Research
05.27.2025
Federal Regulations
Getting Started

Writing an Effective Public Comment

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Why Public Comments Matter

The U.S. Department of Education (ED) uses negotiated rulemaking to shape policies that govern federal financial aid programs and institutional accountability. Public comments inform how regulations are drafted and finalized.

As a compliance professional, your insight into policy implementation, institutional burden, and student impact is invaluable. Submitting a thoughtful, well-supported comment can influence regulatory outcomes that affect your institution and the broader higher education landscape.

This philosophy is also important when writing a public comment for the SARA Policy Modification Process.

 

When and Where to Submit

  • Comments must be submitted by the deadline listed in the Federal Register Notice for the negotiated rulemaking or issue under consideration.
  • Submit via: Regulations.gov for comments pertaining to the U.S. Department of Education.
  • Use the docket number listed in the notice.

 

What to Include in Your Comment

Start with Your Credentials

  • Identify yourself and your role (e.g., “Director of Compliance at a public university serving 25,000 students”).
  • Do not indicate that you represent the views of your institution unless you have specific permission to do so.
  • Briefly explain your institutional context (e.g., online programs, financial aid scope, student population).

State Your Position Clearly

  • Indicate whether you support, oppose, or seek clarification on specific parts of the proposed rule.
  • Reference the section number, issue, or provision you are addressing.

Provide Evidence or Examples

  • Describe the impact of the proposal using data, institutional experience, or implementation challenges.
  • If possible, share specific, real-world examples of how the proposed rule could affect:
    • Student access or success
    • Financial or operational feasibility
    • Provide data, if possible.

Suggest Improvements

  • Offer constructive recommendations. For example:
    • "Consider extending the reporting deadline by 6 months to allow for accurate data integration."
    • "Clarify whether this requirement applies to exclusively online programs."

 Be Professional and Respectful

  • Avoid inflammatory language or political rhetoric.
  • Comments should be factual, focused, and policy driven.

 

Tips for Impactful Comments

  • Focus on your area of expertise (e.g., distance education, GE data reporting, accreditation).
  • Coordinate with institutional leadership to align your message or submit as an individual if offering a unique perspective.
  • Use bullet points or headers to enhance readability.
  • Keep it under 1,500 words unless depth is needed.

 

Effective public comments do not require legal training, just your informed, practical perspective. The Department values implementation insight, and your comment can help shape policy that balances student consumer protection and access. If you need help writing or reviewing a comment. Collaborate with your government relations, legal, or institutional research teams.

 

For more details about Negotiated Rulemaking, please review the U.S. Department of Education Rulemaking Process on the SAN website. 

 

Note: This resource was created by the State Authorization Network (SAN) a network of WCET. Regulatory language and references are subject to change. The information should not be considered legal advice. Legal questions should be directed to legal counsel.

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