Fewer Than 1% Of Comments Support TPS Expansion Guidance

Phil Hill and Associates

Phil Hill
April 18, 2023
I have yet to meet anyone who thinks that the decision one week ago by the US Department of Education (ED) to announce delays and reductions in scope of the third-party servicer (TPS) guidance was bad news. The changes were welcome. I have a more pessimistic, or perhaps less optimistic take than most other commenters had on the news, which you can read in this post, and we’ll cover how that conversation is or is not happening at the conference in a future post.
Whether you think the issue has been put to bed and is under control now, or whether you think the TPS expansion is still a major issue for the EdTech community, I think it is worth looking at the roughly 1,100 public comments submitted to ED to get a broad view of opinions on the Dear Colleague Letter DCL 23-03.
Data Source
We (I had some help) used the bulk download tool at the public comment site and then worked to structure the data to make it more usable. For example, we consolidated the organizational categories into a more manageable set, and we added a column hyperlinking back to the original comment, and did other data cleanup of adding a few organization names, etc. Then we added our classification of the responses:
  • For: Commenter supports DCL 23-03 and the expanded TPS definitions as written
  • Against: Commenter is against this expansion as written and believes ED should rescind or significantly change the guidance
  • Neutral: Commenter only seeks minor change to protect their specific interest, or only asks questions without stating opinion, or is off topic

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