On June 13, 2024, TCF deputy director of higher education policy and senior fellow Denise Smith and TCF higher education policy associate Jordan Nellums submitted a public comment to the U.S. Department of Education regarding the Research and Development Infrastructure (RDI) Grant Proposed Rules. The public comment is reproduced below.
Thank you for the opportunity to provide public comment on the notice announcing the priorities, requirements, and definition for the Research and Development Infrastructure (RDI) grant, dated Friday, May 17, 2024.
The RDI grant program marks a tremendous commitment by Congress to ensure that Historically Black Colleges and Universities (HBCUs), Minority-Serving Institutions (MSIs), and Tribally Controlled Colleges and Universities (TCCUs) have the opportunity to invest in their research and development infrastructure on campus. Specifically, universities that are awarded funds from the RDI will be able to use the funds to invest in numerous projects/initiatives, including:
- Improving research infrastructure and deferred maintenance
- Hiring expert faculty
- Expanding internship/fellowship opportunities for students, and
- Creating institutional research centers
The RDI grant program seeks to provide resources to institutions that not only have a diverse student population, as determined by their designations, but also support institutions that have historically been underfunded. We applaud the Department of Education for clarifying that universities must be defined as an HBCU, MSI, or TCCU in order to qualify for grants under the RDI grant program.
Specifically, compared to predominantly white institutions (PWIs), HBCUs have been chronically underfunded for decades which has disproportionately impacted their campus infrastructure. In 2018, the Government Accountability Office (GAO) issued a report detailing the infrastructure needs of HBCUs based on a survey of all 100-plus accredited HBCUs. In that same year, the federal government spent $42 billion in R&D for institutions of higher education (IHE) and only 1 percent of that funding went to HBCUs. Meanwhile, PWIs have received significant funding support from their state governments, allowing them to invest heavily in their research infrastructure capabilities. Due to the advanced nature of some of their research capabilities resulting from this robust funding, many PWIs have reached R1, the “very high” research activity designation, according to the American Council on Education’s Carnegie Classifications. Currently, no HBCU holds the designation of R1; therefore, many are excluded from further grant funding for research. Of the eleven HBCUs that already are categorized as “high” research activity or R2, they are a mix of private and land-grant HBCUs: Clark Atlanta University, Florida A&M University, Howard University, Jackson State University, Morgan State University, North Carolina A&T State University, Prairie View A&M University, Southern University and A&M College, Tennessee State University, Texas Southern University, and University of Maryland Eastern Shore. Increases in research and development infrastructure support from federal agencies such as the Department of Education would only enhance faculty capacity, and other factors would move these institutions closer to, and eventually into, R1 status. A recent report—published by The Carnegie Foundation for the Advancement of Teaching and the American Council on Education—highlights how the Carnegie Classification system has perpetuated historic funding inequities between the PWIs and HBCUs. Specifically, the report notes that although the Carnegie Classification system was created to facilitate a process for classifying institutions, it has instead “become a marker of institutional elitism, capacity, and prestige.”
Prioritizations and Barriers to Impact
We applaud Congress and the Department of Education for solely focusing on HBCUs, MSIs, and TCCUs, who have often unfortunately been left out of funding opportunities to upgrade their infrastructure. While this new program highlights the value of these institutions, we would like to underscore that prioritizing the institutions based on their designation alone does not fully guarantee an equitable leveling of the playing field. If designation alone were used, PWIs or very-well-funded MSIs would be eligible to apply for some of the funds from the RDI program. For example, a university with the designation of Hispanic-serving institution (therefore an MSI) can receive that designation with as little as 25 percent or more of its student body being Hispanic, and so, if designation alone were used, then Texas A&M University—one of Texas’s flagship universities, an R1 institution with an enormous endowment—would be eligible to apply for funds from the RDI grant program. And so, we applaud the Department of Education for including language that specifies that an institution must be actively seeking to move from R2 to R1 status, or be a master’s college or university seeking R2 status. By making that additional distinction, the Department of Education will ensure that already well-resourced universities can not draw from the limited funding approved by Congress for the program.
Furthermore, we applaud the Department of Education for including in its proposal to prioritize institutions with at least 50 percent of its total enrolled undergraduate students receiving the Pell Grant Award. The prioritization would ensure that institutions that serve a higher percentage of low-income students have the necessary resources to make important infrastructure investments. This priority ensures that HBCUs are highly prioritized. Specifically, only six out of the 101 HBCUs do not currently have more than 50 percent of their student body being Pell Grant receipts. Therefore, the overwhelming majority would be able to apply for the competitive grant program.
One-to-One Matching Requirement
Despite the Department of Education’s efforts to ensure HBCUs, MSIs, and TCCUs can benefit from the RDI program, there is a pressing need to address one aspect of the program. Specifically, the Department requires that any institution awarded this grant funding must identify non-federal matching funds. Even though the Secretary will have waiver authority, exercising it may also lead to additional labor for the university, which will have to chronicle well-established ongoing fundraising challenges in applying for a waiver. The Century Foundation has extensively documented how this one-to-one matching requirement has historically been a systematic barrier for HBCUs in accessing additional funding. In fact, specifically, the nineteen HBCU land grants lost nearly $200 million in funds over the past decade due to the failure of states to provide matching funds for federal research and formula funds. This matching fund requirement poses a significant barrier to the institutions the RDI grant program intends to uplift. Therefore, we strongly urge the Department to reconsider including the matching requirement in its entirety.
We appreciate the opportunity to provide feedback on the RDI grant program. This program is an important step in addressing the historical and systematic barriers that have prevented universities from receiving equal funding, especially those that have educated students from diverse communities and varying socioeconomic backgrounds.
