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Problem / Issue

Federal Advocacy

It is more important than ever for California community college stakeholders to be engaged in advocacy efforts at the federal level to ensure our colleges can continue to offer quality public education to California students. The League has identified several critical federal advocacy issues and developed supplemental documents to assist you in advocating for California's community colleges. 

Supporting Undocumented Students

Language Around Supporting Undocumented Students Across the CCC

From the CO website - advocating for outreach to state and federal representa

Supporting Undocumented Students by Raising Your Voices and Taking Action

Raise Your Voice! Take Action. 

Join us in advocating for undocumented students at California's community colleges by completing one or both of our action steps.

Action Step #1: Email Congress
Action Step #2: Send a Tweet

My name is [@advFirst] and I live in [@advCity].

The California Community Colleges (CCC) is the largest system of public higher education in the United States. Our 115 colleges across 73 districts serve 2.2 million students, which includes two-thirds of the undergraduate students in the state. California is home to thousands of undocumented students and their families. Of the estimated 223,000 California DACA participants (totally 800,000 nationwide), approximately 72,000 are enrolled at California Community Colleges. Many recipients have built their lives in the U.S.—most who are now working, studying in college, and/or enlisting in the armed services.

The California Community Colleges, alongside the University of California (UC) and the California State University (CSU) systems, provide access to affordable, high-quality public education. By providing undocumented students with the means to pursue higher education the CCCs are positioning them to contribute meaningfully to California’s economic, social, and cultural fabric. The displacement of undocumented students and the elimination of DACA could dramatically impact the nation’s current labor market demand for a highly skilled and well-trained workforce.

1. Support legislation like H.R. 6 (the 2019 American Dream and Promise Act), which would create a pathway to citizenship for undocumented students who were brought into this country as children and permit them to be eligible for Title IV financial aid programs like Pell Grants and Work-Study.

2. Vote in support of H.R. 3222 (No Federal Funds for Public Charge Act of 2019), which would prohibit the Department of Homeland Security from moving forward with the new interpretation of the public charge rule.

3. Provide a permanent solution to the Deferred Action for Childhood Arrivals (DACA) program.

4. Exempt students receiving assistance via the Temporary Assistance for Needy Families (TANF) program, as that is primarily an educational benefit and thus is in the spirit of the new interpretation of the rule.

5. Address the humanitarian crisis at the border.

Summary of Proposed Changes by Immigrants Rising

See also, language for SB 68. Should we make Citizenship language stronger?

Proposed Changes from Immigrants Rising

The document contains a series of proposed changes. Each one is listed below with a summary of the response from CCCApply.

NEW issues to review:

Revise the "No Documents"

Parking Lot Items - Follow Up Soon

Update AB540 algorithm

Add the California Dream Act Applicaiton to the Special Links & Opportunities page

https://dream.csac.ca.gov/

CCCApply Privacy Policy is outdated;

Privacy policy does not include FERPA or SB 54, only info practices act of 1977. 

Suggestion: Add FERPA and SB54 to privacy policy.

Our Response:  This change is on the roadmap. The CCCTC Communications team is working on a combined MyPath - CCCApply-OpenCCC privacy policy and Terms of Use.  This suggestion will be passed on to that team.

Add Link to IRS for Nonresident Aliens

Suggestion: Add a link to nonresident aliens: (the IRS definition seems like a good one: https://www.irs.gov/individuals/international-taxpayers/taxation-of-nonresident-aliens) 

Our Response: It's NOT our policy to include links in the CCCApply applications which takes the user away from the application, and given the amount of text we are already placing behind the hyperlink, we would rather have colleges send an email or notification to students who indicate they are "Exceptions" by clicking the "SSN Exceptions" checkbox after stating they have no SSN. 

However, I do agree that the IRS information provided in the link is valuable for the colleges and could be transferred into a MyPath checklist notification. 

N/A

Fear of Disclosing Personal Information in Parent/Guardian Information Section

Summary of Proposed Changes by Immigrants Rising

• Revise language and layout of the SSN number
• Revise language in the Financial Aid Acknowledgment checkbox
• Revise language in the SSN Type question
• Add Link to IRS for Nonresident Aliens
• Move up the SSN Exceptions question
• Encouragement to Provide SSN
  
  
  
• Privacy Policy needs to be updated
• Fear of Disclosing Personal Information in Parent/Guardian Information Section
• Add Language about Discriminatory Practices up under ? Gender / Citizenship/Military sections?
• “No documents” is very small font
• Visa Type: Other
• ADD to “California Residence” for Tuition Purposes
• Support for Undocumented Students

See also, language for SB 68. Should we make Citizenship language stronger?

