Federal policy updates and resources

• Potential changes to federal student aid programs, including Pell Grants and student loan forgiveness policies
• Adjustments to FAFSA requirements and processing timelines
• Shifts in federal work-study funding and eligibility

• Modifications to federal grant opportunities that support student success, workforce development and institutional funding
• Impact of federal budget decisions on community college funding initiatives
• New compliance or reporting requirements for federal grant recipients

• Revisions to federal regulations affecting how colleges handle reports of sexual harassment and discrimination
• Changes in protections and rights for students and employees under Title IX
• Updates on how colleges must implement and enforce policies related to gender equity and campus safety

• Federal policy changes impacting undocumented students, including Deferred Action for Childhood Arrivals (DACA)
• Visa and travel restrictions affecting international students
• CCC’s response to potential actions by Immigration and Customs Enforcement (ICE), including policies regarding campus safety and student protections

Oregon joined 21 other states to file a lawsuit regarding the federal funding freeze, and a judge last Friday released a ruling with a temporary restraining order in that case: "The federal government may not pause, freeze, impede, block, cancel or terminate" federal awards and obligations to the states and others except as allowed under existing statutes and regulations. Basically, this prohibits the freeze or stop of any federal assistance funds already approved by Congress, even after agencies complete reviews of all current funding streams. All federal grant program funding streams should be restored under this temporary restraining order. OCCA continues to monitor this as we have heard that there may still be some issues with some funding streams. We are making our national partners aware of those situations as they arise. 

With regard to the 2024 Title IX rules implemented by the Biden Administration in August 2024, on Monday, the U.S. Department of Education, Office of Civil Rights, issued a "Dear Colleague" letter essentially reinstating the 2020 Title IX rules. Community colleges, universities, and K-12 school districts are required to revert back to the 2020 Title IX rules and review cases initiated under the 2024 rules to ensure compliance with this guidance. Those colleges that subscribe to the OCCA Board Policy Program will receive more information from OCCA on how to update your policies soon. OCCA is working with the Community College League of California to ensure all of our board policy and procedure templates are legally compliant.

OCCA understands that this is a time of great uncertainty for our students, staff, faculty and communities. OCCA will continue to closely monitor the rapidly changing federal requirements and provide additional guidance as it becomes available from federal and state agencies.

The U.S. Senate Committee on Health, Education, Labor and Pensions will hold its first confirmation hearing today (February 13) for Secretary of Education nominee Linda McMahon. It is expected that McMahon will be questioned about the Administration’s plans to “shut down” the Department of Education and recent access granted to DOGE representatives to student financial aid data.

The administration continues to move forward on implementing recent executive orders targeting higher education institutions pertaining to ending illegal discrimination and diversity, equity, and inclusion programs, and combatting antisemitism. Much of the week was focused on the changes proposed by the National Institutes of Health and the reimbursement of indirect costs allowed as a part of university health research activities. Additional lawsuits have been filed challenging the legality of recent executive orders and changes to Congressionally approved funding. No further guidance has been issued by the Department of Education related to the various executive orders.

A lawsuit was also filed this week by multiple religious organizations challenging the rescission of long-standing guidance related to federal immigration enforcement activities in “sensitive locations” such as churches and schools. We expect other lawsuits to follow. New resources have been posted on the Oregon Attorney General’s website and can be found here.

Oregon community college representatives who were in Washington, DC, this week for the ACCT National Legislative Summit had a chance to meet with members of Oregon's Congressional delegation and share potential impacts of these federal actions on community colleges, students, and the communities we serve. OCCA will share photos from the events and more information next week.

Please continue to reach out to your Congressional representatives to share how the potential loss of federal funding will impact your communities and the ability to educate and train Oregon’s future workforce.

On Friday, February 14, the U.S. Department of Education, Office of Civil Rights, issued a Dear Colleague letter stating the Administration’s intent to interpret the Supreme Court’s 2023 decision in the Students for Fair Admissions (SFFA) cases broadly and to aggressively enforce federal civil rights law.

The letter reiterates the obligations of education institutions to avoid discrimination based on race, color, or national origin. While the Supreme Court’s decision was focused only on the use of race-based preferences in college admissions, the Department broadly interprets the SFFA ruling and states in the letter that institutions may not use race in decisions related to “admissions, hiring, promotion, compensation, financial aid, scholarships, prizes, administrative support, discipline, housing, graduation ceremonies, and all other aspects of student, academic, and campus life.”

While the letter does not have the force of law and does not change existing legal requirements, it signals the intent of the Department to enforce federal civil rights laws for all education institutions that receive federal financial assistance. The letter notes that additional legal guidance will be provided “in due course” and the Department will assess institutional compliance with antidiscrimination requirements as a condition of the receipt of federal funding over the next 14 days.

OCCA will continue to monitor these developments and provide updates as they become available.

Click here to read the letter.

