11 Mar Dr. Dowden Preparing to Speak on Capitol Hill

G. Blair Dowden, president of Huntington University, will be speaking on Capitol Hill at 10 a.m. regarding new regulations for higher education institutions. He has been invited as an expert witness to testify in front of the Subcommittee on Higher Education and Workforce Training’s hearing on “Education Regulations: Federal Overreach into Academic Affairs.” His testimony will be streamed live at http://edworkforce.house.gov/Calendar/EventSingle.aspx?EventID=227134.

More information is available at this release: http://www.huntington.edu/news/1011/capitol-hill.htm. A transcript of his oral testimony is included below.

“Education Regulations: Federal Overreach into Academic Affairs”
Testimony of G. Blair Dowden
President, Huntington University, Huntington, Indiana
Before the Subcommittee on Higher Education and Workforce Training
U.S. House of Representatives

March 11, 2011

Good morning Chairwoman Foxx and Ranking Member Hinojosa:

I appreciate your invitation to share my concerns about the “program integrity issues” regulations. My name is Blair Dowden, president of Huntington University in Huntington, Indiana, and I have served in that capacity for the last twenty years. I am a past Board chair of the Council for Christian Colleges and Universities, and I presently serve as a Board member of the National Association of Independent Colleges and Universities.

As a president of a private college, I am concerned about the wide sweeping regulatory overreach that these regulations signal. The American higher education system is the best in the world largely because of its independence, innovation and creativity. These regulations work to undermine these characteristics.

Certainly, colleges and universities should be held accountable for their work and the expenditure of federal funds. Earlier this year, in fact, Huntington University was visited by the US Department of Education for a routine review of our Title IV programs. After a week of review, the Department representatives indicated that we were a “very clean” operation in the management of Title IV funds. This type of oversight is appropriate. But the increase in regulation and oversight that is contained in some provisions of the Department’s new program integrity regulations is not warranted and will severely burden colleges and universities.

Specifically, two parts of these regulations are most concerning: state authorization and credit hour, the topics of this hearing.

The federal definition of the credit hour inserts the federal government squarely into one of the most sacrosanct elements of higher education. I believe that it is very problematic for the federal government to impose a “one-size-fits-all” definition of the credit hour. A scientific laboratory class is different from practicing a musical instrument which is different from engaging in a business practicum. I strongly believe that it is colleges, universities and accrediting organizations — not the government — that are best able to assess and quantify the learning that results from these varied experiences.

Huntington is a private liberal-arts university; we are also a Christian institution. Our Christ-centered mission is foundational to our educational purpose and informs every decision that we make. As president, I am also concerned that these new regulations have the potential to interfere with our faith-based mission.

In particular, the state authorization component of these regulations expands on the requirement that an institution must be authorized by a State in order to participate in Title IV funding. State authorization is currently required by the Higher Education Act, so it is not at all clear to me what value would be added by these new—and confusing—requirements. These regulations clearly open the door for states to impose requirements that go well beyond authorizing an institution to offer postsecondary education. My concern is that there appears to be no limits to what factors a state can consider when granting or withholding authorization, and no mechanisms for appeal or due process.

As the president of a Christian institution, I am acutely aware that religion and religious practices can sometimes invoke strong reactions in people, reactions that can sometimes motivate certain political positions and actions. The Department’s new regulations delineate a very small category of institutions that are eligible to be exempted under state law, if the state should choose to provide a religious exemption. This category of schools is so narrowly defined that neither Huntington University nor any other member of the Council for Christian Colleges and Universities would qualify for an exemption as outlined by the new regulations.

This prospect is very troubling and is widely shared as a concern by my fellow Christian college presidents. I do not want to have our students’ eligibility to receive Title IV funding placed solely in the hands of a politically motivated state entity.

In addition, the possibility exists that certain states may use this new state authorization requirement as leverage to achieve their own higher education policy agenda at the expense of institutional missions. For instance a state could require certain curriculum or textbooks in order to gain authorization, potentially violating both the academic prerogatives and religious convictions of the institutions.

Let me conclude by assuring you that these concerns are not a denial of the need for accountability and excellence in higher education, or out of a concern that Huntington University would not meet quality standards. To the contrary, Huntington University is ranked by U.S. News & World Report among the Midwest’s top ten regional colleges and among the region’s top five best values. We are providing our students with an excellent education, and are equipping them for the future.

Rather, I oppose these regulations because they unnecessarily interfere with the good work that my institution and many others are doing, and because they create the potential for misunderstanding, misapplication, and even mischief by politically motivated state actors.

I appreciate your time here today and look forward to answering your questions.