Comments: Proposed Revisions to the Education Department General Administrative Regulations (EDGAR)

On behalf of the American Council on Education (ACE) and the undersigned higher education associations, we write to share our significant concerns with the proposed revisions to the Education Department General Administrative Regulations (EDGAR).1 These revisions would incorporate and expand many problematic provisions that were included in the May 2026 Office of Management and Budget (OMB) proposed rule on Uniform Guidance,2 codifying historic and harmful changes to how the U.S. Department of Education (the Department) operates, competes, and funds its competitive and formula grants.

Over nearly 70 years, Congress has established and funded foundational programs in higher education, career and technical education, and workforce innovation to support college access and success for all students, and to support colleges and universities in serving their campus communities. As part of sustaining the strong framework of higher education and workforce development programs that Congress creates and funds, the Department has a statutory obligation to faithfully uphold congressional intent in program implementation.

Through EDGAR, the Department establishes the foundational regulations for the administration of grant programs. Over the past 50 years, these rules have periodically been updated to better align with statutory changes to grant programs as authorized by Congress. However, the Department’s proposed revisions would instead incorporate and build upon the recently proposed OMB rule on Uniform Guidance, codifying a range of harmful changes that would weaken selection criteria based on objective merit, create significant financial risks for institutions of higher education, diminish transparency in grantmaking, and create misalignment between grant selection criteria and the purposes of programs authorized and funded by Congress. It appears the Department is inappropriately incorporating and implementing parts of the OMB rule in direct opposition to recent actions by Congress blocking implementation of the rule until December 11, 2026… (download attachment for full letter).