[Senate Hearing 116-578]
[From the U.S. Government Publishing Office]


                                                        S. Hrg. 116-578

    NAME, IMAGE, AND LIKENESS: THE STATE OF INTERCOLLEGIATE ATHLETE 
                              COMPENSATION

=======================================================================

                                HEARING

                               BEFORE THE

                 SUBCOMMITTEE ON MANUFACTURING, TRADE,
                        AND CONSUMER PROTECTION

                                 OF THE

                         COMMITTEE ON COMMERCE,
                      SCIENCE, AND TRANSPORTATION
                          UNITED STATES SENATE

                     ONE HUNDRED SIXTEENTH CONGRESS

                             SECOND SESSION
                               __________

                           FEBRUARY 11, 2020
                               __________

    Printed for the use of the Committee on Commerce, Science, and 
                             Transportation


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                Available online: http://www.govinfo.gov
                
                             __________

                   U.S. GOVERNMENT PUBLISHING OFFICE
                    
52-659 PDF                WASHINGTON : 2023                
                
                
                
       SENATE COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION

                     ONE HUNDRED SIXTEENTH CONGRESS

                             SECOND SESSION

                  ROGER WICKER, Mississippi, Chairman
JOHN THUNE, South Dakota             MARIA CANTWELL, Washington, 
ROY BLUNT, Missouri                      Ranking
TED CRUZ, Texas                      AMY KLOBUCHAR, Minnesota
DEB FISCHER, Nebraska                RICHARD BLUMENTHAL, Connecticut
JERRY MORAN, Kansas                  BRIAN SCHATZ, Hawaii
DAN SULLIVAN, Alaska                 EDWARD MARKEY, Massachusetts
CORY GARDNER, Colorado               TOM UDALL, New Mexico
MARSHA BLACKBURN, Tennessee          GARY PETERS, Michigan
SHELLEY MOORE CAPITO, West Virginia  TAMMY BALDWIN, Wisconsin
MIKE LEE, Utah                       TAMMY DUCKWORTH, Illinois
RON JOHNSON, Wisconsin               JON TESTER, Montana
TODD YOUNG, Indiana                  KYRSTEN SINEMA, Arizona
RICK SCOTT, Florida                  JACKY ROSEN, Nevada
                       Nick Rossi, Staff Director
                 Adrian Arnakis, Deputy Staff Director
                    Jason Van Beek, General Counsel
                 Kim Lipsky, Democratic Staff Director
              Chris Day, Democratic Deputy Staff Director
                      Renae Black, Senior Counsel
                                 ------                                

                 SUBCOMMITTEE ON MANUFACTURING, TRADE, 
                        AND CONSUMER PROTECTION

JERRY MORAN, Kansas, Chairman        RICHARD BLUMENTHAL, Connecticut, 
JOHN THUNE, South Dakota                 Ranking
DEB FISCHER, Nebraska                AMY KLOBUCHAR, Minnesota
DAN SULLIVAN, Alaska                 BRIAN SCHATZ, Hawaii
MARSHA BLACKBURN, Tennessee          EDWARD MARKEY, Massachusetts
SHELLEY MOORE CAPITO, West Virginia  TOM UDALL, New Mexico
MIKE LEE, Utah                       TAMMY BALDWIN, Wisconsin
RON JOHNSON, Wisconsin               KYRSTEN SINEMA, Arizona
TODD YOUNG, Indiana                  JACKY ROSEN, Nevada

                            C O N T E N T S

                              ----------                              
                                                                   Page
Hearing held on February 11, 2020................................     1
Statement of Senator Moran.......................................     1
Statement of Senator Blumenthal..................................     3
Statement of Senator Wicker......................................     4
Statement of Senator Fischer.....................................    65
Statement of Senator Tester......................................    67
Statement of Senator Thune.......................................    69
Statement of Senator Blackburn...................................    71
Statement of Senator Capito......................................    72
Statement of Senator Young.......................................    75

                               Witnesses

Hon. Anthony Gonzalez, U.S. Representative from Ohio.............     5
Bob Bowlsby, Commissioner, Big 12 Conference.....................     7
    Prepared statement...........................................     9
Dr. Mark Emmert, President, National Collegiate Athletic 
  Association....................................................    15
    Prepared statement...........................................    17
Douglas A. Girod, Chancellor, University of Kansas...............    21
    Prepared statement...........................................    23
Ramogi Huma, Executive Director, National College Players 
  Association....................................................    24
    Prepared statement...........................................    26
Kendall Spencer, Chair, Student-Athlete Advisory Committee, 
  National Collegiate Athletic Association.......................    52
    Prepared statement...........................................    53

                                Appendix

Response to written questions submitted to Bob Bowlsby by:
    Hon. Jerry Moran.............................................    89
    Hon. Dan Sullivan............................................    94
Response to written questions submitted to Dr. Mark Emmert by:
    Hon. Roger Wicker............................................    97
    Hon. Jerry Moran.............................................    98
    Hon. Mike Lee................................................   100
    Hon. Dan Sullivan............................................   101
    Hon. Richard Blumenthal......................................   104
Response to written questions to Douglas A. Girod, M.D. submitted 
  by:
    Hon. Jerry Moran.............................................   107
Response to written questions submitted to Ramogi Huma by:
    Hon. Jerry Moran.............................................   109
    Hon. Deb Fischer.............................................   112
    Hon. Dan Sullivan............................................   113
    Hon. Richard Blumenthal......................................   114
    Hon. Amy Klobuchar...........................................   115

 
    NAME, IMAGE, AND LIKENESS: THE STATE OF INTERCOLLEGIATE ATHLETE 
                              COMPENSATION

                              ----------                              


                       TUESDAY, FEBRUARY 11, 2020

                               U.S. Senate,
Subcommittee on Manufacturing, Trade, and Consumer 
                                        Protection,
        Committee on Commerce, Science, and Transportation,
                                                    Washington, DC.
    The Subcommittee met, pursuant to notice, at 10:05 a.m. in 
room SD-106, Dirksen Senate Office Building, Hon. Jerry Moran, 
Chairman of the Subcommittee, presiding.
    Present: Senators Moran [presiding], Wicker, Thune, 
Fischer, Blackburn, Capito, Young, Blumenthal, Cantwell, 
Tester, and Rosen.

            OPENING STATEMENT OF HON. JERRY MORAN, 
                    U.S. SENATOR FROM KANSAS

    Senator Moran. Good morning, everyone. The Subcommittee 
will come to order.
    We are honored to have the Full Committee Chairman with us 
this morning, and I expect Senator Blumenthal, the Ranking 
Member of this Subcommittee, to join us momentarily.
    As Chairman of this Subcommittee, with jurisdiction over 
amateur athletics, I welcome all of you to today's hearing. It 
is entitled ``Name, Image, and Likeness: The State of 
Intercollegiate Athletic Compensation.'' The expectation or 
hope is that we might limit ourselves to that type of 
conversation, but I have no control over my colleagues or 
necessarily what the witnesses will say that may take us a 
little broader in scope.
    I absolutely look forward to hearing from our witnesses. I 
am appreciative of all of them being here but especially the 
Chancellor of my alma mater, the University of Kansas; the 
President of the National Collegiate Athletic Association; the 
Commissioner for Big 12; and two former student athletes.
    In my home state, we have a rich history of college 
athletics. The University of Kansas won 14 straight Big 12 
men's basketball titles and the women's soccer team just won 
their first Big 12 title last year. In my hometown of 
Manhattan, Bill Snyder revolutionized college football at 
Kansas State University, a legacy that has been continued by 
the current coach, Chris Klieman, and Athletic Director Gene 
Taylor. And who can forget Wichita State's Cinderella run at 
the NCAA men's basketball tournament in 2013?
    In addition, Kansas City was the national headquarters for 
the NCAA for 45 years before moving to Indianapolis. Senator 
Young is not here, but I would remind the NCAA we would welcome 
them back to Kansas City at any time.
    [Laughter.]
    Senator Moran. While Division I schools often come to mind, 
in my view we cannot lose sight over the 1,000 colleges and 
universities across three divisions included in the NCAA. In 
Kansas, we have impressive Division II athletics at Fort Hays 
State, Pitt State who won four D-II titles, most recently in 
2011, Emporia State, Newman, and Washburn. I hope that in this 
conversation that those schools and their athletes are not 
forgotten.
    Altogether there are nearly 500,000 student athletes that 
compete in 24 different sports. The NCAA's considerable 
financial restrictions tied to amateur athletics eligibility 
has gained national media attention and heated debate in recent 
years, specifically how student athletes are currently 
restricted from profiting from their name, image, or likeness 
to supplement the current scholarships and related benefits 
they receive.
    These debates have resulted in State legislatures taking 
their own actions. In California, the Fair Pay to Play Act was 
signed into law last September and will prohibit California 
universities and colleges from preventing their student 
athletes from gaining compensation for the use of their name, 
image, or likeness from third parties.
    Coming into effect in 2023, the law will also allow student 
athletes in California to hire agents and other representation.
    Following suit, legislation has been introduced in over 20 
other states with more expected to follow raising concerns of 
the ability of nationwide organizations to function within a 
system of differing State laws and provisions.
    Last May, the NCAA began to take steps to address the 
debate around student athletes potentially profiting from their 
name, image, and likeness by appointing a working group to 
examine potential modifications that still allow a clear 
demarcation between professional and amateur athletics and 
ensure that they are still aligned with the general student 
body. The working group is expected to issue recommendations 
later this year with new rules scheduled to be implemented in 
2021.
    Understanding how State and Federal laws and regulations on 
name, image, and likeness of student athletes would affect the 
existing intercollegiate athlete system is critical in shaping 
Congress' efforts on this issue. Some of the complexities 
surrounding this issue include the use of third party agents, 
the possible elimination of athletic programs, current 
definition of amateurism, and allowable incentives made 
available to today's college athletes.
    As we will hear today, college athletics teaches young men 
and women many values and skills that serve them throughout 
their life, but the most important aspect is that they are 
first a student athlete. NCAA student athletes have 
considerably higher graduation rates than non-athletes which is 
significant because less than 2 percent of student athletes go 
on to become professional athletes.
    It is important that actions taken by Congress do not harm 
the education, health, and wellbeing of student athletes.
    Joining us today to provide a variety of different 
perspectives on this issue is Mr. Bob Bowlsby, Commissioner of 
the Big 12 Conference; Dr. Mark Emmert, President of the 
National Collegiate Athletic Association; Dr. Douglas Girod, 
Chancellor of the University of Kansas; Mr. Ramogi Huma, 
Executive Director of the National College Players Association 
and former UCLA football student athlete; and Mr. Kendall 
Spencer, Chair of the NCAA?s Student-Athlete Advisory Committee 
and former University of New Mexico track student athlete.
    We are also honored to be joined by former Ohio State 
University football student athlete and U.S. Congressman 
representing the 16th district of Ohio, Anthony Gonzalez. The 
Congressman's background and active advocacy for this issue is 
highly valued by the Subcommittee, and I thank him for his 
willingness to join us today and present an opening statement.
    With the conclusion of my opening statement, I turn to the 
Ranking Member, Senator Blumenthal, for his.

             STATEMENT OF HON. RICHARD BLUMENTHAL, 
                 U.S. SENATOR FROM CONNECTICUT

    Senator Blumenthal. Thank you so much, Chairman Moran.
    I want to express my special appreciation to you and to 
Chairman Wicker, who is with us, as well as to Ranking Member 
Cantwell, for addressing an issue that I think will grow in 
importance. Already it has preoccupied the minds and hearts of 
many who are interested in college athletes and the future of 
the great individuals who participate in college sports. And we 
are now holding the Senate's first-ever hearing on compensating 
college athletes, thanks to you, Representative Gonzalez, for 
advancing a number of very promising ideas, which I hope we 
will take into account in our work.
    We have a highly significant opportunity today to better 
understand how we can protect college athletes while promoting 
intercollegiate sports. Our college athletes fuel the $14 
billion industry that literally makes money for countless 
companies and agents and almost nothing for the athletes 
themselves. We should ensure they receive equitable 
compensation for their hard work and the value that they 
create.
    Across the country, college athletes are being taken 
advantage of by a financial model that has allowed the NCAA and 
its members to profit off athletes' names, images, and 
likenesses without allowing those athletes to receive any 
compensation in return. College athletes risk their health and 
safety to play these sports, but in return, their compensation 
is capped at the cost of attending their college or university. 
Athletes are not even guaranteed to have costs for sports-
related injuries be covered by their schools, and they can have 
their scholarships revoked in the event of a college and 
career-ending injury.
    This system is deeply unfair, repugnant to the very ideals 
that the colleges so actively espouse, and inherently flawed as 
an economic matter, as well as marred with inconsistencies. 
Only student athletes are barred from compensation, whereas 
other students are able to monetize their skills in their free 
time by working, such as music students who teach budding 
musicians, or math majors who tutor high school students. 
College athletes receive no remuneration, no compensation, no 
financial recognition at all. That has to change.
    So we are here to hear from some of the experts and to 
begin this consideration. The kinds of egregious unfairness are 
multiple. We know well that college coaches are paid 
multimillion dollar salaries, outpacing the pay of many 
corporate executives and almost all the teachers at their 
schools. Many of the college coaches rank as the highest paid 
public employees. In fact, they do so in 41 out of 50 states. 
When universities are not turning their coaches into 
millionaires, they pump millions of dollars into lavish new 
athletic facilities, in fact, tens of millions of dollars that 
can cost upwards of $130 million.
    In short, everyone is profiting off the fame, image, 
likeness, and accomplishments of college athletes except for 
the athletes themselves, and it is during a period when their 
prowess and, in effect, earning capacity may be at one of its 
heights. Amateurism cannot be a means to monopolize college 
athleticism for lucrative media deals.
    I hope that states like the California Fair Pay to Play Act 
will be part of our consideration. Among other things, these 
laws provide new opportunities for women athletes who have less 
professional sports options after college than men, allowing 
them to be compensated for their athletic achievements while in 
college.
    And I look forward to continuing this work because we have 
a responsibility, especially in the absence of leadership 
elsewhere. But I hope there will be a leadership. I hope the 
NCAA will take advantage of the real opportunity it has to do 
right by hundreds of thousands of athletes across the country 
whose talents generate billions of dollars for the college 
sports industry. And I am glad that the NCAA is taking 
necessary steps to update its policies, and I look forward to 
hearing from the NCAA as to new rules to compensate athletes 
for their name, image, and likeness. Fundamental fairness is at 
stake here.
    Thank you, Mr. Chairman.
    Senator Moran. Senator Blumenthal, thank you. I look 
forward to working with you on this topic in this subcommittee, 
and you and I have a habit of responding to California 
legislation.
    [Laughter.]
    Senator Moran. We will see if we can do it one more time or 
maybe we can do it in both instances.
    I now recognize the Chairman of the Full Committee, Senator 
Wicker. He and his staff have been instrumental and supportive 
of our efforts to bring this hearing to fruition this morning, 
and I appreciate his presence here this morning.
    Senator Wicker is recognized.

                STATEMENT OF HON. ROGER WICKER, 
                 U.S. SENATOR FROM MISSISSIPPI

    The Chairman. Well, thank you very much, Chairman Moran and 
Ranking Member Blumenthal, for calling us together for this 
important hearing. I think we see by the size of the crowd and 
the attention that this hearing is receiving that we are onto 
something very important and very timely.
    I do not know how I feel about this issue, Mr. Chairman. I 
do not know where it is going to lead, but let me say that I do 
not disagree with anything that the Chair or Senator Blumenthal 
have said during their opening statements. We have got a 
situation where states are moving forward, and we need to 
address the issue.
    I am as proud of my state's history of intercollegiate 
athletics as Senator Moran is and pointed out in his opening 
statement. If Senator Blumenthal had taken the time to do so, 
he could have pointed to great accomplishments in Connecticut 
also.
    Many college athletes come from middle class families, as I 
did, who could scrape together the funds and pay for a college 
education on their own if they had to. But for many collegiate 
athletes, male and female, in football, basketball, or some of 
the other sports that are not quite so popular, it is the first 
opportunity for that family to get out of poverty, to go to 
college, to grab a rung on the ladder of economic success.
    And certainly the legislation in California and the 
legislation being proposed elsewhere recognizes that there has 
been a disparity there that ought to be addressed. I agree that 
it ought to be addressed.
    Perhaps name, image, and likeness is the answer. I wonder, 
Senator Blumenthal, if it is the answer in all categories of 
intercollegiate sports, and I wonder if we can come up with 
something as a nation, with the help of the NCAA and with the 
help of States, to help us figure out the fairest way to make 
sure that no one is left out and that the athletes that do 
contribute to this $14 billion per year economy are given their 
fair share in bringing this largesse to our universities.
    I agree with you, Mr. Chairman, also. We could get into 
other issues. I had another hearing just a few days ago dealing 
with doping, and we learned that there is a problem with 
intercollegiate athletics with doping. I am going to stay away 
from that today. I hope that members up and down the dais will 
heed your admonition that we have a specific topic to talk 
about today. I do not know where this is going to lead, but I 
think this is an important step. And the Chair and Ranking 
Member are due kudos for getting us moving on that.
    And with that, I yield back, sir.
    Senator Moran. Chairman Wicker, thank you very much and 
thank you for your leadership in this issue and on the Full 
Committee and your hearing last week.
    Let me now recognize Representative Anthony Gonzalez, a 
Member of the House of Representatives from Ohio, with a 
history regarding being a student athlete, and we welcome your 
statement, Representative. Thank you.