Proposed Changes from Immigrants Rising

The document contains a series of proposed changes. Each one is listed below with a summary of the response from CCCApply.

NEW issues to review:

Revise the "No Documents"

Parking Lot Items - Follow Up Soon

Update AB540 algorithm

Add the California Dream Act Applicaiton to the Special Links & Opportunities page

https://dream.csac.ca.gov/

CCCApply Privacy Policy is outdated; Privacy policy does not include FERPA or SB 54, only info practices act of 1977.  Suggestion: Add FERPA and SB54 to privacy policy.	Our Response:  This change is on the roadmap. The CCCTC Communications team is working on a combined MyPath - CCCApply-OpenCCC privacy policy and Terms of Use.  This suggestion will be passed on to that team.	REQUIREMENT: Update Privacy Policy & Terms of Use.  (Under determination)
Add Link to IRS for Nonresident Aliens Suggestion: Add a link to nonresident aliens: (the IRS definition seems like a good one: https://www.irs.gov/individuals/international-taxpayers/taxation-of-nonresident-aliens)	Our Response: It's NOT our policy to include links in the CCCApply applications which takes the user away from the application, and given the amount of text we are already placing behind the hyperlink, we would rather have colleges send an email or notification to students who indicate they are "Exceptions" by clicking the "SSN Exceptions" checkbox after stating they have no SSN.  However, I do agree that the IRS information provided in the link is valuable for the colleges and could be transferred into a MyPath checklist notification.	N/A
Fear of Disclosing Personal Information in Parent/Guardian Information Section Students are worried to put in their parents’ information without knowing that it is protected under federal and state law. Information about residency could cause confusion about eligibility for AB540 and SB68Suggestions: eligibility for AB540 and SB68 Suggestions: After “By CA law...circumstances.” Add “ This information is protected by federal and state laws.” Put “The following... residency.” into separate paragraph. After “Your response..college”, add “ Non-residents who meet eligibility requirements can apply for AB540/SB68.”  Image Added	Our Response: Update the text in the Parent/Guardian Information section (additional information) as suggested to support student identity and reduce ambiguity.  After “By CA law...circumstances.” Add “ This information is protected by federal and state laws.” Put “The following... residency.” into separate paragraph. After “Your response..college”, add “ Non-residents who meet eligibility requirements can apply for AB540/SB68.”  Image Removed Our Response: Update the text in the Parent/Guardian Information section (additional information) as suggested to support student identity and reduce ambiguity.  After “By CA law...circumstances.” Add “ By California law, determining your residency for tuition purposes is based on the residency of your parent(s) or guardian(s) until you are 19 years of age, except in certain special circumstances. This information is protected by federal and state laws. The following questions will be used to determine whether or not you need to provide your information or your parent or guardian's information for the purpose of determining residency for tuition purposes. This information is protected by federal and state laws .” Put “The following... residency.” into separate paragraph. After “Your response..college”, add “ Non-residents and will not affect your admission to college.  Nonresidents who meet eligibility requirements can may apply for AB540 for instate tuition  /SB68 .”	REQUIREMENT:  Update the text in the Parent/Guardian Information section (additional information) as suggested to support student identity and reduce ambiguity.  After the text, “By CA law...circumstances.” Add “ This information is protected by federal and state laws.” Put “The following... residency.” into separate paragraph. After “Your response..college”, add “ Non-residents who meet eligibility requirements can apply for AB540/SB68.”
Sexual Orientation & Transgender Students are concerned that it is unsafe to state this information and don’t know how it will be shared  Suggestion: Add this language under the citizenship box:  This information will be used for admissions and state reporting purposes. It will not be used for a discriminatory purpose  By law, your responses are kept private and secure.	Our Response: Add this language under the citizenship box:  This information will be used for admissions and state reporting purposes. It will not be used for a discriminatory purpose  By law, your responses are kept private and secure.	REQUIREMENT: Update the language in Gender section with the proposed additional information language, as follows: Add this language under the additional information language displayed in the Gender section:   This information will be used for admissions and state reporting purposes. It will not be used for a discriminatory purpose  By law, your responses are kept private and secure.
Citizenship / Visa Type “No documents” is very small font and is not very clear because it could be interpreted as I don’t have my documents with me.  Suggestion Use: bigger Font for No Documents  ADD Including Undocumented, DACA, AB 540/SB 68 after “No documents” So it would read: No Documents (Including Undocumented, DACA, AB 540/SB 68)	Our Response: Increase the font size for "No documents" Add text to label/question text:   AP 5017:  Shall not use this information for admissions or enrollment.	REQUIREMENT: Increase the font size in the "No documents" label/checkbox to the same size as the question text size.
Visa Type: Other If you choose "Other" in the Citizenship status, and you don’t see the box, this visa information comes up right away. Then you have to scroll ALL the way down this visa list to choose other again.  Suggestion: Move the no documents box (with new proposed language up to right after Citizenship Status drop down menu, before Visa Status.	Our Response:  This suggestion will be reviewed by the International steering committee to determine relevancy.	N/A
Concern: In reading the date below, many students could assume they meet the residency if they have been in CA since this date (as if it’s physical presence alone that decides it)  Suggestions: ADD to “California Residence” for Tuition Purposes Add a link to what requirements are for CA residency for tuition purposes, with info regarding non-resident tuition exemptions (including AB 540/SB 68)	Our Response: Currently we don't link out to additional information because we don't want to link the student out of the application for any reason. Usually, if it there's a critical need we will add Help text to clarify ambiguous language to avoid adding a hassle or barrier to the application workflow.  However, this information could be added to the Support pages we are considering.	NA/ for now
Support for Undocumented Students No listing of support for undocumented students Suggestion : Add Undocumented Student Support”in programs and services	Our Response:  This suggestion will be reviewed by CCCApply & MyPath Steering committees.  If approved, we will add to Programs & Services in Needs & Interests page.	N/A for now

