In short, yes it applies to all federal funds – and in government “double speak” of course there are exceptions. Some federal funds are exempted; thanks to amendments secured in part by our VT Senate delegation, funds primarily related to student loans, financial aid and funds used in the administration of these types of funds are exempted.

When completing any requests/applications for federal funds (even just a research grant which might fund a professor’s subbatical) there is generally a whole host of assurances and certifications that are made as part of the compliance pages of the application. For example most federal funds require compliance with Title IX, Title VI of the Civil Rights Act of 1964, ADA, EEO, the Drug Free Workplace Act, the Age Discrimination Act, just to name a few.

On the particular subject of military recruitment, I am not so altruistic, to think that the college would forego the funds. (There are only three colleges nationwide that have done so and been decertified for receipt of federal funds – VT Law School being one of the three.) I just believe we (as an institution) need to understand and acknowledge that some college policies and practices, for better or worse, are dictated by the monies we accept.

Thank you again for taking the time to follow up on this topic, and for allowing me to voice (ok vent) my concerns.

Thank you for your prompt, thorough and comprehensive response. I am pleased to realize that funding is not the driver of the programming.

I do however want to reiterate that Federal Funding comes with strings; Strings which, in no small measure, do dictate Middlebury policy.

In this case, Section 9528 of the No Child Left Behind Act of 2001 (20 USC 7908) contains provision that educational institutions (and MMLA as part of Middlebury College is a covered entity) receiving Federal Funds must when requested provide military recruiters access to secondary students names, addresses, telephone numbers and area of study for the purpose of military recruitment.

Furthermore, as discussed in other forums, receipt of federal funds also obligates Middlebury College to comply with the Solomon Amendment providing military recruiters access to the undergraduate campus and the names, addresses, phone numbers and area(s) of study of all its students upon request. Failure to comply risks the loss of those funds while compliance also allows recruitment access to an employer that practices legal discrimination.

Thus, while the funds are of use to support programs with inherent value, the acceptance of those funds does indeed dictate at least one of Middlebury’s policies.

I do have questions, or more directly concerns, regarding full disclosure of funding. In part I begin with your statement: “Yet, it was odd to me, at least, how these two major departments of the federal government seemed to think the solution to the country’s gap in our language proficiency in strategic languages (e.g., Arabic, Mandarin, Russian, Farsi, etc.) was to pump funds into colleges and universities.”
In fact by the time you were at the State Department Conference, the federal plans were underway to fund development of K-12 language programs. A point I find hard to believe was not a part of the 2005 State Department Conference, but for which, I will take you at your implied word that it was not.

NO, THIS CONFERENCE WAS ABOUT HIGHER EDUCATION AND DID NOT SPEAK TO PRE-SECONDARY EDUCATION, INCLUDING ANY FUNDING OPPORTUNITIES.

However it was as early as Jan. 5, 2006 that former President Bush announced the National Security Language Initiative which included the STARTALK program funded through, and promoted by, the US Department of Education; the US Dept. of State; the US Dept. of Defense and The office of the Director of National Intelligence.
This federal funding has been, and continues to be, a source of revenue for the MMLA programs and bolsters MMLA enrollment with available scholarship funding. Thereby making MMLA a viable option for the college to incubate MMLA into a revenue generating stream to support its many other programs.
The real question is similar to that of the chicken/egg question – Was MMLA conceptualized out of awareness of federal fund availability or did this availability of federal funds simply make the MMLA decision an easier sell? The timing of the State Department Conference, followed promptly by the availability of funds and the opening of MMLA, beg an answer to this question so that we as a community might better understand how some programs are developed and funded or, as the case may be, are funded and then developed.

