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In an effort to advance health and well-being within Federal policy, ¶À¼ÒºÚÁÏ has submitted several public comments to the U.S. Federal government concerning a wide range of topics. Before a comment is finalized and submitted for the Federal government’s consideration, the comment opportunities are flagged and discussed with the ¶À¼ÒºÚÁÏ Advocacy Committee and relevant ¶À¼ÒºÚÁÏ leadership. The Committee connects the public comment drafters with relevant key stakeholders within ¶À¼ÒºÚÁÏ who can provide relevant information, expertise, and data that better inform the drafting of the public comments.

So far in 2024, ¶À¼ÒºÚÁÏ has submitted comments to inform the Federal government of ongoing issues impacting the higher education health and well-being space. Below are the issues on which ¶À¼ÒºÚÁÏ has commented:

Family Education Rights and Privacy Act (FERPA)Ìý

In March 2024, the U.S. Department of Education (ED) requested comments addressing ongoing issues with FERPA compliance regulatory requirements. Under the current implementation of FERPA, existing law requires that educational agencies, schools, and colleges notify parents and students of their rights under FERPA, and it requires that they record disclosures of personally identifiable information from education records. Using the expertise of a privacy awareness professional, ¶À¼ÒºÚÁÏ developed and drafted a comment requesting that the ED consider student privacy concerns when enforcing FERPA regulations.

Sexual Violence PreventionÌý

In March 2024, the Office of Postsecondary Education and Office of Elementary and Secondary Education, within the U.S. Department of Education (ED), along with the U.S. Attorney General invited comments requesting suggestions on sexual violence prevention and responses in educational institutions. Using the expertise of the ¶À¼ÒºÚÁÏ Sexual Health Coalition, ¶À¼ÒºÚÁÏ drafted and submitted a comment encouraging the ED to implement trauma-informed care and social-emotional learning to better address and prevent instances of sexual violence.

Title IX Regulatory ReviewÌý

In March 2024, before the finalization of the U.S. Department of Education’s (ED) updated Title IX regulations, ¶À¼ÒºÚÁÏ submitted a comment to the US Office of Budget and Management as the institution reviewed the ED’s proposed Title IX regulations. The comment stated that Title IX regulations should prioritize the health and mental well-being of impacted students/victims rather than just reporting compliance adherence.

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Integrated Postsecondary Education Data Survey (IPEDS)

In May 2024, ¶À¼ÒºÚÁÏ submitted a comment detailing recommendations for the Integrated Postsecondary Education Survey (IPEDS). The comment was drafted with input from ¶À¼ÒºÚÁÏ leadership and requested further questioning within the survey that directly addressed health and well-being services and their availability.

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Marijuana Reclassification

In July 2024, using the expertise and input of the ¶À¼ÒºÚÁÏ Alcohol, Drugs, Tobacco, and Other Drugs (ATOD) Coalition, ¶À¼ÒºÚÁÏ submitted a comment to the U.S. Drug Enforcement Agency (DEA) as they considered the reclassification of marijuana from a schedule I substance to a schedule III substance. The comment asserted that ¶À¼ÒºÚÁÏ recommended greater partnership with/support for college prevention offices and alcohol and other drugs (AOD) counseling services on campus to be able to provide clear and consistent messaging to students. The comment also addressed that medical marijuana is a topic that warrants further discussions.

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Drug Chain Supply Security Requirement

In September 2024, ¶À¼ÒºÚÁÏ industry partner Pharmedix, flagged the upcoming beginning of enforcement of the Drug Supply Chain Security Act (DCSCA), which could potentially impact independent college pharmacies as it established certain drug verification requirements. Using feedback from the ¶À¼ÒºÚÁÏ Pharmacy Section, ¶À¼ÒºÚÁÏ drafted and submitted a comment to the U.S. Federal Food and Drug Administration (FDA) requesting further clarity on the verification requirements and their applicability to higher education pharmacies.

¶À¼ÒºÚÁÏ will continue to monitor opportunities to connect with and educate the Federal government. ÌýIf you hear about issues that you think ¶À¼ÒºÚÁÏ should be aware of and/or consider commenting on, please feel free to email advocacy@acha.org to share it with the ¶À¼ÒºÚÁÏ advocacy team.