We applaud many of ED’s proposals to ensure that incarcerated individuals’ renewed Pell Grant eligibility yields the most benefit to them and is not abused by predatory for-profit institutions. However, we urge ED to, at a minimum, automatically enroll all defaulted incarcerated borrowers in Fresh Start. We also urge ED to create a long-term automatic income-driven repayment (IDR) enrollment system for incarcerated borrowers. Otherwise, ED’s Fresh Start proposal, as well as its expanded Pell proposal for those recipients who already have student loans, are bound to fail because neither proposal fully addresses the unique hardships of managing a student loan while incarcerated.