U.S. Senator Lamar Alexander, Chairman of the Senate Health, Education, Labor, and Pensions Committee (HELP), requested comments in response to a white paper on accountability in the Higher Education Act (HEA). In our comments CLASP focuses on the need to retain current accountability systems, including cohort default rate, 90/10 rule, and Gainful Employment. In addition, CLASP urges careful consideration on any new proposals that claim to be based on return on investment for students and taxpayers, often known as risk-sharing. Risk-sharing policies could have negative incentives that harm low-income and underprepared students and the institutions that serve them. Any risk-sharing policy must meet certain conditions, including a strong focus on students, an acknowledgement of institutional mission, and a plan to overcome gaming. CLASP cannot support proposals that do not meet these conditions, which are further described in our comments.