By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. Much has continued to unfold since our last Advocacy Update. Federal education policy is moving in multiple directions at once — new data reporting requirements are taking effect, structural changes within the U.S. Department of Education are raising questions about program oversight, and new projections warn that the Pell Grant program could face an $11.5 billion funding shortfall, putting one of the nation’s most important need-based aid programs under increased scrutiny. At the same time, states are advancing new affordability initiatives and institutions are responding to shifting federal expectations around admissions, data, and compliance.

Policy & Legislative Updates 

The policy landscape surrounding college access and higher education continues to evolve rapidly. Over the past several weeks, federal agencies, Congress, state legislatures, and the courts have all taken actions that could shape the environment for students, institutions, and the college admission counseling profession. Taken together, these developments point to a period of continued transition in federal education policy, student aid, and institutional oversight.

One of the most significant shifts is occurring inside the federal government itself. The U.S. Department of Education continues to undergo structural changes that may reshape how federal education programs are administered. The administration has expanded its use of interagency agreements (IAAs) to move management of certain programs to other federal agencies — including the Departments of Labor, Health and Human Services, and State. While the Education Department retains statutory authority over these programs, other agencies are increasingly responsible for day-to-day management and grant administration. Members of Congress have raised concerns about transparency, oversight, and whether these moves could fragment federal education programs.

The department is also operating with a significantly reduced workforce following last year’s large-scale layoffs. Watchdog reports and outside experts say the staffing reductions have strained key functions such as civil rights enforcement, student loan oversight, and grant monitoring.

Higher education institutions are navigating increased federal scrutiny as well. Although courts have blocked some federal guidance targeting diversity, equity, and inclusion initiatives, the administration continues to pursue enforcement through civil rights investigations, grant conditions, and other regulatory tools. One example is a proposed change through the U.S. General Services Administration that would require nearly all recipients of federal funding — including colleges, universities, school districts, and nonprofit organizations — to certify compliance with the administration’s interpretations of federal law related to diversity, equity, and inclusion, immigration, public safety, and religious liberty.

Institutions are also adapting to new federal reporting requirements tied to admissions practices following the Supreme Court’s decision ending race-conscious admissions. Through the Admissions and Consumer Transparency Supplement (ACTS) to the Integrated Postsecondary Education Data System, selective institutions are being asked to report detailed historical admissions data, including test scores, grade point averages, and demographic information. NACAC and coalition partners have warned that the complexity of the reporting requirements and compressed timeline make it difficult for institutions to submit accurate data. The policy is also facing legal challenges. A coalition of 17 states recently filed a lawsuit challenging the federal data collection requirement, arguing that it is burdensome, rushed, and risks turning federal education data systems into tools for enforcement rather than research.

Student aid policy is experiencing significant change as well. Legal developments and regulatory actions have created continued uncertainty around the future of the SAVE income-driven repayment plan, while federal watchdog reports have raised concerns about reduced oversight of student loan servicers following staffing cuts at the Department of Education.

Another major concern involves the long-term sustainability of federal need-based aid. The Congressional Budget Office recently warned that the Pell Grant program could face an $11.5 billion funding shortfall within the next few years. With more than 7 million students relying on Pell Grants annually, the program’s financial outlook is a critical issue for students, institutions, and policymakers alike.

Federal aid systems are also being updated to implement provisions of the OBBBA, including the creation of a Workforce Pell program and new limits on federal student loan borrowing.

Beyond Washington, states are playing an increasingly active role in shaping higher education policy. Several states are exploring new ways to support minority-serving institutions amid uncertainty about federal funding, while others are tying academic programs more directly to workforce outcomes. In Indiana, lawmakers are advancing legislation that would review and potentially close college programs whose graduates earn less than typical high school diploma holders.

Georgia is also moving forward with a landmark need-based financial aid program, marking a major shift in a state that has historically relied on merit-based aid through the HOPE Scholarship. The proposal reflects years of advocacy from college access leaders — including NACAC and SACAC members — who have pushed for stronger need-based financial aid to improve affordability for students with the greatest financial need.

Global developments are also affecting the higher education landscape. New data shows that student visas issued ahead of the fall 2025 semester dropped by more than 35 percent, reflecting visa delays, policy changes, and increasing global competition for international students.

NACAC Advocacy 

Since the last Advocacy Update, NACAC has continued to engage policymakers and coalition partners on key issues affecting college access, affordability, and accountability across higher education. NACAC recently endorsed the Lowering Student Loans Act, bipartisan legislation introduced by Rep. Mike Thompson (D-CA) and Rep. Jim Moylan (R-GU) that would set a fixed 2 percent interest rate on all federal student loans beginning July 1, 2026. The proposal would apply to both new and existing federal loans and would automatically reduce rates for borrowers unless they opt out. Lowering interest rates across the federal loan portfolio would help ease long-term repayment burdens and improve financial stability for millions of borrowers who rely on federal loans to pursue higher education.

NACAC is also working with a coalition of higher education and research organizations to elevate implementation challenges related to the Admissions and Consumer Transparency Supplement (ACTS) reporting requirements within IPEDS. The coalition has urged federal officials to make practical adjustments — including updates to reporting fields and an extension of the submission timeline — to help institutions ensure accurate reporting during this first collection cycle. NACAC and its partners are also sharing resources and guidance to support admission professionals and institutional partners as they navigate the evolving requirements.

In addition, NACAC has endorsed the Proprietary Education Oversight Task Force Act, introduced by Senator Dick Durbin (D-IL), which would strengthen federal oversight of proprietary institutions through improved coordination among federal agencies, greater transparency around investigations and enforcement actions, and the creation of a “For-Profit College Warning List” to help students and families better understand institutional risk.

Earlier this month, NACAC welcomed members of the Pacific Northwest Association for College Admission Counseling (PNACAC) to Washington, D.C., where they met with their members of Congress to advocate for policies that support students and the college admission counseling profession. NACAC helped provide policy briefings, advocacy materials, and coordination support to ensure members were well prepared for their meetings and able to effectively elevate the priorities of college admission counseling professionals and the students they serve.

Together, these efforts reflect NACAC’s continued commitment to advancing policies that expand college access, strengthen accountability, and ensure students and families have the information and support they need to navigate the path to higher education.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Urge Congress to Extend the ACTS/IPEDS Deadline
• Tell Congress: Keep Education Programs at the Department of Education
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

The policy debates unfolding today will shape how students access higher education for years to come. While the landscape continues to evolve, one constant remains: the commitment of college admission counseling professionals to support students and families as they navigate an increasingly complex path to higher education.

Through advocacy, collaboration, and engagement with policymakers, NACAC and its members are helping ensure that the voices of students, and the professionals who guide them, remain part of the decisions shaping the future of education.

As NACAC continues this work alongside members and partners across the country, we are reminded of the enduring importance of educational opportunity. As former United Nations Secretary-General Kofi Annan once said:

“Knowledge is power. Information is liberating. Education is the premise of progress, in every society, in every family.”

Together, we will continue advocating for policies that expand opportunity, strengthen access, and support the students and families who rely on our profession every day.

By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. This moment continues to demand sustained, coordinated advocacy. Across Congress, federal agencies, and the courts, decisions are unfolding — often quickly and sometimes with shifting guidance — that will shape college access, affordability, civil rights enforcement, and institutional stability for years to come. Appropriations battles, workforce restructuring, evolving interpretations of federal law, and state-level policy innovation are converging in ways that directly affect students, counselors, and institutions navigating an already complex landscape. In this environment, advocacy is not optional or abstract. It can be as simple — and as powerful — as sharing your story.

Policy & Legislative Updates 

Congress ultimately approved an FY 2026 funding package that largely maintains level funding across major education programs, including Pell Grants, TRIO, GEAR UP, Title I, IDEA, and other core investments. That agreement followed a brief partial government shutdown triggered by a lapse in appropriations, even as the Senate had advanced a multi-bill spending package. The shutdown was short-lived, but it underscored ongoing volatility in the federal budgeting process. Importantly, the final bill includes stronger congressional guardrails reinforcing that report language and funding directives tied to higher education programs are not optional, signaling an effort to reassert congressional authority over program transfers, staffing decisions, and interagency agreements.

At the same time, broader questions about federal workforce stability remain. A temporary congressional pause on reductions in force (RIFs) is set to expire, potentially reopening the door to agency layoffs, including at the Education Department. While Federal Student Aid operations have continued during funding lapses, staffing capacity and long-term program oversight remain areas to watch closely.

On FAFSA implementation, the Education Department has reported improved metrics for the 2026-27  cycle, including earlier launch timing, higher satisfaction rates, and more than 8 million submissions to date. New data from the National College Attainment Network also show that FAFSA simplification has significantly expanded Pell eligibility, with more than 1.5 million additional students qualifying for the maximum award over the past two years. However, flat Pell funding raises concerns about long-term purchasing power, particularly as affordability pressures intensify. A combination of proposed federal funding reductions, changes in institutional financial aid practices, and rising tuition may make it more difficult for low-income students to access and complete postsecondary education. While FAFSA completion and college applications among low-income students have increased, enrollment and completion outcomes will likely depend on the availability of sufficient financial aid and support services.

Recent research reinforces both progress and risk in the access landscape. An independent evaluation of Rhode Island’s statewide GEAR UP initiative found that sustained advising beginning in middle school increased college completion by 48 percent for participating students — particularly among Latino/a and Black students — underscoring the impact of long-term, structured support systems. At the same time, the cancellation of $40 million in TRIO grants last fall — the first in the program’s history — has already left nearly 44,000 low-income and first-generation students without services. Although a federal court ruled the cuts unlawful, funding has not yet been restored, and more than 100 programs remain shuttered, creating immediate disruption for students in the middle of critical transition periods.

Civil rights enforcement continues to generate significant concern. A new Government Accountability Office report found that efforts to sideline staff at the Education Department’s Office for Civil Rights cost taxpayers up $38 million while sharply reducing enforcement activity, including virtually no resolution agreements in key areas such as racial harassment, disability discrimination, and sexual assault. Separate data show that OCR did not resolve a single K-12 sexual harassment or assault case in 2025 — a marked departure from prior years.

Legal uncertainty also persists around federal diversity, equity, and inclusion enforcement. Although a federal court blocked the Feb. 14 Dear Colleague Letter, the department has signaled it will continue enforcing its interpretation of Title VI consistent with the Supreme Court’s decision in Students for Fair Admissions v. Harvard (SFFA). At the same time, the department has agreed not to rely on or enforce that specific guidance as part of a lawsuit settlement with the National Education Association. Institutions therefore remain in a complex compliance environment, navigating evolving enforcement postures while continuing to advance lawful, mission-aligned access and belonging efforts.

