We hope Secretary Spellings' important speech marks a step toward engaging the higher education community as full participants in addressing the challenges facing our colleges and universities. NAICU looks forward to working productively with the Education Department in the coming months. We will also be proactively addressing the issues raised by the commission through the higher education community's comprehensive "Next Steps" initiative.

We support many of the commission's recommendations, some of which were cited in the secretary's speech. These include the commission's emphasis on increasing access; the recognition of the vital role of higher education in contributing both to the public good and to individual enhancement; the need for accountability (although we would add the word "appropriate"), the importance of additional resources in science, technology, engineering and mathematics (STEM); the call for deregulation of higher education at the federal and state level; the importance of producing globally literate graduates; and the need to address policies relating to the admission of foreign students at U.S. institutions.

Conspicuous by its absence, however, was an endorsement of the commission's specific call for a substantial increase in the maximum Pell Grant – the key form of federal student financial aid for the neediest students. In her prepared remarks, Spellings made a reference to need-based aid, but only mentioned a generic commitment to Pell Grants in response to an audience question.

Also in her speech, the secretary called for reform of the entire financial aid system, which by every implication means the elimination of some student aid programs, resulting in a net loss of aid for the nation’s neediest students. Federal efforts might better be directed toward supporting the proven federal aid programs already in place, not finding ways to dismantle the current array of financial aid programs that have worked amazingly well.

Secretary Spellings, in her third action item, also called for collecting student-level data to create a higher education information system that would provide consumer information to every student. However we are not clear as to why, to accomplish that goal, the system must include information on every student.

Data already collected by the federal government has yielded many high-quality, statistically valid studies that give us illuminating insights into the process – and the shortcomings – as we move students through their higher education experience. We concur that the Department of Education's existing COOL Web site has the potential to be a powerful tool for college choice, and NAICU has had a longstanding proposal in place to work with the department in expanding that resource.

NAICU and its member institutions share a fundamental belief that student and family privacy must be protected, as it has been for more than 30 years under the Family Educational Rights and Privacy Act (FERPA). Guarantees made by Secretary Spellings that individual student information would be fully protected is at odds with the reality of federal databases, which have experienced numerous widely-publicized breaches in recent months. Such a national system for tracking students from high school through college and into the workplace, in order to measure institutional performance, would shift the control of those records from the student to the federal government.