The Education Trust is a national nonprofit that works to close opportunity gaps that disproportionately affect students of color and students from low-income backgrounds. Through our research and advocacy, Ed Trust supports efforts that expand excellence and equity in education from preschool through college; increase college access and completion, particularly for historically underserved students; engage diverse communities dedicated to education equity; and increase political and public will to act on equity issues.

These communities have been disproportionately affected by the simultaneous crises facing America: racism, a recession, and COVID-19. More than 200,000 people have died as a result of COVID-19, and deaths have disproportionately impacted Black communities. Staggeringly, COVID-19 has claimed the lives of nearly 1 out of every 1,000 Black Americans. The mortality rates for Indigenous Americans, Pacific Islander Americans, and Latino Americans also far outstrip the rate for White Americans. Black and Latino individuals are more likely to be essential workers than their White peers, exposing them more frequently to the virus. And still, despite doing the necessary work to keep our economy functioning, Black and Latino unemployment rates are significantly worse than those of their White peers.

These disparities are also present in our nation’s educational system. Over 16 million K-12 students lack access to high-quality internet and/or devices at home and are locked out of remote learning as a result. Before the pandemic, White households were significantly more likely to have access to internet than Black and Latino households, and that remains the case during the pandemic. As states face the increasing likelihood of crippling budget cuts, historical patterns indicate that the worst cuts are likely to be visited upon districts serving students of color and students from the lowest-income backgrounds in the country. There is much, much more to be done to respond to COVID-19 in particular, but systemic racial inequities plague our country, and the next administration must do more to address them.

This memo outlines federal legislative and executive policy recommendations made by The Education Trust to the next presidential administration. The policies described herein are not exhaustive, but are designed to communicate an overview of the issue areas we are focused on, with more specific actions included as well. It is our hope that both presidential campaigns will continue to view The Education Trust as a resource, and that the next presidential administration will work to implement equitable policies that increase educational opportunity for our nation’s students of color and students from low-income backgrounds at the early childhood, secondary, and post-secondary levels.

Students, families, and educators continue be impacted by the devastating effects of the COVID-19 pandemic, with the most vicious effects being visited on lower-income communities of color. The next administration should act as soon as possible to work with Congress to pass additional relief and continue executive actions designed to give relief to families, students, and educators. The Education Trust recommends the following legislative actions be taken to stabilize education budgets and increase educational equity for students most impacted by the pandemic:

• Congress should allocate at least $500 billion for state and local budget stabilization, including at least $175 billion for K-12 education, and at least $50 billion for higher education. It should also protect our nation’s most vulnerable students and educators from cuts by including maintenance of effort and maintenance of equity provisions to shield the highest need districts and schools from bearing the weight of these cuts, as well as set aside funds for extended learning time and high dosage tutoring to tackle the significant learning loss experienced by students during the pandemic, and for resources to address students’ and educators’ nutritional, social, emotional, and mental health needs.
• Congress should include at least $4 billion for the FCC’s E-Rate program to enable online K-12 learning access for millions of students during the pandemic, as detailed in the Emergency Educational Connections Act. Congress also should include $1 billion for a higher education emergency broadband connectivity fund for students from low-income backgrounds, as detailed in the Supporting Connectivity for Higher Education Students in Need Act.
• Congress should include a $50 billion child care stabilization fund, as detailed in the Child Care is Essential Act, to ensure providers can continue to operate in the face of widespread closures and financial pressure triggered by the pandemic.
• Congress should expand the Supplemental Nutrition Assistance Program (SNAP) to combat food insecurity exacerbated by the pandemic by increasing the maximum allotment by 15%; increasing the minimum monthly benefit from $16 to $30; eliminating work requirements that bar college students from accessing critical SNAP benefits; and preventing any administrative actions that would eliminate or weaken SNAP benefits or participation, including changes to categorical eligibility.
• The next administration and Congress must ensure that the Pandemic EBT program, which was recently extended and expanded by Congress, is implemented with fidelity and a focus on reducing food insecurity for our nation’s students and children.
• Congress must protect students’ civil rights in upcoming legislation by forgoing waivers of statutory provisions in the Every Student Succeeds Act (ESSA) and the Individuals with Disabilities Education Act (IDEA).
• The next administration or Congress should extend the student loan relief provisions included in the CARES Act into next year via legislation or an executive order. Additionally, the relief provisions should be expanded to all federal and private student loans and offer equitable and targeted debt forgiveness in recognition that the recession has made repaying student debt impossible for millions of borrowers.
• Congress should also allocate future COVID-19 relief funding for institutions of higher education using a measure of unduplicated headcount instead of full-time equivalent (FTE) enrollment, to ensure that the resources are inclusive of part-time students and are provided to the colleges serving students with the greatest financial need.

