Title IV Changes and Potential Impact on Equity in Global Programs

The Department of Education released guidance on February 28, 2023 that could restrict institutions from working with international partners that are critical to administering components of education abroad programming and recruiting international students. Institutions and other stakeholders can submit comments highlighting how the guidance will affect their institutions/organizations by March 30, 2023, and we encourage those who can to do so.

The early part of 2023 has already been a busy time for policy and legislative related activities that have the potential to impact equity and inclusion in the field of international education and exchange. In addition to threats to campus diversity, equity, and inclusion work, a significant activity has come in the form of a Dear Colleague letter issued by the Department of Education on February 15, 2023 titled “Requirements and Responsibilities for Third-Party Servicers and Institutions” The updated guidance has the potential to significantly disrupt education abroad programming and international student recruitment activities at institutions that administer student assistance programs under Title IV (most institutions of higher education in the United States).  


About the Guidance

Dear Colleague letters are generally focused on providing clarifying guidance on how a particular policy should be interpreted and implemented. In this case, the Dear Colleague letter attempts to clarify requirements for institutions administering federal student assistance on third-party service (TSP) providers and services they offer (i.e., “performing the functions of student recruiting and retention, the provision of software products and services involving Title IV administration activities, and the provision of educational content and instruction”). Initially, guidance was to go into effect immediately. However, after receiving an incredible amount of feedback from institutions of higher education, education associations, and other TPS that would be affected by the guidance, the Department of Education has extended the period that it will accept comments on the guidance to March 30, 2023 and adjusted the effective date to September 1, 2023. 

The Impact on Equity and Inclusion in International Education 


Low Income Students May Have Fewer Global Learning Opportunities

Most institutions rely on TPS to administer part if not all of the education abroad experience and in many cases virtual exchange. Education abroad and some virtual global learning programs could be immediately halted to review existing partnerships for compliance with the updated guidance. Education abroad programs that could continue  despite the new guidance will likely only be available to students with the financial means to cover the costs independent of financial aid. Students who rely on federal student assistance (i.e., federal loans, pell grants) to attend university would not be able to apply their aid to programs that don’t meet the broadened definition of TPS, making most education abroad programming out of reach for students from lower-income backgrounds.

This could have a devastating effect on efforts to increase access to BIPOC (Black, Indigenous, and People of Color) students in education abroad programming, too. According to the Department of Education’s National Center on Education Statistics:

  • “Ninety-two percent of full-time, full-year Black undergraduate students received financial aid, compared to 85 percent of Hispanic students, 77 percent of White students, 68 percent of Asian students, 80 percent of Native Hawaiian or Other Pacific Islander students, and 83 percent of students or two or more races.” IES NCES Status and Trends in the Education of Ethnic and Racial Minorities

Research from the University System of Georgia has shown that BIPOC students’ academic success improves and graduation rates increase for those who study abroad. If education abroad programming is halted, many institutions will lose access to a vital tool for supporting minoritized students’ academic success and retention.

Other student populations that are also likely to be affected include first-generation college students.  First-generation college students have been shown to receive higher proportions of financial aid assistance than students who are not the first in their family to attend college. 

International Student Representation May Become More Homogenous

The new guidance also emphasizes TPS involved in the student recruitment process. Many institutions rely heavily on TPS to recruit international students and in recent years have focused on diversifying the countries represented in their international student body. With fewer options to work with providers in places like Africa and Latin America where recruitment agencies may be less prepared to respond to U.S. policy requirements, institutions may find it more difficult to recruit from regions historically underrepresented at U.S. campuses. 

Preparing: Strategies International Education Offices Could Employ in the Meantime

While the guidance is under consideration, Diversity Abroad will continue to monitor changes and/or updates related to the guidance. We are also preparing a letter to submit during the open comment period and supporting the efforts of our colleagues at other education associations to ensure international education is considered a top priority in the review of the guidance. 

There are also ways we would encourage our community to engage. 

Work with Campus Government Relations Offices to Comment on the Guidance

Provide the offices the information they need on how the guidance will impact education abroad and international education initiatives on campus. 

Communicate with Internal Campus Partners

Education abroad can be a high impact experience that supports the holistic success of students. As historically marginalized students will potentially lose the most based on current language of the policy, we encourage you to consider engaging campus partners such as central diversity, equity, and inclusion offices, TRiO units, student success to support letter writing efforts. This could include identifying programs that have been particularly successful in reaching minoritized student populations and have demonstrated improvements in student success outcomes, and presenting student profiles that highlight the importance of financially accessible education abroad programming.

Our colleagues at NAFSA and the Forum on Education Abroad have pulled together resources for education abroad offices that can be useful to draft response letters to submit during the commenting period. We will continue to provide information and resources throughout this process.  

We invite you to read the full Dear Colleague letter to learn more about the proposed changes.

Read the Guidance Here

Global Inclusive Leadership Certificate

Learn More

2023 Global Inclusion Conference

Learn More