There were several developments this week related to the Trump Administration’s attempts to end federally funded diversity, equity and inclusion programs. Late last Friday, a federal district judge in Maryland issued a nationwide preliminary injunction preventing the federal government from changing or terminating grants and contracts they believe violate the president’s executive orders "Ending Illegal Discrimination and Restoring Merit-Based Opportunity," and " Ending Radical and Wasteful Government DEI Programs and Preferencing." In this ruling, the judge found that the vagueness of the orders would make compliance impossible and would likely violate free speech guarantees found in the First Amendment of the U.S. Constitution. While the judge allowed the federal government to continue to investigate and prepare a report on DEI practices in accordance with one of the orders, he blocked enforcement of the orders.

College and university leaders are still analyzing the February 14 Dear Colleague letter issued last week by the U.S. Department of Education, Office of Civil Rights reaffirming the requirement of education institutions to abide by federal civil rights law. Oregon Higher Education Coordinating Commission Executive Director Ben Cannon released a statement earlier this week reiterating Oregon’s support for serving all students in compliance with state and federal laws. He noted Oregon’s commitment to the “principles of anti-discrimination, equity, and inclusion” that are reflected in many Oregon laws and HECC’s continuing commitment to “Oregon’s values in compliance with all applicable laws.” Click here for the statement.

On Feb. 25, the American Council on Education sent a letter addressed to Craig Trainor, Acting Assistant Secretary for Civil Rights at the U.S. Department of Education requesting the Department withdraw the February 14 Dear Colleague letter and engage the higher education community in further conversation to develop guidance consistent with existing federal laws that will better guide institutional compliance. This letter was signed by all major higher education associations including the American Association of Community Colleges (AACC) and the Association of Community College Trustees (ACCT). Click here to read the letter.

On Wednesday (March 5), Oregon Attorney General Dan Rayfield joined a coalition of 15 state attorneys general in releasing guidance to higher education institutions and K-12 school districts related to the Trump Administration’s executive orders related to diversity, equity, and inclusion and the February 14 Dear Colleague letter issued by the U.S. Department of Education. The guidance reiterates that the recent Supreme Court decision in the Students for Fair Admissions case applies only to the use of race as a factor in college admissions and does not apply broadly to other diversity, equity, inclusion and accessibility programs or initiatives. In the memo, the attorneys general note that community colleges, universities, and K-12 districts can continue to legally address diversity and inclusion in their institutional missions and through their outreach to students to continue to ensure that institutions reflect the diversity of the communities they serve. AG Rayfield’s press release can be found here. A copy of the guidance is here.
 
Earlier this week, the U.S. Senate approved the confirmation of Linda McMahon as Secretary of Education. She was sworn in on Monday evening. In a publicly posted statement to Department of Education employees titled “Our Department’s Final Mission”, Secretary outlined plans for reducing the department, returning authority over education to the states, and carrying out the President’s directives. She highlighted three convictions: 1) Parents are the primary decision makers in their children’s education; 2) Taxpayer-funded education should refocus on meaningful learning in math, reading, science, and history — not divisive DEI programs and gender ideology; 3) Postsecondary education should be a path to a well-paying career aligned with workforce needs. Her entire statement can be found here.
 
Finally, over the weekend the U.S. Department of Education released a Frequently Asked Questions (FAQ) document clarifying the Dear Colleague letter released on Feb. 14. The FAQ document includes 15 questions and answers attempt to provide more detailed information about what is required to comply with federal civil rights laws in light of the ruling in the Students for Fair Admissions (SFFA) case. The FAQ also provides some examples of what the Department would consider a violation of civil rights and nondiscrimination laws and rulings. It is noted that whether a diversity, equity, or inclusion program violates the SFFA case must be determined on a case-by-case basis depending on the “facts and circumstances of each case.” The FAQ also includes a link to a newly created webpage for filing complaints against institutions alleged to have engaged in discriminatory conduct. While neither the Dear Colleague letter nor the FAQ have the force of law, both provide important insight into how the Office of Civil Rights will handle investigations going forward. The full FAQ document is available here. 

Federal Update - Department of Ed cut in half

This week this U.S. Department of Education announced the firing of more than 1,300 employees and the closure of several regional offices including the Office of Civil Rights (OCR) regional office in San Francisco. This action combined with previous terminations of probationary employees and employee buyouts will leave the Department with half of the staff it had at the beginning of the year.  While details about specific staff reductions have not been made publicly available by the Department, it appears that staffing cuts were made in a number of offices that provide support and guidance to higher education institutions and students including the Office of Civil Rights, Office of Federal Student Aid, and the Institute of Education Sciences that houses the National Center for Education Statistics. It is unclear how responsibilities will be shifted to the remaining staff.

For the near future, these changes will likely impact the Department’s ability to provide guidance to students and institutions related to the administration of financial aid, FAFSA filing, pending OCR investigations, and pending grant applications. President Trump has not yet issued an executive order related to the ongoing operations of the Department of Education, but Congressional action would be necessary to eliminate the Department and cease the statutory funding and programs implemented by the Department.

