IHEP Comments on the Postsecondary Student Success Grant Program’s Proposed Rules

Washington, DC (July 8, 2024) –  The Institute for Higher Education Policy (IHEP) submitted comments to the U.S. Department of Education (ED) on the proposed priorities, requirements, and definitions for the Postsecondary Student Success Grant (PSSG) program. This grant program is designed to equitably improve postsecondary student outcomes by leveraging data and implementing, scaling, and rigorously evaluating evidence-based activities to support data-driven decisions and actions by institutional leaders committed to inclusive student success.

Our comments aim to strengthen the PSSG program’s impact on completion rates and economic mobility. Key recommendations include:

• Tiered Grant Structure: We support ED’s proposal for a tiered grant structure based on the level of evidence and scale of proposed projects. This will allow funding for a variety of effective interventions while building a strong evidence base.
• Data-Driven Decision Making: Data is crucial for continuous improvement. We recommend ED prioritize applicants who demonstrate strong data use practices and consider awarding funds to address data system gaps. Additionally, fostering a culture of data use within institutions is essential for maximizing the impact of PSSG grants.
• Broadening the Scope of Supported Projects: While college-to-career pathways are important, we recommend making this an invitational priority rather than a mandatory focus. This allows funding for a wider range of evidence-based strategies for student success.
• Rigorous and Culturally Appropriate Evaluations: Independent evaluations are vital for building the knowledge base on what works. We recommend using a variety of methodologies appropriate to the research question and ensuring culturally appropriate evaluations for diverse student populations.
• Disseminating Research Findings: Effective dissemination of research findings is critical for maximizing the program’s impact. We encourage ED to require strong dissemination plans from grantees and leverage existing channels to share research with policymakers and practitioners.
• Defining “Completions of Value”: We support ED’s focus on completions of value and propose using the minimum economic return, Threshold 0, from the Postsecondary Value Framework as one way to measure this.
• Defining “Underserved Student”: Language choices matter. We recommend refining the definition of “underserved student” to explicitly include specific racial and ethnic groups.

Read the full letter to learn more.