In 2021, Congress and the White House are uniquely positioned to use federal spending and executive powers to influence state and local education policy on behalf of our nation’s most vulnerable and historically marginalized students. It is critical that leaders in Washington, D.C., invest substantially in our nation’s public schools in response to the recession induced by COVID-19, and in doing so must use those dollars to advance educational equity across the following areas:

Funding

Systemic racial and economic inequities have resulted in districts serving large populations of students of color and students from low-income backgrounds receiving far less funding than those serving White and more affluent students. Despite inequitable funding formulas being declared unlawful — and advocates who have spent decades calling attention to the problematic nature of how America funds its schools — too many states continue this unfair practice. Across the country, school districts with the most Black, Latino, and Native students receive roughly $1,800, or 13%, less per student in state and local funding than those serving mostly White students, and states and districts spend approximately $1,000 less per pupil on students educated in our nation’s highest poverty districts than on those educated in the lowest poverty districts. While money alone will not solve the deeply embedded systemic inequities our students face, it makes a difference. Research shows that increased school spending leads to increases in educational attainment, higher wages, and a reduction in adult poverty, especially for students from low-income backgrounds. The Education Trust recommends the following actions be taken by Congress and the next administration to address this issue:

Legislative:

• Congress should support and incentivize states to increase equity in their school funding systems, including ensuring more funding to districts with higher student need or low-property wealth; ensure that dollars are used well to improve student learning experiences and outcomes; be transparent about the funding system’s design; and monitor funding to districts.
• Congress should substantially increase federal funding to support high-need schools by increasing funding for Title I of ESSA.
• Congress should substantially increase federal funding for IDEA to ensure that all schools have the
  resources needed to provide free and appropriate public education to students with disabilities.
• Congress should substantially increase federal funding for Title III of ESSA to provide schools with the resources they need to ensure English learners attain proficiency and meet state academic standards.
• Congress should reintroduce and pass the Strength in Diversity Act to fund grants to districts to implement strategies to address the effects of racial isolation or concentrated poverty by increasing racial and socioeconomic diversity.

Executive:

• The next administration should conduct negotiated rulemaking to define “supplement not supplant” to ensure states and districts are held to a meaningful standard for using federal funding in Title I schools.
• The next administration should leverage and expand existing data collections to improve the collection and reporting of school-level per-pupil spending data. This could include regulating or providing technical assistance to states to help them meet ESSA’s school-level fiscal transparency requirement, retaining spending data elements in the Civil Rights Data Collection, or expanding the NCES school-level finance survey to ensure more state participants.
• The next administration should promulgate guidance that supports states and schools legally pursuing desegregation strategies.

Transparency and Support for Struggling Schools

Not long ago, information on how schools were serving students from low-income backgrounds, students of color, English learners, and students with disabilities was difficult to discern, hidden behind averages. Parents had no way of knowing how well their schools were serving their children, equity advocates had no way of knowing whether students were getting the necessary learning opportunities and resources, employers had no way of ensuring graduates they hired would be equipped with the right skills for the job, and states had no real way of identifying schools that needed additional support and resources to improve. In 2015, ESSA, building on earlier federal legislation, challenged states to refine their accountability systems to provide the right combination of pressure and support for school improvement. The law leaves many key decisions up to states — decisions about what to measure, how to communicate how schools are doing on those measures,
how to identify schools that need to take action to improve for any group of students, what to do to support school improvement efforts, and what to do if schools don’t improve — balancing the federal and state role in the education of our nation’s children. As multiple pandemics — systemic racism, COVID-19, and economic uncertainty — further disrupt this school year, there is an urgency for all stakeholders, families, and teachers to understand the ongoing impact on students’ learning through a variety of measures of student achievement and opportunity. There is still more that the federal government can do to ensure that traditionally underserved populations are getting the support and resources they need to succeed. The Education Trust recommends the following actions be taken by Congress and the next administration to address this issue:

