U.S. Department of Education » Bulletin Board
(October 22, 2014) 

Student Support Services Draft Application Amended — A Radical Policy Shift

Dear Colleague,

Today, notice of a revised draft application for the Student Support Services grant competition was published in the Federal Register Document is available for download (.pdf). A copy of the revised draft application is attached Document is available for download (.doc). You may also access the revised application by visiting (http://www.regulations.gov/) and searching for ED-2014-ICCD-0137-0002 (Document ID) and selecting “FY 2015 SSS Application Package FINAL10 14 14Revised - without standard forms,” or simply click here Document is available for download (.doc). The notice also extends the comment period through November 20.

The revised application now includes no invitational priorities, but rather two competitive preference priorities — (1) increasing postsecondary success (10 points) and (2a) providing individualized counseling for personal, career, and academic matters (1 point) and (2b) individual counseling based on moderate evidence of effectiveness (2 points). Note also that the U.S. Department of Education (ED) indicates on pages 29-30, an intention to add an additional competitive preference priority — “Influencing the Development of Non-cognitive Factors” — should the Department finalize its Final Supplemental Priorities and Definitions for Discretionary Grant Programs prior to the closing date of the competition. In that instance, three important changes would occur with respect to competitive preference priorities.

  1. The new priority — “Influencing the Development of Non-cognitive Factors” — would be worth four points;
  2. The first competitive preference priority would shift from “Increasing Postsecondary Success” to “Increasing Postsecondary Access, Affordability, and Completion,” with a point value of only six points (down from 10); and
  3. The definition of “high-need students” will be replaced with the updated definition of this term from the new supplemental priorities and definitions.

During the last Student Support Services competition in 2009, applications were available October 22; applications were due December 7, and the slate was released August 6, 2010. The appeal process was not implemented because regulations following the 2008 passage of the Higher Education Act had not been finalized.

The Council for Opportunity in Education (COE) has three major concerns with the notice as published today.

  1. By providing 13 points to competitive priorities, the U.S. Department of Education reduces the weight given prior experience, expressly disregarding the law on how TRIO grants are to be awarded;
  2. By re-issuing the draft application to emphasize the importance the importance of evidence-based practices, the Department acts in contradiction of its own goal. For, it will be impossible for colleges to provide these very same research-backed services to current students in a seamless manner in the fall 2015 term, when they are most critical; delayed notification will also deprive incoming students of the necessary early interventions (e.g., pre-orientation, academic bridge services, intrusive advising, learning communities, etc.) that offer them the best opportunity to succeed in college.
  3. The language suggests that the U.S. Department of Education is not seeking to partner with colleges and universities nor to recognize the expertise of educators working there — particularly at institutions serving large numbers and percentages of low-income and minority students — but that ED is rather attempting to utilize TRIO Student Support Services as a research or demonstration program.

COE is consulting with others in the higher education community and in Congress and will keep you informed of the options available to the TRIO community.

Maureen Hoyler
Council for Opportunity in Education