Tags: university, university funding, higher education funding
Biden Administration’s Increased Research Infrastructure Funding a Huge Step Forward for HBCUs
On June 13, 2024, TCF deputy director of higher education policy and senior fellow Denise Smith and TCF higher education policy associate Jordan Nellums submitted a public comment to the U.S. Department of Education regarding the Research and Development Infrastructure (RDI) Grant Proposed Rules. The public comment is reproduced below.
Thank you for the opportunity to provide public comment on the notice announcing the priorities, requirements, and definition for the Research and Development Infrastructure (RDI) grant, dated Friday, May 17, 2024.
The RDI grant program marks a tremendous commitment by Congress to ensure that Historically Black Colleges and Universities (HBCUs), Minority-Serving Institutions (MSIs), and Tribally Controlled Colleges and Universities (TCCUs) have the opportunity to invest in their research and development infrastructure on campus. Specifically, universities that are awarded funds from the RDI will be able to use the funds to invest in numerous projects/initiatives, including:
The RDI grant program seeks to provide resources to institutions that not only have a diverse student population, as determined by their designations, but also support institutions that have historically been underfunded. We applaud the Department of Education for clarifying that universities must be defined as an HBCU, MSI, or TCCU in order to qualify for grants under the RDI grant program.
Specifically, compared to predominantly white institutions (PWIs), HBCUs have been chronically underfunded for decades which has disproportionately impacted their campus infrastructure. In 2018, the Government Accountability Office (GAO) issued a report detailing the infrastructure needs of HBCUs based on a survey of all 100-plus accredited HBCUs. In that same year, the federal government spent $42 billion in R&D for institutions of higher education (IHE) and only 1 percent of that funding went to HBCUs.1 Meanwhile, PWIs have received significant funding support from their state governments, allowing them to invest heavily in their research infrastructure capabilities. Due to the advanced nature of some of their research capabilities resulting from this robust funding, many PWIs have reached R1, the “very high” research activity designation, according to the American Council on Education’s Carnegie Classifications. Currently, no HBCU holds the designation of R1; therefore, many are excluded from further grant funding for research. Of the eleven HBCUs that already are categorized as “high” research activity or R2, they are a mix of private and land-grant HBCUs: Clark Atlanta University, Florida A&M University, Howard University, Jackson State University, Morgan State University, North Carolina A&T State University, Prairie View A&M University, Southern University and A&M College, Tennessee State University, Texas Southern University, and University of Maryland Eastern Shore. Increases in research and development infrastructure support from federal agencies such as the Department of Education would only enhance faculty capacity, and other factors would move these institutions closer to, and eventually into, R1 status. A recent report—published by The Carnegie Foundation for the Advancement of Teaching and the American Council on Education—highlights how the Carnegie Classification system has perpetuated historic funding inequities between the PWIs and HBCUs. Specifically, the report notes that although the Carnegie Classification system was created to facilitate a process for classifying institutions, it has instead “become a marker of institutional elitism, capacity, and prestige.”2
Prioritizations and Barriers to Impact
We applaud Congress and the Department of Education for solely focusing on HBCUs, MSIs, and TCCUs, who have often unfortunately been left out of funding opportunities to upgrade their infrastructure. While this new program highlights the value of these institutions, we would like to underscore that prioritizing the institutions based on their designation alone does not fully guarantee an equitable leveling of the playing field. If designation alone were used, PWIs or very-well-funded MSIs would be eligible to apply for some of the funds from the RDI program. For example, a university with the designation of Hispanic-serving institution (therefore an MSI) can receive that designation with as little as 25 percent or more of its student body being Hispanic, and so, if designation alone were used, then Texas A&M University—one of Texas’s flagship universities, an R1 institution with an enormous endowment—would be eligible to apply for funds from the RDI grant program. And so, we applaud the Department of Education for including language that specifies that an institution must be actively seeking to move from R2 to R1 status, or be a master’s college or university seeking R2 status. By making that additional distinction, the Department of Education will ensure that already well-resourced universities can not draw from the limited funding approved by Congress for the program.
Furthermore, we applaud the Department of Education for including in its proposal to prioritize institutions with at least 50 percent of its total enrolled undergraduate students receiving the Pell Grant Award. The prioritization would ensure that institutions that serve a higher percentage of low-income students have the necessary resources to make important infrastructure investments. This priority ensures that HBCUs are highly prioritized. Specifically, only six out of the 101 HBCUs do not currently have more than 50 percent of their student body being Pell Grant receipts. Therefore, the overwhelming majority would be able to apply for the competitive grant program.
One-to-One Matching Requirement
Despite the Department of Education’s efforts to ensure HBCUs, MSIs, and TCCUs can benefit from the RDI program, there is a pressing need to address one aspect of the program. Specifically, the Department requires that any institution awarded this grant funding must identify non-federal matching funds. Even though the Secretary will have waiver authority, exercising it may also lead to additional labor for the university, which will have to chronicle well-established ongoing fundraising challenges in applying for a waiver. The Century Foundation has extensively documented how this one-to-one matching requirement has historically been a systematic barrier for HBCUs in accessing additional funding. In fact, specifically, the nineteen HBCU land grants lost nearly $200 million in funds over the past decade due to the failure of states to provide matching funds for federal research and formula funds.3 This matching fund requirement poses a significant barrier to the institutions the RDI grant program intends to uplift. Therefore, we strongly urge the Department to reconsider including the matching requirement in its entirety.
We appreciate the opportunity to provide feedback on the RDI grant program. This program is an important step in addressing the historical and systematic barriers that have prevented universities from receiving equal funding, especially those that have educated students from diverse communities and varying socioeconomic backgrounds.
Notes
Tags: university, university funding, higher education funding