Legislative:

• Congress must conduct oversight to ensure that ESSA’s civil rights requirements are implemented and executed as written.
• Congress should provide funding for state innovations in assessment systems and ensure these efforts require collaboration from communities, families, and students to make assessments better. These efforts must focus on preventing tests from being used for purposes for which they were not designed, continuing to reduce redundant or unnecessary testing, and ensuring that tests are unbiased.

Executive:

• The next administration should continue to ensure that statewide assessments are administered during the 2020-21 school year by declining state waiver requests due to the COVID-19 pandemic. These assessments aligned to grade-level expectations are critical not only to helping families and educators understand how well students are learning, but also to supporting policymakers and leaders in identifying the places that are seeing promising results for all students so we can learn from those places.
• The next administration should promulgate regulations and issue guidance concerning school accountability, school improvement, and state and local report cards under ESSA that emphasize the use of multiple measures for each group of students, require states to pair assessment and accountability systems with real action to address the systemic inequities these measures bring to light, and ensure greater transparency for parents, families, and communities.
• The next administration should issue guidance to states on how they can use data on multiple measures, including measures of student learning, to identify schools that need additional support in the 2021-22 school year.

College and Career Readiness

Advanced coursework opportunities can set students up for college and career success. When students are given access to advanced coursework opportunities, they work harder, are more engaged in school, and in turn have fewer absences and suspensions and higher graduation rates. The Education Trust published a report earlier this year titled, “Inequities in Advanced Coursework: What’s Driving Them and What Leaders Can Do,” which shows how Black and Latino students are systemically locked out of advanced coursework opportunities in elementary, middle, and high school. The core of the problem is both that the schools that serve mostly Black and Latino students do not enroll as many students overall in advanced classes as schools that serve fewer Black and Latino students, and that schools that do offer advanced coursework opportunities, especially racially diverse schools, deny Black and Latino students access to those courses. These problems are not inevitable — when students of color have the opportunity to enroll in advanced courses, and their teachers receive training and supports, these students thrive alongside their peers. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should support and incentivize states to advance equity in access to and success in advanced coursework, including using data to identify barriers to enrollment, setting clear and measurable goals, investing in expansion of advanced coursework opportunities, requiring and supporting districts to take similar action, and supporting Black, Latino, and low-income students’ success in advanced courses. One important first step would be to reintroduce and pass the Advanced Coursework Equity Act, which would establish a grant program for states and districts to address equity gaps through instituting equitable enrollment mechanisms, increasing enrollment in advanced courses, covering the costs of advanced coursework exams and materials for students from low-income backgrounds, and preparing and supporting educators to teach these courses, all while setting clear and measurable public goals to achieve.
• Congress should increase ESSA Title IV funding to allow for more students of color and students from low-income backgrounds to access and get credit for AP/IB courses.

Executive:

• The next administration should disseminate guidance on equitable strategies for enrolling more students of color and students from low-income backgrounds in advanced coursework opportunities, and guidance on ensuring undocumented students are not denied opportunities to participate in dual enrollment programs.
• The next administration should ensure that the Civil Rights Data Collection contains data elements pertaining to AP course taking and exam success rates and credit recovery participation, and add data elements to collect dual enrollment and CTE enrollment and credential earning by race, ethnicity, income, English learners, disability status, and gender.

Educator Equity and Diversity

Research shows that teachers are the single greatest in-school factor influencing student success. Students with the strongest teachers receive what amounts to months’ worth of additional learning each year. In addition, all students benefit from a diverse teacher workforce, and the benefits of teacher diversity can be especially important for students of color, who are less likely to be chronically absent or suspended from school and more likely to be recommended for gifted and talented programs, graduate high school, and consider college when they have had a teacher of the same race or ethnicity. Unfortunately, thousands of Black and Latino students attend a school where they have no same-race teachers. Even larger percentages of White students attend a school without a Black teacher and/or Latino teacher. As of 2012, approximately 51% of public school students in grades K-12 are Black, Latino, Native, or Asian/Pacific Islander, yet only 20% of teachers are Black, Latino, Native, or Asian/Pacific Islander, and we know the numbers of students of color are going to continue to grow.