The Trump administration’s broader posture toward higher education has intensified. Disputes with Harvard University have escalated, including public claims of financial penalties and the Defense Department’s decision to sever certain academic partnerships. Meanwhile, investigations into the use of student civic engagement data and the diversion of federal funds away from student-support grants toward politically favored initiatives — including proposed accreditors unlikely to meet federal standards — raise additional concerns about the direction of federal oversight and resource allocation.

Enrollment data following the Supreme Court’s 2023 SFFA decision show continued redistribution across sectors. While Black and Hispanic enrollment has declined at some highly selective institutions, underrepresented minority enrollment has increased at many flagship public universities, suggesting shifts in where talented students are enrolling rather than a disappearance of demand. At the same time, broader data continue to demonstrate that for most students, admission is becoming more accessible: approximately seven in ten applicants to private colleges and nearly eight in ten applicants to public universities are admitted, with institutions expanding direct admission, test-optional policies, and application simplification to reduce barriers.

Institutions are also adapting their internal models. Increasingly, admissions offices are moving beyond traditional gatekeeping toward student-centered “success coaching” approaches that focus on helping admitted students navigate financial aid, housing, registration, and other enrollment hurdles. The message is clear: access does not end at admission — it culminates in enrollment and completion.

Immigration policy continues to intersect directly with educational access and campus climate. Two Minnesota school districts and the state teachers’ union have filed suit challenging the administration’s decision to revoke long-standing protections limiting immigration enforcement at schools and other sensitive locations. District leaders report disruptions to instruction, declines in attendance, and significant staff time redirected toward crisis response and student support. At the postsecondary level, students at campuses across the country have pushed back against the presence of immigration enforcement agencies at career fairs, raising concerns about safety, campus climate, and institutional values. These debates underscore the real-world implications of federal immigration policy decisions on students’ sense of belonging and stability.

New research also highlights the stakes for undocumented students. An analysis from the Presidents’ Alliance on Higher Education and Immigration and the Migration Policy Institute estimates that roughly 75,000 undocumented students graduate from U.S. high schools each year. While these students demonstrate strong persistence and high graduation rates, their postsecondary pathways are increasingly constrained by enforcement actions and the rollback of tuition-equity policies in several states. With most current graduates ineligible for DACA protections, access to in-state tuition, state aid, and institutional support becomes even more critical. The data reinforce that policy choices at both the federal and state levels directly shape whether academically prepared students can continue their education.

At the same time, legal and structural questions about the U.S. Department of Education remain unresolved. A new Congressional Research Service analysis raises significant concerns about the department’s use of interagency agreements to shift administration of major programs — potentially affecting tens of billions of dollars in funding. CRS notes unanswered questions about statutory authority, congressional intent, and whether such transfers exceed permissible boundaries. These issues are now under active litigation and could have long-term implications for program oversight, accountability, and institutional funding stability.

Concerns about federal oversight also extend to student data and civic engagement. The Education Department has warned institutions against using data from the National Study of Learning, Voting and Engagement (NSLVE), citing potential FERPA concerns and opening investigations into Tufts University and the National Student Clearinghouse. NSLVE has long been used as a voluntary tool to help institutions understand and strengthen student civic participation. Questions remain about the legal basis for the department’s claims, and institutions are watching closely for potential chilling effects on efforts to promote informed civic engagement among students.

Meanwhile, advocates are urging caution as Congress considers reopening the Individuals with Disabilities Education Act (IDEA). While some proposals under discussion are narrowly focused, disability rights leaders warn that revisiting the statute in the current political and enforcement climate could expose foundational protections to broader amendments. For students with disabilities the stability and integrity of IDEA remain central to educational equity and compliance obligations.

Finally, innovation conversations continue at the state level. Massachusetts has authorized pilot three-year bachelor’s degree programs, joining a growing national movement toward accelerated pathways that aim to reduce cost and time to degree while raising important questions about rigor and support.

NACAC Advocacy 

Since our last issue, NACAC has remained actively engaged on both funding and legal developments that directly affect college access and the professionals who support students. We publicly applauded Congress’s passage of the FY 2026 Labor–HHS–Education funding bill, which preserves level funding for critical federal programs that advance access, affordability, and student success. By rejecting proposed cuts to key investments, lawmakers reinforced the importance of sustained federal partnership in postsecondary opportunity. This outcome reflects consistent engagement from NACAC members across the country — meeting with lawmakers, elevating student stories, and underscoring the real-world impact of Pell Grants, TRIO, GEAR UP, and other core programs. We will continue advocating to protect and strengthen these investments and encourage members to remain engaged as the next appropriations cycle approaches.

At the same time, NACAC has been closely monitoring and communicating about recent federal court decisions affecting diversity, equity, and inclusion efforts tied to federal funding. While one ruling permits continued enforcement of certain executive actions related to DEI grants and certifications, another blocks broader attempts to withhold funding over lawful educational practices. Together, these decisions create a complex and evolving compliance environment for institutions. NACAC remains concerned that ongoing ambiguity and aggressive enforcement postures risk chilling lawful, mission-aligned practices that are central to expanding student access, enrollment, and success. We will continue providing updates and advocating for clarity, fairness, and policies that support students and the counseling profession.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Your Senators: Keep Education Programs at the Department of Education
• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

Taken together, this moment reflects both resilience and strain within our education system. Core federal investments have been preserved for now, FAFSA improvements are expanding Pell eligibility, and research continues to demonstrate the power of sustained advising and support. At the same time, civil rights enforcement, program stability, immigration policy, and institutional autonomy remain under significant pressure.

In moments like this, the voice of the college admission counseling profession matters more than ever. Your advocacy has already helped protect critical programs and reinforce the importance of federal investment in student opportunity. As we look ahead, we will continue to engage policymakers, provide timely analysis, and equip you with the tools to make your voice heard.

As Dr. Martin Luther King Jr. reminded us, “The arc of the moral universe is long, but it bends toward justice.” That arc does not bend on its own — it bends because dedicated professionals, like you, continue to show up for students every day. NACAC remains committed to standing alongside you to protect access, expand opportunity, and ensure that every student has a clear path to postsecondary success.

By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. This moment demands sustained, coordinated advocacy. Across Congress, the courts, and federal agencies, decisions are being made — often quickly and with limited transparency — that will shape college access, affordability, and institutional autonomy for years to come. Funding negotiations, administrative restructuring, and legal challenges are converging in ways that directly affect students, counselors, and institutions navigating an already volatile landscape. In this environment, advocacy is not optional or abstract. It can be as simple — and as powerful — as taking a few minutes to complete an action alert and speak up for the programs, protections, and students that matter most.

Policy & Legislative Updates 

Congress is navigating a narrow and volatile endgame for FY 2026 appropriations, with education funding at the center of high-stakes negotiations. The House has already passed a bipartisan six-bill minibus that includes Labor-HHS-Education and largely rejects the administration’s most aggressive proposed cuts to education and student-support programs. That same package stalled in the Senate earlier this week after failing a procedural vote, bringing the government to the brink of a shutdown. Late last night, Senate Democrats and the White House reached an agreement to move the bill forward by advancing five of the six appropriations bills — including Labor-HHS-Education — while relying on a two-week continuing resolution for the Department of Homeland Security to allow additional negotiations over immigration enforcement reforms. The Senate is expected to vote on that agreement today. Even if the package advances, a brief shutdown now appears likely, as the House will not return to session until next week and must vote again before funding can be finalized. Decisions made in the coming days will shape funding stability, program continuity, and congressional oversight for the year ahead, making this a critical moment for sustained advocacy.

At the same time, broader efforts to reshape the federal role in education are accelerating. The Department of Education has announced that higher education staff will be detailed to the Department of Labor as interagency agreements move forward, shifting the administration of several postsecondary and workforce-related programs. Affected grantees will transition to Labor’s grants and payment systems in the coming weeks. While the administration frames these changes as integration and efficiency, they raise serious concerns about the erosion of statutory responsibility, loss of institutional expertise, and weakened accountability within federal education programs — especially as Congress signals clear intent to keep these functions within the Education Department, even if it stops short of fully blocking the transfers.

Recent events have also underscored how federal volatility is disrupting institutions’ ability to plan and serve students. The abrupt cancellation by the Trump administration — and equally abrupt reinstatement — of up to $2 billion in student mental health and addiction treatment grants left schools and states in limbo, highlighting the real-world consequences of uncoordinated federal action. A new survey of college leaders reinforces this picture, with nearly all respondents reporting heightened uncertainty tied to federal policy shifts affecting student aid, research funding, immigration, and academic freedom. Together, these pressures are straining long-term planning and undermining confidence across higher education.

Against this backdrop, several important legal developments offer both guardrails and caution. A federal court has ordered the Education Department to reconsider canceled TRIO grants, finding that the department failed to follow required statutory and regulatory processes and improperly applied new policy priorities retroactively. The ruling is a significant rebuke and an important step toward restoring transparency and stability for programs serving tens of thousands of students. Separately, the administration has dropped its appeal of a federal court decision blocking its attempt to threaten institutions over lawful diversity, equity, and inclusion activities, leaving in place a ruling that affirms First Amendment protections and limits executive overreach. Courts have also intervened after newly unsealed records revealed that international students and scholars were targeted for deportation based on protected speech, raising profound concerns about academic freedom and civil liberties.

Other policy shifts remain mixed. The administration announced a suspension of wage garnishment and tax refund seizures for borrowers in default on federal student loans, offering short-term relief to millions, though interest accrual and credit reporting will continue and long-term repayment clarity remains unresolved. Meanwhile, states including Texas and Florida have moved to pause H-1B visa hiring at public universities, compounding new federal fees and threatening institutions’ ability to recruit international faculty and sustain research capacity.

As federal pressure on higher education continues to intensify, new responses are emerging. A national Alliance for Higher Education has launched to push back against political interference and defend academic freedom and institutional autonomy. Institutions are also navigating new accessibility obligations as updated Title II regulations take effect this spring, reinforcing that digital access is now central to college access and student success. At the institutional level, some colleges are expanding affordability in meaningful ways, including Yale’s decision to extend free tuition to families earning up to $200,000 — a reminder that access-focused policy choices remain possible even amid uncertainty.

NACAC Advocacy 

Since the last issue, NACAC has continued to engage aggressively at the federal level to protect college access, affordability, and institutional autonomy during a period of heightened uncertainty. Most notably, NACAC publicly supported a bipartisan congressional minibus funding package that includes the Labor-HHS-Education bill and rejects the administration’s most harmful proposed cuts to education. The legislation preserves Pell Grants, TRIO, GEAR UP, campus-based aid, and support for Minority-Serving Institutions, while reinforcing congressional intent to keep education programs housed within the U.S. Department of Education and placing guardrails on further administrative disruption. NACAC issued a detailed statement analyzing the bill and urging Senate action to secure funding stability for students and institutions.

