, I went to a small liberal arts school, school, maybe 10 miles away from my house called Rollins College. Um, and the summer before I started, they called and said, hey, we're looking for a work study student in the financial aid office. And I said, you know what, they're probably good people to know, in case you mess anything up, you still have money to go to college. So I started working there and I worked there for the entire 4 years. Um, and then my first job was in a financial aid office here in Washington DC. So that's kind of why I moved to DC in the first place. I thought originally, oh, I'll become like a history professor and I'll work in academia and things like that. Um, but then I discovered the wonderful and interesting work world of how taxes fit in with tuition remission. And I learned very quickly that if uh the academic program you're pursuing doesn't meet the work requirements you're doing, they tax you. And I was poor, and it was 2024 years ago and I needed as much money as I could to pay rent in a big city. And so I immediately switched my plans and did a master's in higher ed administration. Um, and then filed that immediately by starting a doctorate in higher ed administration. Uh, I worked at GW for about 8 years, um, before switching over to a role at the US Department of Education. Uh, stayed there over on and off for a total of about 11 years. At some point right before COVID hit, I moved to another agency called the Consumer Financial Protection Bureau. Um, some people are unfamiliar with it, but they, um, basically protect, uh, American citizens about issues related to your banks, your credit cards, your student lenders, things like that. So I worked over there. In their Office of Students and young consumers, where I was interim director for a number of years, um, and worked on complaints issues and I, um, will say this I love federal service. I really enjoyed my time there. um, I have nothing but the highest level of respect for people who dedicate their life to that when I know they could probably make more money on the outside, but their commitment to ensuring. Protections to the American populace is important to our country. And um it breaks my heart what has happened over the last couple of years with them, but um they have my love and support entirely. Um, and that's kind of how I got to ACR, um, uh, part of the incoming administration was to shutter agencies and they have, uh, been in a legal battle to shutter the Consumer Financial Protection Bureau, and many people started looking for new jobs, um, and that's kind of what brought me to ACR. I, OK, I have a couple of questions. Why, you start, you start. What is bocce? That's bocce is Italian lawn bowling. So basically there's a small ball you throw into the court of play, and then your team and the other team takes turns throwing larger, heavier balls to get as close to that small ball as possible. OK, OK. Another question I have, what was the last book you read or what is the book that you are currently reading? I am currently reading two books. Um, I am on the 4th book in the Heated Rivalry series, uh, the gay romance, uh, that had an HBO, uh, season recently on it. I have been enjoying those books immensely. And then my other book that I read, um, is a multicultural history of America. I have so many places I want to go that we didn't intend to go in-- this-- podcast. I have succeeded in my introduction. I can pretty much guarantee that the title is going to be bartending books, bocce and Bills. Um, little nod to the office. That was a fantastic introduction. Um, I can't wait to dig into more of it as we have more of these webinars. Um, all right, so we really want people to watch the webinar. I want to talk about how people can get at it. You can still register for it on the website, even though it's done, and that gives you access to the recording and the materials. Correct me if I'm wrong, but I, I believe that's how it works. So folks, if you haven't seen the webinar. Go back and watch it because this is not gonna be um sort of a full recap. But let's talk briefly about this as a structure and just what you're hoping people get out of it, um, and outcomes you might be looking for related to your own work at ACR. Why, why do these things? A lot of credit, I think, has to go to some degree to Scott for coming in and Taking a look as an outsider, what was GR doing? Why were we doing these things, in what format were we doing it. Um, for, for those that that may not be aware, there was a period of transition where, uh, the GR team was, uh, down to just one person, myself, um, for about 6 months there, and I didn't want to let anything drop off that we were doing, but I also didn't have a whole lot of bandwidth to be really strategic about why are we doing these things. So I kind of just said yes to everything. Um, and I have no regrets about that, but it did mean that by the time Scott came on, we were doing a quarterly webinar, and we were involved in podcasts, and we're doing state and regional presentations, and we're going to conferences. And while all of those things were important, we were doing so many venues that oftentimes the content at each venue was very similar, cause you just didn't have time to, you know, if, if I give one presentation on Monday and another one on Wednesday, not much has changed between those two, and even if something did change, I didn't really have time to go and research and refresh my my presentation. Um, so Scott came in and said, These are all important venues, but we are doing very similar content in each of these. Is there any way that we could look to continue engaging in all of these, but do so with more intention? Um, so, I'll, I'll let Scott expand on that, but I, I think this, this interview today is, is in part kind of extension of that, cause we were, we didn't want to just repeat what was said in the webinar, but we do think it's important that we give folks the opportunities to, to ask questions, to dive into it in a different format, and just folks consume content differently, right? Some, some person might be able to go to a webinar, but another person likes. The flexibility of a podcast in the morning commute. Uh, so we want to make sure to give people options for how they can stay informed. Yeah, so I think uh the benefit of me coming in without really having association experience or traditional GR experience with