The role of Historically Black Colleges and Universities (HBCUs), Minority Serving Institutions (MSIs), Hispanic Serving Institutions (HSIs), and Tribal Colleges and Universities (TCUs) in producing teachers of color to help serve that growing population of students of color cannot be overstated. HBCUs, TCUs, and MSIs, collectively, award only 11% of the nation’s bachelor’s degrees in education, yet they produce more than 50% of the bachelor’s degrees earned in education by Hispanic and Native Hawaiian and Pacific Islander students. HBCUs graduate approximately 50% of the nation’s African American teachers with bachelor’s degrees. HSIs prepare nearly half of all Hispanic teachers, and along with other MSIs, constitute a vital pipeline to maintain diversity among our nation’s teachers. There is also a growing need for bilingual teachers to help teach English learners, which comprise 10% of all public school students. As of 2019, 31 states and the District of Columbia reported having teacher shortages in the areas of bilingual, dual language immersion, and English as a Second Language. Additional investments in successful programs are needed to continue to meet the demand of a diversifying national student body. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should support and incentivize states to establish clear goals at the state and district levels to increase access to strong and diverse educators; target resources to the districts and schools that struggle the most to provide students from low-income backgrounds and students of color with access to strong and diverse teachers; target resources to diversify the teaching workforce and to address bilingual teacher shortages; set high standards for how teachers are prepared and licensed to improve teaching quality for students in high-need schools and in historically underserved groups; and make educator quality and diversity data more visible and actionable.
• Congress should increase funding for HBCUs, HSIs, TCUs, and other MSIs, as well as increase funding for Higher Education Act (HEA) Title II-Part A to support state, local, and institutional efforts to recruit, retain, and support teachers and school leaders of color, including establishing pathways for teachers from community colleges into four-year programs and creating teacher training programs to respond to bilingual teacher shortages.
• Congress should also fund the Augustus Hawkins Centers of Excellence Grant program for the first time. This program would provide critical funding to HBCUs and MSIs to provide increased and enhanced clinical experience and increased financial aid to prospective teachers of color, who, as detailed above, face higher burdens in college access and affordability than their White peers.
• Congress should improve HEA Title II data reporting requirements by passing legislation to include program completer data, licensure pass rates, placement rates, and alternative certification programs data, all of which should be disaggregated by race and ethnicity.

Executive:

• The next administration should disseminate guidance on programming related to increasing the racial and linguistic diversity of the teacher workforce, including best practice guides on how to set up Grow Your Own programs, forge high-retention pathways, create supportive and inclusive mentoring, and share culturally responsive, anti-bias school leader resources.
• The next administration should disseminate guidance that would encourage school report cards to contain information on teacher demographics, teacher experience, and teacher certification.

Early Childhood Education

Unfortunately, the racial and socioeconomic inequities within our early child education (ECE) system begin before children enter kindergarten. Majorities of Latino families and 60% of American Indian and Alaska Native families reside in child care deserts. By comparison, the areas that are least likely to have child care shortages are high-income suburban neighborhoods, which tend to be predominantly White. Even when families of color have access to child care services, the cost — which may take up to 116% of a low-income family’s household income — can be prohibitive without financial assistance. Research on comprehensive, high-quality, birth-to-5 early childhood programs for historically underserved children found that they yielded a 13% return on investment per child annually, through better education, economic, health, and social outcomes. However, when states do fund high-quality preschool programs, access is often lower for Black and Latino children, who are underrepresented in several such programs. Compared to early learning programs attended by White children, programs attended by Black children are, on average, lower quality, and therefore aren’t associated with the many positive outcomes linked to high-quality early learning opportunities. Young children of color who do have access to early childhood education are also pushed out of the classroom at alarming rates: Black children are disproportionately suspended and expelled from early learning settings, even though such practices are harmful and ineffective. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should make significant investments in the early childhood education system by reintroducing and passing the Child Care for Working Families Act, which would subsidize child care for all families within 150% of a state’s median income and below, ensuring they spend no more than 7% of their income on child care. The bill would also fund pre-K expansion.
• Congress should increase funding for existing programs that can help meet the need for quality early childhood education, including Head Start, Early Head Start, Preschool Development Grants Birth through Five, and the Child Care and Development Block Grant.