NACAC also joined an amicus brief led by the American Council on Education warning against unprecedented federal retaliation that threatens academic freedom and institutional autonomy. Filed in response to federal actions targeting Harvard University, the brief underscores that the First Amendment protects colleges’ core functions — including who may teach and learn — and cautions that viewpoint-based punishment would set a dangerous precedent across higher education. Together, these efforts reflect NACAC’s continued commitment to defending lawful institutional independence, protecting students’ access to education, and ensuring that federal policy supports — rather than undermines — the work of college admission counseling professionals.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Your Senators: Keep Education Programs at the Department of Education
• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

The pace and scope of federal action can feel overwhelming, but progress has never depended on a single moment or a single voice. Advocacy works when it is steady, collective, and grounded in the lived experiences of those closest to students and institutions.

As historian Howard Zinn reminded us, “Small acts, when multiplied by millions of people, can transform the world.”

Whether it is sharing your perspective, completing an action alert, or engaging with policymakers, each step matters — and together, they strengthen our shared commitment to protecting access, opportunity, and the transformative power of postsecondary education.

By Sean Robins, NACAC’s director of advocacy

Happy New Year and welcome to the newest issue of the Advocacy Update on NACAC’s Admitted blog. Meeting the moment in the midst of much uncertainty requires subtle perseverance, a dedicated spirit, and an opportunity to elevate your story and advocate for what matters most. Across federal and state policy arenas, decisions are being made — sometimes quietly, sometimes abruptly — that carry real consequences for students, families, and the institutions that support them.

At NACAC, we are dedicated to ensuring that these decisions do not happen in a vacuum. We work to bring clarity where there is confusion, elevate the lived experiences of students and college admission counselors, and hold policymakers accountable when actions threaten access, equity, or transparency in admissions and college access. Through our collective advocacy, we can shape outcomes that reflect the realities on the ground. By sharing your perspectives, engaging with policymakers, and standing together as a profession, we strengthen our ability to protect opportunity, expand access, and ensure that higher education remains a pathway — rather than a barrier — for the students we serve.

Policy & Legislative Updates 

New court filings have renewed scrutiny of the Education Department’s handling of federal student loan repayment programs. Despite reopening application portals and committing to regular updates, the department continues to sit on a backlog of more than 800,000 income-driven repayment applications, with only a small share of eligible borrowers receiving forgiveness through IDR or Public Service Loan Forgiveness. The American Federation of Teachers argues the department has failed to meet its legal obligations, citing stalled processing, limited approvals, and staffing cuts that have slowed progress. For borrowers who followed the rules and are waiting for relief, these delays are not abstract administrative challenges — they represent real and ongoing financial harm.

At the same time, the Trump administration has announced it will resume student loan wage garnishment, ending a five-year pause that began during the COVID-19 pandemic. In early January, defaulted borrowers started receiving notices warning that up to 15 percent of their disposable income may be withheld, with collections expected to ramp up quickly in the coming months. This move comes as borrowers face a weakening labor market, shifting repayment rules, and persistent barriers to accessing relief. With more than 5 million borrowers already in default — and that number projected to rise — advocates warn that renewed collection efforts risk deepening financial instability for those already struggling to stay afloat.

Legal uncertainty is also intensifying for institutions. A quiet but consequential signal from the U.S. Supreme Court suggests that challenges to terminated federal grants should be brought in the U.S. Court of Federal Claims — a venue that can award limited damages but cannot reinstate funding. In practice, colleges could prevail in court and still permanently lose the grant. For higher education, this shift weakens accountability and leaves institutions facing years-long litigation while programs shut down, staff are laid off, and students lose access to services those grants were meant to support. Over time, it risks chilling equity-focused innovation and making already fragile access pathways even more vulnerable.

Questions about federal authority and oversight are also playing out in the states. In Virginia, the outgoing attorney general agreed to a fast-tracked settlement with the Department of Justice that would block undocumented students from accessing in-state tuition. Civil rights and immigrant-advocacy groups argue the agreement sidesteps due process and threatens to upend college plans for thousands of students who meet state eligibility requirements. Incoming state leaders have criticized the move as a last-minute attempt to lock in a policy change before the new administration takes office and say they are reviewing options to defend the law. If approved, the agreement could force students to pay significantly higher tuition — or leave school midyear — while similar legal challenges continue to unfold nationwide.

Federal accountability policy continues to take shape as the Education Department’s AHEAD advisory committee reached consensus on a new “Do No Harm” earnings test that would apply across all postsecondary programs. The framework establishes a single baseline measure of financial value and expands consequences for some failing programs beyond loan eligibility, and in certain cases to Pell Grant access — steps several committee members viewed as necessary to strengthen student protections, particularly for certificate programs. At the same time, advocates continue to raise concerns that the final approach may not go far enough to prevent low-value programs from continuing to receive Title IV funds, pointing to the removal of the debt-to-earnings metric and other safeguards included in prior accountability rules. The proposal now moves to public comment, where questions about enforcement, legal authority, and whether the rule meaningfully balances consistency with accountability are expected to remain central.

Funding decisions are also reshaping the federal landscape. The Education Department announced it awarded $169 million — nearly the entire FY2025 allocation — for the Fund for the Improvement of Postsecondary Education (FIPSE), redirecting resources toward priorities such as artificial intelligence in teaching and learning, civil discourse initiatives, accreditation reform, and short-term programs, including short-term Pell. These awards represent a sharp departure from congressional intent, which emphasized student success initiatives, research infrastructure at HBCUs and other minority-serving institutions, veterans centers of excellence, rural postsecondary economic development, open textbooks, and basic needs supports. The shift raises important questions about how federal innovation dollars are being redirected — and which students and institutions are being left out.

Congressional funding decisions remain unsettled as well. The House has passed a three-bill FY2026 appropriations package covering Commerce-Justice-Science, Energy and Water, and Interior and Environment, advancing six of the twelve funding bills. The Labor-HHS-Education bill remains unresolved, however, with some Democrats signaling they may withhold support for further appropriations until issues around expired health insurance subsidies are addressed. As current funding is set to expire on Jan. 30, appropriators are working toward a separate three-bill package that would include Labor-HHS-Education alongside Defense and Transportation-HUD. The coming days represent a critical window to secure education funding levels and the spending and administrative guardrails needed to protect students and institutions, with a continuing resolution still a real possibility if negotiations stall.

Administrative changes within the federal government add another layer of uncertainty. Beginning next week, the Education Department will assign higher-education staff to the Department of Labor as part of previously announced interagency agreements (IAAs) aimed at integrating postsecondary education and workforce development programs. Grantees in the Higher Education Programs division will also transition to Labor’s Grant Solutions and Payment Management System. While a list of affected programs has been posted, the move raises ongoing concerns about the transfer of statutory responsibility, institutional expertise, and oversight away from the Education Department — and the implications for program continuity and accountability.

Data and transparency issues have also come to the forefront. On Dec. 18, the Education Department announced Office of Management and Budget approval of the expanded IPEDS Admissions and Consumer Transparency Supplement (ACTS), giving institutions just three months — through Mar. 18, 2026 — to collect and report extensive new admissions data. Despite hundreds of public comments, including substantive concerns raised by NACAC and a broad coalition of higher-education and data experts, no meaningful changes were made. OMB approval came the day after the comment period closed, and the department did not notify public commenters or issue a public release; instead, the decision appeared only in a “This Week in IPEDS” post.

NACAC’s public comment warned that the scope and timeline are unworkable, risk inaccurate or misleading reporting, and impose significant administrative burden without clear guidance or technical support. We also emphasized that admissions data collected without appropriate context could distort public understanding of college access and misrepresent holistic admissions practices. The decision to proceed as-is is deeply disappointing and raises serious questions about data quality, stakeholder engagement, and collaborative policymaking. NACAC is actively working with partners and engaging the department to request additional guidance while continuing to elevate member concerns and advocate for improved clarity and implementation in future cycles.

Broader policy shifts are also shaping student behavior and institutional planning. As the Trump administration intensifies its attacks on diversity, immigration, and gender equity, many high school seniors are rethinking how — or whether — to share aspects of their identity in college admissions essays. Reporting highlights growing self-censorship among students who fear that discussing race, immigration status, or gender identity could hurt their chances. While some institutions continue to invite essays grounded in lived experience, others have quietly revised prompts, narrowing how students feel able to present themselves and raising serious concerns about equity and authenticity in the admissions process.

International education remains similarly unsettled. After a year marked by visa delays, SEVIS revocations, OPT uncertainty, and shifting federal signals, colleges are navigating an admissions cycle shaped by policy volatility. New international enrollment fell sharply last fall even as interest in studying in the U.S. remains strong. Institutions are adapting by diversifying recruitment markets and offering more flexible pathways, but leaders warn that persistent visa backlogs and mixed messaging risk long-term enrollment losses and added financial strain. Those concerns have been heightened by the State Department’s announcement of a pause on processing immigrant visas for individuals from 75 countries. While officials say student visas are not affected, the lack of clarity and conflicting reports send a chilling signal, particularly given that these countries collectively sent more than 200,000 students to U.S. colleges last year.

At the state level, policymakers are grappling with the downstream effects of federal decisions. In Connecticut, lawmakers are proposing a new state-level graduate student loan to backfill access lost with the elimination of Grad PLUS under OBBBA. The proposal reflects how states may increasingly be forced to step in to protect graduate access, workforce pipelines, and affordability as federal support diminishes. More broadly, state higher-education leaders report that economic and workforce development now tops their policy priorities for 2026, alongside growing concern about affordability, return on investment, and completion amid tightening budgets and federal uncertainty.

Those fiscal pressures are already being felt in K–12 systems. States like Oregon, which automatically conform to the federal tax code, are facing unprecedented mid-year education cuts tied to federal tax changes under OBBBA. With contracts already in place and limited flexibility, districts are confronting difficult choices that underscore how quickly federal policy decisions can cascade into classroom-level consequences.

Finally, new enrollment data from the National Student Clearinghouse Research Center show that while overall college enrollment has rebounded to pre-pandemic levels, the recovery is uneven. Growth is concentrated in community colleges, dual enrollment, and short-term credentials, while adult learners and international graduate students continue to decline. The data suggest a sector in transition, where apparent enrollment recovery masks underlying access and equity challenges driven by federal policy decisions, demographic shifts, and disparities in who higher education is currently serving — and who it may be leaving behind.

NACAC Advocacy 

Since the previous issue of Advocacy Update on the Admitted blog, NACAC has continued to engage actively with partners, policymakers, and coalition allies to defend college access, protect students’ rights, and promote a stable and equitable postsecondary system.

