AAU submitted a comment letter to Secretary of Education Miguel Cardona on the Department of Education’s notice of proposed rulemaking (NPRM) to make improvements to the areas of gainful employment, financial value transparency, financial responsibility, administrative capability, certification procedures, and ability to benefit. AAU expressed agreement with the department on the value of increasing “transparency on college costs and success rates” but noted reservations with the proposed expansion of financial value reporting requirements to all programs.