              STATEMENT OF HON. ANTHONY GONZALEZ, 
                 U.S. REPRESENTATIVE FROM OHIO

    Mr. Gonzalez. Thank you. Chairman Wicker, Chairman Moran, 
Ranking Member Blumenthal, and members of the Subcommittee, 
thank you for inviting me to speak on this timely topic.
    As a former student athlete at Ohio State University, I 
know firsthand the impact college sports has on our students, 
our athletes, and our communities across the country. For me, 
my time playing for Ohio State shaped my life immeasurably, and 
my appreciation for the lessons I learned on and off the field 
grows every day. College athletics has a way of doing that. For 
many of my teammates, college sports provided the best and 
sometimes the only opportunity to attend college and earn a 
degree.
    That said, college sports has morphed into a multibillion 
enterprise that few could have imagined when the NCAA first 
formed in 1906. College athletics generated more than $10 
billion in revenue in 2018, but student athletes are still 
barred from capitalizing off their name, image, and likeness. 
This is a regulation unique to student athletes on college 
campuses. An award-winning, full scholarship chemist can accept 
any financial rewards that may come her way, but the fastest 
runner on the track team cannot.
    The reality is that the majority of student athletes are 
facing the same intense financial pressures as the general 
student body, including student loan debt. Outside of the high 
revenue sports, the majority of student athletes do not receive 
full tuition scholarships. Division III athletes receive no 
athletic scholarship at all. NIL rights would empower these 
athletes to make a few extra dollars to alleviate some 
financial pressure.
    It is this disparity that spurred the passage of 
California's Fair Pay to Play Act. The law grants NIL rights to 
student athletes who compete in California. While I agree with 
the idea in principle, California's law fails to capture the 
nuance that is required to get this right.
    Firstly, a state-by-state approach to NIL would throw the 
collegiate athletic system into chaos. It would undermine 
competition among schools from different states even if they 
compete in the same conference. As it stands, UCLA and Arizona 
State, both PAC 12 members, are now on unequal footing because 
of the California law. Students considering athletic 
scholarship offers at the two schools now have an added outside 
incentive to pick UCLA, the ability to profit off name, image, 
and likeness. This reality will only get worse if a patchwork 
of State NIL laws becomes the norm.
    Second, the California law created an anything goes system 
that fails to understand the realities of the hyper-competitive 
recruiting process. Guardrails are crucial to protecting the 
integrity of the game and student athletes from overzealous 
boosters who may want to buy their way to their school's next 
national championship.
    Nevertheless, the California did get one thing right. It 
forced the discussion of NIL into the national conversation and 
compelled the NCAA, universities, and conferences to confront 
the reality head on. Over the past several months, I have 
talked to student athletes, conference commissioners, athletic 
directors, the NCAA, and university administrators, including 
some of those testifying here today.
    Despite uncertainty on the right path forward, there is 
consensus that something must be done and that Federal action 
is needed. Over 20 additional states are in the process of 
passing different NIL laws. The question is not should student 
athletes be able to profit off of NIL. That question has been 
answered. The question before us today is how can we prevent 
state-by-state chaos and protect the collegiate athletic system 
that is beloved across the Nation.
    First, the system must permit student athletes to 
capitalize on their NIL rights regardless of whether they 
participate in a high revenue sport like football or pitch for 
the university softball team. NIL will benefit star players in 
high revenue sports but also athletes who want to earn a little 
money using their talents to pay off student loans or take 
their significant other on a date.
    Second, Federal legislation must protect student athletes 
in the recruitment process and penalize bad actors who seek to 
take advantage of the new NIL laws. By expanding upon existing 
protections in Federal law, we can deter bad actors, encourage 
oversight, and promote transparency so universities are aware 
of the NIL contracts their students are entering into.
    Third, any legislation must also guarantee that student 
athletes are still considered students, not employees of an 
institution. Using NIL to create an employment framework would 
destroy college sports as we know it. Important protections 
that currently exist for student athletes would be completely 
eradicated. For one, if a student athlete can be hired, that 
means he or she can also be fired. From personal experience, I 
can tell you that incoming freshmen recruits often do not live 
up to expectations in their first few seasons. Firing these 
students instead of investing in their development would 
eliminate countless opportunities, in many instances the only 
opportunity.
    The reality is the train has left the station on NIL. It is 
no longer a question of if but rather when and how. Congress 
must act to preserve the collegiate sports system we all know 
and love.
    For those reasons, I have begun to draft Federal 
legislation in the House to allow student athletes to profit 
from their NIL and create one uniform national standard.
    I look forward to hearing from the witnesses on this issue 
and working with my colleagues in the Senate to find a 
bicameral, bipartisan solution to the challenge before us 
today.
    Thank you for the opportunity to provide a statement.
    Senator Moran. Representative, thank you very much for your 
statement. We appreciate your interest in this topic, and you 
bring a particular expertise both on the field and now in 
Congress. We look forward to that bipartisan, bicameral effort 
to get this right. Thank you.
    We will now call the panel of witnesses to the table: Mr. 
Bob Bowlsby, Commissioner of Big 12 Conference; Dr. Mark 
Emmert, President National Collegiate Athletic Association; Dr. 
Douglas Girod, Chancellor, University of Kansas; Mr. Ramogi 
Huma, Executive Director of National College Players 
Association; and Mr. Kendall Spencer, Former Chair, Student-
Athlete Advisory Committee, National Collegiate Athletic 
Association.
    Welcome to all of you, and we will begin with Mr. Bowlsby 
when he is ready.

            STATEMENT OF BOB BOWLSBY, COMMISSIONER, 
                       BIG 12 CONFERENCE

    Mr. Bowlsby. Good morning.
    Chairman Moran, Ranking Member Blumenthal, Chairman Wicker, 
distinguished members of the Subcommittee, on behalf of the Big 
12 Conference and its members, I thank you for holding this 
hearing and providing me with this opportunity to testify.
    I believe in the extraordinary opportunities our colleges, 
universities, provide to our Nation and the world. I also 
believe in the American model of intercollegiate athletics as a 
co-curricular activity on our campuses. I have worked in 
intercollegiate athletics for more than 40 years because I 
believe that the fundamental purpose is to help 18-year-old 
adolescents become 22-year-old adults and, in that process, to 
provide an opportunity for an outstanding athletics experience 
and a first-rate education.
    I left my last position at Stanford University largely 
because I believed that there was much that is good and right 
about intercollegiate athletics and that I could perhaps better 
be a part of effecting change from a commissioner's position.
    Over the past 8 years, I have been afforded the opportunity 
to participate in just such a change. Along with our 
commissioner colleagues and our members, we work to provide 
student athletes with the full cost of attendance in addition 
to tuition, fees, room, board, and books. This change provided 
funds for trips home, entertainment, and incidental living 
expenses in amounts ranging between $3,000 and $6,000 per 
student per year. We have changed rules so former participants 
can return to school on scholarship to complete their degrees. 
We have configured legislative changes to allow unlimited meals 
and snacks. We have implemented transitional health care so 
that medical expenses for injuries that linger on until after 
graduation or departure from school can be reimbursed, all of 
this plus Pell Grant benefits up to $6,800 a year for those 
qualified.
    The covenant with the 21st century student athlete is far 
superior to the scholarship and benefits package available just 
5 years ago. We have made constant progress since receiving the 
prerogatives that have come with the new autonomy structure of 
the NCAA.
    When all of the recent NCAA legislative amendments are 
considered along with the quality of the facilities, medical 
services, academic support, travel opportunities, and high 
level coaching and mentorship, the quality of the life of the 
student athlete in Division I is really quite high.
    I have spent a great deal of time recently working with 
colleagues and advocates considering what an open NIL pay for 
play environment might look like. I find myself supportive if 
modernization, but daunted by the dark shadow between the ideas 
and the reality. The changes advocated in many of the State 
legislative proposals and likely in some of the national 
concepts will benefit a very small percentage of the 450,000 
student athletes in our country and will, de facto, render a 
much larger percentage to a lesser status. For decades we have 
funded broad-based sports programs, including our nation's 
Title IX initiatives, on the revenue derived from a few sports. 
This approach is defensible and worthy of protection because of 
the multitude of opportunities that it creates.
    Student athletes in a wide array of sports work very hard 
in search of excellence. Their labors are neither less 
intensive nor less strenuous than the efforts in football or 
basketball or baseball. The participants in high profile sports 
simply enjoy the benefits that accrue to those in sports, that 
are adored by the public, and coveted by the television 
networks.
    The current model of athletics funding works because it 
meets the university's objectives of offering a full array of 
co-curricular, equitable opportunities for its students. There 
is plenty of work to be accomplished and I advocate that we be 
thoughtful in our collaboration.
    The potential for harm is present and changes that some 
assert as inalienable rights also have the possibility to 
irreparably damage the collegiate model of athletic 
participation. This model is and has been the envy of the 
world. College sports is not a vocation and the participants 
are not employees. Professional sports offer this arrangement. 
Conversely, for more than 98 percent of the college athletes 
population, the 4 years of college sports participation is the 
last they will enjoy in organized high level competition. Their 
active sports careers will be over, but the education they 
earned, the camaraderie they enjoyed, and the experiences they 
treasured will pay dividends for many years to come.
    I thank you for this opportunity to testify and I refer you 
to the written version of my comments which go into greater 
depth on the pertinent issues of this hearing. Thank you.
    [The prepared statement of Mr. Bowlsby follows:]

   Prepared Statement of Bob Bowlsby, Commissioner, Big 12 Conference
    Chairman Moran, Ranking Member Blumenthal and distinguished members 
of the subcommittee, on behalf of the Big 12 Conference and its 
members, thank you for holding this hearing and providing me with this 
opportunity to testify. I am grateful for the expressed interest of the 
Senate in issues pertaining to intercollegiate athletics. The impact 
our Nation's student-athletes have had on our American culture is truly 
remarkable.
    I believe in the extraordinary opportunities our country's colleges 
and universities provide to our Nation and the world. I also believe in 
the American model of intercollegiate athletics as a co-curricular 
activity on our campuses. I have worked in collegiate athletics for 
more than forty years because I believe that the fundamental purpose is 
to help 18 year-old adolescents become 22 year-old adults and in the 
process provide opportunities for an outstanding athletics experience 
and to provide first-rate educational opportunities. We should not 
forget in this discussion that an athletics scholarship has provided 
educational opportunities for millions of young men and women in the 
last century. Most of them have left college with a degree and little 
or no debt. Sometimes this experience also leads to a professional 
career or an Olympic opportunity; both are highly desirable byproducts 
of a successful collegiate athletics experience, but not the 
foundational goal. I served as the director of athletics at three fine 
universities for almost 35 years and left my last position at Stanford 
University because I believe there is much that is good and right about 
intercollegiate athletics and that I can be a part of changing that 
which is not as good as it can be.
    I theorized that I could be a more effective agent for change by 
occupying one of the five Autonomy Conference (Pac12, BigTen, ACC, SEC 
and Big12) Commissioner positions. Over the past eight years I have 
been afforded the opportunity to participate in affecting just such 
change. Along with my commissioner colleagues and our members we worked 
to provide student-athletes with the full cost of attendance in 
addition to Basic Educational Expenses (Tuition, Fees, Room, Board and 
Books). This change has provided funds for trips home, entertainment, 
incidental living expenses, etc. and amounts to between $3000 and $6000 
per student per year. We have changed rules so former participants can 
return to school on scholarship to complete their degrees. We have 
configured legislative changes to allow unlimited meals and snacks. We 
have implemented transitional healthcare so that medical expenses for 
injuries that linger on until after graduation or departure from school 
can be reimbursed. We have accomplished all of this while still making 
sure that scholarship student-athletes can also receive the full 
measure of PELL Grant benefits up to $6800 per year.
    The covenant with the 21st century student-athlete is far superior 
to the scholarship and benefits package available just five years ago. 
We have made constant progress since receiving the prerogatives that 
have come with the new Autonomy structure of the NCAA. Among these 
prerogatives is legislative authority to make changes that address the 
needs of highly recruited and exceptionally talented student-athletes. 
When all of the recent NCAA legislative amendments are considered along 
with the quality of the facilities, medical services, academic support, 
travel opportunities and high level coaching and mentorship, the 
quality of life for the Division I student-athlete is quite high. In 
fact, one of every five collegiate athletes is a first generation 
student and the opportunity to attend college is truly life changing 
for them and their families. Over my many years involved in higher 
education I have encountered very few former participants who did not 
view their college years as the best of their careers.
    I recently attended the memorial service for Coach Hayden Fry. 
Coach Fry and I were colleagues while I was the Director of Athletics 
at the University of Iowa. It was remarkable to see so many former 
players come back and talk about the impact Coach Fry had on their 
lives. They talked of the value he placed on education and on learning 
to be a productive adult.
    I also heard the story of how Coach Fry integrated the Southwest 
Conference when he brought Jerry Levias to Southern Methodist 
University. Mr. Levias went on to be a first team all-conference 
performer for three straight years but also endured the injustice of 
opponents' treatment. Coach Fry passed at age 90 and he and Mr. Levias 
spoke regularly until the time of his death.
    I quickly realized that Coach Fry's legacy had much more to do with 
the relationships than it did with the 230+ victories or the induction 
to many halls of fame. I heard very few comments about the details of 
the games they all played but instead many anecdotes about the hard 
discipline when they missed a class or the celebration when a young man 
walked across the stage to receive his degree after coming to campus as 
a ``high risk'' student. I also heard of the shared experiences that 
truly made them a team.
    The four years that student-athletes spend on campus are 
transformative. There are stories of failure but many more stories of 
extraordinary and unlikely success. The kinship of a college sports 
team is singular in its ability to shape. I fear that if we adopt a 
process that permits per se ``play for pay'' or any proxy for ``pay for 
play'' we will find ourselves changing the team chemistry that has made 
college athletics so special.
    In the same time frame that we have provided more benefits and 
celebrated the growth potential afforded by intercollegiate athletics, 
we have witnessed explosive growth in debt service through mind-
boggling facility projects intended to impress 17 year-olds and we have 
experienced meteoric escalation in compensation for coaches, directors 
of athletics and commissioners. This rapid escalation is principally 
facilitated by the increases in revenue from the sale of media rights. 
These trends require attention and I suggest for your review an essay 
by Dr. Kevin Blue, the Director of Athletics at the University of 
California at Davis, which thoughtfully dissects the expense trends and 
the causality for the dramatic increases in the past 20 years. I have 
included Dr. Blue's analysis for your reference.
    Consistent with my comments above, I am a believer in constant 
evolution and I am devoted to any sort of continuing improvement 
program. As it pertains to a new model of collegiate licensing and a 
loosening of restrictions on how student-athletes might activate around 
their personal name, image and likeness opportunities, I find myself 
supportive of the concept but daunted by the shadow that lies between 
the idea and the reality. I am particularly hesitant regarding the 
viability of the ``guard rails'' that are nebulously asserted to be 
capable of ensuring boosters, donors, and other interested third 
parties are not disruptive, unregulated and unwelcome participants in 
the recruitment processes.
    In an era of increasingly frequent transfers, the outside 
influencers noted above will most certainly engage in the transfer 
space, even without the knowledge or invitation of institutional 
employees. Within the Autonomy Conferences where recruiting competition 
is most acute, we have sought to do everything possible to embrace and 
enhance integrity. Our constituents, college sports fans and our 
universities, demand it. I fear, and I believe, that the invitation of 
third parties into the NIL space will irretrievably insert them into 
the recruitment and transfer environment. We have already witnessed far 
too many such intrusions on fair play.
    The American collegiate model of intercollegiate athletics has no 
parallel in the world. We are not the NFL, NBA or MLB where well-
organized drafts determine the participants. Neither are we the 
Olympics where the athlete's only choice of participation is with their 
country of origin. Recruitment, especially in Division I, is highly 
competitive and highly regulated. To replace or significantly amend the 
current benefits system we must be able to move ahead with assurance 
that recruitment can exist and that integrity can be maintained and 
enhanced.
    As a former collegiate wrestler, and having served two terms on the 
United States Olympic Committee, I have significant concerns regarding 
any legislative or structural initiative that will weaken our Olympic 
Sports on campus or that could compromise our Nation's aspirations to 
ascend podiums in international competitions. While all college sports 
participants might be alleged to have equivalent opportunities to 
profit from name, image and likeness activities, I believe that the 
present discussion is principally about football and men's basketball 
players and I am certain that the participants in these two sports will 
harvest the vast majority of the opportunities. It follows that this 
disparity will ultimately diminish other sports on campus. This 
diminishment could come in the form of reduced scholarships, declining 
budgets or even sport eliminations. Because more than 80 percent of our 
Summer Olympians come through college programs, any damage to Olympic 
Sports on campuses could have a profoundly negative effect for our 
international Olympic efforts. I also believe that the relegation of 
some sports to second-class citizenship could directly or indirectly 
impact institutions' compliance with Title IX. Before Title IX's 
implementation only 1 in 27 high school females played varsity sports, 
today that figure is 1 in 2.5. Simply put, I do not believe the 
architects of the Title IX of the Education Amendments of 1972 
envisioned two or more classes of student-athletes on campuses, even if 
the funding were to come from outside the campus coffers. These two 
considerations implore caution.
    Will intercollegiate athletics survive? Of course. Will we evolve 
and will games still be played? Without question. Likely, the balance 
of competition will not be dramatically altered. There have always been 
institutions and locations that have enjoyed advantages, and there 
always will be. Having stated that, we must go forward with our eyes 
wide open. The changes advocated in many of the state legislative 
proposals and, likely, in some of the national concepts, will benefit a 
very small percentage of the 450,000 student-athletes in our country 
and will de facto render a much larger percentage to a lesser status. 
It is difficult to argue that the American collegiate model is not 
collectivism in some form. For decades we have funded broad-based 
sports programs, including our institutions' Title IX initiatives on 
the revenue derived from a few sports. This approach is defensible and 
worthy of protection because of the multitude of opportunities it 
creates. Student-athletes in a wide array of sports work very hard in 
the search of excellence. Their labors are neither less time consuming 
nor less strenuous than the efforts in football, or basketball or 
baseball. The participants in high-profile sports enjoy the benefits 
that accrue to those in sports that are adored by the public and 
coveted by television networks. Likewise, the coaches in these sports 
have benefitted from an inflated marketplace and aggressive 
representatives who play institutions off against one another for the 
highest offer. Notwithstanding these sometimes misguided expenditures, 
the current model of athletics funding works because it meets the 
universities' objective of offering a full array of co-curricular 
opportunities for its students. There is plenty of work to be 
accomplished but I advocate that we be thoughtful in our collaboration.
    The potential for harm is present and changes that some assert as 
inalienable rights also have the possibility to irreparably damage the 
collegiate model of athletic participation. This model is, and has 
been, the envy of the world. This unique and long standing model exists 
as a useful and appropriate rite of passage between high school and the 
rest of one's life. College sports is not a vocation and the 
participants are not employees. Professional sports offer this 
arrangement and it is fair and timely to consider whether the current 
limits to access should be amended or eliminated to allow those who 
wish to pursue professional opportunities to do so at any time. 
Conversely, for more than 95 percent of the collegiate athletics 
population, the four years of college sports participation is the last 
they will enjoy in organized, high level competition. Their active 
sports careers will be over, but the education they earned, the 
comradery they enjoyed and the experiences they treasured will pay 
dividends for many years to come.
                                 ______
                                 