NACAC joined an American Council on Education–led coalition letter responding to the Office of Science and Technology Policy’s request for information on accelerating the American scientific enterprise. In those comments, the coalition emphasized that U.S. research leadership depends on people, predictability, and integrity. The coalition underscored the essential role international students, graduate and professional students, postdoctoral researchers, and faculty play in sustaining the nation’s research workforce, and warned that proposed visa limits, a new $100,000 H-1B fee, and federal graduate loan caps threaten to undermine that pipeline. The letter also stressed the importance of sustained, predictable federal research funding to avoid disruptions that waste taxpayer dollars and drive talent abroad, while strongly affirming the need to preserve a merit-based peer review system and guard against politicized grantmaking.

NACAC also endorsed the bipartisan Creating Opportunities to Use Received Student Exam Credit (COURSE Credit) Act, introduced by Rep. Suhas Subramanyam and Rep. Jefferson Van Drew. The legislation would bring greater transparency to how colleges and universities award Advanced Placement and International Baccalaureate credit by requiring the Department of Education to collect and publish program-level credit policies on the College Scorecard and ensure institutions clearly post the same information on their websites. NACAC’s support reflects our longstanding commitment to helping students make informed enrollment decisions, better leverage advanced coursework, reduce time and cost to degree, and strengthen equitable pathways into and through postsecondary education.

In addition, NACAC joined coalition partners in urging Congress to intervene in response to the Trump administration’s efforts to dismantle the U.S. Department of Education through interagency agreements. The coalition letter emphasized that Congress — not the executive branch — has sole authority over the department’s structure and funding, and warned that fragmenting education programs across multiple agencies will weaken oversight, increase bureaucracy, and place students’ civil rights at risk. Rather than creating clarity or returning authority to states, these actions threaten to introduce instability and new barriers for students, families, and institutions. The coalition called on lawmakers to reverse the transfers, enforce appropriations law, and restore the Department of Education to full operation to protect equal opportunity and ensure effective federal stewardship of education programs.

Together, these efforts reflect NACAC’s continued focus on advancing policies that promote transparency, stability, and access for students — while pushing back against actions that jeopardize educational opportunity, equity, and trust in federal education policy and programs.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Your Senators: Keep Education Programs at the Department of Education
• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

The months ahead will continue to test how higher education responds to uncertainty, shifting policy, and competing priorities. The choices made now will shape not only institutional practice, but who feels welcome, supported, and able to pursue postsecondary opportunity. NACAC will remain engaged alongside our members — tracking developments, elevating concerns, and advocating for policies that center students and the professionals who support them. Progress in moments like this is rarely immediate, but it is built through consistency, collaboration, and a shared commitment to purpose.

As conservationist and global advocate Jane Goodall reminds us, “What you do makes a difference, and you have to decide what kind of difference you want to make.”

By meeting this moment with purpose and persistence, our advocacy can expand opportunity and safeguard access for the students we serve.

By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. With the holiday season upon us, I would like to wish you Happy Holidays. As the year comes to a close, this is a time for reflection, anticipation, and planning — and, I hope, a chance to disconnect and spend time with family and friends. I also hope you are able to find moments to rest and recharge as we look ahead to a busy 2026.

This past week brought meaningful opportunities for advocacy in the face of ongoing and, at times, intensifying challenges that continue to complicate pathways to postsecondary education and the work of the professionals who support students as they navigate the next chapter in their stories. The updates below highlight key developments shaping the federal education landscape and NACAC’s continued efforts to advance access, equity, and stability for students and institutions alike.

Policy & Legislative Updates 

Recent court decisions and administrative actions continue to shape the federal education landscape, underscoring both the importance of accountability and the instability facing students, institutions, and the agencies meant to serve them. A federal judge recently rejected the Education Department’s request to delay implementation of the Sweet v. McMahon borrower defense settlement, reaffirming that borrowers are entitled to timely relief under the 2022 agreement. With nearly 200,000 post-class applicants still awaiting decisions, the court ordered the Education Department to meet the Jan. 28, 2026 deadline for resolving most remaining cases or approve them automatically, emphasizing the real financial and emotional harm caused by prolonged uncertainty.

At the same time, federal courts have stepped in to curb other administration actions affecting the department’s capacity. A separate ruling ordered the reversal of hundreds of shutdown-era layoffs across several agencies, including roughly 150 staff in the Education Department’s Office for Civil Rights. The judge found the layoffs violated congressional spending law and stressed that administrative inconvenience does not outweigh statutory requirements or the harm inflicted on workers and the public they serve. These rulings come as lawmakers and advocates continue to warn that the administration’s use of interagency agreements to shift education programs out of the Education Department would erode expertise, add bureaucracy, and weaken federal support for students in ways Congress did not authorize.

Programmatic uncertainty is also evident in federal grantmaking. After months of terminations, appeals, and litigation tied to allegations that prior awards reflected Biden-era diversity, equity, and inclusion priorities, the Education Department announced more than $208 million in new mental health grants. However, the new awards are narrowly focused on expanding the pipeline of school psychologists and exclude universities and diversity-centered initiatives, leaving gaps in broader mental health supports and continued uncertainty for many schools and communities. The department has also announced a $15 million grant competition to support statewide “Talent Marketplaces” that document skills, credentials, and work histories, reflecting growing interest in learning and employment records even as questions remain about funding sources and long-term implementation.

Congress, meanwhile, is advancing legislation aimed at college affordability and transparency. The House education committee has moved bipartisan bills that would require a universal net price calculator, expand program-level data on the College Scorecard, and standardize financial aid offer letters by 2029. While these efforts are framed as rebuilding public trust, institutions remain concerned about implementation burden and the Education Department’s capacity to carry out new mandates amid staffing disruptions and program transfers. A recent analysis from New America raises concerns that the House’s College Financial Aid Clarity Act falls short of delivering true price transparency for students and families. While the bill sets some content requirements for financial aid offers, it stops short of requiring a fully standardized, comparable format — allowing institutions to use different layouts, terminology, and loan presentations. Advocates warn this approach could perpetuate confusion, obscure true net price, and make oversight difficult, undermining the goal of helping students make clear, informed decisions about college affordability.

On the student aid front, federal negotiators have reached consensus on Workforce Pell regulations, clearing the way for Pell Grants to cover certain short-term workforce programs as early as July 1, 2026. The proposal includes detailed guardrails around program quality, outcomes, and earnings, signaling a broader shift toward program-level accountability. Attention is now turning to the next phase of rulemaking, where the department has indicated it will revisit earnings-based metrics across sectors, including gainful employment and a new “Do No Harm” standard. At the same time, graduate education is preparing for major changes as new federal loan limits and the elimination of Grad PLUS loans take effect next summer, raising concerns about enrollment shifts, increased reliance on private lending, and added pressure on institutions already navigating financial and demographic challenges.

Federal civil rights laws are increasingly being used by the administration to challenge — rather than advance — equity-focused education policies. The Department of Justice has filed a lawsuit against Minneapolis Public Schools, challenging provisions in a teachers’ union contract that support the recruitment and retention of educators of color. The Trump administration argues these measures violate the Civil Rights Act of 1964, a position that has raised significant concern among educators and advocates who view the case as an effort to weaponize civil rights statutes against the very communities those laws were intended to protect.

In higher education, institutions are navigating similar pressures in the wake of the Supreme Court’s ban on affirmative action. Many highly selective colleges have turned to economic diversity strategies — including expanded need-based aid, tuition-free policies, and broader recruitment — to preserve access for low-income students. While early data show increases in Pell enrollment at elite institutions, those gains have not consistently translated into racial diversity, and the Trump administration has signaled that even socioeconomic approaches may face heightened scrutiny as potential racial proxies.

Immigration policy developments are also raising alarms across the education community. The administration has expanded travel restrictions to 39 countries, including Nigeria, one of the largest sources of international students to the United States, with new limits taking effect Jan. 1, 2026. In parallel, a coalition of 20 states has filed a third lawsuit challenging the administration’s $100,000 fee on new H-1B visas, arguing it exceeds executive authority and threatens staffing pipelines for colleges, schools, and healthcare systems.

Against this backdrop, new data and research continue to highlight both opportunities and challenges in access and affordability. Common App data through Dec. 1 show strong growth in applications from low-income, first-generation, Black or African American, multiracial, rural, and Southwest-based students, even as international applications — particularly from Asia and Africa — decline. Additionally, a new Brookings analysis also pushes back on claims that college no longer pays off, finding that lifetime earnings premiums for bachelor’s degree holders remain substantial and that inflation-adjusted tuition and net costs have been largely flat since the Great Recession.

NACAC Advocacy 

This week, NACAC took action on multiple federal policy issues that directly affect students, counselors, and institutions. NACAC joined a coalition of higher education and data experts urging the U.S. Department of Education to pause and reconsider its proposed Admissions and Consumer Transparency Supplement (ACTS) to IPEDS. While NACAC supports meaningful transparency in college admissions, the coalition raised serious concerns that the current proposal relies on unclear definitions, an accelerated timeline, and insufficient technical support—conditions that could result in inconsistent reporting and misleading comparisons across institutions. The coalition also emphasized that ACTS data cannot determine whether race is a factor in admission decisions and, without additional context and clearer guidance, risks confusing rather than informing students, families, policymakers, and the public.

NACAC also endorsed bipartisan legislation to strengthen the Public Service Loan Forgiveness (PSLF) program. The PSLF Payment Completion Fairness Act would address a technical gap that has denied loan forgiveness to public servants who completed 120 qualifying payments but retired or changed jobs before their applications were processed. With ongoing backlogs and delays, NACAC supports this commonsense fix to ensure borrowers who meet the program’s requirements receive the relief they earned and to reinforce PSLF’s role in supporting the public service workforce.

In addition, NACAC called on Congress to preserve the integrity of federal education programs by keeping them within the U.S. Department of Education. NACAC urged support for the Murray/Baldwin amendment to the Labor–HHS–Education minibus, which would block the transfer of education programs to other federal agencies through interagency agreements. Such transfers risk disrupting complex programs that depend on specialized expertise, established systems, and close coordination with states, institutions, and students. As the Senate considers the appropriations package, NACAC is encouraging members to share their perspectives with senators and underscore the importance of maintaining congressional intent and ensuring education programs remain housed within the department best equipped to administer them effectively.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Your Senators: Keep Education Programs at the Department of Education
• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

As we close out the year, the policy developments outlined in this update reflect both the complexity of the current moment and the continued importance of steady, values-driven advocacy. While the challenges facing postsecondary education are real — from legal uncertainty and administrative strain to shifting federal priorities — so too is the collective commitment of NACAC members to ensuring students have clear, supported pathways forward. As we head into the holiday season and prepare for the work ahead in 2026, thank you for the time, care, and professionalism you bring to students, institutions, and this community every day.

As educator and civil rights leader Howard Thurman once wrote, “Don’t ask what the world needs. Ask what makes you come alive, and go do it — because what the world needs is people who have come alive.”

We look forward to continuing this work together in the year ahead.