my background is that I could look at things and be like, why are we doing this this way? And, or I think this is dumb, we need to change it a little bit. And this is how we should change it. Like, I think the first um quarterly webinar we had scheduled was something like 2 weeks after annual meeting. And I'm like, nothing is gonna happen in 2 weeks for us to have an entirely new webinar that they didn't get at annual meeting. This doesn't make sense. So, and I'm super type A, so I wanted to schedule. So I thought a good schedule made sense that if we started off with a new GR presentation at the annual meeting, and then did something every 3 months after that to get us to the next annual meeting where we'd have a new GR presentation ready, that made the most sense. So this is our first one on that. Also, there are a lot of GR presentations we do at the state and regional level. And so, for that, we kind of retool with updates that GR presentation we did. Uh, at the annual meeting, which is a legislative component, a regulatory component, a kind of just what's going on, here's everything you probably need to know. So I wanted to look at something that would provide a different value in our quarterly webinar. So I thought maybe we could use it as a deep dive on particular issues that are happening, um, and so, uh, that was kind of what, at least for the first one that we did, uh. Made sense to do on a couple of topic issues. And then also looking at um as we engage with other ways that we can get GR information out there such as the Herd podcast, how do we also then provide additional information that's not just The GR update and not just the quarterly webinar update. And so, you know, following up on that as well as like kind of taking in some new directions that might be appropriate for your uh listeners also makes sense there. Uh, so with this particular one, it worked really well because kind of right, uh, before we started um working on the planning for the quarterly webinar, the Department of Ed. had the rulemaking on accreditation issues, which turned into some transfer of credit stuff and when we were at annual meeting, it had just started, so we didn't really have any information yet. But then as the process went through, we had a lot more information to give on how they're looking at transfer of credit and people started panicking, get scared, which I always say, don't panic yet, don't panic yet. I'll tell you when to panic. We're not there yet. Um, and we're not, we're not panicked yet, but we are escalating concern and looking at our current practices, uh, based on what the proposals are. And so, as we started kind of a leadership meeting, we did our first deep dive, and these are what the regulations said. And so we knew that we need to do a lot more of that. And so this gave us the first opportunity we could, where we could say, let's just look at that. And then I think two other things popped up that we wanted to add as well. There were some changes to our guidance to the Solomon Amendment, and how to give out information to military recruiters when they asked about drop lists. And then the duration of status uh regulations also dropped right before we did the webinar. So we thought it would be criminal if we didn't at least mention them and let people know what was in those regulations as well. But we were. Still able to spend most of our time talking about transfer of credit issues and then kind of get the questions that what I wanted was everybody to be like, this is what we do. Are we still gonna be able to do that? Because that not only lets us give them an answer, but let's just go back to the Department of Education and their process to say, this is where we think problems are gonna be that you need to clarify or you need to change your language so that they can actually make workable regulations. Do they listen to us? Did they or do they? Those are, I think, two different questions. Um,-- and-- sometimes we have a reasonable expectation that we will be listened to. Um, so I will say we were, we had some good conversations with the negotiators during the rulemaking process, and I believe that some of the changes that came out in the regulations in their final consensus language proposal. Or because we shared information with them. We shared the Learn Commission report as well as some other ACR um member oriented guidance, and they changed how they talked about some of the issues. They started talking about transferability versus applicability, which was not in their original proposal. So do I think that the people at the Department of Education are experts on transfer yet? No. But have they at least heard that they were talking about some of the concepts wrong? Yes. Going forward, when we go through that 30 day comment period and they write a final regulation, do I expect them to be like, oh, we've done something horribly wrong, we're gonna change everything? No, they, they almost never do that. But what we will get them to do is make some clarifications in their sub-regulatory. Portions of that final rule, that we can then take back and be like, see, they don't mean for you to do X, Y, or Z. They only meant this in this particular instance, and that will help us help schools implement those regulations. So they probably won't like, slash everything, be like, we're wrong, but they'll give us at least further guidance of like, well, we didn't really think about that. Our intent is this or that. I feel like Tashaw and I can relate to that as registrars. There might be policies or things that get put into place that we're like, uh, that's not a thing, that's actually in conflict with state law or that's gonna hurt students, and we can't go in and just tell people not to do it. Um, you got to use influence and make a difference around the edges, I guess. So, this wouldn't be hurt if we didn't talk about diversity, access, and equity. So, at a high level, um, with the topics that you were talking about, what are some of the key implications of duration of status and the AI Committee's work or the Solomon Amendment work for diversity, access and equity? I, I love numbers, I love stats. I think that they, some particularly punchy stats always kind of sound good, but they also help you contextualize what it is we're talking about. Um, so, in a moment I'll, I'll get to those, but just briefly, what is duration of status for those that may not be