                                  ADU
    Rising Expenses In College Athletics And The Non-Profit Paradox
    This article examines the structural reasons why controlling 
expenses--especially for salaries and facilities--has been difficult in 
the current economic system of major college sports. The combination of 
three significant economic characteristics currently drives financial 
choices: the non-profit organizational structure, zero-sum competition, 
and accelerating revenue. The combination of these structural 
characteristics creates inescapable upward pressure on expenses, and 
differentiates financial decision-making in college sports from both 
professional sports and other non-profit sectors. The structural 
uniqueness of the non-profit economic system of college sports calls 
for innovative business and legal solutions to curtail excessive 
spending and its associated problems, and ensure the long-term health 
of college athletics in the United States.
            For-Profit Business and Non-Profit Organizations
    A business exists to maximize income for its owners, while also 
maintaining a sense of corporate social responsibility to other 
stakeholders. On the other hand, a non-profit organization, such as a 
school or a charity, exists solely to execute its mission.
    Non-profit organizations do not have owners expecting a financial 
return, so their leaders do not operate with the goal of making a 
profit. Instead, financial decisions are guided by the primary 
objective of mission impact, while also being mindful of long-term 
investments and sustainability.
    Accordingly, when revenues increase for a non-profit organization, 
expenses tend to grow commensurately. New income is used by the 
organization to further pursue its mission, not to create profitable 
operating margins. For example, a food bank that receives a new large 
grant will expand to serve more disadvantaged people rather than 
keeping the money. The level of annual expenditures for a non-profit 
organization is generally determined by its anticipated annual 
revenues.
           Athletics Departments as Non-Profit Organizations
    College athletics departments and their associated foundations are 
structured as non-profit organizations since they are part of 
universities. However, they differ from most other non-profits in two 
important ways.
    First, college athletics programs compete against each other in a 
zero-sum game; in other words, a college sports program can only 
succeed at the competitive part of its mission (win) if another fails 
(lose). Other kinds of non-profit organizations do not deal with this 
dynamic to the same extent. The zero-sum nature of competition in 
college sports thus creates an insatiable desire for an athletics 
program to make investments that drive success in the competitive part 
of its mission.
    And second, for modern college programs in the major conferences 
especially, revenue has accelerated at an unusually strong rate in 
recent years. The median Division I Football Bowl Subdivision (FBS) 
athletics program experienced inflation-adjusted revenue growth of 67 
percent from 2006-2015[1], a higher rate of revenue growth 
than all other non-profit sectors in the United States over this period 
of time[2].
---------------------------------------------------------------------------
    \[1]\ According to the 2016 edition of Revenues and Expenses of 
NCAA Division I Intercollegiate Athletics Programs, median revenue 
growth from 2006-2015, on an inflation-adjusted basis, was 67 percent 
for FBS, 55 percent for FCS, and 55 percent for D1 without football.
    \[2]\ Information about non-profit revenue and expense growth by 
sector can be found on this 2018 report by the Urban Institute called 
The Non-Profit Sector in Brief. On an inflation-adjusted basis, overall 
higher education sector revenue grew by 39 percent from 2005 to 2015. 
Religious organization revenue grew by 59 percent over the same time 
period, the most growth of any non-profit sector outside of college 
sports.
---------------------------------------------------------------------------
    The combination of zero-sum competition, revenue acceleration, and 
non-profit financial incentives would predict an increase in spending, 
which has indeed come to fruition in major college sports. With 
gravity-like inevitability, expenses are pulled to the threshold 
established by the highest revenue earners. Paradoxically, the non-
profit organizational structure--typically associated with austerity 
and frugality--has actually helped to create the extraordinary spending 
growth we've seen.
               Comparing College and Professional Sports
    Unlike professional teams, college athletics departments do not 
have owners with a personal financial stake in the game. Professional 
owners want to win, but they are simultaneously incentivized to control 
costs in order to turn a profit or manage operating losses, and to 
consider long-term franchise value. These incentives are reflected in 
league-wide policies developed to control spending and enhance 
competitive equity, and also in the financial decision-making of team 
executives.
    On the other hand, financial decision-making in college athletics 
reflects the different set of incentives that the non-profit structure 
encourages. Every dollar of generated revenue is spent in pursuit of 
the competitive and student-athlete education missions. Some income 
might be saved for contingent or long-term use, but none is taken as 
profits[3]. When revenue increases dramatically, increases 
in spending quickly follow.
---------------------------------------------------------------------------
    \[3]\ In a few cases, a portion of net income from athletics is 
redirected to the financial needs of main campus.
---------------------------------------------------------------------------
    In fact, head coach salaries in Power Five college football and 
men's basketball have increased more rapidly than head coach salaries 
in the NFL and NBA, relative to the rate of revenue growth in each 
environment. The median Power Five head football coach salary grew by 
87 percent from 2010-2017, at a faster pace than the median revenue 
increase of 58 percent for Power Five athletic departments during this 
period[4]. On the other hand, media reports suggest that NFL 
head coach salaries grew by approximately 50 percent during the same 
period, at a slower pace than the 70 percent growth of NFL revenue. In 
the NBA, revenue increased by over 90 percent from 2010-2017, but head 
coaching salaries are estimated to have grown less than 40 percent 
during this period[5]. Coaching salaries grow at a faster 
rate in college sports than in professional sports as more revenue 
becomes available to fund them.
---------------------------------------------------------------------------
    \[4]\ Salary information gathered from USA Today database and other 
publicly available sources. Analysis included public school data only, 
unless private school coaching salary information appeared on the Form 
990. Revenue data gathered from EADA reports and Knight Commission 
College Athletics Financial Database.
    \[5]\ NFL and NBA revenue gathered from statista.com. Salary 
information gathered from media reports. NFL and NBA salary information 
is not comprehensive, but is sufficient for the purposes of these 
general conclusions.

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Of course, another notable difference between college and pro is 
that paid professional athletes share in revenue increases through 
collective bargaining agreements, which means that a smaller portion of 
revenue growth remains to flow through to coaches, management, or 
ownership. But the non-profit structure of athletics departments also 
inherently facilitates salary growth, especially when negotiating 
contracts with star coaches. Athletics directors and presidents do not 
have the support of an owner who is incentivized to keep costs in check 
and provide the reassurance--and personal career insurance--to walk 
away from unfavorable deals.
    Instead, athletics directors and presidents know that they will be 
harshly criticized by vocal fans and influential benefactors if they 
fail to come to terms with a star coach, even if the terms being 
negotiated are not optimal for the school. Agents understand this 
dynamic, and have been able to negotiate college coaching contracts 
that are increasingly favorable as media rights revenue growth created 
a larger pool of available funding[6]. There is a more 
direct path from organizational income received to coaching salaries 
paid in non-profit, mission-driven college sports.
---------------------------------------------------------------------------
    \[6]\ Coaches are also incentivized to secure the best possible 
contract terms because schools are growing less patient about results. 
Available revenue makes it easier for schools to terminate coaches and 
endure switching costs.

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              These Decisions are Rational and Predictable
    From a behavioral economics perspective, financial decision-making 
in college sports has been perfectly rational within the structures of 
the current system. Aggressively reinvesting available revenue back 
into the competitive mission is sensible behavior that is aligned with 
the local interests of each school and its leadership. In some 
instances, there is clear evidence that a coach or team has made a 
transformational impact on the overall profile of a university, further 
justifying the decision to invest[7].
---------------------------------------------------------------------------
    \[7]\ For example, here is a brief note about the major 
institutional impact of successful football at Clemson and Alabama.
---------------------------------------------------------------------------
    The overall increase in spending on facilities and salaries in 
college sports is a natural byproduct of each school's mission-driven 
desire to compete in a zero-sum game, where leaders are incentivized to 
spend available revenue towards the competitive mission rather than 
make profits. Expense increases thus reflect systemic characteristics, 
and not ``flaws'' of involved individuals. College athletics decision-
makers are acting rationally and predictably in the current system, 
just like others would if confronted with similar industry 
characteristics.
                         Why Does This Matter?
    Aggressive expense growth in college athletics--that is 
structurally reinforced by its economic system--has created some of the 
most pressing challenges our industry faces. It has increased 
perceptions of unfairness for student-athletes and led to 
gerrymandering around the definition of amateurism in an effort to 
preserve the educational roots of college athletics. It has intensified 
financial pressure--ironically, given that we're in an era of 
unprecedented revenue growth throughout the industry--on athletics 
departments who aren't at the very top of the revenue production 
pyramid (i.e., the top quartile of Power Five programs) and placed 
these middle-income schools at an even greater competitive 
disadvantage. And, it has created long-term financial obligations that 
might turn into problematic exposures if revenue growth were to slow, 
stop, or reverse.
    Importantly, the focal point of this issue is not the resource 
imbalance between Power Five schools and Group of Five or FCS, but 
rather the financial and competitive challenges that arise due to the 
effects of relative expense growth within each competitive level. For 
example, even though Power Five schools have more revenue to deploy 
than others on an absolute basis, a majority of them remain under 
financial pressure trying to keep up with the small group of schools 
who set a high bar on expenses in search of every possible competitive 
advantage.
    Accordingly, even if setting aside financial sustainability 
considerations and viewing the issue only through the lens of 
competitive self-interest, a majority of Power Five schools ought to 
support a systemic solution among major conferences to control 
expenses. Such a system would not only mitigate challenges related to 
financial sustainability and public perception regarding spending, but 
would also enhance competitive opportunity for median schools by 
reducing the spending power advantage currently held by top-quartile 
revenue earners. In fact, successfully lobbying for a system of expense 
limits would be the most impactful action some schools could take to 
enhance their competitive self-interests.
                          What Should Be Done?
    To stimulate progress towards a solution, a critical mass of 
influencers must first recognize that the expense growth problem in 
college sports is structural in nature--i.e., it is not the result of 
``flawed institutional leadership'', nor can it be effectively 
addressed without systemic change. The next step of identifying 
feasible solutions requires an in-depth legal, economic, and political 
analysis that is beyond the scope of this particular article.
    Many people in our industry think about this problem often. 
Conventionally suggested methods--such as expense caps or other 
legislated changes about how resources are allocated or shared with 
central campus--are intuitive but complex to implement. Some solutions 
might present legal challenges, particularly around antitrust law, that 
could require a degree of regulatory involvement. Additionally, there 
would be political difficulties for some campus leaders to advocate for 
solutions that may be unpopular with a portion of their local 
constituents, a dynamic which would slow legislative progress in the 
member-driven governance model of the NCAA.
    However, even with the complexities involved, an invigorated focus 
on establishing mechanisms for expense control is worthwhile, and 
should be acted upon as an important priority for the sustainability of 
college sports. Aggressive expense growth, and its associated 
challenges, will continue unless there is systemic change.
    The economic system of major college sports uniquely combines the 
non-profit structure, zero-sum competition, and extraordinary revenue 
acceleration. It is a structural outlier in the American economic 
landscape, and should be managed as such from a legal and antitrust 
perspective. The uniqueness of its economic system calls for new 
thinking and innovative solutions if we seek to ensure the long-term 
health of college sports in the United States.

    *Undergraduate research assistants Mitch Iwahiro, Mia Motekaitis, 
and Tyler Mundy contributed to this article*

    Senator Moran. Mr. Bowlsby, thank you for your testimony. 
We now turn to Dr. Emmert.

           STATEMENT OF DR. MARK EMMERT, PRESIDENT, 
            NATIONAL COLLEGIATE ATHLETIC ASSOCIATION

    Dr. Emmert. Chairman Moran, Ranking Member Blumenthal, 
Chairman Wicker, and distinguished Members of the Subcommittee, 
thank you for this opportunity to appear before you today.
    My name is Mark Emmert and for almost 10 years, I have had 
the privilege of serving as President of the NCAA. We are an 
organization led by the colleges and universities of America, 
and we are dedicated to the wellbeing and success of student 
athletes on the field, in the classroom, and in life.
    College sports in our country provide student athletes with 
rewarding and a uniquely American experience. But while a 
record number of students play college sports today and more 
fans than ever enjoy watching them, there is also legitimate 
concerns being expressed about the fundamental fairness of our 
system. We share those concerns. We agree that college athletes 
should be allowed to benefit from their name, image, and 
likeness, commonly known as NIL, and we are in the process of 
identifying appropriate ways to do so.
    After several months of analysis by a working group of 
student athletes, presidents, commissioners, athletic 
directors, and faculty members, in October our board of 
Governors directed each of the NCAA's three divisions to begin 
immediately to consider how to modify the rules to permit 
student athletes to benefit financially from the use of their 
name, image, and likeness consistent with the values of 
intercollegiate athletics. Like Congress, our process is 
thoughtful and deliberate, and our member schools plan to make 
changes no later than January 2021.
    Unfortunately, constant litigation, litigation threats, and 
recent State legislative efforts to regulate aspects of college 
sports have complicated these efforts. These actions are 
doubtlessly the product of good intentions, but without proper 
guardrails and structure, some NIL proposals threaten to 
undermine the core values of college sports by allowing 
payments for NIL to serve as pay for play and potentially 
turning college athletes into employees.
    Also, as many have pointed out, a patchwork of different 
laws from various states will create an uneven and unfair 
playing field for our schools and college athletes. We simply 
do not believe our schools can effectively support students and 
host fair national competition if college athletics is pulled 
in various directions by State legislatures.
    It is critical that the administration of college sports be 
undertaken by the NCAA at a national level. We believe that the 
modernization efforts currently underway with respect to NIL 
will address the concerns about fairness, but we need to make 
sure that college sports operate consistent with two principles 
that are not always aligned. On the one hand, we want to allow 
student athletes to benefit from their NIL, like all college 
athletes. On the other hand, we want to preserve the unique 
character and quality of college sports that serves student 
athletes so well.
    And, Senators, we may need your help to achieve those 
goals.
    We have a history of making continual improvements to 
benefit college athletes. Our member schools now award nearly 
$3.5 billion in athletic scholarships each year, and more 
students are earning degrees than ever before, including many 
whose financial circumstances would have otherwise prevented 
them from attending college. The past decade has seen enormous 
enhancements in the support for student athletes, including in 
health care, nutritional programs, academic assistance, 
prevention of sexual violence, and covering the costs of 
attending school entirely.
    Today there are nearly a half a million NCAA athletes 
competing in 24 sports, three divisions, and on 19,000 
different teams. Regardless of their sport, their gender, their 
division, regardless of whether their school is big or small, 
rural or urban, public or private, we seek to support all 
students and help them be successful.
    We know we are not perfect. We know that the world is 
constantly changing and we want to change accordingly. I am 
confident that there is a path forward on this issue of NIL 
that preserves what we love about college sports while creating 
even greater opportunities for our students. That is what we 
are seeking, and that is what brings us here today, Mr. 
Chairman.
    Thank you again, and I look forward to your questions.
    [The prepared statement of Dr. Emmert follows:]