On Thursday morning, Oregon Attorney General Rayfield joined a coalition of 21 state attorneys general in a lawsuit filed in Massachusetts federal court stating that the employee terminations at the Department of Education this week were “illegal and unconstitutional.” The suit challenges the administration’s legal authority to dismantle the department through employee cuts, and states the reduction of half of the department’s workforce will hurt students, especially those with disabilities and from low-income backgrounds.

OCCA continues to closely monitor these and other federal law and policy changes that may impact community colleges. The Higher Education Coordinating Commission (HECC) has also created a webpage with information about state responses to federal actions. You can access the page here.

Also at the federal level this week, former Oregon Congresswoman Lori Chavez-DeRemer was confirmed by the Senate as President Trump's new Secretary of Labor. She was sworn in on Tuesday. Chavez-DeRemer has stated her strong support for apprenticeship programs and the importance of community and technical colleges in workforce development.

With the new federal administration, there have been significant policy changes at the national level, and certainly more to come. We are closely monitoring these developments and working to understand how they may impact you and the Clackamas Community College community.

New laws and regulations often take time to evolve as they undergo legal and legislative processes. While these changes unfold, we are gathering resources to support you.

As we navigate this time of transition, I want to reaffirm my commitment — and the college’s commitment — to serving allstudents. We are here to support you regardless of your background, identity, or circumstances. Our mission is to provide a safe, welcoming, and inclusive environment where every student can succeed. CCC remains dedicated to its values of learning, equity, student success, community, and belonging.

We understand that uncertainty can create stress and concern. If you need support, I encourage you to contact CCC’s free counseling services.

Protecting student information 

The Family Educational Rights and Privacy Act (FERPA) protects the privacy of student education records. We will continue to adhere strictly to our FERPA policy, and ensure that any request for student information is handled through established processes.

Responding to law enforcement inquiries 

If law enforcement comes to campus with a subpoena or warrant, the college will review the request, verify its legal validity, and ensure it follows the law before providing any information. Our priority is to handle these situations appropriately and protect our students’ rights.

Available resources 

• Undocumented and DACA students webpage 

• American Council on Education Immigration-related campus concerns document

• Legal Rights Red Cards 

We are committed to keeping you informed and minimizing disruptions as much as possible. We are also developing a webpage with updates and resources, including translation options for accessibility. Once it is live, we will share the link.

We are here for you and will continue to advocate for and support all CCC students.

Sincerely,

President Dr. Tim Cook
Clackamas Community College

Many of you have questions about changes to policy at the Federal level and the college’s response to those changes. Every week I consult with the other Oregon community college presidents and the Oregon Community College Association’s attorney to understand the implications of those changes. I have also convened a work group to update leaders at the college and coordinate responses.  

On Friday, the U.S. Department of Education released a “Dear Colleague” letter outlining nondiscrimination obligations for colleges receiving federal funding. We are carefully reviewing this information and seeking guidance to ensure our policies and practices remain in full compliance with the law.

As with many federal directives, the legal and practical implications may take time to clarify. Therefore, it is important not to react too quickly, as policy interpretations and enforcement can evolve. We are committed to a thoughtful, measured approach that ensures compliance while also following Oregon law and our institutional mission. Additionally, we do not preemptively comply with executive directives until they have gone through the appropriate legal and regulatory processes.

It is important to note that a small portion of CCC’s funding — about 2% — comes from federal sources. The vast majority of our funding comes from the state, local property taxes, and student tuition. 

To help you stay informed on federal policies impacting higher education, we have launched a Federal Policy Updates and Resources webpage. This page will provide timely updates and resources as new information emerges.

We appreciate your patience and support for our students and each other as we navigate these changes together. I will continue to update you as we review and implement any necessary changes.

Sincerely,

Tim

Dear CCC Community, 

The college wants to make sure you have access to the resources and support you need. Teams have been working to gather information and develop response plans to help you navigate a variety of situations, including interactions with law enforcement, immigration matters, and accessing identity-affirming support. 

Here are some new updates: 

Law enforcement and immigration guidance 

• You can find information on the Federal policy updates and resources webpage about:
• The college’s policies and procedures regarding access to your student information.
• Procedures for officials accessing CCC’s campuses, including law enforcement and federal officers such as the FBI or Immigration and Customs Enforcement officers.

Support for undocumented and DACA students 

• We've updated our Undocumented and DACA Students webpage to include legal resources and a “Know Your Rights” section to help you stay informed.

Resources for LGBTQIA+ students 

• The Gender and Sexuality Club (LGBTQ+) meets on Thursdays from noon to 1 p.m. in the Multicultural Center (Wacheno 161) — a space to connect and build community.
• Looking for support? Visit the Multicultural Center or the LEAP Office (Rook Hall 120) to connect with allies.
• CCC has partnered with New Avenues for Youth, which provides LGBTQIA2S+ youth support in Oregon City and Portland. Learn more and sign up for their newsletters on their website or email tlrinfo@newavenues.org.

For more information and resources, visit the Federal policy updates and resources webpage. 

We’re here for you — please reach out if you have any questions or need support.