familiar. Um, so duration of status is, uh, a long standing policy of the federal government that would allow students to be admitted to the US and to stay for however long it takes them to complete their program of study. Um, so if that took you 5 years, you could be admitted for 5 years. It took you 6, 644, sure. Um, the The Trump administration has recently enacted a change Department of Homeland Security that would create a set of fixed admittance that can not exceed a maximum of 4 years. So, uh, when we think about graduate students in particular, right, a lot of graduate programs are longer than 4 years, this is going to mean that those students would need to apply for, uh, an exception in order to get an extension beyond those 4 years, or any other students, not just your graduate students, but if your student wants to stay for longer than 4 years, they will need to apply and get approval. To do so. So Mike, can I pause right there because you said this during the webinar and my jaw dropped because when I think of 4 years, I think of undergrad. I don't think of a graduate. So just to clarify, this is all career levels, all matriculating career levels. Correct. This is all matriculated, uh, career levels. Uh, it also, the, the proposed rule also, or I can't even say proposed rule now, it is the rule, um, also. Create some barriers to uh transfer transferring institutions or to changing your course of study. So at the undergraduate level, students cannot transfer institutions, I believe it is within the first year. Um, at the graduate level, they can't transfer institutions at all. They need to get an exception to do so. Um, I believe at the undergraduate level they can't, uh, Change majors within the first year. So it's also within the first year and at the graduate level. That's correct. OK, thank you. They, they have to get a, they can't transfer or change majors at all at the graduate level without that, uh, approval. There's some other minor things, like it makes some changes to, um, in the past, after a student completes their course of study, they had 60 days to kind of, maybe they have to finish out their last month of their lease, pack up some things, whatever, right? They had 60 days to kind of get themselves situated and either leave the country, or if they were going to get onto an OPT program during that time, like that was their transition period, that has been shortened to 30 days now. Um, so, some other Subtle changes like that. And what this ultimately means is, uh, some huge disruptions for international student exchange. Uh, and in particular, speaking of OPT, that is a huge Incentive for students coming to study in the US or a lot of them. Um, there's an article I read recently that that looks at, in particular, Indian students. A part of their ROI, right, that the value of why they're coming to the US is on the backside, this, this assumption that they're going to get a US job, and that's what makes potentially the higher price of a US institution relative to what they may be able to get domestically worthwhile still for them. When you take away OPT or that the the that promise of kind of employment on the, the backside of it, it does fundamentally change the calculus of do I come to this US institution anymore. Um, so, Talking about access, uh, it certainly is going to mean that students from some students will just, it, it no longer makes sense to come to the US. They're not going to be able to afford it. It doesn't make sense for their family situation. Um, for the US economy, it's going to mean a huge hit. We do benefit from having these international students here. I'm sure it'll come no surprise to this group, um, but international students, they tend to pay the highest fare. So they in in many ways kind of subsidize our domestic students by paying those higher rates, but not just at the institutional level, the economy as a whole benefits from these individuals being here. Um, there is some, here's where I get into some of the stats that I, I referenced earlier. Uh A sustained loss of 1/3. This is analysis coming from the Peterson's Institute. The full Peterson's Institute for International Economics found that a 1/3, uh, sustained loss of 1/3 of the annual inflow of international students, which is a conservative estimate, right? They're giving a range here. This is the lowest end of their estimate. Um, would cost the US roughly 200 to $400 billion per year. That's 1.7 to 1.3% of our GDP or the loss of the entire state of Utah or South Carolina. If we just got rid of the entirety of the economic output of those two states. That is what international students on the conservative side contribute to the US. This isn't the tuition dollars, this is they're going out to eat pizza, this is they're getting gas at the gas station, they're buying clothing. Getting haircuts in your community, all of that. Um, I earlier I talked about OPT is kind of a huge incentive driving students to come to the US, so, um, Some stats around that. 1/3 of all STEM workers in a PhD program in America came here as international students and stayed. So, a lot of students, if they come here for graduate study, they're going to stay, and 64% of all international students at US universities work on OPT at some point during their graduate study. So it is by and far, it is a majority of those graduate students that are coming. Um, that are going to work in OPT. Mike, I just want to clarify here, when you say stay, you do mean legally through appropriate channels, correct? And not just that they are overstaying their visa, which is a concern that the administration continuously refers to in their opposition to duration of status. Yes, thank you for, for clarifying, uh, and in fact, I, I didn't pull out those. Numbers, but the, the article that that I'm pulling these from, from the Peterson Institute for International Economics, uh, does go into uh an analysis of the administration's claims of rampant fraud in OPT, uh, and there is no evidence to suggest that there is rampant fraud in the OPT program. It is, we're talking, you know, less than 1% point, um, well below anything that that we would call systemic for a fraud program. I can keep talking, but I also don't want to take up too much time.