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Advocacy Letters Comments in Response to Prison Education Programs Regulation

Comments in Response to Prison Education Programs Regulation

In a letter to the U.S. Department of Education, the Student Borrower Protection Center (SPBC), National Consumer Law Center (NCLC), and Prison Policy Initiative (PPI) offer comments on proposed regulations to implement new statutory requirements to establish Federal Pell Grant (Pell Grant) eligibility for confined or incarcerated individuals enrolled in Prison Education Programs (PEPs).

The comment urges the Department to, at a minimum, automatically enroll all defaulted incarcerated borrowers in Fresh Start.  We also urge ED to create a long-term automatic income-driven repayment (IDR) enrollment system for incarcerated borrowers. Otherwise, ED’s Fresh Start proposal, as well as its expanded Pell proposal for those recipients who already have student loans, are bound to fail as neither proposal fully addresses the unique hardships of managing a student loan while incarcerated.

Attached to the comment is a report authored by SBPC and NCLC that outlines the conditions of incarceration—including the exorbitant expense of communicating with those outside of the prison while earning little to no income and the lack of regular internet or computer access—which impose barriers to accessing debt relief programs like IDR plans and loan rehabilitation, and leads to heightened default rates for incarcerated borrowers. If these conditions are not addressed through automatic enrollment in debt relief programs for incarcerated borrowers, the Department’s efforts to expand Pell and education access will fail.

Read the Comment Here: Comments in Response to Prison Education Programs Regulation

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