           Prepared Statement of Dr. Mark Emmert, President, 
                National Collegiate Athletic Association
    Chairman Moran, Ranking Member Blumenthal, and distinguished 
members of the Subcommittee, thank you for the opportunity to submit 
this testimony in connection with today's hearing. For almost ten years 
I have had the privilege of serving as the president of the NCAA, a 
school-led organization dedicated to the well-being and lifelong 
success of college athletes on the field, in the classroom, and in 
life. We appreciate the Subcommittee's attention to the important issue 
of name, image, and likeness (``NIL'') opportunities.
    College sports in America is at a critical juncture: while a record 
number of college athletes are benefiting from more opportunities than 
ever before, there is a legitimate concern about the fundamental 
fairness of our system. We share that concern, and NCAA schools and 
conferences are currently evaluating reforms to give athletes 
opportunities to take advantage of their own NILs. We believe that 
these efforts will address the concerns that have been raised about how 
to treat student-athletes equitably. But the process will take time, 
because we need to make sure that we operate consistent with two 
principles that are not always aligned. On the one hand, we want to 
allow opportunities for students to benefit from their NILs. On the 
other hand, we want to preserve the character and quality of the 
uniquely American phenomenon of college sports. And with ongoing serial 
litigation and NIL legislation pending in over half the states, we may 
need your help to accomplish this on a nationwide basis.
    I welcome the opportunity to speak to you today about our progress 
and goals, and I welcome the opportunity to hear from the Members of 
this Subcommittee. We greatly value the ongoing dialogue with you and 
look forward to the continued support of the Congress as we work toward 
a solution that meets the needs of student-athletes in a manner 
consistent with the long-held educational values of the NCAA, its 
schools and conferences, and the nearly 500,000 individuals who 
participate in college sports each year.
NCAA Background: Who We Are
    I would like to begin by briefly describing the mission of the 
NCAA. As the governing body for intercollegiate athletics, the NCAA 
prioritizes three important principles in providing opportunities for 
students: academic success, well-being, and fairness. While most people 
associate the NCAA primarily with college sports, the truth is that 
education is at the heart of our work. Each year, students from across 
the country and the world participate in sports they love. 16 percent 
are first-generation college students, and a similar number report that 
they would not have attended college if not for athletics. To make 
these opportunities possible, our member schools award nearly $3.5 
billion in athletic scholarships each year, including up to the cost of 
attendance. Athlete recruitment to attend a particular institution is 
one of the key principles that sets apart college sports from 
professional sports. This unique recruiting environment encourages 
student choice in where to attend college. No other model in sports is 
like it--not the Olympics nor professional sports.
    Student-athlete graduation rates are the highest ever, with 84 
percent earning their degrees. In Division I, nearly 9 in 10 student-
athletes are earning bachelor's degrees, their highest rate ever. 83 
percent of men's basketball players graduate, as well as 82 percent of 
Football Bowl Subdivision participants. And in particular, since 2002, 
the graduation rate for African-American men's basketball players has 
increased by 36 percentage points, and 79 percent of African-American 
student-athletes are earning their degrees. Historically, student-
athletes have graduated at rates higher than the rest of the student 
body.
    But I acknowledge that what happens off the field does not always 
garner as much attention as what happens on the field. When many people 
think of college sports, they think of March Madness, the College 
Football Playoff, or College Game Day. They think of the popularity and 
success of powerhouses like the University of Kansas men's and the 
University of Connecticut women's basketball teams. They see multi-
million dollar contracts, elaborate facilities, and Hollywood-style 
productions. But this is just a sliver of college sports. College 
sports is half a million student-athletes in 24 different sports spread 
across three divisions and 19,000 teams, most of which generate no 
revenue. College sports is a culture in which hundreds of thousands of 
fans feel connected through alma mater or geography and appreciate that 
the athletes are ``kids'' in pursuit of an education that will last 
them a lifetime. College sports is, and always has been, about students 
playing other students.
    College sports has always had commercial aspects, but its rules 
have consistently promoted education, opportunity, well-being, and 
fairness. While we are considering important and necessary changes to 
create additional monetary opportunities for student-athletes, any 
changes must take into consideration these core values.
NCAA Rules: The Legislative Process and Enforcement
    College sports as we know it is evolving. For over a hundred years, 
the NCAA's member schools have provided significant opportunities to 
tens of millions of athletes to obtain an education at this country's 
top colleges and universities. But recent increases in the popularity 
of NCAA-governed competition have brought greater interest in college 
sports, raising questions about how to ensure that this evolving system 
is inclusive, equitable, and fair.
    The internal balancing act between preservation and reform poses 
particular challenges in an organization with hundreds of diverse 
schools. Each of our schools brings a unique perspective to college 
sports, often informed by the size of the school and its athletic 
program, the NCAA division in which it competes, its mission, its 
geography, and myriad other factors. Each perspective is valuable 
individually, but the adoption of each, without harmonizing, would 
result in a chaotic college sports landscape. The NCAA's role reflects 
the reality that no one school has the expertise or resources to ensure 
that all opponents play by the same set of rules, both on and off the 
field. The voluntary agreement to a central governing system offers a 
whole that is greater than the sum of its parts.
    In its role as convener, the NCAA National Office oversees a 
ground-up, school-driven legislative process in which representatives 
serve on committees that propose rules, and schools ultimately decide 
which rules to adopt. Reflecting the diversity of our schools and 
conferences, each of the NCAA's three divisions develops and approves 
legislation unique to that division. Groups of presidents and 
chancellors lead each division through committees with regularly 
scheduled meetings. Once the NCAA schools and conferences establish a 
rule through the legislative process, responsibility for enforcing that 
rule on campus rests on both the institutions and the NCAA National 
Office. By mutual agreement, each school agrees to establish mechanisms 
to detect, prevent, and discourage rule violations, as well as 
protocols to self-report and cure any rule violations.
Student Equity in the NCAA Model: Recent Reforms
    As president of the NCAA, my role is to make sure that, during our 
rigorous rulemaking process, our schools and conferences are 
considering the best interests of students in a constantly evolving 
college sports landscape while keeping our values front and center. In 
recent years, we have undertaken initiatives or changed rules to 
promote better student well-being. For example, within the last few 
years the NCAA:

   Partnered with leading organizations to develop best 
        practices and training modules for coaches and administrators 
        in support of student-athlete mental well-being. The goal of 
        these resources is to encourage a culture in which reaching out 
        for mental health care is normal and expected.

   Paired with the U.S. Department of Defense to launch a 
        landmark alliance to enhance the safety of athletes and service 
        members by more accurately preventing, diagnosing, and treating 
        concussions. This alliance is undertaking the most 
        comprehensive longitudinal study of concussion and head impact 
        ever conducted, managed by the Concussion Assessment, Research, 
        and Education (``CARE'') Consortium. Twenty-six participating 
        universities enrolled their student-athletes in the study, and 
        the four military academies enrolled all cadets. The CARE 
        Consortium is continuing its work in a phase known as CARE 2.0, 
        featuring 40,000 participants.

   Funded and operated the Sport Science Institute (the 
        ``Institute''), which promotes health and safety through a 
        variety of initiatives, including research and training on 
        cardiac health, concussions, overuse injuries, drug testing, 
        mental health, nutrition and sleep, sexual violence prevention, 
        athletics healthcare administration, and data-driven decisions. 
        Last year, the Institute, in partnership with the NCAA Office 
        of Inclusion, released the second edition of a sexual violence 
        prevention tool kit that provides schools with appropriate 
        tools to support a safer campus environment. The new tool kit 
        was developed with input from leading professionals in the 
        field and aims to help NCAA schools reduce incidents of sexual 
        violence involving student-athletes and other college students, 
        and to respond appropriately when they occur. The Institute 
        also is collaborating with the most respected medical and 
        sports organizations in the country to promote research, 
        education, and best practices around cardiac health to reduce 
        injuries and death from heart conditions.

   Enhanced funding for an insurance policy covering all 
        college athletes who experience catastrophic injuries while 
        playing or practicing their sport--providing up to $20 million 
        in lifetime insurance benefits--and saw many of our schools 
        provide medical coverage for athletic-related injuries for at 
        least two years after a student-athlete graduates or leaves 
        school.

   Permitted any Division I institution to provide athletic 
        scholarships to the federally-defined cost of attendance, 
        without limits on duration.

   Enhanced student voice and vote by expanding the Division II 
        and III student representation to Division I, where they are 
        now voting participants at all levels of governance.

   Allowed college basketball players investigating their 
        professional options to be represented by an agent.

   Reformed the transfer rules to make it easier for students 
        to change schools.

   Required Division I schools to provide independent medical 
        care for student-athletes to determine medical management and 
        return-to-play decisions.

    These reforms demonstrate that the NCAA is ready and able to 
address emerging challenges to ensure that students are treated 
equitably and the essential character of the college sports is 
preserved. While we have more work to do, including on the issue of 
NILs (discussed below), I am confident that the NCAA, in partnership 
with Congress, has the tools to achieve a balance that minimizes 
unintended consequences.
Modernization of Name, Image, and Likeness Rules
    We have heard the concerns about the NCAA's current rules governing 
an athlete's ability to license his or her NIL for commercial purposes, 
and we recognize that changes need to be made. Currently, the NCAA 
schools and conferences are reviewing our rules and proposing changes. 
We are moving thoughtfully on this, and our membership plans to vote on 
those changes in January 2021.
Recent Developments around NIL
    Recognizing the need to further modernize our rules with respect to 
NILs, in October 2019 our Board of Governors directed each of the 
NCAA's three divisions to immediately begin considering how the 
relevant NCAA rules could be modified to permit student-athletes the 
opportunity to benefit financially from the use of their NILs 
consistent with the values of intercollegiate athletics--including and 
especially the principle of amateurism. This principle means that 
students are ``students first'' and not professional athletes who are 
paid for their athletic performance. What makes college sports 
different from and more popular than other sporting options (such as 
minor-league professional sports) is that college athletes are 
participating in a sport they love as part of their educational 
experience, because the reality is that most student-athletes will not 
play professional sports and thus need to rely on their education to 
support their success in life. Our schools and conferences' commitment 
to amateurism helps keep athletics programs and student-athletes 
integrated within the larger educational mission, promotes competitive 
balance among schools, and creates a fairer system for recruiting and 
retaining top talent. Without rules, the highest-resourced schools 
would use their greater financial resources to attract the most 
promising student-athletes, depriving other schools of the ability to 
build strong teams and decreasing fair competitive opportunities for 
many student-athletes.
    The Board of Governors' decision followed the work of our Federal 
and State Legislation Working Group (a group consisting of presidents, 
commissioners, athletics directors, administrators, and student-
athletes) in gathering input on NIL issues from current and former 
student-athletes, coaches, presidents, faculty, and commissioners 
across all three divisions in response to Federal and state legislators 
proposing NIL legislation. The Board directed these modernization 
efforts to take place in harmony with eight principles and guidelines.

   First, schools should assure that student-athletes are 
        treated similarly to non-athlete students unless a compelling 
        reason exists to differentiate.

   Second, schools should maintain the priorities of education 
        and the collegiate experience to provide opportunities for 
        student-athlete success.

   Third, schools should ensure rules are transparent, focused, 
        and enforceable and facilitate fair and balanced competition.

   Fourth, schools should make clear the distinction between 
        collegiate and professional opportunities.

   Fifth, schools should make clear that compensation for 
        athletics performance or participation is impermissible.

   Sixth, schools should reaffirm that student-athletes are 
        students first and not employees of the university.

   Seventh, schools should enhance principles of diversity, 
        inclusion, and gender equity.

   Eighth, schools should protect the recruiting environment 
        and prohibit inducements to select, remain at, or transfer to a 
        specific institution.

    The Working Group will continue to gather feedback from the schools 
and conferences and their student-athletes through April 2020 and will 
refine its recommendations. And the NCAA's divisions are working to 
create new NCAA bylaws reflecting divisional priorities. This effort is 
to be completed in January 2021.
    We have undertaken this modernization effort committed to balancing 
the vital need for the continuation of college sports with the need to 
adapt our rules to changing student-athlete environments. We want to 
improve the experience for our student-athletes, as well as fans, 
alumni, and student bodies. We remain committed to our student-athletes 
being students first, with emphasis on their education and the 
physical, mental, and social benefits to be derived from 
intercollegiate athletic competition.
    It is for this reason that, as part of this modernization effort, 
we will not consider any concepts that could be construed as payment 
for athletic play. We believe it is imperative to the success of 
college sports as both an integral component of the educational 
experience and a popular form of entertainment that we maintain a clear 
line of demarcation between college and professional sports. To do so, 
payment to student-athletes for use of their NILs should not be a 
substitute for or vehicle to deliver pay for athletic performance; nor 
should the payment serve as an inducement for a prospective or current 
student-athlete to select or remain at a particular NCAA school. 
Consequently, the NCAA has no intention of taking any action that is 
contrary to the position advocated by the NCAA or accepted by the Ninth 
Circuit with respect to the types of NIL payments that were at issue in 
the O'Bannon case decided a few years ago.
Need for National Uniformity
    Just as the NCAA has done in the past on issues involving student 
fairness, we believe that the modernization efforts currently underway 
with respect to NILs will address the concerns about equity. But given 
the current legislative landscape, uniformity will not be achieved 
without Federal support for our mission.
    The Subcommittee is aware of the dozens of proposals on NILs in 
state legislatures that, in our view, risk converting college sports 
into professional sports. While we understand the desire to assist 
student-athletes, we believe many of these ideas would be harmful to 
intercollegiate athletics and its many stakeholders, including the 
student-athletes. For instance, one state has passed legislation that 
effectively eliminates the distinction between college and professional 
sports. It allows payments for NILs to serve as pay for play and thus 
turns college athletes into employees. This law in particular, and 
others like it, threaten to undermine the mission of college sports 
within the context of higher education--that student-athletes are 
students first and choose to play a sport they love while earning a 
degree.
    In the short term, such legislation is creating confusion for 
current and future student-athletes, coaches, administrators, and 
campuses. Some of these laws would take effect as early as July 2020. 
If implemented, these laws would give some schools an unfair recruiting 
advantage and open the door to sponsorship arrangements being used as 
recruiting inducements. This would create a huge imbalance among 
schools and could lead to corruption in the recruiting process.
    As more states consider their own NIL legislation, it is clear that 
a patchwork of different laws from different states will make 
unattainable the goal of providing a fair and level playing field--let 
alone the essential requirement of a common playing field--for our 
schools and nearly half a million student-athletes nationwide. It is 
thus critical that the administration of college sports be supported at 
a national level. We believe that, given its role, the NCAA--informed 
by its schools and conferences--is best positioned to provide a uniform 
and fair NIL approach for all student-athletes on a national scale. But 
we cannot effectively achieve our goals if we are pulled in various and 
potentially inconsistent directions by state legislatures that may be 
focused on serving one set of constituents rather than serving the 
entire array of participants that the NCAA's own rulemaking processes 
are designed to serve.
Conclusion
    At the NCAA, we are proud of the role that intercollegiate 
athletics have played in creating opportunities for our Nation's 
student-athletes, especially those who might not otherwise have had the 
opportunity to pursue higher education. Over the last ten years, we 
have actively worked to drive much-needed change and address many of 
the concerns that surround intercollegiate athletics. Our membership is 
large and diverse with an equally large and diverse range of 
viewpoints. While this diversity can, at times, slow the pace of reform 
in our democratically governed association, we have made significant 
strides across a variety of areas and are actively working to modernize 
in the area of NIL opportunities. But that process takes time, and we 
may need Congress's support in helping maintain uniform standards in 
college sports. I appreciate the Subcommittee's attention to this issue 
and look forward to collaborating with this body to achieve these 
important goals. Thank you again and I look forward to your questions.

    Senator Moran. Thank you, Dr. Emmert.
    Now Dr. Girod.