-- I-- wanna, I wanna interrupt and kind of go back to the, the 4 years in that career. I mean, I cannot think. Of a PhD program that lasts 4 years. Um, are we talking about, like, in the terms of the practical application of this to students, is it OK, you're done with your coursework, in 4 years, you can leave the country and continue working on the rest. You've done your sort of milestones except for your dissertation, or is it like you are done and graduated in 4 years? I believe it's you have to be finished with your program of study. Well, I, I, I'll also say this, they do have an appeals process. I think the intention is that people who are in programs longer than 4 years will at the 4 year mark appeal because of the length of their program to remain in there.-- They're just not automatically-- guaranteed if they come at all. I mean, this is right, like the intention isn't just to, to regulate things when they're here. It's just, um, it's to have an impact on people coming at all. Correct. How can institutions manage the resistance when we're trying to update the governance processes or implementing any new systems? You know, I, I think that coming with the knowledge of what is happening both statutorily and regulatorily is a strong argument when you need to make changes and get buy into things. Um, I, I think this especially in terms, not so much of the duration of stuff that Mike was talking about with, with, but with the accreditation transfer regs. If you need to be making changes on your campus based on what these new regulations are going to be. Having something that says, this is what the Department of Education is now going to require of us is a strong, strong push to get recalcitrant people to say, OK, I guess we have to, even if I don't want to, um, you know, it, uh, so much of my career has been like, you can't just say it's because the federal government wants you to do it, but sometimes the answer is the federal government wants you to do it. I would add on the the I, I think that speaks kind of the institution side, the, the flip side, the student facing. Oftentimes when there's changes in processes or new systems, it, it's can cause confusion for the student navigating that. So I, I know that it's Probably an additional ask, right? To say, if we're going to make this system update, we also need to maybe hire an additional advisor, right? That's an extra resource your institution then has to commit to. But I, I, I do think it's worth having the conversation. If we're going to make these changes, here, I'm thinking about duration of status. I might have a whole cohort of graduate students who now I need to educate them on, you will need to apply for an extension to your duration of stay at some point during your program. Here's person A, who's gonna work with you when that time comes, cause it will come. It is not an if, it is a, it will come. How do we as an institution help you navigate through that. I think there's probably also an opportunity for registrars to, you know, partner for enrollment professionals to partner with other people and be like, help an institution understand the impact that this is going to have on the population as it stands today. So, um, so one clarifying question I guess is when the, with the regulation being in place, is it forward-looking? Does it look back at who is here already, to whom, what is the, the population to whom that applies? People starting in fall 2026. It, it will apply to everyone ultimately. Uh, the regulations go live, I believe, on September 15th of this year. And so anyone that comes to the United States after September 15th will automatically fall under the, the new, uh, program. Uh, if you're already here, you're sort of grandfathered in until the point that you leave the country and come back again. And then upon your re-entry, they will then move you from duration of status into the new fixed term program. So, uh, it's not exactly a grandfathering because once you leave and come back, they, they're gonna update their records for you, uh, but you don't have to rush to go out and have anything updated before that occurs. When I, I wanted, you, you kind of hinted at the now this rule is final, which sparked me, it is final. I don't want in any way muddle that, um, but there is this thing called the Congressional Review Act, which allows Congress to, I believe it's within 90 days, correct me if I'm wrong, Scott. I think 60, but I'm not 100% sure on that. OK, within a certain period of time, 60 to 90, please don't quote Scott and I on this one. Uh, after a regulation goes into effect, is finalized, Congress has that 60 or 90 day period to say, we actually, we don't like where these final regs landed, we're vetoing this. After that 60 or 90 day period, Congress can't, so this isn't a permanently open that Congress can just go and kind of mark, take regulations off the books, nilly willy, but because this is a regulation that was very recently finalized, it does fall within this window. Um, now, is, is there any appetite for that in Congress? Is that likely to happen? No. Uh, there's not been a whole lot of discussion on the hill, but no, there is the potential for Congress to take action here, and there also is the potential for there to be some court action. Um, I, I, I talked briefly kind of about the economic impact of these rules. So one of the things that regulations have to take into account when being finalized is their economic impact, and there is some debate whether or not the Department of Homeland Security adequately weighed the economic impact of this rule when finalizing it. a court might take issue with that and say no, you did not give an adequate enough weight, we're tossing this out. You need to go back and do a full evaluation. Mike, while you were, uh, talking, I did Google search the answer. It is 60 days. Thank you. Uh, but to the listeners, I also, I, I, I'm going to be the bad guy here. Um, there is absolutely no chance that a congressional review act on this issue is going to pass this Congress. Uh, by and large, I think that, uh, the party in charge. Is supportive of these rules. So I don't want to get anyone's hopes up that Congress is going to step in here and say, no, no, let's, let's go back to our old system of duration of status. Um, in a future Congress, could they relook at this and implement legislation on that? Yes, they could. Uh, it would probably be not until the end of the Trump administration for a president who would be willing to sign such a piece of legislation. Um, if there is going to be any change to this, it would come through the legal system. Um, uh, while Mike and I have our ears to the ground, I haven't heard anything going forward about a legal, uh, challenge to this, uh, but I, I, it wouldn't surprise me that people are talking about it and determining whether or not it's a viable course of action. Well, it's still helpful to know the, how the sausage is made, even if the sausage isn't going to go through that particular step in the QA process. I really, I kind of like worked that metaphor out as I was saying it. I don't know that it works. What about, um, what about the AIM committee?