Executive:

• The next administration should issue guidance on how best to invest Title III funds to promote research-based dual-language immersion models for dual language learners in ECE.
• The next administration should issue guidance on how best to ensure quality standards for early childhood education are culturally and linguistically competent, including detailing how to design standards that include input from people of color and multilinguistic people.

Access to Safe, Equitable, and Positive Learning Environments

Recognizing that school is where students spend the bulk of the time learning about themselves, their emotions and behaviors, and how to interact with others, over 90% of schools and districts report that they are working to support the social and emotional learning of students. Studies also show that social and emotional well-being is inextricably linked to the context in which students develop and the relationships they build over time. Too often, approaches to supporting social and emotional learning in schools ignore context, focusing solely on building specific skills (e.g., lessons on controlling behavior or emotions). Ignoring context carries significant risks, especially for those students who are already underserved by our education system: students from low-income backgrounds, students of color, LGBTQ youth, students with disabilities, and English learners. Failing to acknowledge the influence of the learning environment or failing to address the processes and structures in schools that disadvantage some students, may do more harm than good.

To truly support all students’ social, emotional, and academic development with an equity lens, policymakers must first address adult biases and beliefs and the systems and structures in place before turning to skill-building programs. For example, in 38 states, the schools that serve more students of color and students from low-income backgrounds have fewer counselors per student than schools that serve fewer of these students, which puts historically underserved students at a disadvantage when social, emotional, and academic supports are needed beyond the classroom. Additionally, studies show that adult bias influences discipline decisions. Black students are disproportionately suspended, expelled, and arrested at school for exhibiting the same behaviors as their White peers. According to the Civil Rights Data Collection, Black students comprise only 15% of school enrollment, but account for 40% of students who receive an out-of-school suspension, 35% of those expelled, and 36% of students who were arrested at school. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should reintroduce and pass the Ending PUSHOUT Act and the Protecting Our Students in Schools Act of 2020, both of which create grant programs for states and schools that commit to ending discriminatory disciplinary practices and improving their school climates. Both bills provide resources to create more inclusive discipline policies, provide professional development to educators, and invest in counselors and mental health staff to implement restorative justice, positive behavioral intervention supports, implicit bias training, and other practices that are critical to creating inclusive learning environments. They also prohibit corporal punishment and seclusion, and severely limit exclusionary discipline and restraint.
• Congress should provide funding for states and districts to hire adequate and well-trained support staff (restorative justice coordinators, counselors, psychologists, nurses); provide meaningful professional development and coaching on topics such as reducing bias and anti-racist mindsets; improving working environments and conditions to retain educators of color; integrate student services or wraparound services at state and district levels; and ensuring equitable access to and supports for success in rigorous and culturally sustaining coursework.

Executive:

• The next administration should reinstate a strengthened version of the guidance issued by the Departments of Education and Justice in 2014 related to the nondiscriminatory administration of school discipline. This improved guidance should include directions on how to build anti-racist, anti-sexist, and anti-discriminatory schools; promote culturally sustaining and restorative practices as an alternative to punitive discipline; regularly hold anti-bias training for educators; invest in staff and structures that support student needs instead of structures that criminalize them; effectively engage students, families, and the community in the process of creating and implementing discipline policies; discontinue discriminatory dress and grooming code policies that can lead to sex and race discrimination; and use healing-centered engagement in place of punitive or deficit-based practices to support students who experience chronic stress or acutely harmful experiences.
• The next administration should disseminate guidance to states on how best to monitor and reform policies that disproportionately harm children of color, including corporal punishment, restraint and seclusion, and suspension and expulsion. That guidance should also advise on how to use existing federal funding streams to reduce harsh discipline practices and narrow racial disparities.
• The next administration should ensure that the Civil Rights Data Collection contains data elements pertaining to preschool discipline to include students who have been suspended once and students who have received one or more suspensions, as well as data on the percentage of students, teachers, and staff taking school climate surveys.