STATEMENT OF DOUGLAS A. GIROD, CHANCELLOR, UNIVERSITY OF KANSAS

    Dr. Girod. Good morning, Chairman Wicker, Chairman Moran, 
Ranking Member Blumenthal, and members of the Subcommittee. 
Thank you for the opportunity to be here today.
    My name is Doug Girod. I am the Chancellor at the 
University of Kansas.
    The University of Kansas is a leading public research 
institution and a member of the Association of American 
Universities. We are also the proud sponsor of a robust NCAA 
Division I athletics program competing at the highest level of 
intercollegiate athletics.
    Senator Moran, sir, I would like to begin this morning by 
thanking you for your outreach, not just to the University of 
Kansas and to our student athletes, but also to the Big 12 
Conference and to the NCAA, and really all the constituents who 
care deeply about the model of collegiate athletics.
    You have repeatedly stated in our conversations that we are 
in a fact-finding mission here to try and understand better how 
name, image, and likeness may impact collegiate athletics. And 
honestly, we too are in that fact-finding mode. And we join you 
and your colleagues on this subcommittee, as well as a growing 
voice of Members in the House of Representatives, to seek a 
working solution to the challenges brought by the patchwork of 
recently enacted and pending State legislation with varying 
degrees of name, image, and likeness provisions. And it is 
clear to me that the imperative of national consistency, 
fairness, and equity requires a Federal solution. Like all 
Division I universities, we compete in 50 states, and really 
only a Federal approach that creates a level playing field for 
competing athletes and universities makes sense.
    KU acknowledges that it is a new day in college athletics, 
and if there is an opportunity for student athletes to earn 
value from their name, image, and likeness, we should support 
them and provide reasonable guardrails that will protect them 
and the integrity of the game while maintaining successful 
educationally based athletic programs across the country.
    There is no doubt this is a complicated policy matter and 
none of us has the answers at the moment, which is why it is 
important we are having these discussions. But no matter what 
solutions we pursue, I think there are two ironclad principles 
that should inform us every step of the way. First, we must 
continue to prioritize what is in the best interest and welfare 
of our student athletes; and second, we must preserve and 
protect the collegiate athletic model.
    So as this process moves forward, we must not forget that 
more than 98 percent of student athletes do not turn 
professional in their sport after they graduate or have 
significant opportunity to earn income from name, image, and 
likeness, yet they benefit greatly from the education and the 
resources and the development that they have access to as 
student athletes. So we must be cautious not to risk losing 
what is so valuable for the 98 percent while addressing the 
specific needs for those blessed to take their athletic talents 
to the professional level. And additionally, we must preserve 
access for first-generation students and under-represented 
minorities to an education through sports and continue to 
enhance gender equity in compliance with Title IX. The bottom 
line is there are ways to allow student athletes to benefit 
from name, image, and likeness while maintaining the benefits 
of the collegiate athletic model.
    Additionally, these actions that we contemplate today on 
name, image, and likeness have the potential to transcend 
athletics and really impact every aspect of the university 
mission from education and service to research. For better or 
worse, a major athletics department at a university like KU is 
inextricably linked to the entire university model in 
everything that we do.
    For example, athletics is important in student recruitment, 
particularly for a Midwestern university like ours that is 
highly dependent on out-of-state student enrollment.
    Athletics is crucial to our engagement with alumni and 
donors, whose support is essential to our most important 
academic missions and research initiatives.
    And athletics enhances our work to improve access to 
education and campus diversity by enrolling students from 
diverse backgrounds.
    As a university chancellor, one of my responsibilities is 
to support more opportunities for our students while they are 
enrolled at our university, whether that is an internship, an 
opportunity to research in a company, or study abroad. And most 
certainly today I want to support this new opportunity for 
student athletes who have the potential to earn money while 
competing at our institution to do so.
    And right now student athletes, parents, alumni, and 
supporters of our universities are counting on us to do this 
fairly and correctly. Forming a comprehensive national plan for 
name, image, and likeness is a challenge and it will take some 
time to implement. But together, we can do this together.
    So let us partner with the universities, Congress, our 
governing association, our conferences, and all our key 
stakeholders to create a solution that ensures the best 
interests of our student athletes are front and center while 
also preserving the current collegiate model to the benefit of 
all of our student athletes.
    Thank you.
    [The prepared statement of Dr. Girod follows:]

   Prepared Statement of Douglas A. Girod, Chancellor, University of 
                                 Kansas
    Good morning, Chairman Moran, Ranking Member Blumenthal, and 
Members of the Subcommittee. My name is Doug Girod, and I am the 
Chancellor of the University of Kansas.
    The University of Kansas is a leading public research institution 
and a member of the Association of American Universities. We also are 
the proud sponsor of a robust NCAA Division I athletics program 
competing at the highest levels of intercollegiate athletics.
    Thank you for the opportunity to appear in front of you today to 
discuss the impact of recently passed and pending state legislation 
around the country related to ``Name, Image and Likeness.''
    Senator Moran, I would like to begin by thanking you for your 
outreach during the past several months, not just to the University of 
Kansas, our student-athletes, the Big 12 Conference and to the NCAA--
but to the community of stakeholders who hold dearly the value of 
collegiate athletic programs.
    You have repeatedly stated that you are in a ``fact-finding'' mode 
to learn how the Name, Image and Likeness issue may impact college 
athletics. And honestly, we, too, are in a fact-finding mode. We join 
you and your colleagues on this Subcommittee and a growing voice of 
Members of the House of Representatives to seek a working solution to 
the challenges brought by the patchwork of recently enacted (and 
pending) state legislation with varying degrees of Name, Image and 
Likeness provisions. It is clear to me that the imperative of national 
consistency, fairness, and equity requires a Federal solution. Like all 
Division I universities, we compete across 50 states. Therefore, only a 
Federal approach that creates a level playing field for competing 
athletes and universities makes sense.
    KU acknowledges that it is a new day in college athletics, and if 
there is an opportunity for student-athletes to earn value from their 
Name, Image and Likeness, we should support them and provide reasonable 
guardrails that will protect them and the integrity of the game while 
maintaining successful educationally based athletic programs across the 
country.
    This is a complicated policy matter, and none of us has all of the 
answers. That's why it is important that we are having these 
discussions. But no matter what solutions we pursue, there are two 
ironclad principles that should inform us every step of the way: (1) we 
must continue to prioritize what is in the best interests and welfare 
of our student-athletes; and (2) we must preserve and protect the 
collegiate athletic model.
    As this process moves forward, we must not forget that more than 98 
percent of student-athletes do not turn professional in their sport 
after graduation or have significant opportunity to earn income from 
NIL, yet they benefit greatly from the education and resources they 
access as student-athletes. We must be cautious not to risk losing what 
is so valuable for the 98 percent while addressing the specific needs 
of those blessed to take their athletic talents to the professional 
level. Additionally, we must preserve access for first-generation 
students and underrepresented minorities to an education through sports 
and continue to enhance gender equality in compliance with Title IX. 
The bottom line is, there are ways to allow student-athletes to benefit 
from Name, Image and Likeness while maintaining the benefits of the 
collegiate athletic model.
    Additionally, Senators, please keep in mind the following: The 
actions we take on NIL have the potential to transcend athletics and 
impact every aspect of our university mission--from education, to 
service, to research. For better or worse, a major athletics department 
at a university like KU is inextricably linked with the entire 
university model and everything we do. For example, athletics is 
important to student recruitment, especially for Midwestern 
universities that rely on out-of-state student enrollment. Athletics is 
crucial to our engagement with donors, whose support is essential to 
our most important academic and research initiatives. And athletics 
enhances our work to improve access to education and campus diversity 
by enrolling students from diverse backgrounds. Again, the decisions we 
make on Name, Image and Likeness have implications that extend beyond 
the athletic playing field and into virtually every aspect of what we 
do as universities.
    As a university chancellor, one of my responsibilities is to 
support opportunities for students while they are enrolled at KU--
whether that is an internship, a chance to study abroad, or a chance to 
do research with a company in our region. Today, I want to support this 
new opportunity for those student-athletes who have the potential to 
earn money while competing at our institution. Like all new 
initiatives, there will be hurdles, and we will learn from them and 
adapt. But let's work together to do what is right and support our 
student-athletes in these new opportunities.
    Right now, students, student-athletes, parents, alumni and 
supporters of our universities are counting on us to do this fairly and 
correctly. Forming a comprehensive national plan for Name, Image and 
Likeness is a challenge that will take some time to implement. But we 
can do it together.
    So let us partner--universities, Congress, our governing 
association and conferences, and other key stakeholders--to create a 
solution that ensures the interests of our student-athletes are front 
and center while also preserving the current collegiate athletic model 
to the benefit of all student-athletes.
    Thank you.

    Senator Moran. Dr. Girod, thank you very much.
    Mr. Huma, welcome.

STATEMENT OF RAMOGI HUMA, EXECUTIVE DIRECTOR, NATIONAL COLLEGE 
                      PLAYERS ASSOCIATION

    Mr. Huma. Thank you. Good morning. My name is Ramogi Huma. 
I am a former UCLA football player and the Executive Director 
of the National College Players Association, the NCPA, a 
501(c)(3) nonprofit advocacy group comprised of over 20,000 
current and former college athletes nationwide.
    First, I would like to thank Chairman Wicker, Chairman 
Moran, and Ranking Member Blumenthal, and members of the 
Subcommittee for allowing me to testify today.
    College sports is a $14 billion per year commercial 
industry where multibillion dollar TV revenues fuel 
multimillion dollar salaries for coaches, administrators, and 
commissioners. The NCAA's basketball tournament alone generates 
over $1 billion per year. Under Armour is paying UCLA $280 
million to require UCLA players to serve as walking billboards 
to advertise its apparel.
    Meanwhile, the NCAA denies players third party compensation 
claiming it is to protect players from forces of 
commercialization. This double standard has inflicted serious 
economic harm on countless college athletes, many of whom are 
from low-income backgrounds.
    The NCPA is a co-sponsor of California SB 206, known as the 
Fair Pay to Play Act, and is currently assisting 14 of an 
estimated 28 states that are pursuing similar legislation.
    In short, a wave of bipartisan action is sweeping across 
this Nation in response to longstanding, unjust NCAA rules that 
deny college athletes economic freedoms afforded to other 
students and Americans.
    As part of my written testimony for today, I submitted an 
updated white paper on this issue that was published last 
Friday, and I will cover some of the key advocacy positions 
included in that document.
    First, Federal legislation is not necessary for positive 
reform in this area, but there are some reasonable provisions 
or guardrails that could be positive.
    For instance, Congress could prevent third-party 
compensation offers used as inducements to high school recruits 
and college transfers to attend a particular college.
    It could also ensure that colleges themselves do not 
coordinate third-party athlete compensation.
    Similar to some of the state guardrails, they should be 
enacted directly through law and not through any NCAA antitrust 
exemption.
    If Congress acts, it should also uphold the freedom for 
players to secure independent representation, which 28 states 
are currently pursuing. Congress should not grant the NCAA and 
its colleges the power to certify athlete agents and other 
representation because this representation would also be 
expected to represent players in disputes with the NCAA and 
colleges.
    Also, current NCAA rules are discriminatory as they only 
allow elite men's basketball players the ability to secure 
agents while denying the same right to all female athletes. 
States are capable of setting athlete agent standards and many 
have already adopted such standards into law.
    Additionally, the NCAA conferences and colleges should not 
be allowed to represent players in name, image, and likeness 
compensation agreements.
    And Congress should not appoint any entity to control 
college athletes' group licensing rights, which the NCAA stated 
in December they will be asking Congress to do. The NCAA 
conferences and colleges are already taking advantage of 
players in this area, selling players' rights and refusing to 
give them any compensation for it.
    Again, some guardrails can be helpful, but there are 
serious concerns about the potential for even well-intentioned 
guardrails to serve as hammers, hammers that can harm college 
athletes' economic freedoms being unlocked by the states. Some 
have proposed banning third-party compensation agreements from 
people and companies affiliated with players' colleges. This 
would mean players could not get a deal with Nike if Nike 
sponsored their college. They could not get a deal with 
countless companies that contract with their colleges. If a fan 
happens to be an alumni or donor, pays admission to a player 
autograph signing, the fan, player, and college could be in 
violation of Federal law and be subject to punishments.
    Yet, these are precisely the opportunities that states are 
seeking to open up to college athletes. The states are 
realizing that proposals that would prohibit or cap college 
athletes' opportunity in the name of competitive equity are 
especially problematic largely because competitive equity does 
not exist under current NCAA rules. In fact, after 6 years of 
legal scrutiny in the O'Bannon v. NCAA name, image, and 
likeness antitrust lawsuit, the Federal courts came to this 
exact conclusion in their rulings. Colleges with the most 
revenues and wealthiest boosters have the largest recruiting 
budgets, have the best coaches, and build the best facilities. 
In turn, they get the best recruits, they win the most games, 
and score the richest TV deals allowing them to continue their 
dominance.
    Importantly, if NCAA sports was truly committed to pursuing 
competitive equity and recruiting and winning, they would ban 
booster payments to athletic programs and teams would share TV 
revenue equally like they do in other multibillion sports 
leagues. College athletes should not be forced to sacrifice 
their economic freedom and rights so the NCAA and its colleges 
can pretend that competitive equity exists while doing nothing 
about huge disparities in booster donations and athletic 
revenues.
    Finally, the State legislation in question will have no 
effect on players' employee status or Title IX because payments 
would be from third parties not colleges. If Congress does act, 
it should advance college athlete freedoms being pursued by the 
states not roll them back.
    Thank you.
    [The prepared statement of Mr. Huma follows:]

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
    
                      Name, Image, and Likeness: 
           The Players' Plan for Economic Liberty and Rights