-- What about transfer work and-- equity? Um, and I'm so glad you used AIM. DC loves its acronyms, doesn't it? Um, so just for those who don't know, AIMS stands for accreditation, innovation, and modernization. Uh, and that is what the Department of Education called the rulemaking around the accreditation issues. Um. In an interesting way with what I think is a completely unintended consequence here. I think that the transfer of credit regulations will actually be beneficial towards issues of access and diversity. Um, I don't think they intended that at all based on all of their other actions, but, um, if you can kind of go back on the history of this issue, for a very long time, for-profit colleges used to argue traditional colleges won't take our transfer credit and it's hurting our students when they're leaving our institution to go to another institution, and they fought left and right calling it discrimination of all sorts, um, and. Part of what the Trump administration did the first time around was, uh, and I know we're probably gonna talk about this a little bit later, they start removing terms like regional and national as far as how you talk about an accrediting agency, so that schools wouldn't be able to differentiate what type of accreditor was looking at a for-profit institution. Um, and then you kind of bring it to today, and There, there's a request or a requirement that that you can't not accept credits solely based on it being based on what the institution is or who their accreditor is. And in that they're trying to get to the same issue, they want you to not be able to say, well, this is, this is um accredited by an agency that really only approves for-profit institutions and so we don't want those credits at all, um. So if schools then will step back based on these regulations and look at the actual learning that happened in those courses. They could end up accepting a lot more courses from these traditionally for-profit institutions, and if you look at the demographics of who takes for-profit institutions, it's predominantly older students, it's predominantly women, and it's predominantly racial minorities. So you could see a lot more learner mobility in those populations as they're transferring between for-profit and not for profit institutions and seeing a lot more of their credits accepted at those institutions. Now, the caveat to that is, as I've told in all of our presentations, it doesn't mean that an institution has to take those credits, they just have to have a legitimate reason for denying that transfer of credit. It has to be academic in nature or performance based. It can't just be, well, it came from a poor profit institution or they came from this type of a creditor and we're not gonna do that. It has to come because it doesn't meet the curricular requirements of their institution. Um, so ideally. That should improve the transferability of credits for a variety of populations that traditionally go to those for-profit institutions, which should ideally reduce cost, it should ideally improve their graduation rates and improve them getting into a well-paying career afterwards. When when I think about the um the AI negotiated rule making and and access. I can't help but think of the ACA recently had a meeting of the assembly, previously known as tech and Transfer, and one of our plenary sessions was, uh, featured a panel of some students who had transferred, and they were talking about their experience as transfer students. Uh, and one very striking anecdote that that comes to mind from that was one of the, the students on the stage had committed to their institution of choice, their dream institution, not knowing whether or not any of their credits were going to actually transfer to that school or not. The accreditation regulations that we that we got do require that a student has to be informed, know the actual decision about their transfer of credits before they make a financial commitment to the institution. Um, so I don't, I don't have specific demographic who that will impact, but I do think that is actually a positive thing, uh, that students have to know before I make a financial commitment to this school, are you going to take my history one on one, or do I need to retake that at your school? And just to kind of piggyback off of that observation, there's a bigger transparency element overall to this too. So if you don't take my credits, you have to have a pub, you have to publish policy, right? And if you don't take my credits, you have to tell me why, right? And I have to, I have to be given the opportunity to appeal that decision. I think that was part of it as well. So, I appreciate you bringing up kind of the dichotomy of You know, on the one hand, we have the duration of status, which is really about closing doors as, as tight as they can be closed for a population of students. And then, unintentional though it may be, you have this like other thing that is opening the doors. Um, a little bit more. So I appreciate you highlighting that balance. You, you did mention, um, institutional versus regional accreditation, Scott, and at the leadership team meeting, I know this came up a lot. I remember there was a series of questions and it was like, no, no, no, no, there is no more regional. So, uh, what is it like to clarify that confusion, uh, what's the difference, right? And you talked about why it matters, but just expound on that a little more. Yeah, um, and I, I'll, I'll give myself a little plug here in our most recent, uh, issue of Connect that went out, I think yesterday or the day before. Uh, I have an article in there specifically talking about how the term regional accreditation has gone away. Uh, so people want a, uh, written form that uh references some of the actual documents there. I highly recommend looking at that document. Um, and