By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. As we head into the final weeks of the year, I’m struck by how much our community continues to carry — and how consistently our members show up for students despite the volatility of the policy landscape. This past week brought a series of fast-moving legislative, regulatory, and legal developments that will shape the environment in which students make decisions about their futures. While the pace of change remains challenging, the work you do every day brings clarity, stability, and hope to students navigating an increasingly complex system. NACAC remains grateful for your leadership and deeply committed to ensuring your experiences guide our advocacy at the federal level.

Policy & Legislative Updates 

At the national level, the Supreme Court issued a shadow-docket ruling allowing Texas to use redrawn congressional maps in 2026 for the upcoming midterm elections, despite a lower court finding that the plan was likely an unconstitutional racial gerrymander. Civil rights groups warn the decision sidelines communities of color and reflects a broader pattern: high-stakes election questions increasingly being resolved through emergency orders rather than full judicial review. These decisions ripple into our work, shaping the political context in which education policy is debated and implemented.

As the Education Department moved into negotiated rulemaking this week, much of the focus was on the future of Workforce Pell and whether existing accountability systems adequately protect students. The Education Department’s new AHEAD proposal outlines the first regulatory framework for short-term Pell-eligible programs, including completion and job-placement thresholds, a “value-added earnings” test, and a dual state–federal approval process. The proposal also introduces a significant new eligibility restriction for all Pell recipients: students whose non-federal aid meets or exceeds their cost of attendance would lose Pell eligibility, forcing institutions to adjust aid packages or return Pell funds. At the same time, a major unresolved question remains whether undergraduate certificate programs — explicitly exempted from Congress’s new Do No Harm earnings test — will face any meaningful oversight going forward. With Workforce Pell expansion moving forward and accountability gaps widening, this week’s negotiations will determine whether federal funds continue to support low-value pathways or whether protections will evolve to meet student and taxpayer expectations.

Federal instability is also intensifying. More than 30 Senate Democrats recently warned that the department’s efforts to shift core functions to other agencies may be unlawful and risk eroding longstanding student supports — including TRIO, GEAR UP, and the Postsecondary Student Success Grant Program. The letter underscores a growing concern on the Hill: interagency transfers are deepening operational instability at a moment when students and institutions most need clarity.

That concern is mirrored inside the department itself. After attempting to lay off more than 260 civil rights employees, the Education Department is now requiring those same workers to return due to a backlog exceeding 25,000 unresolved discrimination complaints. The reversal reflects the profound operational strain created by workforce reductions and the severe risks posed to students and families awaiting legally required protections. Efforts to dismantle the department continue to collide with the realities of its core enforcement responsibilities.

Legal and fiscal uncertainty is affecting K–12 programs as well. A federal appeals court temporarily reinstated funding for 49 school mental health projects the Turmp administration attempted to cancel, but the department has not committed to sustaining these grants through the end of the year or awarding new funding on schedule. Districts and states remain in limbo, navigating conflicting directives while trying to sustain services students rely on. The instability highlights the urgent need for predictable timelines and adherence to congressional intent under the Bipartisan Safer Communities Act.

Students and families are also beginning to see new federal transparency tools. The FAFSA now includes a “lower earnings” warning for institutions where graduates earn less than adults with only a high school diploma. While the flagged institutions represent about 23 percent of colleges in the department’s database, they enroll fewer than 3 percent of all undergraduates and receive approximately $2 billion of the more than $100 billion in annual federal student aid. The list is dominated by for-profit colleges and cosmetology programs, reflecting long-standing concerns about poor labor market outcomes and high debt-to-earnings ratios in these sectors. Although consumer protection advocates view the move as an important step toward clarity, higher education groups continue to raise questions about data quality, regional wage variation, and the blunt nature of institution-level labeling. Even so, this shift signals the federal government’s accelerated push toward outcomes-based accountability ahead of next year’s implementation of the Do No Harm earnings test.

The Pell Grant program faces a separate long-term challenge. A new analysis from the Committee for a Responsible Federal Budget warns that, despite a $10.5 billion infusion this summer, the Pell reserve remains on track for a $61–$97 billion shortfall over the next decade. Workforce Pell expansion has increased program costs, and without structural solutions, the nation’s core need-based aid program will continue to face recurring instability.

In the K–12 arena, declining enrollment is prompting states to revisit longstanding questions about the sustainability of small school districts. Wisconsin’s latest push for voluntary consolidation mirrors conversations underway in several states as communities grapple with governance, transportation, staffing, and identity concerns. Even with incentives and feasibility studies, consolidation is not a remedy for broader funding inequities or rural resource constraints. As pandemic-era “hold harmless” policies expire and enrollment continues to fall, more districts may face difficult structural decisions.

Borrowers are also confronting renewed uncertainty. The Trump administration has reached a settlement with Missouri to formally end the SAVE repayment plan — pending court approval — accelerating the timeline set by OBBBA. Nearly eight million borrowers could soon be transitioned into new “legal repayment plans” with no clear alternatives or forgiveness pathways. Advocates warn that this abrupt shift heightens the risk of default for borrowers already navigating inconsistent federal policy.

Significant changes are also emerging in accreditation. The Education Department’s new Request for Information explicitly invites commenters to propose revisions aligned with the administration’s ideological priorities: restricting DEI, expanding “intellectual diversity,” curbing grade inflation, and removing race, ethnicity, and gender from outcomes measures. While there is room to strengthen standards around program quality and student outcomes, the RFI signals how easily accreditation could become a vehicle for ideological requirements outside of formal rulemaking.

The administration’s broader effort to restructure the Education Department through interagency agreements is drawing increased scrutiny. A new analysis from the Center for American Progress reinforces what we and many partners have been warning: these transfers are not a streamlining exercise, but an unlawful attempt to dismantle the department by shifting major K–12, higher education, and workforce programs to agencies that lack the expertise, statutory authority, or operational capacity to administer them. The agreements would fragment oversight across multiple departments, move billions of dollars in programs such as Title I, TRIO, GEAR UP, CCAMPIS, and the Postsecondary Student Success Grant Program, and create new bureaucratic steps for institutions already struggling with rapid policy swings. CAP also underscores that these actions circumvent Congress’s role in establishing and organizing federal agencies — mirroring earlier efforts to downsize the department through executive order, workforce reductions, and policy reinterpretations. Rather than reducing duplication, the transfers would slow funding, confuse points of contact for states and institutions, undermine equity initiatives, and destabilize core services that students and families rely on every day.

Even amid this volatility, the evidence remains clear that educational investments generate broad public benefits. A new UCLA Civil Rights Project report finds that closing gaps in early childhood access, high school completion, and college attainment — particularly for Black and Hispanic students — could yield up to $72.6 billion in annual public benefits. These findings reinforce that equitable investments strengthen our national economic future, while recent federal cuts and policy shifts move in the opposite direction.

Finally, new research highlights the growing fear and instability facing international students. A national survey from Stop AAPI Hate found that most international students feel unsafe, uncertain about their visa status, and hesitant to participate fully in campus or civic life. Many expressed fears of surveillance, detention, or family separation. Institutions continue working to support affected students, but gaps in legal guidance and immigration clarity persist.

Amid these challenges, employer confidence in higher education remains strong. A new AAC&U–Morning Consult survey shows seven in ten employers continue to trust colleges and universities and believe degrees retain their value. Employers emphasize communication, problem-solving, ethical judgment, and AI literacy as essential skills — and affirm that diverse perspectives and open dialogue remain central to workforce readiness.

Across all of these developments, the through-line is clear: stability, transparency, and student-centered policymaking are urgently needed. NACAC will continue monitoring these shifts closely, engaging federal partners, and ensuring that the experiences of our members — and the students they serve — remain front and center in national debates.

NACAC Advocacy 

This week, NACAC continued its federal engagement on multiple fronts as policymakers move quickly on issues that directly affect students, institutions, and the professionals who support them. We met with coalition partners to coordinate strategies that defend equitable pathways to postsecondary education and to ensure the field is prepared for the rapidly evolving landscape surrounding negotiated rulemaking on Workforce Pell. These discussions remain essential as the AHEAD proposal raises new concerns about program quality, student protections, and the implementation burdens institutions may face.

NACAC also submitted formal comments on the Education Department’s revised ACTS proposal, reiterating the significant feasibility, accuracy, and privacy concerns our members have consistently raised. While we appreciate the department’s decision to limit ACTS to four-year institutions, the revised proposal still presents major operational challenges — from unclear definitions and unrealistic reporting expectations to the risk of generating misleading or easily misinterpreted admissions data, particularly regarding race. Members continue to warn that the proposal would divert scarce staff time away from direct student support and require data many colleges do not currently collect or maintain.

In our comments, we urged the department to delay implementation, engage practitioners meaningfully in developing clearer guidance, restore technical assistance, and adopt stronger privacy safeguards. Our goal remains consistent: ensuring any federal reporting requirements strengthen accuracy, equity, and transparency without undermining the work that supports students’ access to college.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

Through every challenge we have navigated this year, what continues to stand out is the strength, generosity, and resolve of this community. Your work — advising students, guiding families, shaping institutional decisions, and lending your voice to advocacy — anchors our field during a period of extraordinary uncertainty. NACAC will continue pressing for stability, transparency, and policies that reflect the realities you see every day, but it is your commitment that gives this work purpose and momentum.

I am reminded of Grace Lee Boggs’s powerful reflection:

“We never know how our small activities will affect others through the invisible fabric of our connectedness. In this exquisitely connected world, it’s never a question of ‘critical mass.’ It’s always about critical connections.”

As we begin to close out 2025, I want to express my deep gratitude for all you do to support students and uphold the values that define our profession. Your efforts, both visible and unseen, move this work forward in ways that matter.

By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. As the Trump administration continues advancing its plan to dismantle the Department of Education through a series of interagency agreements, uncertainty remains the defining feature of the federal education landscape. Each week brings new indications of how deeply these moves are straining the systems students, counselors, and institutions depend on — from grant management and program oversight to civil rights enforcement and borrower support. What was once framed as administrative “streamlining” has instead revealed widespread disruption, shrinking capacity, and growing confusion across agencies. Against this backdrop, educators, state leaders, tribal nations, and higher education institutions are raising alarms about the operational, legal, and equity implications. It is within this environment of rapid change and diminished transparency that NACAC continues to monitor developments, engage partners, and advocate for the stability and protections that students and institutions urgently need.

Policy & Legislative Updates 

Internal documents continue to underscore how fragile — and risky — the administration’s dismantling of the Education Department truly is. Even the small-scale transfer of OCTAE to the Labor Department strained ED’s capacity and nearly disrupted funding, raising serious concerns as far larger programs are slated for relocation to Labor, HHS, Interior, and State. Staff describe a lack of answers, rising anxiety, and real fears that these moves will weaken oversight, destabilize grant management, and disrupt services that students and institutions rely on. While the administration frames these shifts as efficiency, the internal assessments paint the opposite picture.