                  National College Players Association

                Author: Ramogi Huma, Executive Director

                            February 7, 2020

Overwhelming Support for College Athlete NIL Pay
    California made history when it approved SB 206, legislation that 
will allow California college athletes the right to secure legal and 
professional representation as well as earn compensation for use of 
their name, image, and likeness (NIL) beginning on January 1, 2023. The 
bill was voted into law with unanimous bipartisan support: 73-0 in the 
Assembly and 39-0 in the Senate.
    The National College Players Association (NCPA) was a co-sponsor of 
SB 206 and is working with thirteen states of the estimated twenty 
states that are pursuing similar legislation at the time of this 
writing. Lawmakers in these states express sincere opposition to the 
NCAA's prohibition on such rights due to the harm it inflicts on 
athletes in their states.
    Florida state lawmaker Representative Chip LaMarca who introduced a 
college athlete NIL stated, ``Not allowing college athletes to 
participate in the same free market opportunities that drive our 
institutions runs counter to the American principles of free enterprise 
and equal rights.''
    Missouri state Representative Nick Schroer (R) introduced similar 
legislation and stated, ``The NCAA has long banned student athletes 
from obtaining compensation from their own name and likeness. This ban 
violates every capitalistic principle of free markets which has made 
this country exactly what it is today. While student athletes are 
barred from making money off of their image and likeness, the NCAA 
continues to cash in as they siphon money away from the very student 
athletes the organization should be protecting.'' \1\
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    \1\ https://www.stltoday.com/news/local/education/anger-with-ncaa-
could-speed-measure-to-pay-missouri-college/article_2da211ed-3d06-5bd5-
a96b-d13b0467b3db.html
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    After introducing a Pennsylvania NIL compensation bill, state 
lawmaker Dan Miller (D) said, ``Athletes are forced to give up their 
rights and economic freedom while the colleges make hundreds of 
millions of dollars off of their talent and likeness. This bill would 
help to balance the scales. . .'' \2\
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    \2\ https://www.cbsnews.com/news/fair-pay-to-play-act-pennsylvania-
lawmakers-seek-compensation-college-student-athletes-2019-10-01/
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    In addition, there is bipartisan interest in Federal college 
athlete NIL legislation among members of the United States Senate and 
House of Representatives.
    US Senator Mitt Romney (R): ``We're coming to help these young 
athletes in the future, and the athletes of today, make sure that they 
don't have to sacrifice their time and sacrifice, in many cases, their 
bodies without being fairly compensated.'' \3\
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    \3\ https://www.sportingnews.com/us/ncaa-basketball/news/mitt-
romney-warns-ncaa-about-compensating-athletes-were-coming-for-you/
mguqknsv5e3o1p19p3dtwi8ut
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    US Senator Chris Murphy (D): ``College athletes are being used as 
commodities to make money for the NCAA, colleges and corporations, 
while not being compensated for the work they do, nor given the 
appropriate health care and academic opportunities they deserve.'' \4\
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    \4\ https://www.athleticbusiness.com/college/senator-s-report-
calls-for-ncaa-to-overhaul-its-health-care.html
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    Congressman Mark Walker (R): ``Signing on with a university, if 
you're a student-athlete, should not be (a) moratorium on your rights 
as an individual. This is the time and the moment to be able to push 
back and defend the rights of these young adults.'' \5\
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    \5\ https://www.si.com/college/2019/03/07/ncaa-student-athletes-
profit-name-use-bill-introduced-mark-walker
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    The NCPA is engaging in talks with various members of Congress to 
help ensure any Federal legislation advances these protections 
nationwide without rolling back provisions sought by states.
    Finally, polls show that 66 percent of Americans \6\ and 80 percent 
of regular students \7\ support allowing college athletes the ability 
to earn compensation for use of their NIL. Also, 52 percent of 
Americans support providing college athletes a share of millions of 
dollars in TV revenue generated by football and basketball players. 
While the NCAA opposes such legislation, it also ranks among 
institutions with the lowest public approval--only 14 percent of 
Americans have a favorable opinion of the NCAA and its colleges.\6\
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    \6\ https://apnews.com/3ab2b10f53e2c7f6a16b25ccaf49eb1a
    \7\ https://collegepulse.com/2019/09/college-students-say-the-ncaa-
takes-advantage-of-athletes.html
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Declarations
   1.  College athletes' talents, time, and physical sacrifices are 
        central to fueling a highly commercialized, $14 billion per 
        year industry that pays coaches and administrators multimillion 
        salaries and allows apparel companies to spend millions of 
        dollars to require college athletes to advertise their logos on 
        their bodies.
   2.  The commercial use of college athletes' NIL rights is not 
        necessary to field school-based athletics and non-revenue 
        sports; it is an optional, lucrative activity for which 
        athletes should have the freedom to be fairly compensated by 
        3rd parties.
      a.  If large commercial revenues were required for colleges to 
            field athletic programs and their nonrevenue sports, NCAA 
            Division II and III would not exist.
   3.  College athletes should have the same economic liberties and 
        rights afforded to other students and Americans.
   4.  The NCAA's athlete NIL compensation ban infringes upon college 
        athletes' 1st Amendment Rights. The NCAA prohibits college 
        athletes from receiving compensation for engaging in highly 
        protected forms of speech on their own time such as religious 
        or creative expression.
      a.  The NCAA would punish a player receiving compensation for 
            giving a speech or writing about his or her experience as a 
            Christian college athlete. There are many players who are 
            members of The Fellowship of Christian athletes and other 
            organizations who are not allowed to pursue such 
            opportunities.
      b.  Central Florida football player Donald De La Haye lost his 
            NCAA eligibility for receiving compensation from his 
            YouTube channel.\8\
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    \8\ https://www.latimes.com/sports/more/la-sp-ucf-kicker-
ineligible-youtube-20170801-story.html
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   5.  NCAA rules prohibiting college athlete compensation for use of 
        NIL rights do not bring forth competitive equity and do not 
        justify denying college athletes equal rights and economic 
        freedom.
      a.  After six years of deliberations in O'Bannon v. NCAA, federal 
            courts determined that the NCAA's prohibition of players' 
            NIL compensation did not foster competitive equity because 
            various colleges have numerous other competitive advantages 
            and disadvantages that the NCAA permits (recruiting 
            budgets, quality of coaches/facilities, etc.)
   6.  Allowing successful female athletes (i.e., Olympians) to enter 
        into commercial activities can raise the profile, popularity, 
        and value of women's college sports.
   7.  The NCAA, athletic conferences, and their member colleges should 
        not be allowed to represent college athletes in NIL commercial 
        agreements. These entities have a conflict of interest and they 
        are currently taking advantage of such powers. The NCAA has 
        stated publicly that it wants the U.S. Congress to grant it the 
        ability to represent players' group licensing rights, yet this 
        conflicted, forced athlete representation is among the 
        injustices that states are seeking to eradicate.\9\ \10\ It is 
        not necessary for the government to appoint a college group 
        licensing entity, but if it did, it should not be the NCAA, 
        conferences, or colleges.
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    \9\ https://www.aspeninstitute.org/events/future-of-college-sports-
governments-role-in-athlete-pay/
    \10\ https://www.usatoday.com/story/sports/ncaaf/2019/12/17/ncaas-
mark-emmert-meets-mitt-romney-chris-murphy-reform/2675473001/
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      a.  NCAA sports has been a bad actor in this area. NCAA rules 
            restricting college athlete compensation have been ruled 
            illegal multiple times in Federal courts (O'Bannon v. NCAA 
            & Alston v. NCAA) and have harmed countless college 
            athletes.
      b.  The O'Bannon v. NCAA ruling found that the NCAA, conferences, 
            and schools sell valuable players group licensing rights to 
            3rd parties but give players $0 in return.
      c.  The NCAA chose to end the popular EA sports video games 
            rather than allow college athletes, whose NILs were used in 
            the games, to receive any portion of revenue.
   8.  College athletes' NIL representation should not be nationalized/
        operated by the government.
   9.  Sports agents, financial advisors, and other individuals and 
        entities facilitating college athlete compensation for use of 
        their name, image, or likeness rights and athletics reputation 
        should be subject to standards to help prevent fraudulent and 
        negligent activity that can harm college athletes.
  10.  The NCAA, athletic conferences, and their member institutions 
        should not govern certification of college athlete 
        representation.
      a.  College athletes must have representation certified by an 
            entity that does not have a conflict of interest. College 
            athlete representation must have the freedom and 
            qualifications to represent college athletes in 
            negotiations with 3rd parties as well as during any NIL 
            rights disputes with colleges, conferences, and the NCAA.
      b.  The NCAA has demonstrated ongoing opposition and poor 
            judgment regarding college athlete representation. For 
            instance, it denies all female athletes the ability to 
            secure a sports agent while giving this right to select 
            men's basketball players.
  11.  College athletes should receive financial skills development.
      a.  While NCAA sports leaders point to a lack of college 
            athletes' financial skills as a reason to deny athletes 
            economic freedom, but NCAA sports is responsible for 
            failing to use its robust educational infrastructure and 
            some of its commercial revenue to address any lack of 
            financial development skills among athletes.
  12.  NIL college athlete compensation should not be locked in a trust 
        fund but, if it was, the NCAA, athletic conferences, and their 
        colleges should not administer it.
      a.  The NCAA did a poor job of administering the 2008 White v. 
            NCAA antitrust settlement that was supposed to provide $10 
            million to players to complete their degree and continue 
            their education. It did not do enough to inform players of 
            available funds and returned $4.3 million dollars in unused 
            funds to its colleges.\11\
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    \11\ http://www.ncaa.org/about/resources/media-center/news/six-
schools-selected-grant-program-pilot
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Group Licensing
    In addition to individual commercial opportunities that can benefit 
an individual athlete, group licensing would provide even revenue 
distributions among each athlete on each team or set of teams included 
in a group license. When it comes to group licenses, each player is 
equally valuable. For instance, a star quarterback cannot participate 
in a televised game and would have virtually no value to a sports 
videogame maker if his teammates--including backups who standby to fill 
in for injured and tired starters, did not participate. For this 
reason, each individual in the group is equally valuable.
    Federal court antitrust rulings recognize that a group licensing 
market for college athletes' NIL rights exists and declared the 
following:

  1.  NCAA's prohibition on athlete name, image, and likeness 
        compensation violated Federal antitrust law and deprives 
        college athletes of compensation that they would otherwise 
        receive.

  2.  If the NCAA did not have a prohibition on athlete compensation 
        for use of their name, image, and likeness, athletes would be 
        able to create and sell group licenses;

  3.  3rd parties purchase groups of athletes' name, image, and 
        likeness rights for commercial purposes including for use in 
        live game telecasts, sports video games, game rebroadcasts, 
        advertisements, and other archival footage to ensure they have 
        the legal right to use every athlete in a group of 
        athletes.\12\
---------------------------------------------------------------------------
    \12\ O'Bannon v. Nat'l Collegiate Athletic Ass'n, 802 F.3d 1049 
(9th. Cir. 2015)

    California SB 206 and other similar legislation will allow players 
to secure representation to create, bundle, and sell group licenses. 
College athletes should be informed and empowered to make decisions 
regarding group licensing distributions.
Title IX & Athlete Representation Certification
    College athlete NIL compensation from 3rd parties is not subject to 
Title IX.
    The NCAA's policy to allow men's basketball players to sign with 
sports agents while denying female athletes the same rights sets up 
NCAA colleges for possible violations of Title IX and the 14th 
Amendment's Equal Protection Clause.\13\
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    \13\ https://www.si.com/college/2018/08/09/ncaa-agents-student-
athlete-one-and-done-nba-draft
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    There is a reasonable desire to have standards for college athlete 
representation. Such standards can help protect college athletes 
against fraudulent and negligent activity. Inadequate representation 
can also lead to the loss of college athletes' eligibility.
    For instance, there are questions surrounding a new online platform 
that allows fans to incentivize recruits to play for a particular 
college. Fans are allowed to pledge money by position and college. The 
platform, StudentPlayer.com, claims it has already raised $100,000 from 
both named and anonymous donors to make offers to 800 athletes at 42 
different colleges. It states that such activity is made legal due to 
emerging state legislation. However, no such state legislation is 
currently in effect, and some states like California have laws that 
likely prohibit such activity. The NCAA may punish a recruit if he or 
she publicly indicates such inducements as a factor in selecting a 
college team. Many states already have standards for athlete agents and 
are capable of addressing this area.
Employee Status
    The NCAA argument that 3rd party college athlete NIL compensation 
will change players' employee status and lead to unionization is false. 
Such NIL payments would not come from the colleges and, therefore, 
would not be a factor in considering employee status of college 
athletes. If the NCAA were correct, bipartisan support for college 
athlete NIL compensation would not be taking place among states and in 
Congress.
State Legislative Reform Model Summary
    (See Attachment 1 for The NCPA's Model State Legislation)

   Allow college athletes to receive NIL compensation from 3rd 
        parties.

   Allow college athletes to secure professional and legal 
        representation.

   Avoid language prohibiting NCAA and conference punishments. 
        The NCAA has signaled it will use that language to pursue a 
        legal challenge based on the Dormant Commerce Clause. While 
        such a legal challenge would be weak, it could delay justice 
        for college athletes and unnecessarily tax states' Attorneys 
        General resources. States can enforce their own state antitrust 
        laws to protect their players and colleges from NCAA group 
        boycotts and other illegal cartel punishments. States may want 
        to include their athlete NIL legislation under their antitrust 
        law for this reason. In addition, and most importantly, it will 
        not be practical for the NCAA to expel so many colleges from 
        the numerous states that are likely to adopt similar laws.