I'll be asking this, so this again started with the first Trump administration when I was at the Department of Education and I worked on the rulemaking of that dealt with this issue. Um, and the department was, uh, uh, the Trump administration was frustrated and upset that they felt regional accreditors had this kind of monopoly on accreditation, because they're like, we're regional accreditors, and we do everything within a geographic area, and you really can't as an institution, go somewhere else. They thought this stopped innovation, they thought this drove up, drove up costs. And so part of. What they did in their first accreditation, um, reform was to remove the geographic definition from all accrediting agencies so you no longer have the definition of a regional versus a national, uh, in, in the term of accreditation and I thought. The communities had finally learned about it, they had moved on from it. And I was kind of very surprised when, you know, 6 years down the road, I'm at ACR at the leadership meeting, and I find out, start finding out exactly how many institutions are still using the term regional accreditation. Um, I thought it had just been fully implemented and people have moved on their merry way. Um, but no, apparently a lot of schools have just continued on using the term regional. Um, and I think that there are some nuts and bolts issues with that in that the department doesn't do it. So if you're referring to a regional accreditor, the regional accreditor no longer calls themselves a regional accreditor. Um, and the Department of Education is like, no, no, there are no regional accreditors anymore, so we don't know what you're referring to when you use that in your, in your various terms. So it would be possible that, uh, uh, the department could come back and look at a disclosure or a reason on something and be like, what are you talking about here? There are no regional accreditors, so what, what do you mean you don't, you only accept credits from regional accreditor? Uh, what is that? Um, I think there's a fundamental, uh, student facing issue which is it's been 6 years, that means. That people who are transferring now were never in could never have been in college when the term regional accreditor was used and therefore they don't know what that term is, and they, if they looked at their previous institution, there's no way to find out if they were regional accrediting because that that term should have stopped as well. Um, so there's a, a lack of information to the student about whether or not their credits would have transferred or not. The department has moved to the term institutional accreditor versus programmatic accreditors, and programmatic accreditation has always been a thing that was kind of the third wheel between outside of, uh, national and, um, regional, but regional and national accreditors are now just institutional accreditors. Um, at the assembly, uh, uh, on the panel that I led and moderated on, uh, learning mobility, uh, Heather Perfetti was there and she runs, um, uh, Middle states. And we, I asked her specifically um whether or not they've encouraged their members to move away from the term. Um, regional accreditor as well, and she was like, yes, we have 100% done that, um, and we've asked them to stop using the term. So I, I, I think that at this point, institutions should also stop moving away from that term as well. Um, in terms of the new regulations, uh, uh, we've gotten a lot of questions and pushbacks if they could still refer to things as like accrediting agencies previously known as. Uh, regional creditors, and my hesitation saying yes to that is that I think it still creates problems for the student who doesn't know that term, um, but also I think that it gets away from the, the real issue here which is you should have a curricular or academic reason for denying credit and not just who that accreditor is, um, and I think that the department's pushing us for that. I think that, uh, the, the spirit of the Learned commission report is also pushing institutions to that. So I think it's time for institutions to start actually looking at that and kind of making those changes. So they're doing the best by their students. I'm, I'm gonna play the devil's advocate here or the, the fly on the wall question. If people wanted to see a list of institutional creditors, where would they go on Department of Ed's website? No, I, I, if you give me a minute, I can 100% find that, I'm sure, uh. While you're looking for that, uh, you did speak to this on the podcast. We are preparing for our accreditation right now at UEA, um, and I think it, there was a question of when things would take effect and the timing of that. And your guidance, I believe, was, I mean, You should start looking at it now. Eventually, it's going to have an impact on you. Um, and in my mind, I was like, how, how will this affect us at the University of Virginia right now if we're having an accreditor visit in February, for example. So, do you have just kind of like that blanket advice for people as they're thinking about, cause this is all. This language is to accrediting agencies, right, around transfer, that they, these are the standards that they have to be looking at for institutions. So what should institutions themselves be doing? To prepare to respond to that language. Yeah, and, uh, before I jump there, Mike, I, I found the link with the Department of Education, and I don't think it will help anyone if I try to read the URL to them. Uh, it is a very lengthy one. But if one were to search, uh, institutional accreditors and Department of Education, it will take you to a Department of Education website where they list all currently recognized accrediting agencies. Um, do you know that it has to go through a process, uh, with an organization called Miki, which is a quasi-government advisory group, uh, that makes determinations on, uh, uh, who is approved for that, uh, but I would also specifically tell people 100% make sure you're going to the Department of Education's websites on who are the approved accrediting agencies and not a third party source. Um, and to switch over, Ingrid, to your question about kind of the processes that we're looking to play out with the accreditation regulations, um, I, I have breaking news, everyone, to be honest, I, I, as I learned yesterday afternoon that I think I, I've only shared with one other