The ripple effects are being felt across communities. Tribal leaders have sounded the alarm that the administration’s decision to shift dozens of Native American education programs to other federal agencies was made without the legally required tribal consultation. Leaders from Standing Rock to the American Indian Higher Education Consortium warn the transfers will create instability, add bureaucratic hurdles, and undermine supports for Native students — a direct breach of trust and a failure to center those most impacted. Tribal advocates are calling for the transfers to pause until meaningful consultation occurs and capacity concerns are addressed.

On campuses, heightened immigration enforcement is adding another layer of uncertainty. North Carolina institutions are responding to intensified ICE and CBP activity across Raleigh, Durham, and Charlotte by issuing urgent reminders about FERPA protections and protocols for verifying warrants, but anxiety among students is rising. International students, faculty, and staff report unconfirmed sightings of federal agents and growing concern that existing protections are insufficient in this moment. National survey data reinforce these trends: a new EdWeek analysis shows increased immigration enforcement is leading to missed school days, disengagement, and higher demand for mental health supports — especially in high-poverty districts. Many schools still lack clear written protocols, leaving students and educators without reliable guidance. Our partners at the Presidents’ Alliance on Higher Education and Immigration have developed resources designed to support school counselors, K-12 educators, and college counselors working with mixed-status and undocumented families. These tools provide timely information, policy clarity, and community support to help educators and counselors advocate for students and expand access to higher education.

Legal challenges are also accelerating. The Department of Justice has sued California and its three public higher education systems to strike down the state’s decades-old policy allowing undocumented students to pay in-state tuition — a move that threatens affordability for thousands and adds another layer of uncertainty for institutions already navigating a volatile policy environment. Meanwhile, the administration’s broader effort to dismantle ED has resurfaced a two-century-old debate over the federal role in education. Scholars note that shifting congressionally mandated programs across multiple agencies is more symbolic than substantive, and almost certain to create confusion at a moment when institutions need clarity and stability.

Congressional scrutiny is intensifying. Senator Elizabeth Warren has called on the department’s inspector general to investigate the dismantling effort, citing incomplete responses from ED, concerns about weakened civil rights enforcement, and questions around staff selected for reductions in force. Her letter highlights the growing unease in Congress as transparency declines, and the administration accelerates timelines for moving programs out of the department.

Transparency within the administration’s reorganization efforts is shrinking, with reports that senior officials have been required to sign non-disclosure agreements limiting what they can share about the department’s restructuring. Staff relocations to Labor and HHS are already underway, even as timelines, logistics, and implications for students and institutions remain unclear. The challenges are already evident: the transfer of career and technical education programs to Labor earlier this year resulted in grant-system glitches, delayed reimbursements, and confusion among state leaders. These individuals warn that shifting $28 billion in K–12 funding — particularly Title I — into a workforce-focused agency is likely to deepen inequities and operational dysfunction. Despite assurances of a “smooth transition,” educator feedback reflects a growing sense that capacity shortfalls and misaligned missions are putting vulnerable students at risk.

The administration’s shrinking of ED’s internal capacity is also showing up in borrower relief efforts. The department is seeking an 18-month extension to resolve borrower defense claims under the Sweet v. McMahon settlement, citing diminished staffing and resource constraints. Advocates warn that delays would undermine the agreement’s core promise of timely relief for students defrauded by predatory institutions.

Elsewhere, the administration continues to pressure institutions through federal investigations. Northwestern has reached a $75 million settlement — similar to earlier agreements with Columbia and Brown — to close federal probes and restore access to research funding. The agreement requires updated discrimination and harassment policies and new protections for Jewish community members and international students. While ED leaders call these deals a model for accountability, critics warn that the settlements reinforce ongoing federal intrusion into institutional governance.

Legal challenges to the dismantling effort are expanding as well. A broad coalition of states, districts, unions, and disability-rights advocates has amended its lawsuit arguing that outsourcing core ED responsibilities violates federal law and destabilizes systems that students and educators rely on. The complaint points to mounting delays, reduced capacity, and increased confusion as clear evidence of harm.

In contrast to these destabilizing trends, new research highlights the important role international students have played in strengthening U.S. higher education. A new National Bureau of Economic Research (NBER) analysis shows that the surge of Chinese students entering U.S. master’s programs in the early 2000s not only fueled academic growth but also helped keep tuition down for American students and boosted local economies. These findings come as policymakers consider tighter visa restrictions and increased scrutiny of Chinese nationals.

On campuses, financial and policy pressures continue to drive difficult decisions. November saw a wave of program cuts, layoffs, and other cost-saving measures tied to declining research funding, steep drops in international enrollment, and new state laws mandating program closures. Institutions cite a challenging landscape shaped by shifting federal policy and eroding public trust.

Concerns about institutional autonomy deepened further when the Trump administration asked a state court to compel the University of Pennsylvania to release names and contact information of Jewish students and employees — a demand widely condemned by higher education leaders, civil rights groups, and Jewish organizations. Penn has refused to release identifying information without consent, citing its responsibility to protect privacy and safety.

In more positive news, NCAN’s FAFSA Tracker offers critical insight into early FAFSA completion trends for the class of 2026. While overall completions are rising under the simplified form, significant disparities persist across race, income, and community type — a reminder that simplification alone cannot close longstanding equity gaps in financial aid access.

Research on direct admissions also reinforces that policy changes work best when paired with sustained support. New analyses show that direct admissions boosts application and enrollment rates, but affordability, advising, and clear communication remain central barriers. NCAN’s new Direct Admissions Best Practices hub brings together state models and practical guidance for partners seeking to strengthen or implement these programs, emphasizing that direct admissions are most effective when integrated into a broader strategy that centers student support.

Finally, new data from the National Student Clearinghouse Research Center show that college completion rates have remained remarkably stable despite the pandemic-era disruptions faced by the fall 2019 cohort. Full-time enrollment and early exposure to college coursework continue to be strong predictors of completion, with dual-enrollment students posting especially high success rates. Yet persistent gaps by income, gender, age, and enrollment intensity underscore the ongoing equity challenges facing institutions and policymakers.

NACAC Advocacy 

This week, NACAC continued to deepen our advocacy on several fronts as the landscape around federal education policy grows more complex. We met with coalition partners to coordinate our shared response to the administration’s accelerating effort to dismantle the Education Department. These conversations focused on the operational disruptions already emerging across federal programs, the cascading impact on students and institutions, and the need for a unified strategy to defend core functions ranging from civil rights enforcement to financial aid administration.

Our team also engaged in ongoing discussions around Negotiated Rulemaking — particularly the RISE and AHEAD committees — as we prepare for another round of regulatory debates that will shape the future of accreditation, student protections, and institutional accountability. Workforce Pell continues to be a central topic in these conversations. NACAC is working closely with partners to ensure that any expansion aligns with quality standards, safeguards students from predatory practices, and strengthens — rather than fragments — pathways to meaningful postsecondary credentials.

We also spent time this week in conversations with congressional offices. These meetings provided insight into evolving legislative priorities and helped us better understand how we can support and strengthen our partnerships with lawmakers. With shifting appropriations dynamics, growing concern about agency reorganization, and heightened attention to affordability heading into 2026, maintaining close communication with congressional staff remains essential. Our goal is to ensure that NACAC members’ perspectives on access, equity, and student well-being are shaping the policies under development in real time.

Across all of this work, NACAC continues to emphasize the same core message: students, counselors, and institutions need stability, transparency, and a functioning federal education infrastructure. We will remain at the table with partners and policymakers to protect these commitments and advocate for solutions that keep students at the center of every decision.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

As we navigate another week of shifting policies and mounting uncertainty, one constant remains: the collective strength of this community. Counselors, educators, and advocates continue to show up for students with clarity and conviction, even as the systems around them grow more unstable. Your work — the daily guidance, the advocacy, the steady presence — is shaping outcomes in ways that matter deeply.

In this moment, I am reminded of a reflection from Michelle Obama:

“You may not always have a comfortable life and you will not always be able to solve all of the world’s problems at once. But don’t ever underestimate the impact you can have, because history has shown us that courage can be contagious and hope can take on a life of its own.”

While uncertainty feels overwhelming, these words ground us in what endures: our shared commitment to students, our belief in opportunity, and the power of collective action. NACAC will remain beside you in this work — steadfast, vigilant, and hopeful about what we can accomplish together.

By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. After a 43-day federal government shutdown — the longest in U.S. history — agencies are reopening, backlogs are emerging, and the full scope of the disruption is becoming clearer by the day. As institutions, students, and college admission counselors continue to navigate the uneven path toward recovery, federal policy activity is accelerating across all branches of government. This week brought significant administrative actions reshaping the U.S. Department of Education, new court decisions with national implications, major enrollment and research trends, and continued debates on Capitol Hill.

Congress is also preparing for the year ahead, with both the House of Representatives and the Senate releasing their 2026 Congressional Calendars — a reminder that many of the issues unfolding now will define the policy landscape well into next year.

As we head into the Thanksgiving holiday next week, we want to extend our gratitude for the work you do every day to support students and center equity in the college admission process. Because of the holiday, the next Advocacy Update will be published on Dec. 5. With so much in motion, NACAC remains focused on providing clarity, elevating member voices, and ensuring that federal decisions strengthen, not undermine, the pathways students rely on to access and complete postsecondary education.

Policy & Legislative Updates 

Federal agencies are still digging out from the 43-day shutdown. As staff returned, many found locked systems, frozen grants, backlogs stretching months, and projects that simply halted. While backpay provided some relief, agency officials warned that the operational damage — from stalled civil rights investigations to delayed Impact Aid, shuttered Head Start programs, and cybersecurity lapses—will ripple well into next year. The instability highlights just how fragile education and early childhood systems have become as Congress again postpones long-term funding decisions.

These fiscal pressures are compounding across higher education. A new Pew analysis shows public colleges bracing for a worsening financial landscape as state budgets tighten, federal reductions loom, and enrollment declines continue. Even “flat” budgets amount to cuts once inflation and operating costs are considered. Research institutions warn that new caps on indirect cost reimbursements, paired with federal cuts, could destabilize regional economies and research pipelines. With international enrollment down and tuition revenue strained, institutions face another year of uncertainty with few pathways to relief.

Despite these pressures, new Common App data show a modest bright spot: early application volumes are up, particularly among Black, first-generation, low-income, and rural students. Yet international applications are falling sharply, driven by visa delays and denials under the Trump administration. The most selective campuses are seeing the slowest growth, and test score submissions have increased as more institutions reinstate requirements — though first-generation and underrepresented students remain far less likely to report scores.

