Comment on FR Doc # 2026-13248
Mary Elizabeth MalinkinOpposeIndividual
Summary: The commenter, an experienced administrator in international education, opposes the rescission of the Title VI programs regulations. They argue that the current rules ensure fair competition and transparency, and that the Department should revise specific outdated provisions rather than eliminating the regulations entirely.
I have worked for nearly a decade in program administration at a university-based international and area studies center, and I previously completed graduate study in a related program. In my professional role, I have helped prepare two successful Title VI FLAS grant applications. I share this background only to establish my experience with international education and grant administration. I submit these comments in my personal capacity and not on behalf of any institution or association.
Based on that experience, I strongly oppose the proposal to rescind the existing regulations governing Title VI programs.
The Department describes this proposal as a way to create flexibility. But from the perspective of someone who has helped prepare Title VI applications, the existing rules make fair competition possible. They tell applicants what the Department values, how applications will be judged, and what standards everyone is expected to meet.
Without clear and publicly available rules, the application process becomes a guessing game. Centers will still spend months preparing proposals, coordinating faculty and staff, developing budgets, documenting need, and making difficult choices about priorities. But they will do so with less information about how their work will be evaluated. That does not reduce burden. It shifts more uncertainty onto applicants.
The proposal also does not explain why full rescission is necessary. International education does need to respond to changing geopolitical conditions, emerging national needs, and new technologies. Title VI programs should be able to adapt. But flexibility and transparency are not opposites. The Department already has tools to set competition priorities, identify areas and languages of national need, and adjust requirements from one grant cycle to the next. If specific regulations are outdated or too burdensome, they should be revised, not eliminated.
I am also concerned about what this would mean for Less Commonly Taught Languages. Federal funding is essential for supporting language study that may not survive on enrollment numbers alone but remains vital to U.S. national interests. FLAS fellowships make it possible for students to pursue serious language training in fields and regions where expertise is urgently needed but often underfunded. Removing clear rules for these programs may put the commitment to these languages at risk.
The proposal raises basic questions that should be answered before any rescission moves forward. Will Title VI programs still be awarded through open grant competitions? If so, what criteria will be used to evaluate applications? If not, will funds be distributed through contracts, subgrants, or some other process? How will the Department ensure public accountability and effective oversight of federal funds? How will applicants know what standards they are being held to?
Perhaps the Department believes the current rules are too detailed or need updating. If so, it should identify the specific provisions that create unnecessary burden and propose targeted revisions. That would preserve the transparency and fairness that applicants depend on while still allowing the Department to modernize the programs.
I urge the Department not to rescind the Title VI regulations in full. The law should strengthen, not weaken, the infrastructure that supports foreign language training, regional expertise, and international education. These programs serve long-term national needs, and they should be administered through a process that is clear, public, accountable, and fair.