An Education Department proposal to expand the scope and reach of its central database for student aid would violate federal law and distort the database's purposes, a group of higher education associations argued in a letter sent to department officials Monday.
The letter,  sent by the American Council on Education on behalf of seven other groups, responds to a request for comment published in the Federal Register in late June, in which the Education Department's Federal Student Aid office proposed to make a set of changes to information collected by the National Student Loan Data System.
The associations' letter argues that some of the department's goals are appropriately tied to the database's original purpose, but it questions a plan to modify legal provisions related to gainful employment programs to collect information about students who do not receive federal financial aid, among other things. "[W]e do not understand how the inclusion of information about unaided students in NSLDS can be justified," they wrote.
The groups also challenged the department's plan to expand the student loan database to collect consumer protection and program evaluation data, and the department's authority to make such changes in a Federal Register notice rather than through legislation. The proposals, they write, "exceed the boundaries of the law in ways that the courts have prohibited and that distort the purposes of NSLDS."
The letter also cites numerous ways in which the department's proposal falls short of its obligations under the Federal Privacy Act.