Mr. Michael Sessa Executive Director Postsecondary Electronic Standards Council
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Electronic Standards Council
One Dupont Circle NW
Washington, D.C. 20036-1135
March 3, 2003
Mr. Jeffrey R. Andrade
Deputy Assistant Secretary of Education
Office of Postsecondary Education
US Department of Education
1990 K Street NW
Washington, D.C. 20006
Dear Mr. Andrade:
On behalf of the Board of Directors and membership of the Postsecondary Electronic Standards Council (PESC), I am pleased and honored to provide testimonial for the upcoming Reauthorizaton of the Higher Education Act (HEA) of 1965, as amended.
The proposal that I put forth focuses on standards-setting and recommends that the final step be taken of officially identifying PESC as the organization in which voluntary consensus standards are developed and approved. There are four main points that justify this proposal.
First, existing statute1 issued in the last Reauthorization of the HEA in 1998 requires the Secretary and specifically the Chief Operating Officer (COO) to participate in the establishment of voluntary consensus standards and in the activities of standards setting organization in order to improve the efficiency and effectiveness of the student aid delivery system; yet fails to identify which organization particularly. As the Department of Education (ED) recognizes PESC as that organization, in order to meet the intent of the law, an agreement on standards-setting, attached, was executed by ED's Chief Information Officer (CIO) and PESC's Executive Director in 2002. Officially identifying PESC formalizes this agreement.
Second, in addition to ED's recognition of PESC as the organization in which voluntary consensus standards are established, the student aid and higher education community in general recognizes PESC as that organization. With close to 50 institutions, associations, software providers, lenders, guarantors, servicers, and government agencies, PESC membership is truly representative of the higher education community (see membership list attached). Officially identifying PESC formalizes the community's voluntary endorsement and support for this proposal.
Third, PESC stands as the only open, independent, and balanced standards-setting body in higher education whose administration and management meets the policies2 issued by the Office of Management and Budget (OMB) and accommodates the guidelines on how federal agencies should interact with standards-setting bodies.
Lastly, without an identified organization, specific accountability to administer standards-setting is left vague. Statute tells you what and where, OMB tells you why and how. Identification of PESC tells you who.
What is needed to make this happen? Statute should be revised to identify PESC as the standards-setting organization. Current statute requires that the standards-setting organization be accredited with the American National Standards Institute (ANSI). While PESC continues to be actively involved in ANSI and serves as Chair of Subcommittee A (Higher Education Administration), PESC is not accredited by ANSI at this time. While accreditation can be reviewed for determination, prior to determination though, the need to be accredited should be analyzed and balanced against the higher education community's voluntary endorsement and support of PESC, already in place. This commitment to collaborate between ED and the higher education community meets the intent of the law and fulfills its purpose. Requiring ANSI accreditation, while possible, is extraneous and does not guarantee collaboration.
PESC's role can be as organizer within the higher education community for standards-setting and with its leadership role in ANSI's structure, as facilitator and conduit to ANSI, should the higher education community decide that standards developed for student aid require or necessitate ANSI approval and adoption. As I believe the community's coordinated involvement is the ultimate goal here, I would recommend the requirement that the standards-setting organization be specifically ANSI accredited be removed.
Again, on behalf of the Board of Directors and membership, I thank the Department of Education for your time and effort in this matter. I can be reached during normal business hours at Sessa@StandardsCouncil.org or at 202-293-7383 for questions and further clarification.
Michael D. Sessa
1Title I of the HEA, Section 143, Administrative Simplification of Student Aid Delivery
2Office of Management and Budget (OMB), Circular No. A-119, Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities
cc:PESC Board of Directors
2002-2003 Board of Directors
American Association of Collegiate
Registrars and Admissions Officer
National Associaton of
Student Loan Administrators
University of Illinois at Chicago
National Student Clearinghouse
A. Dallas Martin
National Association of Student
Financial Aid Administrators