   July 1, 2020 effective date

   *States should leave out language regarding conference and 
        athletic association penalties. The vast number of states 
        pursuing similar legislation makes clear that such penalties 
        against large numbers of colleges are unrealistic.
Limits of State Legislation
    Some have expressed a desire to try to make college athlete 
compensation more equal. Any restriction on an individual athlete's NIL 
compensation would be unjust since other students, citizens, and 
athletes in other multibillion-dollar sports industries are not subject 
to such limits. It could also put that state's colleges at a 
competitive disadvantage.
    Contrary to NCAA assertions, state NIL laws will not destroy 
college sports. The NCAA claims it is complicated to find a way to 
enact NIL compensation without allowing certain colleges an advantage 
over others. This is a smokescreen since such advantages and 
disadvantages exist under current NCAA rules. For instance, the SEC's 
television contract is much higher than ``Group of 5'' conferences' 
television contracts. This allows the SEC to maintain a much larger 
recruiting budget, hire better coaches, and build top of the line 
facilities. In turn, these advantages allow SEC colleges to secure the 
best football recruits, win the most games, and position itself for 
even higher television contracts in the future.
Federal Legislative Reform
    Federal reform that advances college athletes' freedoms and rights 
being pursued by many states would represent positive reform, but 
Congressional action to eliminate these college athlete protections 
would undermine states' rights and harm all college athletes. It is not 
necessary for Congress to get involved but, if it does, it should do so 
in a way that does not cement unjust and exploitative NCAA rules into 
law.
    The NCPA's Federal reform model would be similar NCPA's State Model 
Legislation with the following additional provision and considerations:
Additional Provision:
  1.  Congress should void all current NCAA punishments and 
        investigations related to college athlete compensation and 
        financial extra benefits. NCAA economic rules leave many 
        college athletes desperate and vulnerable. Players, coaches, 
        and colleges should not be punished for violating unjust and 
        illegal NCAA rules--many of which would be eliminated upon the 
        implementation of athlete NIL compensation legislation.
Considerations:
  1.  If Congress is truly looking for ways to make college sports 
        ``more equal'', it would be remiss in not considering equal 
        media rights revenue sharing across all colleges themselves. 
        The NCPA is neutral on this, but notions of fairness should not 
        be used to limit players' ability to receive NIL compensation. 
        Perhaps a more powerful action would be for colleges to follow 
        revenue sharing models of other multibillion sports leagues 
        such as the NFL.
  2.  Congress should not buy into NCAA rhetoric and limit college 
        athlete NIL compensation. Other multibillion sports leagues 
        have no such limits and function just fine.
  3.  Federal legislation attempting to prohibit college boosters from 
        arranging NIL endorsements for current college athletes in 
        hopes of making college sports more equal would be seriously 
        flawed. Booster donations are currently used by colleges to 
        pursue an advantage by luring the best recruits via enhanced 
        recruiting budgets, hiring better coaches, building flashy 
        facilities, etc. A booster ban would inflict economic harm to 
        college athletes and do nothing to make recruiting more equal 
        since booster donations would continue to provide some colleges 
        advantages over others. Federal legislation hoping to 
        neutralize boosters' affect on competitive balance would have 
        to ban all booster donations to colleges, a proposition for 
        which no stakeholder has voiced support.
     Alternatively, Federal legislation could take a more reasonable 
        approach by prohibiting NIL opportunities explicitly aimed at 
        recruits as inducements to attend a particular college. 
        Prohibiting colleges from coordinating 3rd party NIL 
        opportunities for their athletes could also be a more measured 
        approach. That provision would be similar to other sports 
        leagues that do not allow teams to coordinate player 
        endorsement deals as a way to circumvent the salary cap. 
        Notably, these leagues do not attempt to prevent players from 
        entering endorsement deals with local businesses run by fans of 
        the player's team. These industries operate just fine, and 
        these leagues are not seeking Federal legislation attempting to 
        stop this practice due to any perceived or actual advantage or 
        disadvantage this may give any team.
A Federal NIL Trust Fund
    Some have expressed an interest in holding college athletes' NIL 
compensation in a trust fund until their eligibility expires. The NCPA 
does not support compensation being held in this way because it would 
continue the economic hardships college athletes face during the 
duration of their college career. Additionally, college athletes would 
be more susceptible to turning to high interest credit cards and high 
interest loans to pay for expenses throughout college. In short, they 
would likely take out loans against what they hoped to eventually 
receive in a future NIL trust distribution. Tying up college athletes' 
compensation in a trust would be a significant disadvantage to a state 
since California and (most likely) other states would have no such 
limitation. However, it would be viable via Federal legislation.
    Any NIL trust fund established by Federal legislation should hold 
only a small portion of NIL revenue. For instance, California, 
Louisiana, New Mexico, and New York laws protecting child entertainers 
from being taken advantage of by their guardians require only 15 
percent of their gross earnings to be placed into a blocked trust 
account.\14\ It should be noted that these entertainers gain access to 
these accounts upon turning 18 years old, and virtually all college 
athletes are at least 18 years old. The NCPA believes young adults 
should be empowered to properly handle their earnings through financial 
skills development rather than receiving a delayed payment. However, if 
Federal legislation requiring a trust fund is enacted, college athletes 
should be allowed to generate interest via investments (i.e., stock 
market) to earn more revenue.
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    \14\ https://www.sagaftra.org/membership-benefits/young-performers/
coogan-law
---------------------------------------------------------------------------
Summary
    NCAA sports imposes second-class citizenship on college athletes in 
its pursuit to monopolize all commercial dollars generated from college 
athletes' NIL rights. NCAA colleges are complicit since they 
collectively adopt and maintain NCAA rules. The NCAA and its colleges 
are making a mockery of Federal and state antitrust laws meant to 
protect free enterprise and have shown a disregard for players' 1st 
Amendment rights.
    As the NCAA and its colleges fight to keep the status quo by 
lobbying state and Federal lawmakers and putting out vague media 
statements with empty promises, two questions should be asked 
persistently. Why should those who break laws be allowed to design new 
laws? Why should those who victimize college athletes be appointed 
stewards of college athlete well-being?
    The NCAA and its colleges' assertion that college athlete NIL 
reform has been too complicated to address is further evidence that 
they are both unwilling and ill-equipped to do so. Reform is not too 
complicated to achieve, and justice for college athletes should not be 
delayed any longer.
References
    Berkowitz, S. (2019, December 17). Two U.S. senators appear to be 
taking aim at NCAA even beyond image, likeness controversy. 
USAToday.com. Retrieved from https://www.usatoday.com/story/sports/
ncaaf/2019/12/17/ncaas-mark-emmert-meets-mitt-romney-chris-murphy-
reform/2675473001/
    College Pulse. (2019, September 11). 8 in 10 college students say 
the NCAA takes advantage of athletes. Collegepulse.com. Retrieved from 
https://collegepulse.com/2019/09/college-students-say-the-ncaa-takes-
advantage-of-athletes.html
    Fritz, B. (2019, December). Senator's report urges NCAA to overhaul 
its health care. Athleticbusiness.com. Retrieved from https://
www.athleticbusiness.com/college/senator-s-report-calls-for-ncaa-to-
overhaul-its-health-care.html
    Gooden, C. (2019, December 19). Anger with NCAA could speed measure 
to pay Missouri college athletes. STLToday.com. Retrieved from https://
www.stltoday.com
/news/local/education/anger-with-ncaa-could-speed-measure-to-pay-
missouri-college/article_2da211ed-3d06-5bd5-a96b-d13b0467b3db.html
    Lawrence, M. (2012, December 11). Six schools selected for grant 
program pilot. NCAA.org. http://www.ncaa.org/about/resources/media-
center/news/six-schools-selected-grant-program-pilot
    McCann, M. (2018, August 8). What's really to come from the NCAA's 
student-athlete agent announcement? SI.com. Retrieved from https://
www.si.com/college/2018/08/09/ncaa-agents-student-athlete-one-and-done-
nba-draft
    McMillen, B. (2019, October 17). Sen. Mitt Romney warns about 
compensating athletes: ``We're coming for you''. Sportingnews.com. 
Retrieved from https://www.sportingnews.com/us/ncaa-basketball/news/
mitt-romney-warns-ncaa-about-compensating-athletes-were-coming-for-you/
mguqknsv5e3o1p19p3dtwi8ut
    O'Bannon v. NCAA O'Bannon v. Nat'l Collegiate Athletic Ass'n, 802 
F.3d 1049 (9th. Cir. 2015). Retrieved from http://cdn.ca9.uscourts.gov/
datastore/opinions/2015/09/30/14-16601.pdf
    O'Donnell, N. (2019, October 1). Pennsylvania lawmakers working on 
``Fair Pay to Play Act'' for college athletes. CBSNews.com. Retrieved 
from https://www.cbsnews.com/news/fair-pay-to-play-act-pennsylvania-
lawmakers-seek-compensation-college-student-athletes-2019-10-01/
    Russo, R. D. (2020, January 6). AP-NORC poll: 66 percent favor 
endorsement money for NCAA athletes. APnews.com. Retrieved from https:/
/apnews.com/3ab2b10f53e2c7f6a16b25ccaf49eb1a
    SAG-AFTRA. (2020). Coogan Law. SAGAFTRA.org. Retrieved from https:/
/www.sagaftra.org/membership-benefits/young-performers/coogan-law
    Solomon, J. (2019, December 17). Future of college sports: 
Government's role in athlete pay: Interview with Mark Emmert. 
Aspeninstitute.org. Retrieved from https://www.aspeninstitute.org/
events/future-of-college-sports-governments-role-in-athlete-pay/
    Schilken, C. (2017, August 1). Central Florida kicker Donald De La 
Haye loses his NCAA eligibility because of his YouTube videos. 
LATimes.com. Retrieved from https://www.latimes.com/sports/more/la-sp-
ucf-kicker-ineligible-youtube-20170801-story.html
    West, J. (2019, March 7). Congressman to introduce bill to let NCAA 
athletes profit from use of their name, likeness. SI.com. Retrieved 
from https://www.si.com/college/2019/03/07/ncaa-student-athletes-
profit-name-use-bill-introduced-mark-walker
                              Attachment 1
Model Legislation--Name, Image, Likeness Pay
SECTION 1. Declarations
  1.  The Legislature seeks to help ensure college athletes have equal 
        rights and economic freedoms afforded to all students and 
        residents in the state of ______________.
  2.  The Legislature recognizes the disproportionate negative impact 
        that economic and legal restrictions have on African American 
        and female college athletes.
  3.  The commercial exploitation of college athletes' name, image, and 
        likeness rights is not required for school-based athletics; it 
        is an optional, lucrative activity for which athletes should be 
        fairly compensated by 3rd parties.
  4.  College sports is a $14 billion dollar industry with millionaire 
        coaches and lucrative apparel deals that require college 
        athletes to advertise for commercial interests.
  5.  Rules prohibiting college athlete compensation for use of name, 
        image, and likeness rights, or athletics reputation do not 
        bring forth competitive equity and cannot justify denying 
        college athletes equal rights and economic freedom.
  6.  State legislatures have adopted or are pursuing legislation, to 
        grant college athletes the right to secure professional 
        representation, which includes their own group licensing 
        representation; and the right to earn compensation for use of 
        their name, image, and likeness beginning as early as July 1, 
        2020.
  7.  Federal court rulings recognize that a group licensing market for 
        college athletes' name, image, and likeness rights exists and 
        declared the following:
      a.  The NCAA, conferences, and schools sell valuable players 
            group licensing rights to 3rd parties, but give players $0 
            in return.
      b.  NCAA's prohibition on athlete name, image, and likeness 
            compensation violated Federal antitrust law and deprives 
            college athletes of compensation that they would otherwise 
            receive.
      c.  If the NCAA did not have a prohibition on athlete 
            compensation for use of their name, image, and likeness, 
            athletes would be able to create and sell group licenses;
      d.  3rd parties purchase groups of athletes' name, image, and 
            likeness rights for commercial purposes including for use 
            in live game telecasts, sports video games, game 
            rebroadcasts, advertisements, and other archival footage to 
            ensure they have the legal right to use every athlete in a 
            group of athletes.
  8.  Sports agents, financial advisors, and individuals and entities 
        facilitating college athlete compensation for use of their 
        name, image, or likeness rights and athletics reputation should 
        be subject to certification standards to help prevent 
        fraudulent and negligent activity that can harm college 
        athletes.
  9.  College athletes' representation should be independent from 
        athletics associations, athletic conferences, and colleges to 
        avoid a conflict of interest.
SECTION 2. Definitions
    ``Athlete'' means an individual that participates or participated 
in intercollegiate sport for a postsecondary educational institution 
located in the state. An individual's participation in a college 
intramural sport or in a professional sport outside of intercollegiate 
athletics does not apply.
    ``Athletic association'' means an entity with athletics governance 
authority and is comprised of postsecondary educational institutions 
and athletic conferences.
    ``Athletic conference'' means an entity and/or a collaboration of 
entities such as the autonomy conferences that has/have athletics 
governance authority, is a member of an athletic association, and has 
members comprised of and/or competes against postsecondary educational 
institutions.
    ``Certification'' means the process of developing enforcing 
professional and legal policies and practices.
    ``Group'' means three or more athletes from the same sport.
    ``Group licensing'' means an agreement or agreements to allow a 3rd 
party the right to use the name, image, and likeness rights and 
athletic reputation of a group of athletes.
    ``Postsecondary educational institution'' means any campus of a 
public or a private postsecondary educational institution.
    ``3rd party'' means any individual or entity other than a 
postsecondary educational institution, athletic conference, or athletic 
association.
SECTION 3. Resolution
    The state of ____________ requests that any Federal legislation 
regarding this act respect and permit _____________ college athletes' 
rights, protections, and other provisions included in this legislation.
SECTION 4. Legislation
Part A.
  1.  A postsecondary educational institution shall not uphold any 
        rule, requirement, standard, or other limitation that prevents 
        a student of that institution from fully participating in 
        intercollegiate athletics without penalty and earning 
        compensation as a result of the use of the student's name, 
        image, or likeness rights, or athletic reputation. Earning 
        compensation from the use of a student's name, image, or 
        likeness rights, or athletic reputation shall not affect a 
        student's grant-in-aid or stipend eligibility, amount, 
        duration, or renewal
  2.  For purposes of this section, a grant-in aid and/or a stipend 
        from a postsecondary educational institution in which a student 
        is enrolled is not compensation for use of a student's name, 
        image, and likeness rights, or athletic reputation; and a 
        grant-in-aid or stipend shall not be revoked or reduced as a 
        result of a student earning compensation pursuant to this 
        section.
  3.  A postsecondary educational institution shall not interfere with 
        or prevent a ______________ student from fully participating in 
        intercollegiate athletics for obtaining representation 
        unaffiliated with a postsecondary educational institution or 
        its partners in relation to contracts or legal matters, 
        including, but not limited to athlete agents, financial 
        advisors, or legal representation provided by attorneys.
  4.  A college athlete shall not enter into an apparel, equipment, or 
        beverage contract providing compensation to the athlete for use 
        of the athlete's name, image, or likeness rights, or athletic 
        reputation which requires a student to display a sponsor's 
        apparel, equipment, or beverage or otherwise advertises for the 
        sponsor during official team activities if such provisions are 
        in conflict with a provision of the athlete's team contract.
  5.  A team contract of a postsecondary educational institution's 
        athletic program shall not prevent a college athlete from 
        receiving compensation for using the athlete's name, image, or 
        likeness rights, or athletic reputation for a commercial 
        purpose when the athlete is not engaged in official, mandatory 
        team activities that are recorded in writing and made publicly 
        available. Such team activities may not exceed up to 20 hours 
        per week during the season and up to 8 hours per week during 
        the off-season.
  6.  An athlete with remaining intercollegiate athletics eligibility 
        who enters into a contract providing compensation to the 
        athlete for use of the athlete's name, image, or likeness 
        rights, or athletics reputation shall disclose the full 
        contract to an official of the institution who is designated by 
        the institution. The institution and its designated official 
        shall not disclose terms of an athlete's contract that the 
        athlete and/or the athlete's legal representation deems to be a 
        trade secret and/or non-disclosable.
  7.  An institution asserting a conflict described in Part A. 6. shall 
        disclose to the athlete and the athlete's legal representation, 
        if applicable, the full contract they assert to be in conflict. 
        The college athlete and/or the college athlete's legal 
        representative shall not disclose terms of an institution's 
        contract that the institution deems to be a trade secret and/or 
        non-disclosable.
Part B.
  1.  Postsecondary educational institutions that enter into commercial 
        agreements that directly or indirectly require the use of a 
        college athlete's name, image, and likeness must conduct a 
        financial development program of up to 15 hours in duration 
        once per year.
      a.  The financial development program cannot include any 
            marketing, advertising, referral, or solicitation by 
            providers of financial products or services.
  2.  Athlete attorney representation shall be by persons licensed by 
        the state.
Part C.
  1.  This legislation shall apply only to contracts entered into, 
        modified, or renewed on or after the enactment of this section.
  2.  Athletes have the right to pursue private action against 3rd 
        parties who violate this act through superior court, through a 
        civil action for injunctive relief or money damages, or both.
      a.  The court shall award court costs and reasonable 
            reimbursement for attorneys' fees to the prevailing 
            plaintiffs in an action brought against a violator of this 
            legislation.
  3.  Athletes and state or local prosecutors seeking to prosecute 
        violators shall not be deprived of any protections provided 
        under ______________ law with respect to a controversy that 
        arises in ______________; shall have the right to adjudication 
        in ______________ a claim that arises in ______________.
  4.  The provisions of this chapter are severable. If any provision of 
        this chapter or its application is held invalid, that 
        invalidity shall not affect other provisions or applications 
        that can be given effect without the invalid provision or 
        application.
  5.  Legal settlements cannot permit noncompliance with this act.
  6.  This chapter shall apply to any applicable agreement or contract 
        newly entered into, renewed, modified, or extended on or after 
        July 1, 2020. Such agreements or contracts include but are not 
        limited to the National Letter of Intent, an athlete's 
        financial aid agreement, commercial contracts in the athlete 
        group licensing market, and athletic conference or athletic 
        association rules or bylaws.
    ***States may want to make clear that violations of this 
legislation is a per se violation of their state antitrust law and 
should consider granting the Attorney General some discretion for 
penalties.
                                 ______
                                 
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
                                 

    Senator Moran. Thank you for your testimony.
    Mr. Spencer.

              STATEMENT OF KENDALL SPENCER, CHAIR,

              STUDENT-ATHLETE ADVISORY COMMITTEE,

            NATIONAL COLLEGIATE ATHLETIC ASSOCIATION

    Mr. Spencer. Chairman Wicker, Chairman Moran, and Ranking 
Member Blumenthal, thank you for inviting me to speak on behalf 
of the hundreds of thousands of men and women who represent the 
current, former, and future student athletes, some of whom are 
sitting behind me today.
    My name is Kendall Spencer. As a Division I track and field 
student athlete at the University of New Mexico, I have won 
national championships, secured multiple All-American honors 
both academically and athletically, and represented my country 
abroad in international competition.
    Today my advocacy on behalf of student athletes starts with 
the Student-Athlete Advisory Committee. In this capacity, I led 
my group to numerous policy decisions that were set to benefit 
the student athlete welfare that eventually led to my 
appointment as the first student athlete to serve on the NCAA's 
Board of Directors.
    Today I am a third-year law student at Georgetown 
University where I am a technology, law, and policy scholar 
focusing on privacy, election security, and the role that 
emerging technologies play in shaping this current digital 
economy. I continue to train competitively while in law school 
with my eyes firmly set on making the 2020 Olympic team.
    In this testimony, I will discuss the name, image, and 
likeness through the lens of today's modern student athlete, 
giving strict emphasis to the technological framework that we 
live in today.
    Now, as many of you know, NIL has the right to publicity 
which, as a result of our Federalist system, is determined by 
the extent of its recognition at the State level. Consequently, 
we left with a patchwork of State laws designed to regulate 
NIL.
    Members of the Committee, let me illustrate for you what 
this actually looks like. It looks like a 17-year-old high 
school student athlete choosing between two institutions not 
because of the educational value but rather because of which 
state has the fewest restrictions on the financial benefit they 
can gain from their NIL. If within intercollegiate athletics 
and as a nation we value education, this is not something that 
we should allow to happen so freely.
    Now, today's discussion is not for me to comment on the 
strain this places on interstate commerce or to describe the 
burden it places on institutions that conduct business 
throughout the country, but I can illustrate the glaring danger 
looming in the shadows for student athletes.
    In all of these conversations, we must understand that 
today's student athlete lives in this innovation economy driven 
by social media influencers and emerging technology platforms. 
A student athlete's NIL, however, is inextricably tethered to 
technology, and this makes the value and protection of this 
right incredibly complex. The social media landscape that all 
student athletes today live in is grossly under-regulated 
leaving many of the users without protection when their NIL is 
misappropriated. Additionally, a student athlete will have to 
monitor the use of his or her potential misappropriation and 
ensure that he or she is compliant with this myriad of State 
laws that may or may not recognize these rights.
    The assumption that student athletes, many of whom already 
spend upwards of 60 hours a week on athletically related 
activities, will have the time to monitor the use of their NIL 
in order to protect their profit is absurd. The notion of 
expecting student athletes to potentially hire an agent to 
manage their brand on top of perhaps an attorney to ensure 
compliance with this patchwork of State laws is unreasonable. 
And this expectation that community members will continue to be 
able to support student athletes at such a high level without 
fear of violating a student athlete?s NIL agreement is absurd.
    Members of the Committee, this is not just a matter of 
protecting the student athlete experience. This is about 
maintaining the welfare of students who happen to be athletes.
    So what is the student athlete experience? It is the 
flashcards we take into the ice bath. It is the textbooks that 
we take with us on long road trips to games. It is the term 
papers that my teammates reviewed for me when we were in the 
hotel rooms.
    It is in this moment that we see the distinction between 
college sports and the professional leagues. This is the moment 
that we see the value in protecting the student athlete 
experience and more importantly the welfare of all student 
athletes. Here we recognize the role of education.
    Members of the Committee, when it comes to protecting the 
welfare and the success of student athletes, it is not enough 
to get it done. We have to get it right. And this means 
allowing the membership and the institutions that help guide us 
to our educational goals the appropriate time to be able to 
design a structure where this current innovation economy can 
fit into.
    So in conclusion, I would implore each of you to consider 
the impact this would have on the incredible value of the 
student athlete experience, what it means for intercollegiate 
athletics, and more importantly, the world that student 
athletes live in today. Thank you.
    [The prepared statement of Mr. Spencer follows:]

Prepared Statement of Kendall Spencer, Chair, Student-Athlete Advisory 
          Committee, National Collegiate Athletic Association
    Mr. Chairman and Members of the Committee,