Those trends mirror the latest Institute of International Education (IIE) report, which shows a 17 percent drop in new international student enrollment this fall, especially among graduate students. Campuses cite visa barriers, travel restrictions, and the administration’s immigration crackdown as central drivers. The financial stakes are real: last year, international students contributed nearly $55 billion to the U.S. economy, and this fall’s decline alone represents more than $1.1 billion in lost revenue. Institutions that saw growth attributed it to extensive outreach and advising — underscoring how federal policy is shaping global talent flows.

A major federal court ruling this week also carries national implications. A judge blocked the administration’s attempt to punish the University of California system by suspending future grants and demanding billions related to civil rights investigations. The decision prohibits agencies, including NIH, NSF, and the Education Department, from using funding freezes as leverage and reaffirms that the administration cannot sidestep Title VI due process or coerce institutions in violation of constitutional protections. At stake is the stability of the research enterprise and the principle that civil rights enforcement cannot be weaponized against campuses.

As colleges confront enrollment pressures, institutions are increasingly easing admission processes — expanding direct admission, offering one-click applications, waiving fees, and extending deadlines. While these shifts help reduce procedural barriers, they also reveal the depth of the enrollment decline and the limits of access reforms that don’t address affordability, advising, or the broader structural barriers that shape whether students enroll and finish a degree.

States are now facing a parallel legal front. Texas Attorney General Ken Paxton filed a lawsuit seeking to dismantle three need-based work-study programs, arguing that longstanding restrictions on sectarian work and participation by seminary students amount to unconstitutional discrimination. These programs provide essential wages and training to low-income students. Paxton’s challenge echoes recent cases that threaten evidence-based state policies and could limit access to critical supports.

National research competitiveness also surfaced as a major concern. New data shared at the APLU conference indicate that China may have already surpassed the U.S. in total research and development spending — even before the shutdown froze federal grants for weeks. With proposed cuts looming and federal investments largely flat for two decades, agencies like NIH and NSF are only now restarting award cycles. Short-term funding bills add more instability, raising alarms about talent loss and long–term impacts on U.S. competitiveness.

The administration has now taken its most sweeping step toward dismantling the U.S. Department of Education. On Nov. 18, the Education Department announced six new interagency agreements that transfer major program offices and funding streams to the Departments of Labor, Health and Human Services, State, and Interior. Combined with an initial agreement executed in July, these shifts move oversight of more than 80 federal education programs — totaling nearly $34 billion annually — out of the department and into agencies with very different missions and capacities.

These agreements touch every part of the department’s core work. The Department of Labor will now assume responsibility for almost all K-12 formula and competitive grants, Title I among them, along with most Higher Education Act programs, adult education, and career and technical education. HHS will oversee CCAMPIS and foreign medical education accreditation, State will take on international and foreign language programs, and Interior will administer 14 Indian education programs.

While framed as efforts to “better align” programs with workforce or national security priorities, the transfers align directly with the administration’s goal of eliminating the Education Department. The scale of the shifts raises major concerns about agency capacity, legal authority, and continuity for students, counselors, and institutions — all at a time when clarity and stability in federal education policy are urgently needed.

Courts remain a critical check in the current landscape. A federal court ruling halted Texas’s mid-decade congressional map, finding substantial racial gerrymandering. The state has already appealed to the Supreme Court, adding another high-stakes voting rights case just weeks before candidate filing deadlines.

During this week’s House Education & Workforce Committee hearing on lowering college costs, members highlighted dual enrollment, course sharing, and AI as promising tools — but the discussion quickly turned to the broader federal policy environment. Witnesses underscored that innovation cannot compensate for the administration’s proposed elimination of subsidized loans, deep cuts to research, or efforts to dismantle the Education Department. Investments in programs like TRIO, GEAR UP, and IES remain essential to any affordability strategy.

At the state level, Alaska’s Education Department is transferring ownership of deteriorating rural schools to local districts as a condition of long-overdue repair funding. Many of these communities — predominantly Alaska Native and without local tax bases — warn that taking title to buildings with structural failures, contamination, and major safety risks exposes them to liability they cannot manage. Leaders say they have little choice, highlighting the inequities rural districts face nationwide.

Lawmakers on Capitol Hill are also pushing back on reports that the administration is considering selling portions of the federal student loan portfolio to private companies. More than 40 Democrats warned that such a move could violate federal law, erode borrower protections, and result in significant taxpayer losses. They stressed that safeguards like income-driven repayment, PSLF, and discharge authorities must remain intact regardless of loan ownership.

In another important legal development, a federal judge allowed Kentucky Students for Affordable Tuition to intervene and defend the state’s in-state tuition policy for undocumented students. The state’s higher education board had agreed to end the benefit under administration pressure, leaving students at risk of losing access to courses, credentials, and progress toward their degrees. The court’s ruling affirms the need to protect inclusive tuition policies that expand opportunity and economic mobility.

The administration’s anti-DEI campaign is also intensifying. A new State Department proposal would remove 38 universities from the Diplomacy Lab program because they use diversity, equity, and inclusion-related hiring practices. Institutions labeled as having “clear DEI hiring policies” would be replaced with schools deemed “merit-based,” upending longstanding federal research partnerships and extending the political targeting of campus DEI initiatives.

Finally, state leaders are raising alarms about the weakening of statewide longitudinal data systems — the tools that help policymakers understand student pathways from early childhood to the workforce. While 32 states operate these systems, many lack the resources and modernization needed to keep pace with rapidly changing labor markets, especially as apprenticeships and AI-driven career shifts expand. With declining state appropriations, inconsistent federal support, and the administration proposing to eliminate dedicated funding for longitudinal systems, states risk making policy “in the dark” at the very moment students and institutions need clear, evidence-based guidance.

NACAC Advocacy 

This week, NACAC continued advocating for policies that support students and protect institutional stability. NACAC joined higher education organizations in urging National Defense Authorization Act (NDAA) conferees to adopt balanced, evidence-based research security measures that strengthen national interests without disrupting campus operations or global collaboration. The letter supports bipartisan language aligned with existing federal frameworks and preserving essential indirect cost structures, while warning against overly broad proposals — including the SAFE Research Act and other House and Senate provisions — that would duplicate current processes, impose unworkable restrictions, or risk chilling international research partnerships. It also flags provisions that could jeopardize funding for institutions responding to antisemitism under their civil rights obligations.

NACAC also issued a public statement responding to the administration’s newly announced interagency agreements transferring major education programs out of the Department of Education. These moves represent a significant escalation in the administration’s effort to dismantle the department and fragment its core functions across agencies with no dedicated education mission. NACAC underscored that such actions weaken federal oversight, sidestep Congress, and introduce deep uncertainty for students, institutions, and the counselors who support them. We remain fully committed to defending a strong, coordinated federal role in education and will continue advocating for the stability and protections our members and students deserve.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

The policy landscape continues to shift quickly, with the Trump administration’s efforts to dismantle the only federal agency dedicated to children and students unfolding alongside new enrollment trends, court decisions, and ongoing debates in Congress. Through all of it, NACAC remains focused on ensuring that federal decisions strengthen, rather than destabilize, the pathways students rely on to access and complete college. Your work on the ground, supporting students and advocating for equity every day, continues to anchor our efforts in Washington, D.C.

As we look ahead, I am reminded of William Faulkner’s reflection on the power of collective action: “Never be afraid to raise your voice for honesty and truth and compassion against injustice and lying and greed. If people all over the world… would do this, it would change the earth.”

In a moment defined by uncertainty and change, raising our voices — together — remains our most powerful tool. NACAC will continue to stand with you, speak up for the students and communities we serve, and press for policies that protect opportunity and uphold fairness and opportunity in higher education.

By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. The longest federal government shutdown in U.S. history has finally come to a close after 43 days, ending a period marked by uncertainty, disruption, and strain across the nation. As institutions, students, and college admission counselors begin to navigate the uneven path toward recovery, federal agencies are reopening, policy debates are resuming, and courts and Congress are shaping the landscape in real time. This moment underscores just how closely access to education is tied to the stability and functionality of government — and why continued vigilance, advocacy, and clear-eyed policy engagement remain essential to protecting students and the professionals who support them.

Policy & Legislative Updates 

The higher education sector continues to feel the strain of the record 43-day federal shutdown, with disruptions touching nearly every corner of campus operations and student life. Institutions are reporting significant delays in research activity and grant spending, with universities like North Carolina State freezing federal grant expenditures as interruptions surpass $25 million per month. Students and families are facing widening hardship as partial cuts to SNAP benefits deepen food insecurity for more than one million college students, while military-affiliated students encounter delays in tuition assistance and GI Bill payments. Adjunct faculty are also seeing health care costs rise as federal subsidies stall. Across higher education, many describe this moment as one of “cumulative exhaustion.”

Several court decisions offered temporary relief for families while underscoring the instability surrounding federal programs during the shutdown. A federal judge ordered the administration to restore full SNAP benefits for the 42 million people who rely on the program, finding that officials deliberately withheld available funds for political reasons. The First Circuit then blocked an additional attempt to halt benefits, following an earlier administrative stay issued by Supreme Court Justice Ketanji Brown Jackson, who temporarily paused lower court orders to allow for further review. The Supreme Court extended that stay through the end of Nov. 13. Now that the bipartisan agreement to reopen the government includes the full Fiscal Year 2026 SNAP budget, the status of the lawsuit is uncertain; it may ultimately be dismissed as moot because SNAP recipients will, eventually, receive their missing November benefits.

Congress, meanwhile, has begun to reengage issues beyond the shutdown. Following passage of OBBBA, lawmakers are turning their attention to transparency in college cost information. At a Senate HELP Committee hearing, members from both parties emphasized the need for program-level clarity on price and outcomes. While Republicans framed transparency as central to understanding return on investment, Democratic witnesses highlighted the broader affordability crisis — driven by rising living expenses — that transparency alone cannot solve. Proposals ranged from improving the College Scorecard to standardizing financial aid offers and advancing the bipartisan College Transparency Act.

As funding negotiations slowly progressed, the Senate advanced a bipartisan agreement to end the shutdown. The package will provide full-year appropriations for the Departments of Veterans Affairs and Agriculture and the legislative branch while funding all other agencies under a continuing resolution through Jan. 30. The deal guarantees back pay for more than one million federal employees, temporarily blocks new layoffs, and restores thousands of positions eliminated during the shutdown. Although most Democrats opposed the measure for failing to extend expiring Affordable Care Act premium subsidies — the issue central to the standoff — enough supported the agreement for it to move forward. The legislation passed in the Senate 60-40 on Nov. 10 and passed in the House of Representatives 222-209 on Nov. 12; the president signed the bill into law following passage in the House.

Courts also weighed in on the administration’s internal operations. A federal judge ordered the Education Department to remove partisan language inserted into furloughed employees’ out-of-office messages, finding that the administration had “commandeered” employee email accounts to advance political messaging during the shutdown. The ruling permanently bars the department from inserting partisan content into automated emails and reinforces the longstanding principle of civil-service neutrality.