person. Um, so the Department of Education has sent the final regulations for the accrediting regulations to OPM, the Office of, sorry, not OMB. I always confuse the one I, I, I mean, OMB, um. Uh, and they do the final check of it, make sure everything's, all the T's are crossed, all the I's are dotted, and, and do some back and forth with the department to make sure they mean everything they're putting out there. It is the last dot before publication. Uh, we're probably talking at this 0.2 to 3 weeks out before that notice of proposed rulemaking comes out. Again, 30 day comment period. F rules still expected mid to late October of this year. Implementation date is going to be July 1st of 2027. Uh, ideally, that's when all institutions should be ready to go with everything in that regulation. All accrediting agencies should make all their changes for everything that applies to them. So there's a weird delay, right? Like, there are some things because there are some new requirements that will be directed towards schools, and those should be in place by July 1st, will the department come out and check them? If they do a program review shortly thereafter, they could, they could be like, show us your transfer of credit regulation or your policies. Where do you have it posted? You have, you should be ready to show them stuff. Um, by and large though, it looks like they're going to pass. Ownership of that type of oversight onto the accrediting agencies and so it may be different for each for each institution if you are accrediting agency is looking at you now, but they'll finish July 2nd, they could very well ask, show us all this new stuff. Your accrediting review might be in 4 years, and so you have extra time to kind of get to that point. Do not wait to get to that point. Do it as soon or as close to, uh, July 1st as you can, um, you know, you, you have from kind of November 1st to July 1st for that implementation. Do as much of it as you possibly can so you're ready for the official effective date on July 1st. You don't want to be late on that. So I have a question. Were there any questions that you didn't get to respond to or that you want to answer in more detail, more depth? That's a good question. Um, I, I, uh, from our quarterly webinar, I do wish we had gotten to go a little bit deeper into the duration of status. Um, it was kind of our last minute add-on topic, so we didn't quite get to get feedback from the right people. We had sold the, the webinar. We're going to talk about transfer of credits, and I thought that brought like a specific population to the webinar. So I'm not sure we did a great job in getting the right admissions people in front of us to talk about how the duration status will be implemented and what support they needed. So I would like kind of like, if, if admissions people out there listening to this podcast, email us and tell us what's going on and how, how we can better support you in that. Um, uh, part of, and, and, and I, I, I've been giving some pushback every so often because people are like, can you answer all these questions for me I have about our implementation. And, and I have to push back a little bit, um, and trying to explain the process to the department that we're not at a point yet I can give you full guidance on how to be successful implementers of these regulations. Um, the notice of proposed rulemaking, while they'll have that regulatory language that everyone came to agreement on, they, they have this part called the preamble, and it's the department talking about how they interpret everything in that language. And they say, well, the, the, the department thinks this or the department thinks that, we do not think this or that. And so we're waiting kind of to get that information before we can better provide feedback to people to be like, OK, it's clear they mean this, it's clear you're OK with that. And so we're kind of like in that holding pattern that I know we're gonna have to go back shortly after it's published and start having those conversations again. Um, I think topic wise though, in, in Washington DC, like that's the big stuff that's going on, right? Like, I, I think. Congress is ready to go have their midterm elections and see what happens. Um, primaries are almost over. I think we still have a couple more weeks of that, but by and large, so many incumbents have lost or decided to run for other offices or not run at all. Um, things are kind of at a standstill. It, uh, the House, I believe, is in recess. The Senate starts in 2 or 3 days for their month-long recess. Um, not a whole lot's going to get done when they come back. I think that they might try another reconciliation package. We'll see if it passes. I, I'm not hopeful, but I'm not hopeful that Congress does much nowadays. Um, so, so we'll see. I don't, nothing, nothing as big as like the one big Beautiful Bill Act will, will pass. There won't be that much happening. So I don't think there's any other topic issues that I think we, we missed. But Micah, if you have thoughts on On that, please. I, I think you hit the nail on the head with a lot of the questions that we, that are still pending that we have received are ones where we've had to politely say like, well, we don't know, great question, we'll make sure to ask the department when we ourselves submit comments cause we just don't have enough right now. I'll also say, uh, say this to that, um, I think everyone wants like a specific answer to all their questions, and sometimes the best thing to do is not ask the question. Uh, if there's significant belief that some practice you have will meet what their requirement is, it doesn't benefit anyone to ask them to actually pontificate on it so that they can come back and say, no, no, that's not what we mean. You just go through with it and be like, no, no, we're meeting it because we say X, Y, and Z meets this requirement, and then you can fight them later on. And so I know people want like a white or black answer on this, but sometimes there's just gray area that you kind of have to navigate within, and that's where a lot of this will end up being, I think. I have another question. If we all left this pod and did one thing to both support our institutions and students with all of this good government relations context, what could that one thing be? Mike, I'll let you go first if you want. Oh yeah, no, sure, sure. Put, put, or, or if you need more time, I'm