TO BE REVIEWED BY STEERING COMMITTEES

Language from Gender and Sexual Orientation 

This information will be used for state and federal reporting purposes. It is optional and voluntary and will not be used for a discriminatory purpose. "Gender" in this context, means a person's sex, or a person's gender identity and gender expression . 

1. Gender 2. -- Select Gender -- Female Male 

Decline to state 3. Do you consider yourself transgender ? 4. -- Select Transgender Response -- Yes 

No Decline to State 

Sexual Orientation 

By California law, the California Community Colleges collect voluntary demographic information regarding the sexual orientation, gender identity, and gender expression of students. 

• This information is used for summary demographic reporting and will not be used for a discriminatory purpose. 
• Your responses are kept private and secure. 
• Providing this information is optional. 1. Please indicate your sexual orientation 

See also, language for SB 68. Should we make Citizenship language stronger? LANGUAGE from SB 68 information obtained in the implementation of this section is confidential, shall be used only to administer tuition payments pursuant to this section, shall not be open to the public for inspection, and shall not be disclosed without the written consent of the student, except as necessary to administer this section, or as otherwise required by California law or a state or federal court order.

Issue - How to give applicants access to the Privacy Policy from within the SSN question / application?  (See detail below).

SSN Related Only

Add "including students in noncredit classes, international students, undocumented students and non-resident aliens." in the SSN Exceptions and No SSN languaeg.

