Comments to Department of Education on Establishment of Negotiated Rulemaking Committee

By at 1 July, 2021, 5:51 pm

U.S. Department of Education

400 Maryland Avenue, SW

Washington, D.C.  20202


RE: DOCKET ED-2021-OPE-0077


To Whom it May Concern:

Thank you for the opportunity to comment on the proposal to establish negotiated rulemaking committees to prepare proposed regulations for programs authorized under title IV of the Higher Education Act of 1965, as amended (HEA). The Small Business & Entrepreneurship Council (SBE Council) is an advocacy, education and training organization dedicated to protecting small business and promoting entrepreneurship. For nearly 28 years, SBE Council has worked on a range of issues and initiatives to strengthen the ecosystem for startup activity and small business growth.

As the chief advocate for SBE Council, I see and hear first-hand the direct impact that education policies have on the small business community, and on U.S. entrepreneurship in general. Inclusive education facilitates small business growth, new business creation, opportunity and U.S. innovation. The education of all Americans – at every stage of their lives – is critical to imparting relevant and practical skills and experiences that directly support America’s small businesses. In the modern economy – and especially given the transformative changes brought on by COVID-19 – education and training must be flexible, and a variety of innovative institutions and classrooms must be encouraged to help meet new and ever-changing market demands.

With a significant share of our activities moving into the digital sphere, even before the pandemic, “non-traditional” learning models were already becoming mainstream. With flexible scheduling and the ability to meet the needs of an individual learner, regardless of their other life responsibilities at any given point – such as holding a full-time job, raising children full-time or part-time, or building their own business – non-traditional educational formats can provide powerful, effective and unique opportunities that align with the lives and needs of real people.

Through my work, I have heard the personal testimonies of so many small business owners and entrepreneurs who have forged their own path to success by taking advantage of the benefits of online programs. I recall one veteran who turned to online learning to quickly acquire management and project management skills, and he then started his own online learning business because of his positive experience and the growing opportunity he sees in the marketplace. This veteran entrepreneur frequently champions the benefits of taking courses at night and then applying the training at work the very next day, by sharing his own experience and how that has changed his life and earning power for the better.

Of course, many corporations today offer online training options and/or the ability to work or learn from home. Non-traditional learning models prepare students to thrive in these environments, as it puts them in charge of their own learning – and the ability to work more effectively or learn online – and provides them with practical skills and ownership of their future.

Opening new doors to growth, advancement and opportunity for all requires a broad spectrum of educational options that cannot be met by only offering the traditional, familiar 4-year programs, or on-site only programs.

Our nation’s future workforce was steadily undergoing a shift in how it worked and learned prior to COVID-19, and this online shift has greatly accelerated. Online courses, flexible programs and innovative learning options that can adjust based on individual needs are more critical today than ever.  They should be treated the same as all other school models if we want them to continue to help meet our nation’s evolving workforce and business needs.


Karen Kerrigan, President & CEO


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