Nutrition Assistance

As of July, nearly 14 million children were not getting enough to eat, a number that dwarfs the number of children who did not have enough to eat in all of 2018 and is more than double the amount of hungry children during the peak of the Great Recession of 2008. Recent census bureau data reveals that Black and Hispanic households with children are now nearly twice as likely to be struggling with hunger as similar White families. Even prior to the pandemic, nearly 22 million children rely on their school to provide free-or reduced-price lunch every day; hungry children cannot learn. As touched on in other areas of this memo, Congress has recently acted to extend and expand the essential Pandemic EBT program, as well as summer and afterschool meal waiver authority for the rest of the 2020-21 academic year. However, there is much more to be done to ensure children and their families have enough to eat. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should act to reduce childhood hunger by making the Summer EBT program permanent, and build, expand, and invest in the program through child nutrition reauthorization or other legislative vehicles.
• Congress should increase funding for outreach and education to better connect families from low-income backgrounds to SNAP, WIC, TANF, and other federal nutrition assistance programs that reduce hunger and lift families out of poverty.

Executive:

• The next administration should reverse or decline to pursue administrative actions with respect to nutrition assistance programs like SNAP that place barriers between children and families having access to food.

In 2021, Congress and the White House are uniquely positioned to use federal spending and executive powers to make higher education more accessible and achievable for our nation’s most vulnerable and historically marginalized students. It is critical that leaders in Washington, D.C., act boldly to support our nation’s prospective and current college students, as well as student borrowers, in the face of the recession induced by COVID 19, and in doing so must also advance educational equity across the following areas:

The Pell Grant, Student Debt, and Federal Student Aid

The next administration should take bold steps to improve the Pell Grant, expand student debt relief, and ensure that applying for federal student aid doesn’t act as a barrier to entry for millions of prospective and current students. The Pell Grant program benefits over 7 million students annually and is incredibly effective in helping students from low-income backgrounds access college. Over one-third of White students, two-thirds of Black students, and half of Latino students rely on Pell Grants every year. Pell Grant dollars are also well-targeted to those in need: 83% of Pell recipients come from families with annual incomes at or below $40,000, including 44% with annual family incomes at or below $15,000.

However, the purchasing power of the Pell Grant has dropped dramatically over the past several decades. In 1980, the maximum Pell Grant award covered 77% of the cost of attendance at a public university, but today it covers just over 28%, the lowest portion in over 40 years. If the maximum award continues to stagnate, the grant will cover just one-fifth of college costs in 10 years. That stagnation has contributed to the ballooning and unsustainable level of student debt weighing down millions of students, with the most pernicious and damaging effects felt by Black borrowers. Additionally, there are growing numbers of low-income students who are being forced to stop out of college due to increased financial strain because of the pandemic, and fewer high school students are filling out the Free Application for Federal Student Aid (FAFSA) versus 2019. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should double the Pell Grant as a rational response to the enrollment downturn due to the pandemic and the steady erosion of the purchasing power of the award over time.
• Congress should also make structural reforms to Pell, including indexing the annual Pell Grant to inflation, as it was before 2017, and moving the program to the mandatory side of the budget to avoid potential discretionary cuts to a program that functions like a mandatory program.
• Congress should also expand Pell to include students who are incarcerated, through bills like the Expanding Educational Opportunities for Justice-Impacted Communities Act and the Restoring Education and Learning Act (REAL Act), and allow students who are recipients of DACA and TPS protections to access federal financial aid to maximize education opportunity and help close equity gaps.
• Congress should address the declining FAFSA renewal rate by reintroducing and passing legislation removing obstacles for students and their families, such as removing Question 23 that bars students with convictions for drug sale or possession from receiving federal aid (Beyond the Box for Higher Education Act), allowing students who are not in contact with their families to file without their financial information (FAFSA Fairness Act), and allowing low-income students to file FAFSA once and remain eligible for annual disbursements of student aid (File Once FAFSA Act).
• Congress should pass legislation to create a federal-state partnership to incentivize states to invest in making public higher education debt-free for all, while prioritizing support for historically underserved students (i.e., students of color and students from low-income backgrounds) and the institutions that serve them. This partnership should include additional funding for HBCUs, HSIs, MSIs, and TCUs.
• Congress or the next administration should pass or issue equitable, targeted debt forgiveness for millions of borrowers who are struggling with near insurmountable repayment burdens in the wake of the recession, many of whom are subject to massive generational disadvantages due to the racial wealth gap.

