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DOE’s proposed regulations would destroy study abroad opportunities for US college students

I’ve always said that study abroad changes lives, and that changed lives change the world.

The unintended consequences of the proposed regulations are "massive" for study abroad operators, according to IES Abroad. Photo: pexels

"Every study abroad program, no matter the operator, relies on overseas sub-contractors to deliver critical on-the-ground services"

As someone who had the opportunity to study in another country, worked as an economist engaging with different cultures, served as a US college president seeing first-hand the benefits of global studies, and now CEO and president of a study abroad organisation, I can say that I would not be where I am today without my international experiences.

Our consortium of 250+ colleges and universities and more than 200,000 alumni since our founding in 1950 are testimony that study abroad is a powerful, meaningful experience.

The world is a challenging place at the best of times, and these aren’t the best of times. We’re at a particularly pivotal moment in history where we need thoughtful, interculturally effective, empathetic global citizens more than ever.

However, recent guidance proposed by the Department of Education would make it impossible to proactively cultivate more capable global citizens for the future.

The guidance, referenced in DOE’s Dear Colleague letter on February 15, and updated on Tuesday, February 28, has severe unintended consequences that must be addressed before they are written into policy on September 1.

“As currently drafted, the guidance will devastate the study abroad field”

As currently drafted, the guidance will devastate the study abroad field, making it impossible for American students to experience the benefits that come from greater knowledge and understanding of other languages and cultures, hindering their ability to gain critical global perspectives and understanding.

This cannot be allowed to happen.

Study abroad experiences empower students to step outside of their comfort zones and develop skills outside the traditional American classroom. Students also develop highly sought-after professional skills—adaptability, communication, self-awareness, confidence—that studies have shown enhance their career outcomes.

There are a myriad of educational, cultural, professional, and social benefits linked to study abroad experience; in fact, a survey analysing 50 years of study abroad program participants found that 87% of those participants believe studying abroad served as a catalyst for increased maturity. The programs challenge students to learn new languages, discourse with individuals from different cultural backgrounds, and increase in independence, sometimes for the first time.

Under the DOE’s proposed regulations, the definition of “third-party servicers” has been significantly expanded to include any type of service that would be provided to students outside of the United States, such as medical care providers, professors, foreign universities, and more. This definition will essentially prohibit students from using Title IV federal aid to pay for study abroad experiences, including with accredited institutions, if the servicer or subcontractor is owned or operated outside of the US.

Further, the expanded guidance regarding activities unrelated to handling Title IV funds appears to render it impossible for a provider of study abroad services to operate anywhere in the world if they utilise foreign sub-contractors, such as instructors or providers of housing or classroom space. Every study abroad program, no matter the operator, relies on overseas sub-contractors to deliver critical on-the-ground, in-country student health and wellness services, which could no longer be provided to students under the new definition.

We believe that the DOE’s new guidance was intended to be aimed at Online Platform Management, but due to the vague definitions in the regulations, it could be detrimental to the study abroad industry and higher education as a whole.

The unintended consequences of these proposed regulations are massive. These regulations would critically impact students receiving Title IV financial aid, limiting their ability to participate in study abroad educational programs. In addition, those students basing their college decisions on the availability of study abroad programs may find their dreams of study abroad ending due to this guidance.

Our alumni are a great testament to the power of study abroad. Alums including Amanda Gorman, American poet and activist; Janet Napolitano, former US Secretary of Homeland Security; Mary Ann Peters, retired US Ambassador and CEO, The Carter Center; and David Muir, Journalist, Anchor, ABC World News Tonight, ‘20/20’, to name a few, have all spoken on the positive impact of study abroad on their careers.

For example, according to Amanda Gorman, study abroad “…was so life-changing and phenomenal; I don’t think that I would be who I am today without that experience”.

These regulations would be detrimental to the very students who are already at a financial disadvantage and need more aid for opportunities to expand their education, cultural experiences, and knowledge. We believe education abroad is integral to the mission of higher education and should be accessible to all students, including those receiving federal aid.

“These regulations would be detrimental to the very students who are already at a financial disadvantage”

Even the US Department of State has noted the benefits of studying abroad: “to build skills and knowledge, prepare to solve the world’s toughest challenges, and compete in the 21st century workforce.”

The guidance appears unclear as to what the actual definition of a sub-contractor is. If the guidance is declaring that any individual or organisation providing service to a student overseas is a sub-contractor and therefore not able to provide services to US students, it would be impossible for US universities, colleges or study abroad providers to conduct study abroad programs.

We cannot believe the DOE, nor the underlying statute of regulations, ever intended to take away a student’s opportunity to study abroad, or to take away the opportunity of those students who rely on financial aid to pursue global educational opportunities.

There is still time to fix this. In fact, I plan to speak on this topic and share the concerns of industry leaders at a hearing being held by the Department of Education on April 11.

We urge the DOE to amend its proposed regulations so that students from schools in every part of the United States will be able to study abroad. More specifically, we believe that the DOE should re-draft its guidance so that it clearly and specifically calls out that study abroad providers are not included in their current definition of a subcontractor/third-party servicer.

Let’s meet students where they’re at, rather than keeping them where they are.

About the author: Gregory D. Hess, Ph.D. is president & CEO of IES Abroad.

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