Federal Public Comments in 2024

In an effort to advance health and well-being within Federal policy, ACHA has submitted several public comments to the U.S. Federal government concerning a wide range of topics. Before a comment is finalized and submitted for the Federal government’s consideration, the comment opportunities are flagged and discussed with the ACHA Advocacy Committee and relevant ACHA leadership. The Committee connects the public comment drafters with relevant key stakeholders within ACHA who can provide relevant information, expertise, and data that better inform the drafting of the public comments.

So far in 2024, ACHA has submitted comments to inform the Federal government of ongoing issues impacting the higher education health and well-being space. Below are the issues on which ACHA has commented:

Family Education Rights and Privacy Act (FERPA) 

In March 2024, the U.S. Department of Education (ED) requested comments addressing ongoing issues with FERPA compliance regulatory requirements. Under the current implementation of FERPA, existing law requires that educational agencies, schools, and colleges notify parents and students of their rights under FERPA, and it requires that they record disclosures of personally identifiable information from education records. Using the expertise of a privacy awareness professional, ACHA developed and drafted a comment requesting that the ED consider student privacy concerns when enforcing FERPA regulations.

Sexual Violence Prevention 

In March 2024, the Office of Postsecondary Education and Office of Elementary and Secondary Education, within the U.S. Department of Education (ED), along with the U.S. Attorney General invited comments requesting suggestions on sexual violence prevention and responses in educational institutions. Using the expertise of the ACHA Sexual Health Coalition, ACHA drafted and submitted a comment encouraging the ED to implement trauma-informed care and social-emotional learning to better address and prevent instances of sexual violence.

Title IX Regulatory Review 

In March 2024, before the finalization of the U.S. Department of Education’s (ED) updated Title IX regulations, ACHA submitted a comment to the US Office of Budget and Management as the institution reviewed the ED’s proposed Title IX regulations. The comment stated that Title IX regulations should prioritize the health and mental well-being of impacted students/victims rather than just reporting compliance adherence.

Integrated Postsecondary Education Data Survey (IPEDS)

In May 2024, ACHA submitted a comment detailing recommendations for the Integrated Postsecondary Education Survey (IPEDS). The comment was drafted with input from ACHA leadership and requested further questioning within the survey that directly addressed health and well-being services and their availability.

Marijuana Reclassification

In July 2024, using the expertise and input of the ACHA Alcohol, Drugs, Tobacco, and Other Drugs (ATOD) Coalition, ACHA submitted a comment to the U.S. Drug Enforcement Agency (DEA) as they considered the reclassification of marijuana from a schedule I substance to a schedule III substance. The comment asserted that ACHA recommended greater partnership with/support for college prevention offices and alcohol and other drugs (AOD) counseling services on campus to be able to provide clear and consistent messaging to students. The comment also addressed that medical marijuana is a topic that warrants further discussions.

Drug Chain Supply Security Requirement

In September 2024, ACHA industry partner Pharmedix, flagged the upcoming beginning of enforcement of the Drug Supply Chain Security Act (DCSCA), which could potentially impact independent college pharmacies as it established certain drug verification requirements. Using feedback from the ACHA Pharmacy Section, ACHA drafted and submitted a comment to the U.S. Federal Food and Drug Administration (FDA) requesting further clarity on the verification requirements and their applicability to higher education pharmacies.

ACHA will continue to monitor opportunities to connect with and educate the Federal government.  If you hear about issues that you think ACHA should be aware of and/or consider commenting on, please feel free to email advocacy@acha.org to share it with the ACHA advocacy team.