Dr. Joanie Friend, Association on Higher Education and Disability
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February 28, 2003
Jeffrey R. Andrade
Deputy Assistant Secretary for Policy, Planning and Innovation
Office of Postsecondary Education
United States Department of Education
1990 K Street, N.W. Room 8046
Washington, D.C. 20006
Dear Mr. Andrade:
Attached are recommendations for reauthorization of the Higher Education Act from the Association on Higher Education and Disability.
The Association on Higher Education And Disability ( AHEAD) is an international organization of 1,848 professionals committed to full participation in higher education for persons with disabilities. Our U.S. members represent 1,134 institutions of higher education. In response to the Department of Education's request for comments on the reauthorization of the Higher Education Act (HEA), AHEAD submits the following recommendations specifically related to the Department's request for guidance on how to:
- Improve access and promote additional educational opportunity for all students, especially students with disabilities;
- Change existing HEA programs to work more efficiently and effectively; and
- Prioritize the use of funds provided for postsecondary education and the benefits provided under the HEA programs in order to further the goals of improving educational quality, expanding access and ensuring affordability.
Enrollment of students with disabilities in higher education has continued to increase since the HEA was last reauthorized in 1998. During this same time the cost of attending higher education has increased rapidly, and financial support through vocational rehabilitation has decreased as states struggle with budget deficits. Obtaining a college degree is one of the few paths for persons with disabilities to bridge the wage gap that exists between persons with disabilities and their able bodied peers.
AHEAD's recommendations address the following basic goals:
- Protect the maximum appropriated award for Pell Grants and increase the funding for the maximum Pell Grant.
- Allow the Student Aid Administrator to consider the work-load of students with severe disabilities enrolled in half or reduced time study as the equivalent of full time for calculation of financial need.
- Increase flexibility to allow year round study.
- Increase funding for Demonstration Projects to Ensure Students with Disabilities Receive a Quality Education.
- Increase maximum grant levels for early intervention and student assistance programs such as TRIO and GEAR UP.
- Include language and initiatives that promote the concept of universal design, technology access standards and, the use of accessible educational technologies in all HEA programs.
Increase funding of the Pell Grants. Financial assistance in the form of grants provides critical resources to allow students with disabilities to attain a college degree and enter the workforce without the crushing burden of school loans. AHEAD joins the Association of Higher Education to encourage Congress to double the Pell Grant Maximum within a six-year time frame and to bring level of funding in line with the increased cost of higher education.
Allow student aid administrators to consider the workload of students with severe disabilities enrolled in half or a reduced load as the equivalent of full time for the calculation of financial need. Many students with severe disabilities are pressured to enroll in a minimum of 12 credit hours in order to receive the maximum grant award. While living expenses remain the same for a student enrolled part time as full time, students with severe disabilities are often unable to be successful in a full load of classes; many take one or two courses less per semester as a reasonable accommodation for their disability. For example, students who are blind, deaf, learning disabled or significantly mobility impaired often enter college unprepared to use the adaptive technology and alternative formats necessary to access educational information. Students who are blind or learning disabled must use books on tape and screen readers to access print material. Deaf students must bridge literacy gaps to translate from sign language to English often while colleges struggle to provide qualified interpreters. Students with severe physical disabilities may spend significantly more time on activities of daily living, thus having proportionately less time for their studies. These students need extra time and financial resources to overcome substantial barriers in the college environment.
Allow for year round study; increasing flexibility in the options for students to study year round allows all students the opportunity to graduate earlier, maximize educational living expenses and begin earning a full time income. Year round study particularly benefits students with disabilities by allowing them to reduce their course load each semester, and take more time to complete their degree. The current regulations governing the Pell Grant program assume that all students will enroll in two semesters per calendar year. This unnecessarily restricts student flexibility and forces many students with disabilities to attempt an unrealistic number of classes each semester.
Increase funding and strengthen the dissemination component for Demonstration Projects to Ensure That Students with Disabilities receive a quality education. The research and demonstration projects funded by this program directly benefit the services provided by our members who work to ensure equal access for college students with disabilities. Despite dramatic growth in participation in higher education by students with disabilities since the inception of Section 504 of the Rehabilitation Act and the ADA, students with disabilities remain significantly underrepresented. The research and methods developed by these demonstration grants play a crucial role in the quality of education received by students with disabilities resulting in improved persistence and graduation rates of students with disabilities, enabling them to become productive, tax paying members of society. We also encourage strengthening the dissemination component of the demonstration projects by developing a technical assistance center to disseminate project results after the projects have ended.
Maintain Title IV programs such as TRIO and GEAR UP. Early intervention and support programs such as TRIO have proven to have a positive impact on the enrollment and persistence rate of low income, minority, and students with disabilities in higher education. AHEAD has provided disability awareness training to 3,919 professionals in 20 years. For many institutions, the TRIO program is the only resource available to assist an institution to provide accommodations for students with disabilities. An increase in minimum grant levels is recommended to account for inflation and to meet growing demand for support of low-income and minority students. All of the Title IV programs should be expanded to help students with disabilities better prepare for higher education through increased awareness and training in the use of assertive technology.
Include language and incentives to eliminate barriers to educational technology. Since the last reauthorization of the HEA in 1998, enrollment of students with disabilities has increased. Also during this time, technology has transformed the instructional environment. While most of the technological advances enhance learning for students with disabilities, a lack of awareness of the needs of students with disabilities has created barriers through inaccessible technology. To accomplish the goal of promoting educational opportunity for all students, AHEAD promotes the use of Universal Design principles, technology access standards and encourages the use of accessible technologies in all HEA programs.
While post-school employment rates and earnings for students with disabilities lag substantially behind their non-disabled peers, students with disabilities who receive four- year college degrees report near-comparable employment rates and median earnings. Unfortunately the majority of students with disabilities are unable to obtain a four-year degree. Students with disabilities are more likely than their non-disabled peers to delay enrollment after high school, be financially independent of parent income, report lower income and are more likely to enroll in less than the traditional full time load in community or vocational programs lasting two or less years (NPSAS 2000). The early intervention and support programs, and financial assistance, particularly in the form of adequately funded grants provided by the HEA and the use of Universal Design in instruction are critical for students with disabilities to succeed in college.
The Association on Higher Education And Disability can provide more detailed information regarding the experience of college students with disabilities and the above recommendations. On behalf of our members, I appreciate the opportunity to comment on the reauthorization of this important legislation.
Joanie G. Friend E.d.D.
Director of Communications