THE DC CONFERENCE I REFER TO BEGAN ON JANUARY 5 WITH A RELATIVELY LAVISH DINNER. LAURA BUSH WAS AMONG THOSE WHO SPOKE TO US, AND THE CONFERENCE BEGAN ON THE 6TH. SO WE WENT TO THE CONFERENCE NOT KNOWING OF THE BUSH ADMINISTRATION’S ANNOUNCEMENT ABOUT FUNDING LANGUAGE EDUCATION UNTIL WE GOT THERE, BUT AS I SAID, OUR DISCUSSIONS WERE FOCUSED ON SECONDARY EDUCATION.

This federal funding has been, and continues to be, a source of revenue for the MMLA programs and bolsters MMLA enrollment with available scholarship funding. Thereby making MMLA a viable option for the college to incubate MMLA into a revenue generating stream to support its many other programs.
The real question is similar to that of the chicken/egg question – Was MMLA conceptualized out of awareness of federal fund availability or did this availability of federal funds simply make the MMLA decision an easier sell? The timing of the State Department Conference, followed promptly by the availability of funds and the opening of MMLA, beg an answer to this question so that we as a community might better understand how some programs are developed and funded or, as the case may be, are funded and then developed.

FEDERAL FUNDING NEVER FACTORED INTO OUR CONSIDERATION OF AND DECISION TO PURSUE MMLA. WE ACTUALLY BEGAN LOOKING INTO AFTER SCHOOL LANGUAGE TEACHING/TUTORING BACK IN THE 1990S WHEN I WAS DEAN OF THE FACULTY AND CLARA YU WAS HEAD OF THE LANGUAGE SCHOOLS. WE WENT SO FAR AS TO ALMOST PARTNER WITH ANOTHER FOR PROFIT THAT WE DECIDED WOULD NOT WORK FOR A HOST OF REASONS, BUT FEDERAL FUNDING NEVER FACTORED INTO OUR INITIAL CONSIDERATION AND ULTIMATE DECISION TO PURSUE PRE-COLLEGE LANGUAGE EDUCATION. IN THIS PARTICULAR CASE, THEN, OUR STRENGTH AND MISSION DROVE THE DECISION.

Some years ago, due to ease of other federal funds (loans), the college expanded into a major building boon. We are now dealing with the consequence of those decisions with our current fiscal budgets and staffing decisions. Will this be the same with MMLA or MIL?

NO, NOT AT ALL. FIRST OF ALL, THE DECISION TO MODERNIZE AND EXPAND OUR INFRASTRUCTURE (WE WENT FROM LESS THAN $50 MILLION OF DEBT IN 1997 TO MORE THAN $220 MILLION BY 2003 — BEFORE I BECAME PRESIDENT) WAS DONE THROUGH BOND FINANCING, NOT FEDERAL FUNDS. BUT YOUR QUESTION IS A GOOD ONE. THERE ARE GREAT DIFFERENCES IN FUNDING BUILDING AND FUNDING PROGRAM. IGNORING FOR A MOMENT ANY BENEFITS THAT ACCRUED TO THE COLLEGE BY MODERNIZING ITS INFRASTRUCTURE, AND THERE WERE MANY, THE SCALE OF THE TWO EXAMPLES IS HUGE AND THE IMPACT VERY DIFFERENT. WITH DEBT FOR THE BUILDINGS, YOU NOTE THAT WE “ARE NOW DEALING WITH THE CONSEQUENCE” AND YES, WE ARE. OUR DEBT SERVICE WAS MORE THAN $14 MILLION/YEAR, AND WILL CONTINUE FOR MANY YEARS. THE FUNDS WE HAVE RECEIVED SINCE STARTING MMLA, WHILE HELPFUL TO THE PROGRAM, ARE MINIMAL. MORE IMPORTANT, HOWEVER, IS THAT PROGRAMMATIC SUPPORT, WHICH COMES ANNUALLY ALLOWS FOR FLEXIBILITY IN TERMS OF CONTINUING OR NOT CONTINUING A PROGRAM. ONCE ONE BUILDS A LARGE BUILDING, IT IS WITH YOU AND YOU NEED TO PAY FOR ITS OPERATIONS, ITS DEBT, ITS DEPRECIATION, ETC. FOR PROGRAM, SUCH AS MMLA OR ANY OTHER PROGRAM, IF FUNDS GO AWAY, YOU CAN EITHER CUT BACK ON THE PROGRAM, OR EVEN CLOSE IT. WE USED TO HAVE A BREAD LOAF SITE IN JUNEAU, ALASKA, SUPPORTED BY STATE OF ALASKA FUNDS. WHEN FUNDING CEASED TO COVER THE COSTS OF THE PROGRAM, WE CLOSED THAT SITE. THUS, PROGRAM SUPPORT, WHICH COMES YEARLY, AND IS REALLY A VERY SMALL PART OF THE PROGRAM, ALLOWS FOR FLEXIBILITY IN ONE’S PLANNING AND DOES NOT CREATE WHAT YOU DESCRIBE — LEAVING US HAVING TO “[DEAL] WITH THE CONSEQUENCES” OF THE DECISION TO PURSUE MMLA AND MIL.