happy for the tough one. Mike, Mike needs more time. I understand. I'll go first. Um, I would say. Understand how easy it is to be an advocate. Um, you know, so often I think we think, no, I don't have time to be like fully involved in this government relations thing. I, I, I just have to do my own job. I've got life at home. But, like, you can easily on your drive home from work, set up the call to your phone and call your congressional office and leave a voicemail. You don't even have to talk to someone, right? Like. I, I'm a, I'm a surprisingly being a bartender and a government relations expert, I'm an introvert. I hate talking to people unless I have a plan. And so, you know, sometimes like on my walk home, I'll call who I want to talk to in their office and be like, be like, yeah, you know, I'm Scott Hilder, I'm a constituent. I think X, Y, and Z about this issue. Thanks for listening to me and hang up. It it takes 5 minutes. It's simple to do. You can call, you don't even have to do, just do it about higher education. You should do any issue that you're passionate about. It takes so little time to call a number and leave a voicemail. You don't have to converse. And if you do reach someone, that's great. The person on the line isn't going to debate you. They're just literally there to take that message. So they'll be like, Who are you? Are you a constituent? Like maybe ask for your zip code, and they'll say, and what, what would you like to leave for the congressman or the congresswoman? And they'll take the notes as you say, like you could scream at them, you cannot scream at them, don't scream at them. They're nice. People, they're, they're just doing their job. Uh, you're not, you're not getting the actual decision makers. Um, but it's so easy to do that, like, uh, on our, um, advocacy center, you can pre-populate an email to automatically send, you just have to give them like your address. It's so easy to do. We have pre-populated here on a number of issues. Um, there's just so many ways and it's so simple to be an advocate. People just think it's a lot more than it is. And so anyone can be an advocate, and it takes so little time in your day to do. I similar vein, and probably one that I've said before, uh, but I, I think it's worth repeating. It's OK to feel overwhelmed when reading into this stuff, but it is important that you still stay engaged, that you don't tune out, right? Like I, I Scott and I, our entire days in large part, are centered around the news cycle. I would be lying if I stood before you guys today and said, and I, like, the world is peachy, and I don't have any worries about the future. But I think there's something human about that, right, like to, to feel worried is is that shows that you care, that you're engaged with the issue, that you're aware of its impact, that you sympathize with that impact. So I I would really just encourage people, like, yes, Scott's done a great job pointing out how easy it can be to be an advocate, but at the bare minimum, stay engaged, don't turn off. I know we all want to turn off the news, and that doesn't stop the news from happening though. Now just you're not in the loop when it does happen. You're just less informed, less able to react. Uh, keep leaning in. Again, I, I don't want to say it's good that we all feel overwhelmed, but it's human that we feel overwhelmed. Join the Acro Exchange, find community. I think it's really important nowadays that we all have a support network, both professionally and personally. Um, I, I can't imagine anyone who's dealing with duration of status changes right now. Like, I would need A squat rack and just like a screen room, screen room somewhere in my office, probably if I was, if I was having to advise students about that one, but like that's OK. That's, that's human, keep showing up, engage with us. Um, we try our best to make a transcript and all of our other communications in layman's terms. Uh, so we are talking about these high level concepts, but we are trying to break it down, make it easy for, for people to digest. Uh, and continue to engage with us. Scott mentioned a few times, like, send us emails. You can always reach us at GR@CR.org. We are going to be writing some comments, uh, once the aim in PRM comes, that what comments ACR ultimately says is informed by member feedback. So if you guys are I'm, I'm starting to work on this with my institution. Here's what I'm thinking right now, is, can you just let me know, am I right or wrong? We're happy to receive that, that helps inform what we are going to say to the department. Um, yeah, lean in. It, it's OK to feel overwhelmed, but it's not OK to, to sit out because you're overwhelmed. And, and on that topic, I will say, uh, don't wait for that notice of proposed rulemaking to be published before you send us what you're thinking. I have already started comments, um, and so, uh, the more you send me, the, the more time it will take me to go through and make sure I incorporate that. Um, and the other recommendation I give that, uh, I think Mike missed is, uh, Mike and I are fun people to present. And so following the Scott and Mike Roadshow is always, uh, a, a thing that you should do, uh, to help brighten your day. We have upcoming engagements with West Virginia Acro, Oklahoma Acro. New England cro, uh, Pacific Acro, and our next quarterly webinar is tentatively scheduled now for November 11th. Uh, so always great to start putting that on your calendar so you can, uh, come see the latest, uh, uh, magic act that Mike and I do where we turn, uh, the darkness of Washington DC into a bright shiny day. To your point, Mike, about, uh, being overwhelmed and Scott about you guys being fun, I really do want to commend you for being both, for being so informative, so accessible, and even though this stuff is intense, I feel like it takes the temp, the way you talk about it takes the temperature down. And I'm really, really grateful for that. It's allowed me to approach this more proactively in my institution. Yes, agreed, agreed. I do want to say one thing. Being that we're all like local, uh, Scott, can we meet you at the bar? You certainly can. I work every Friday night. Oh my gosh. Thanks for listening to another episode of Heard. We'd love to hear from you. Please send us an email at heard@acro.org with any feedback you have for us or show ideas. This episode was produced by Doug Mackey. Thanks, Doug.