Beyond the shutdown, universities continue to navigate shifting administrative policies. Cornell University reached a $60 million agreement with the administration that restores more than $1 billion in frozen federal research dollars while explicitly preserving the institution’s autonomy. The settlement requires only limited federal reporting, making Cornell the fifth institution to strike such a deal as the administration continues pursuing investigations and policy changes aimed at reshaping higher education and dismantling diversity, equity, and inclusion structures.

Even as universities respond to these federal actions, states are beginning to consider their own roles in safeguarding civil rights. With the Education Department’s Office for Civil Rights significantly weakened through layoffs, regional office closures, and a narrowed enforcement scope, some states — such as Pennsylvania — are weighing the creation of state-level civil rights offices to fill the gap. Advocates caution that a state-by-state approach risks creating uneven protections for students nationwide.

Enrollment trends continue to evolve amid this uncertainty. New data from the National Student Clearinghouse Research Center show overall enrollment up 2 percent this fall, with community colleges leading growth at 4 percent and the largest increases occurring among students pursuing short-term credentials and associate degrees. Graduate enrollment held flat. The data also highlight a growing racial-reporting gap, with a 45 percent rise since 2023 in students not disclosing their race — complicating efforts to monitor demographic shifts.

At the same time, the Education Department is redirecting nearly all $171 million in Fund for the Improvement of Postsecondary Education (FIPSE) funding from congressionally intended student success and access programs toward administrative priorities such as artificial intelligence, civil discourse, accreditation reform, and short-term workforce training. Stakeholders warn that this shift sidesteps legislative intent, puts pressure on institutions serving rural, veteran, and low-income students, and may be difficult to implement given staff shortages and tight timelines.

In a notable departure from earlier policy positions, Trump recently defended the presence of international students in U.S. higher education, calling them “good” for America’s colleges and cautioning that enrollment cuts would devastate institutions financially — especially HBCUs. The comments contrast sharply with prior administrative actions that restricted visas and imposed heightened requirements for international students, highlighting tension between political messaging and the economic realities facing colleges.

With the shutdown now officially over following House passage of a short-term funding bill, agencies are moving to resume operations, though major policy disputes remain unresolved. The agreement restores pay for federal workers and allows institutions to continue accessing core student aid services, but uncertainty persists around whether the Education Department will comply with provisions reversing recent layoffs. Many expect additional oversight challenges in the weeks ahead.

Meanwhile, legal challenges continue in states seeking to end in-state tuition benefits for undocumented students. Courts in Texas and Oklahoma have already struck down tuition-equity policies, tripling costs for some students with little warning. Similar efforts are underway in Kentucky, Illinois, and Minnesota. Civil rights advocates, including the Mexican American Legal Defense and Educational Fund (MALDEF), are pushing to reopen these cases, arguing that affected students were denied due process. NACAC joined an amicus brief led by the Presidents’ Alliance urging the Fifth Circuit to ensure students have the opportunity to be heard.

Finally, the administration has released a revised proposal to expand IPEDS admissions reporting. The updated draft narrows the scope to four-year institutions with selective admissions and requires six years of disaggregated application and admissions data, including test scores, GPA, Pell eligibility, income, and parental education levels. Community colleges and open-enrollment institutions awarding aid solely based on need are no longer included. While this reduces the burden on open-access institutions, significant concerns remain. NACAC’s previous public comment called for greater clarity, stronger privacy protections, and safeguards against misuse of admissions data. The revised proposal is now open for a 30-day public comment period.

NACAC Advocacy 

This week, NACAC continued to elevate the concerns of our members and the students they serve as federal actions and policy shifts create new challenges across the education landscape. In meetings with congressional staff, I underscored the urgent need to protect equitable pathways to postsecondary education — particularly as institutions navigate the aftermath of the shutdown, ongoing legal battles, and emerging federal proposals that could reshape college access.

These conversations focused on the concrete impacts that recent federal actions are having on students, college admission counselors, and institutions, including rising instability in student aid programs and the growing strain on low-income and first-generation students. I emphasized the foundational principle that public education is a public good, and that federal policy must reinforce — rather than erode — the systems that allow individuals to move toward opportunity.

NACAC also discussed introducing legislation aimed at strengthening college access, supporting students and families through clear admission processes and policies, and reinforcing pathways that help individuals enter and remain in mission-driven careers through the Public Service Loan Forgiveness program. Across each meeting, our message was consistent: students deserve an accessible, stable, and equitable system, and NACAC will continue to push for federal policies that uphold those values.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

As federal operations resume and policymakers turn toward the work ahead, this moment calls for both persistence and a clear commitment to progress. The past 43 days underscored how quickly uncertainty can ripple through classrooms, campuses, and communities — but they also revealed the resilience of the professionals who remain steadfast in their support of students. NACAC will continue to advocate for policies that strengthen pathways to opportunity and reinforce the systems that allow students to move forward with confidence, clarity, and stability.

In the spirit of that work, I am reminded of the words of educator and civil rights advocate Marian Wright Edelman: “Education is for improving the lives of others and for leaving your community and world better than you found it.”

As we look ahead, we carry that charge with us — advancing progress step by step, and persevering on behalf of the students and counselors who depend on it.

By Sean Robins, NACAC’s director of advocacy

Welcome to this issue of the Advocacy Update on NACAC’s Admitted blog. With the federal shutdown now the longest in U.S. history, its impact on education is becoming increasingly visible — from disruptions in food assistance to weakened civil rights protections. Each development underscores the need for steadfast advocacy to ensure students remain at the center of policy decisions. NACAC continues to monitor these challenges closely and advocate for equitable access, institutional integrity, and support for those most affected.

Policy & Legislative Updates 

As the federal government shutdown stretches into its second month, schools and families are facing mounting challenges. SNAP funding lapsed on Nov. 1, nearly 40 percent of recipients are children and at risk of losing access to critical food support. While USDA has temporarily extended school meal funding, delays in reimbursements and potential disruptions to Head Start programs are raising serious concerns about rising food insecurity and instability for students and families. Efforts by states, schools, and organizations like the Hope Center for Student Basic Needs are helping to fill gaps, but millions remain vulnerable, especially as partial SNAP payments have only just begun and are insufficient to meet basic needs.

The shutdown itself is now the longest in U.S. history, now exceeding 38 days, with no immediate end in sight. Congressional negotiations have made only slow progress. The House remains out of session, and Senate Republicans continue to resist Trump’s push to eliminate the filibuster to force passage of a stopgap funding bill. While bipartisan talks are ongoing, lawmakers are grappling with disagreements over full-year appropriations, temporary funding measures, and expiring health care subsidies under the Affordable Care Act. The economic and human toll is escalating, with costs already surpassing $7 billion in lost GDP and projected to reach $14 billion if the impasse continues past eight weeks. At the same time, previously promised back pay for furloughed federal workers has been rescinded, adding to economic uncertainty for hundreds of thousands of employees.

Amid these disruptions, students and families face additional challenges. Mixed-status families are increasingly hesitant to complete the FAFSA due to fears that personal information could be used for immigration enforcement, despite legal protections. The National College Attainment Network (NCAN) has issued new guidance addressing concerns from mixed-status families completing the FAFSA.

The Trump administration’s proposed rule barring employees of organizations supporting migrants or trans youth from Public Service Loan Forgiveness has sparked legal action, with advocates arguing that it politicizes a program intended to reward public service and may violate the First Amendment.

The Department of Education under Secretary Linda McMahon has also seen dramatic reductions in staff, programs, and oversight functions. While student aid remains largely intact, civil rights enforcement has been severely weakened. The Office for Civil Rights has been gutted, leaving students — particularly those facing racial harassment or disability discrimination — without federal recourse. Career staff continue to work to preserve core departmental functions, but the agency’s capacity to ensure accountability and equity has been markedly diminished.

Meanwhile, the administration’s decision to end longstanding initiatives like the National Blue Ribbon Schools program underscores a broader effort to shift responsibility to states, even as at least 18 states step in with their own recognition programs.

Despite these challenges, new research from the Brookings Institution reinforces that higher education remains a strong long-term investment, with degree holders earning substantially more than non-degree peers. However, rising debt burdens and gaps in affordability highlight the urgent need for policy action to support student persistence, equitable access, and smarter loan options.

Finally, political dynamics are shifting. Following Democratic wins in Virginia and New Jersey, party strategists are assessing opportunities in competitive and traditionally Republican states ahead of the 2026 mid-term elections, with attention on Senate and House races in key battlegrounds.

NACAC Advocacy 

This week, NACAC continued its work to advance equitable access and uphold student protections across federal and state policy. NACAC joined the American Council on Education (ACE) and other higher education associations in urging the Department of Veterans Affairs to withdraw its proposed rule redefining “distance learning” and “independent study.” The coalition letter highlights concerns that the proposed definitions conflict with those used by the Department of Education and could expand GI Bill eligibility to unaccredited, non-degree online programs — undermining safeguards that ensure program quality and protect both students and taxpayer investments. The associations called on the VA to collaborate with Congress and the higher education community to modernize these definitions responsibly.

NACAC also joined the Presidents’ Alliance on Higher Education and Immigration and 36 other organizations in filing an amicus brief before the U.S. Court of Appeals for the Fifth Circuit in support of the Texas tuition equity law. The brief emphasizes that allowing all eligible students — regardless of immigration status — to pay in-state tuition and access state aid strengthens institutions, local economies, and state workforce needs. NACAC’s participation reaffirms the association’s commitment to expanding opportunity through higher education and ensuring that college remains a pathway to upward mobility for all students.

Ways You Can Take Action 

We are continuously updating our Take Action page with opportunities to make your voice heard. If you have not already, I encourage you to advocate on the urgent issues below. You can also view all active advocacy campaigns in the yellow column of the Take Action page. 

• Tell Congress: Protect FSEOG and Work-Study Funding
• Tell Congress: Save TRIO and Support College Access
• Tell Congress: Prioritize Visa Appointments for International Students and Scholars 
• Urge Congress to Protect Postsecondary Pathways 
• Tell Congress: International Students are Essential to America’s Safety, Economy, and Global Strength
• Tell Congress to Not Abandon Our National Commitment to Education
• Urge Congress to Protect Disabled Students 
• Don’t Flunk the Future Advocacy Toolkit 

As the shutdown’s effects deepen and new policy debates emerge, NACAC remains committed to advancing fairness, integrity, and opportunity across higher education. Whether defending veterans’ benefits or championing tuition equity, our advocacy continues to center the students and communities most impacted by shifting federal priorities.

In times like these, collaboration and compassion become even more essential. As Coretta Scott King reminded us, “The greatness of a community is most accurately measured by the compassionate actions of its members.”

Together, through thoughtful advocacy and shared purpose, we can ensure that compassion continues to shape the policies guiding access and opportunity for all students.