To return to MIL as the focus, just as the timing of MMLA and federal dollars came into partnership, so too is a similar timing for the rise of MIL. In 2007, Federal funding became available for the “e-learning language clearinghouse” for computer assisted learning developed in part by institutions of higher learning. Has MIL participated in this or other similar federal funding? Is it possible that the Federal Government, our tax dollar, is prompting another Middlebury expansion that may not be sustainable when the funds evaporate or are otherwise redirected? Additionally, might we expect announcements that Middlebury is a participant in the National Flagship Language Initiative or also a recipient of FLAP funds?

NO, MIL HAS NOT PARTICIPATED IN THIS OR ANY SIMILAR FEDERAL FUNDING. MIL IS A SEPARATE COMPANY, 40% OF WHICH IS OWNED BY MIDDLEBURY AND THEREFORE IT WILL NOT BECOME DEPENDENT ON FEDERAL FUNDING. AS FOR MMLA: IN 2009, WE RECEIVED $ 88,000 FOR ARABIC AND $ 32,000 FOR CHINESE IN STARTALK FUNDING, ALL FOR SCHOLARSHIPS. WE ALSO RECEIVED STARTALK FUNDING FOR CHINESE AND ARABIC IN 2008, BUT THERE WAS A BUDGET CUT HALF WAY THROUGH THE PROCESS, SO I BELIEVE WE RECEIVED BETWEEN $ 100,000 AND $ 150,000. WE DID NOT RECEIVE STARTALK FUNDING FOR MMLA IN 2010, BUT WE DID RECEIVE A GRANT FOR LANGUAGE SCHOOLS CHINESE FROM STARTALK IN 2010. UNTIL 2008, WE WERE ALSO PART OF A SMALL SSRC GRANT, WHICH I BELIEVE IT WAS PART OF TITLE IX, FOR ABOUT $ 22,000. THAT FUNDING WAS CUT—THE GRANT ITSELF WAS ELIMINATED. WE ALSO HAD A SMALL GRANT THAT WAS PART OF A FLAGSHIP GRANT CA. $ 48,000. 2008 WAS ALSO THE LAST YEAR FOR THAT.
BUT JUST TO REITERATE, NONE OF OUR DECISIONS WERE MADE KNOWING ANY OF THIS WOULD BE AVAILABLE; IT WAS, AS WE SAY, ICING ON THE PROGRAMMATIC CAKE. AND EVEN IF THE COLLEGE WERE TO RECEIVE IN THE FUTURE FEDERAL SUPPORT FOR MMLA (AS WE GET YEARLY FEDERAL SUPPORT FOR OUR LANGUAGE SCHOOLS AND HAVE FOR A LONG TIME), IT IS NOT, AS I SAID EARLIER, LIKE PAYING OFF DEBT FOR BUILDINGS. WHEN AND IF PROGRAM SUPPORT DRIES UP, THE PROGRAM SHRINKS OR GOES AWAY (AS JUNEAU, ALASKA DID) AND WE ARE NOT COMMITTED TO KEEPING SOMETHING GOING THAT MAKES NO SENSE. IN THE CASE OF LOSING SCHOLARSHIP SUPPORT, IT MEANS WE WOULD HAVE LESS FINANCIAL AID FOR STUDENTS, WHICH, BECAUSE OUR SUMMER PROGRAMS, UNLIKE OUR UNDERGRADUATE FINANCIAL AID POLICY, DO NOT MEET FULL NEED, WOULD MEAN WE WOULD HAVE MORE “FULL PAY” STUDENTS AT MMLA AND THE LANGUAGE SCHOOLS.