Executive:

• The next administration or Congress should pass or issue equitable, targeted debt forgiveness for millions of borrowers who are struggling with near insurmountable repayment burdens in the wake of the recession, many of whom are subject to massive generational disadvantages due to the racial wealth gap.
• The next administration should end federal student loan collection actions like the seizure of Earned Income Tax Credits, tax refunds, and wage garnishment, which can harm low-income borrowers.

Data and Transparency

There has been consistent bipartisan support for improving our current higher education data systems so they may provide more reliable, consistent, and useable information. A student-level data system, currently barred by federal law, would make data on critical measures of student success like enrollment, persistence, retention, transfer, and completion, as well as post-enrollment outcomes such as earnings and employment, much easier to obtain and disaggregate by race, income, gender, ancestry, and other key criteria. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should reintroduce and pass the bipartisan, bicameral College Transparency Act, which would overturn the ban on the creation of a student-level data system and create a new system that would be immensely important in helping policymakers design systems that promote equity.

Executive:

• The next Secretary of Education should conduct an internal review of their legal authority to alter the terms of program participation agreements that all institutions must sign to receive federal financial aid to include standards designed to promote equitable educational access and success for students from low-income backgrounds and students of color.
• The next Secretary of Education should promote the use of the College Scorecard and refine how data is presented by the tool to ensure that it is as useful to all students and their families by doing the following: reinstating both the earnings threshold metric and display of national medians within the tool; reporting disaggregated earnings data at least at one and 10 years after graduation for each program of study; improving the repayment rate measures to ensure the data is relevant to students and families; and continuing to work toward increased data quality on certificates.
• The next Secretary of Education should add the following aspects to the data collection activities conducted as a part of the Integrated Postsecondary Education Data System: increase the differentiation of short-term credentials and aligning program definitions with the Higher Education Act; include distance education enrollment in the 12-month enrollment survey; and add disaggregates to the 12-month enrollment survey to reflect students’ enrollment intensity and first-time or transfer status.

Student Supports

Wraparound, evidence-based support models like the City University New York’s (CUNY) Accelerated Study in Associate Program (ASAP) can be transformational for students and close racial equity gaps. In New York City, ASAP nearly doubled three-year graduation rates for participants, up to 40% from 22%, and drove down the cost per degree by 11%. These findings were replicated by three pilot programs in Ohio, which also nearly doubled three-year graduation rates, increased transfer rates to four-year colleges, lowered the cost per degree, and showed positive effects on enrollment, full-time enrollment, and credits earned. Building on this success, additional ASAP pilot programs at two West Virginia colleges began operating at the beginning of 2020. Investments in historically under-resourced institutions to support the implementation of evidence-based strategies that improve completion for students from low-income backgrounds and students of color are essential to making lasting, positive change for historically underserved students.

Additionally, students who are hungry cannot learn, students who lack housing security cannot learn, and students who cannot connect to the internet at home cannot learn. A 2018 survey of over 86,000 students indicated that 45% of college students were food insecure in the prior 30 days. The same survey found that 36% of university students, and 46% of community college students, were housing insecure in the past year. Furthermore, prior to the pandemic, 79% of White households had broadband access, compared with only 66% of Black families and 61% of Hispanic families. We also know that college students returning home for the pandemic risk being unable to continue their education due to a lack of access to high-speed internet. When asked in a recent survey, 57% of college students said that accessing a stable, high-speed internet connection has been challenging. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should reintroduce and pass the Community College Student Success Act, which would provide grants to community colleges to develop and implement ASAP-type programs.
• In addition to expanding ASAP, there are also promising, evidenced-based practices around emergency student aid and microgrants that deserve further study, and Congress and the next administration should support the development of these practices as well.
• Congress should combat food and housing insecurity by doing the following: making it easier for college students to enroll in SNAP by eliminating the 20-hour work requirement that acts as a barrier for thousands of students; funding a grant program to enable colleges to identify and meet the food and housing needs of their students; directing the Department of Education to coordinate with other federal agencies to identify students who might be eligible for certain federal benefits and coordinate efforts to enroll students in those programs; and reversing and preventing harmful cuts or administrative actions negatively impacting access to SNAP.
• Congress should reintroduce and pass the Supporting Connectivity for Higher Education Students in Need Act, which would provide federal support for HBCUs, TCUs, HSIs, and other MSIs, as well as rural-serving institutions to directly help students in need pay for at-home internet connections and devices for students.