Concern & Immigrants Rising's Suggestion	CCCApply's Response	Requirements
Social Security Number  Concern: "There is a lot of language in the question and if your eye is skimming it, key words are” required” “federal law”, “failure to provide” “penalty levied against the student” which could create a lot of fear."	Our response:  We have a comprehensive revision proposed for the SSN question that has already passed the preliminary approval but a second review by Immigrants Rising would be ideal. The proposed revision includes a new streamlined layout, with all the required legal language moved to a slider drawer (accessed by a series of hyperlinks).	None No additional changes beyond what is already planned for SSN revision. NOTE: At this time, we have not been able to get Legal Office help on whether any of the existing legal language can be removed from the question/application; therefore, none of the language has been changed or removed, we've just placed it behind hyperlinks and help icons.  See below.
Acknowledge Financial Aid Checkbox The sentence that reads “I plan to apply for admission to college or financial aid” directly under SSN could easily lead students to believe that an SSN is required for admission or fin aid, which is not true.  Suggestion: Add However, it is not required for admission after “The SSN... facilitate financial aid.”	Our response: This checkbox question is gone or going away in the revision, so the new language proposed will not be included in question text.  The <ack_fin_aid> flag behind the checkbox was removed several years ago, and therefore no data field needs to be removed by the college.	No additional changes beyond what is already planned for SSN revision.
Federal Statement about SSN Exceptions A lot of students get confused about “non-resident aliens” And believe that undocumented students fall into this category. Suggestion: Add the following after: “Federal law requires...... with a few exceptions” including students in noncredit classes, international students, undocumented students and non-resident aliens.	Our Response The text in the SSN Exception question can be revised. We will add "students in noncredit classes and undocumented students"...to our existing language.  It should read: "...including students in noncredit classes, international students, undocumented students, non-resident aliens, and other exceptions."  We can also increase the font size in the question and additional information text.	REQUIREMENT:  Update text in the SSN language that is staying with SSN Revision change. Update font size in both conditional checkboxes: No SSN and SSN Exception.
Move up the SSN Exception question and text “Check this box”  immediately below the SSN Type field and prompt text, "Please indicate the type of number: SSN or Tax ID Number".	Our Response:  The SSN Type field is being removed from display to the end user.  Logic is being added to the SSN input text fields to determine which type of SSN is being entered.  SSN's never begin with the number 9.  Taxpayer ID's ONLY begin with the number 9.   This field will be auto-populated depending on which type of number is entered.	None No additional changes beyond what is already planned for SSN revision.
Encouragement to Provide SSN Even though I've indicated no SSN or ITIn in account creation, it still tells me it’s important to provide one in my school application. Suggestion: Use a conditional formula to program to determine if it ask me again if I don’t have a social security number.	Our Response: We removed the SSN Encouragement language (nudge) pop-up in September 2018.	N/A
Screen shots for the original New SSN Layout (mobile view) Due to the work being performed by the CCC Foundation in support of the SSN revision, the follow draft screens may no longer be valid. They were created based on the original "New SSN Layout" which included several hyperlinked words that would display chunks of legal language in the right-hand slider drawer.
		This language would appear when the user clicks on the hyperlink, "Why am I being asked for my Social Security Number?"
		This language would appear when the user clicks on the hyperlink, "Penalties"
		This language would appear when the user clicks on the Hover Help question mark icon next to the Social Security Number field or the Confirm Social Security Number field.
		This language would appear when the user clicks on the hyperlink, "Privacy Policy?" PROBLEM: Currently, the only existing hyperlink for "Privacy Policy" is within text that is to be moved into the slider drawer. We would need to expose the link in the onscreen text, I believe, to streamline access to this information.
Move up the SSN Exception question and text “Check this box”  immediately below the SSN Type field and prompt text, "Please indicate the type of number: SSN or Tax ID Number".	Our Response:  The SSN Type field is being removed from display to the end user.  Logic is being added to the SSN input text fields to determine which type of SSN is being entered.  SSN's never begin with the number 9.  Taxpayer ID's ONLY begin with the number 9.   This field will be auto-populated depending on which type of number is entered.	None No additional changes beyond what is already planned for SSN revision.
Encouragement to Provide SSN Even though I've indicated no SSN or ITIn in account creation, it still tells me it’s important to provide one in my school application. Suggestion: Use a conditional formula to program to determine if it ask me again if I don’t have a social security number.	Our Response: We removed the SSN Encouragement language (nudge) pop-up in September 2018.	N/A

Supporting Documentation

Definitions

Taxation of Nonresident Aliens 

NOTE: If you were a nonresident alien student, teacher, or trainee who was temporarily present in the United States on an "F,""J,""M," or "Q" visa, you are considered engaged in a trade or business in the United States. You must file Form 1040NR, U.S. Nonresident Alien Income Tax Return (or Form 1040NR-EZ, U.S. Income Tax Return for Certain Nonresident Aliens With No Dependents) only if you have income that is subject to tax, such as wages, tips, scholarship and fellowship grants, dividends, etc. Refer to Foreign Students and Scholars for more information.

Foreign Students & Scholars

Dependencies, Risks and/or Reporting Requirements?