Lastly, all federal funds come with strings; as a result, I have a low tolerance for the availability of funds driving, or at least enhancing, decisions of the institution and simultaneously binding our capacity to act independent of the strings. This issue however, I have addressed with you elsewhere and we have agreed to disagree so I need not delve into it any further.

THERE ARE NO STRINGS ATTACHED TO ANY FUNDING WE HAVE RECEIVED FOR MMLA.

I HOPE THESE ANSWER YOUR QUESTIONS AND CONCERNS, BUT IF NOT, PLEASE LET ME KNOW. AND THANKS FOR THE COMMENTS.

Much discussion has ensued within the Middlebury College community, both pro and con, around the MIL program development and I am not commenting upon this aspect of your post. The venture and program will prove itself or not.

I do have questions, or more directly concerns, regarding full disclosure of funding. In part I begin with your statement: “Yet, it was odd to me, at least, how these two major departments of the federal government seemed to think the solution to the country’s gap in our language proficiency in strategic languages (e.g., Arabic, Mandarin, Russian, Farsi, etc.) was to pump funds into colleges and universities.”

In fact by the time you were at the State Department Conference, the federal plans were underway to fund development of K-12 language programs. A point I find hard to believe was not a part of the 2005 State Department Conference, but for which, I will take you at your implied word that it was not.

However it was as early as Jan. 5, 2006 that former President Bush announced the National Security Language Initiative which included the STARTALK program funded through, and promoted by, the US Department of Education; the US Dept. of State; the US Dept. of Defense and The office of the Director of National Intelligence.

This federal funding has been, and continues to be, a source of revenue for the MMLA programs and bolsters MMLA enrollment with available scholarship funding. Thereby making MMLA a viable option for the college to incubate MMLA into a revenue generating stream to support its many other programs.

The real question is similar to that of the chicken/egg question – Was MMLA conceptualized out of awareness of federal fund availability or did this availability of federal funds simply make the MMLA decision an easier sell? The timing of the State Department Conference, followed promptly by the availability of funds and the opening of MMLA, beg an answer to this question so that we as a community might better understand how some programs are developed and funded or, as the case may be, are funded and then developed.

Some years ago, due to ease of other federal funds (loans), the college expanded into a major building boon. We are now dealing with the consequence of those decisions with our current fiscal budgets and staffing decisions. Will this be the same with MMLA or MIL?

To return to MIL as the focus, just as the timing of MMLA and federal dollars came into partnership, so too is a similar timing for the rise of MIL. In 2007, Federal funding became available for the “e-learning language clearinghouse” for computer assisted learning developed in part by institutions of higher learning. Has MIL participated in this or other similar federal funding? Is it possible that the Federal Government, our tax dollar, is prompting another Middlebury expansion that may not be sustainable when the funds evaporate or are otherwise redirected? Additionally, might we expect announcements that Middlebury is a participant in the National Flagship Language Initiative or also a recipient of FLAP funds?
My points on funding do not negate the importance and need for these programs. I simply seek the full disclosure our community deserves so that we are not presented with a revisionist historian’s perspective of events as they stage our future.

Lastly, all federal funds come with strings; as a result, I have a low tolerance for the availability of funds driving, or at least enhancing, decisions of the institution and simultaneously binding our capacity to act independent of the strings. This issue however, I have addressed with you elsewhere and we have agreed to disagree so I need not delve into it any further.