On August 24, the U.S. Department of Education (ED) published proposed revisions to the Education Department General Administrative Regulations (EDGAR), which govern the administration of federal education grants, including Perkins V. The proposed changes would establish new compliance requirements for grant recipients, modify how federal grant awards are administered and terminated, and change how grant opportunities are communicated to the public. This proposal contains some overlap with, but is in addition to, changes proposed earlier in the summer to the overall federal Uniform Grant Guidance that are still under review.

On September 22, ACTE and Advance CTE submitted comments expressing opposition to several provisions of the proposed rule and urged ED to withdraw the proposal. Our comments emphasized that these changes would increase administrative burdens on state and local education agencies, create uncertainty for federal grant recipients, and undermine the stability of federal funding supporting CTE programs.

The comments focused on several major concerns:

• Expanding Executive Order Compliance Requirements: The proposal would require recipients of federal formula grants, including Perkins V, to comply with applicable presidential Executive Orders. ACTE and Advance CTE argued that this would create shifting compliance requirements for states and local recipients, increasing administrative burdens and potentially creating conflicts with existing statutory requirements.
• Establishing New Hiring and Participant Selection Standards: The proposed regulations would introduce new requirements governing hiring, admissions and participant selection decisions. The organizations raised concerns that these provisions contain undefined standards and could conflict with Perkins V requirements to serve special populations and expand access to nontraditional career fields.
• Changing Indirect Cost Policies:The proposal would allow ED to give competitive preference to grant applicants willing to accept lower indirect cost reimbursement rates. This could disadvantage smaller institutions and rural districts that lack the financial resources to absorb additional administrative expenses.
• Expanding Authority to Terminate Federal Grants: The proposed changes would give ED greater discretion to terminate discretionary grants or discontinue funding for multi-year projects, even when recipients are meeting performance expectations. This uncertainty could disrupt CTE programs that depend on sustained funding for equipment purchases, instructor recruitment and work-based learning opportunities.
• Reducing Transparency in Federal Grantmaking: The proposal would eliminate certain Federal Register publication requirements and shift grant announcements and priorities to Grants.gov. The existing publication requirements ensure transparency, public accountability and consistent access to federal grant information.

Ultimately, ACTE and Advance CTE are urging ED to withdraw the proposed rule or remove the provisions identified in their comments. If readers have any questions on the proposed EDGAR rules, feel free to reach out to ACTE’s Government Relations Manager Jimmy Koch (jkoch@acteonline.org).