Executive:

• The next administration should issue guidance to institutions on how best to identify student support needs on campus and implement evidence-based policies to improve outcomes for historically underserved students.

Consumer Protections and Accountability

The first step in creating an equity-focused accountability system is maintaining and strengthening the protections available under current law. There is bipartisan, bicameral support for closing the 90/10 loophole that sets up veterans as targets for predatory for-profits by not counting veterans’ educational benefits as federal dollars for the purposes of the rule. Additionally, the recent gainful employment regulatory changes by the Department of Education removed the ability to hold accountable continuously poor-performing career education programs. The prior rule was effective in identifying “high debt to low income” for -profit career education programs disproportionately negatively impacting students of color who constitute over half of the undergraduate enrollment at for-profit colleges. Finally, the recent borrower defense regulatory rewrite all but eliminated the right of defrauded or misled borrowers to get their federal loans discharged. The prior version of the rule granted students automatic group discharge, reasonable evidentiary standards, a longer window of time to file a claim, and preserved their Constitutional right to access the court system. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should close the GI Bill loophole within the 90/10 rule, and move the rule back to 85/15, as it was first conceived in 1992, to protect veterans from predatory behavior and raise the bar for for-profit schools to show market viability before continuing to receive taxpayer support.

Executive:

• The next administration should reinstate the 2014 gainful employment rule to help protect students of color and students from low-income backgrounds from being loaded up with debt from poor-performing programs.
• The next administration should reinstate the 2016 borrower defense rule to ensure that defrauded and misled borrowers can obtain justified student loan relief through a fair and accessible process and maintain their access to the courts if necessary.
• The next administration should form a task force to examine the best ways to construct and implement a higher education accountability framework that would do the following: establish minimum standards for institutions regarding the enrollment rate, performance, experiences, and outcomes of historically underserved students (i.e., students of color and students from low-income backgrounds); provide rewards for institutions making continual progress toward reaching their ambitious access and success goals regarding those metrics; sustain and increase investments in historically under-resourced institutions to support evidence-based strategies to achieve those goals; and enforce meaningful consequences for underperforming institutions that after getting needed resources, time, and support, fail to meet minimum enrollment and performance standards.

Access to Safe, Equitable, and Positive Learning Environments

The federal government has a vital historical role as the protector of civil rights and safety on college campuses. Colleges are venues for the exchange of ideas and the development and growth of students, not places where discrimination, hate crimes, or sexual assault are condoned. We support federal policies that encourage institutions to support a healthy campus racial climate, based on how accepted students feel on campus, how often they are able to engage across lines of difference, and how well the university supports diversity through events, clubs, and policies. The Education Trust recommends the following actions be taken by Congress and the next administration to address these issues:

Legislative:

• Congress should allocate resources to ensure colleges are conducting regular surveys of students and faculty on campus climate, and those responses should determine how to select and implement policies to ensure campus safety and equitable treatment.

Executive:

• The next administration should rescind the recently promulgated Title IX regulation and replace it with a new regulation that does not unnecessarily burden the victims of sexual assault by allowing colleges to raise the burden of proof in sexual assault cases and increase the odds of additional trauma for students created by processes like cross examination.
• The next administration should ensure that data collections administered by the Equal Employment Opportunity Commission and Offices of Civil Rights includes indicators that track and report incidents of bias or violence on campus to help inform Congress and the Department of Education as they look to address systemic racial and gender discrimination on America’s campuses.