    My name is Kendall Spencer. Thank you for the opportunity to offer 
testimony on behalf of the hundreds of thousands of current and former 
student-athletes on this important issue of Name, Image, and Likeness.
    For more than a decade, my efforts--as they relate to student-
athlete advocacy--focused on highlighting today's student-athlete 
experience, and making sure that the impact on our welfare is not 
misplaced in these discussions around emerging issues. Contrary to 
popular belief, student-athletes live considerably active lives beyond 
what the public streams on today's media platforms. In order to protect 
the lives and experiences of these individuals, we must all ensure that 
these conversations reflect the critical impact to relevant components 
such as education, time demands, and gender equity. The complexity 
surrounding the commercial use of Name, Image and Likeness is not 
exclusive to intercollegiate athletics, but reflects the broader 
societal issues that modern America faces today.
    Today I am currently a third-year law student at Georgetown 
University Law Center, where I am a Technology Law and Policy Scholar 
focusing on Privacy and Election Security. Throughout law school, I 
have continued to train competitively as a Track and Field athlete with 
the expectation of competing in the 2020 Olympic Games.
    Before making my way to Washington D.C., I was a Track and Field 
student-athlete at the University of New Mexico. During my time on 
campus I competed in the Olympic Trials, was a National Champion, and a 
Two-Time Division I NCAA All-American, ultimately leading to me 
securing a silver medal for my country while competing in Mexico City.
    As a student-athlete I was a member of the Student-Athlete Advisory 
Committee (SAAC) at the institutional, conference, and national levels, 
charged with representing the voice of student-athletes on all issues 
from time demands to pay for play. I served as the SAAC chair at the 
national level for a number of years and became the first student-
athlete to serve on the NCAA's Board of Directors.
    In this testimony, I will explain the framework that today's modern 
student-athlete lives in, as well as the value of the student-athlete 
experience, with emphasis on the practical application of Name, Image, 
and Likeness within intercollegiate athletics.
                       NAME, IMAGE, AND LIKENESS
    Name, Image, and Likeness (NIL) are smaller but complex elements 
comprising the Right of Publicity. This right, in all of its complexity 
and confusion, is the right of any person to control the commercial use 
of their identity by others without their consent. Despite widespread 
acknowledgement as a core right granted to every individual, there is 
no single right to publicity. A consequence of our federalist system in 
the U.S. is that the recognition of publicity rights is highly 
decentralized, with each state responsible for its standards for 
recognizing human identity--or what is left of it.
    Contrary to today's discussion around NIL and the concept of this 
right to publicity, the first cases delving into this complex topic 
were rooted in privacy issues. Most of the causes of action around NIL 
involve a variety of infractions leading to the conclusion that a 
person was unduly harmed due to the commercial use of their identity 
without their consent. To date, there is no uniform model for the right 
to publicity to serve as a one-size fits all example suitable to cross 
state lines. This creates a porous system designed to protect human 
identity rather than a patch work of state laws.
    Discussions surrounding the issues of commercial use of a person's 
Name, Image, and Likeness is not a new conversation; however, the 
discussion has continued to evolve into a popular issue with regard to 
intercollegiate athletics and the professionalization of student-
athletes.
I. TODAY'S MODERN STUDENT-ATHLETE LIVES IN A WORLD DOMINATED BY 
        POWERFUL ACTORS THAT DID NOT EXIST UNTIL RECENTLY.
    Student-athletes today live in a world that is highly complex, both 
operationally and logistically. The day to day activities of athletes 
on campus involve a sequence of tasks, responsibilities, and hurdles 
shaping the lives of young students in ways that transcend their on-
the-field activity. Beyond the typical balancing act student-athletes 
take up when they commit to an institution looms the societal framework 
we all subject ourselves to in today's modern culture. In today's 
social construct--driven by digital communication and emerging 
technology platforms--student-athletes live lives that often go 
unnoticed to today's fan and proponents who continue to call for the 
recognition of Name, Image, and Likeness as a form of compensation.
    Laws and regulatory frameworks providing societal boundaries for 
Americans do not exist in a vacuum, rather they too manifest themselves 
through the context of the times they exist in. Student-athletes are 
also subject to these factors. As a result, the lives of student-
athletes, and the impact of Name, Image, and Likeness within the 
constructs of intercollegiate athletics, cannot be discussed as if they 
exist in a world without technology. While our rights themselves may 
not change over the years, the way we express these rights is 
fundamentally different. As long as the U.S. values innovation and 
technological advancement, this will continue to be an emerging issue 
within American public policy.
A. ROLE OF TECHNOLOGY FOR THE MODERN STUDENT-ATHLETE
    The lives of today's student-athletes--like most of the nation--are 
in fact dominated by the proliferation of emerging technologies. 
Technology serves a dual purpose in athletics that connects student-
athlete to institutional resources (online lectures, and study 
materials) on and off the field. Emerging tools in the tech space also 
connect fans with the players they love to support and cheer for. 
Athletic contests can be streamed, recorded, duplicated, and used for 
educational purposes presenting enormous value to the student-athlete. 
While the innovative benefits in the form of efficiency and access are 
graciously accepted, a regulatory structure around technology and its 
constructs has been difficult to create at both the state and Federal 
level given the rapid growth within those spaces.
B. STUDENT-ATHLETES AND THE INNOVATION ECONOMY DRIVEN BY 
        SOCIAL MEDIA
    This innovation economy is the idea that entrepreneurs, social 
media influencers, and other content creators (as it relates to 
technology) are really the ones who are helping to drive economic 
growth in today's society. Furthermore, it refers to this idea that 
most anyone has access to the potential for economic success but is not 
guaranteed any benefit for the efforts they are putting in. The 
innovation economy puts into context the world that today's student-
athletes live in, how they interact with each other, and, more 
importantly, their ability to create any narrative that they choose.
    Social media is a vehicle today's student-athlete uses to navigate 
this new innovation economy which allows influencers, entrepreneurs and 
technology authorities to become key drivers for economic growth. When 
people talk about how we exercise some of the core rights granted to us 
in the Constitution, such as free speech, social media is the way that 
today's student-athletes and youth are expressing themselves. Around 
the world, companies see this and, in recognition of its utility to 
reach their target audience and potential consumers of products they 
sell, have begun to redirect advertising to social media and social 
media influencers. The market around social media influencers is one of 
the engines powering the debate around potential financial success via 
Name, Image, and Likeness. One of the many concerns regarding this idea 
is the brand development, significant effort, and extraordinary talent 
or niche needed to capitalize on this opportunity. These necessary 
characteristics are not retained by all student-athletes however. While 
some influencers can receive a very lucrative living from social media 
by leveraging their network, the majority of users do not, and will 
never have access to that type of brand influence. More importantly, 
social media exemplifies one of the many question marks around building 
a regulatory structure involving emerging technologies.
    To date, social media platforms still lack significant regulation--
the current state of financial success when it comes to social media 
platforms, such as YouTube, Instagram, Facebook, and Twitter, are tied 
to the number of subscribers, views, or likes on a picture that any 
individual might receive on their post. At any given time, however, the 
individuals who run these platforms can remove any one of these 
features without permission from the user or the Federal government. 
Unfortunately, this would also remove one of the sources of revenue 
streams for social media users.
    Social media gives us access to the world around us. It allows us 
(student-athletes) to connect with fans, supporters, individuals we 
admire and, more importantly, the community. Despite the role social 
media plays in everyone's lives, most platforms are grossly 
misunderstood and often allow for the Name, Image, and Likeness of any 
of its users to be misappropriated without consequence. A diligent 
review of terms and conditions for many of these platforms would 
illustrate this fact.
C. REGULATORY FRAMEWORK IMPACTING THE STUDENT-ATHLETE 
        EXPERIENCE
    The Right of publicity, personality rights, and Name, Image, and 
Likeness are all phrases often used interchangeably. As with other 
rights, however, the way we exercise this right through technology 
complicates already difficult issues. Because we live in a data driven 
society, one of the floating issues is how we define Name, Image, and 
Likeness. In particular, what is likeness and how can we arrive at a 
definition that is both fair and inclusive?
    Generally, everyone has a right to control the commercial use of 
their Name, Image, and Likeness; however, the value of exercising this 
right is not necessarily worth the efforts needed to protect it. Not 
everyone's commercial use of their Name, Image, or Likeness will be a 
lucrative endeavor. Not all student-athletes attribute the same value 
to their Name, Image, and Likeness. Unfortunately, this publicity right 
has become a subject of popular debate in the U.S. but not for the 
reasons that it should be.
    For the student-athlete, Name, Image, and Likeness has been thrown 
around by the public in an attempt to justify the collegiate model for 
amateurism. It has also been used as a justification for creating a 
free market in intercollegiate athletics despite the negative impacts 
that it would have on the majority of student-athletes. Within the 
current discussion on this topic, conversations fixate around the NCAA 
rather than the welfare of the student-athlete. This unfortunate truth 
reflects the bitter reality that this current debate is placing 
student-athletes in the crosshairs of a war between sports fans seeking 
access to content, and the NCAA looking to provide a workable model 
that prioritizes educational opportunity and academic stability to all 
student-athletes.
    NIL, like the right to publicity, also has important implications 
regarding privacy rights. The right of publicity and the right to 
privacy are inextricably connected. Some of the basic privacy rights we 
enjoy today evolved out of disputes regarding the right to publicity. 
Many privacy rights, for the most part, are, like publicity rights, 
states' rights, which means they exist within the framework that states 
choose to recognize them in. This is why we talk about privacy laws as 
a patchwork of regulations governing protections within this country. 
One of the causes for concern with regard to privacy issues and NIL is 
the close relationship with technology. States are struggling to wrap 
their heads around privacy, how to protect it, and what to do next. The 
patchwork of privacy laws at the state level are leading to constant 
petitions to the Federal government for a broad sweeping piece of 
legislation that will govern privacy protections in the U.S.
    Like many other rights, the right of privacy exists through the 
constructs that student-athletes interact with--social media, a 
platform that exists without regulation. What's important is that 
privacy is intertwined through all of this. Privacy rights were created 
in an environment that did not foresee the changes in society or the 
regulatory structures that we see today. It also did not, or could not, 
predict the growing and emerging role that technology is playing in 
today's social structure. Furthermore, the U.S. reliance on digital 
communications are also heavily impacted by right to privacy--this 
includes streaming (music, television, athletic contests). Legally, in 
intercollegiate athletics, administrators at the institutional 
conference and national level need to understand how these rights and 
regulations operate in order to avoid liability when it comes to 
college athletics.
II. UNDERSTANDING THE STUDENT-ATHLETE EXPERIENCE AND ITS VALUE IS A 
        CRITICAL COMPONENT TO ASSESSING THE IMPACT OF COMPENSATION 
        THROUGH NAME, IMAGE, AND LIKENESS ON THE MODERN STUDENT-
        ATHLETE.
    The recognition of Name, Image, and Likeness as a form of 
compensation for student-athletes substantially impacts the student-
athlete's experience: a critical component to intercollegiate athletics 
and the overall value of participating in college sports. The 
recognition of value and the substantial role that the student-athlete 
experience plays within intercollegiate athletics, and society, was one 
of the many reasons that the Student-Athlete Advisory Committee (SAAC) 
exists and continues to have a voice throughout the membership process. 
One of the many functions carried out by SAAC at both institutional and 
national levels involves highlighting current changes to regulatory, 
political, academic, and athletic frameworks, and analyzing their 
impact on the student-athlete experience. In this regard, the work done 
by SAAC at every level operates as more than a sounding board for 
institutional reform, but instead stands as a principled voice of the 
primary stakeholders in all of these discussions.
A. THE STUDENT-ATHLETE VOICE IS MANIFESTED THROUGH THE 
        STUDENT-ATHLETE ADVISORY COMMITTEES PRESENT ON EVERY COLLEGE 
        CAMPUS
    I served on SAAC at the institutional level, I chaired the Mountain 
West conference SAAC, and eventually became chair of the National 
Division I SAAC. This ultimately led to my appointment as the first 
student-athlete to serve on the NCAA's Board of Directors. National 
SAAC creates the opportunity for student-athletes to involve themselves 
in NCAA's governance, policy making, and transparency efforts as they 
relate to all sports. At the national level, all of the committees 
within the membership, including the Olympic committees that govern USA 
Olympic team selection, receive at least one liaison from the SAAC. In 
this capacity, I have served on the Competitive Safe-Guards and Medical 
Aspects of Sports Committee tasked with creating and reviewing many of 
the changes to concussion protocol and mental health resources. I also 
served as a liaison to the Olympic Sports Committee. This was an 
incredibly important role as it represents the fact that many of our 
outstanding performers at the Olympic Games are current, or former, 
student-athletes. How we deal with issues at the collegiate level 
impacts decisions made elsewhere.
B. THE VALUE OF THE STUDENT-ATHLETE EXPERIENCE
    The student-athlete experience is what gives intercollegiate 
athletics, and many of our college campuses, life. It's why colleges 
sponsor athletics. It's the reason student-athletes have higher 
graduation rates than the regular student body. And it's the motivating 
factor powering student-athletes to give their time, energy, and 
attention to four years of discipline, training and success beyond the 
field. The student-athlete experience encompasses components operating 
beyond the touchdown passes, goals scored, and perfectly executed 
technique. The way we engage with our academic advisors, our student 
body, our coaches, our training staff, and perhaps most importantly, 
our teammates and surrounding community, are all relevant factors that 
impact the student-athlete experience.
    When we arrive on campus, many of us will have an opportunity to 
compete in athletic contests at the institutional level. Some of us 
will have an opportunity to compete at the conference level. But very 
few student-athletes will have the privilege of competing for a 
national title or championship at the national level. Regardless of 
whether you are a third string quarterback, or Division I national 
champion, most student-athletes will find that upon graduation it's not 
the trophies or the on-the-field successes that they take with them 
after graduation. Instead, it's the lessons that come from 
participation in intercollegiate athletics that transcend every 
victory, every loss or injury, and any gold medal that a student-
athlete may experience at one point in time or another. The few 
individuals outside of intercollegiate athletics that actually choose 
to recognize the value of the student-athlete experience and the 
valuable lessons we take away from our experiences usually hear about 
time management skills, discipline, and teamwork. But what you don't 
hear about are things like selflessness, patience, perseverance, and 
comradery. These are themes of our experience that connect us to our 
universities, our communities, and the people that support us beyond 
the talents that we display on the field. These are the interactions 
that student-athletes hold onto.
    Unfortunately, when it comes to the current debates around Name, 
Image, and Likeness, the intercollegiate model for amateurism, and the 
overall value that student-athletes tap into by being a student-
athlete, the majority of individuals leave the student-athlete 
experience out of the equation. This does a great disservice to the 
student-athlete, the institution, and society as a whole because it is 
an experience that makes the intercollegiate athletic model in the 
United States as important as it is. It's also the reason why comparing 
athletes at the professional level with student-athletes at the 
collegiate level is so incredibly dangerous. On balance, the public 
bases this comparison off of what they see. They base it off of the 
performances viewed on ESPN, and the incredible value that 
entertainment brings to their screens. But most viewers don't see the 
experiences we share with each other before or after the game. They 
don't see the flash cards we take into the ice bath. They don't see the 
textbooks that we bring on the bus ride to away games. And for athletes 
like myself, they'll never understand the value of surrounding 
ourselves with likeminded individuals connected by an ambition for 
success on and off the field.
    Because the public typically only pays attention to the 2 percent 
of student-athletes at the elite level, they often fail to consider the 
hundreds of thousands of student-athletes who will go pro in something 
other than their sport. Soccer players who win conference championships 
still go to med school; football players who choose not to participate 
in the draft become professors; and track and field athletes, like 
myself, continue to train for the Olympics while balancing law school. 
But more importantly, student-athletes that participate in 
intercollegiate athletics have an opportunity of exposure that no other 
organization or institution has been able to provide. Student-athletes 
come to these great academic institutions and leave as scholars. The 
same individuals that come to these universities thinking their value 
in society is one dimensional, receive mentorship and guidance that 
enable them to leave with master's degrees and other fantastic 
credentials. Some of these very same student-athletes are probably in 
this room today.
C. KEY FACTORS SHAPING THE STUDENT-ATHLETE EXPERIENCE
                              Time Demands
    The student-athlete experience is tied to a variety of different 
factors. This includes, but is not limited to, time demands, team 
dynamics, and community engagement. The majority of fans think that our 
college experience revolves around the games they see on weekends, when 
in reality we are spending copious amounts of time in, and outside of, 
the training room. In 2014, myself, and the rest of my colleagues on 
Division I SAAC, launched the largest time demands survey in the 
country, which ultimately lead to many of the playing time policies and 
other athletic procedures that you see today. Unsurprisingly, we found 
that student-athletes were spending upwards of 50-60 hours per week on 
athletically related activities.
    On top of these activities, student-athletes are also expected to 
be full time students and to rise to the highest levels of academic 
excellence. The presence of these standards and expectations are what 
lead to the successes off the field that student-athletes are known 
for, many of whom say they would not change it for the world. Name, 
Image, and Likeness complicates this fragile dynamic of time demands. 
NIL is only valuable if it can be controlled and protected. In order 
for a student-athlete to capitalize on this dynamic, her NIL will need 
to be monitored at every level: academic, institutional, conference, 
national and state.
    Any social media influencer will tell you that monitoring an 
individual's Name, Image, and Likeness on some of these platforms can 
be a hefty task. When coupled with the efforts needed to develop your 
brand on social media in order to gain a profit from it, this would 
place a substantial burden on the already limited time and attention 
student-athletes give to the tasks in front of them. Bad actors, acting 
with the malicious intent of taking advantage of this opportunity, 
threaten the welfare of student-athletes.
    Given the current regulatory state of NIL, student-athletes 
choosing to embark on that journey would likely have to hire an 
individual to monitor the use of their brand and perhaps an attorney to 
regulate compliance with the porous framework of state laws governing 
its use. A considerable amount of effort would have to go into the 
management, development, and compliance with the state of Name, Image, 
and Likeness and the regulatory framework around it. Student-athletes 
do not live in world where these external pressures are non-existent. 
As a result, the impact on the already burdensome time demands of 
student-athletes would be exacerbated.
                             Team Dynamics
    Another important aspect of the student-athlete experience is the 
impact of the team dynamic. On the surface, student-athletes develop 
teamwork and the ability to manage expectations. But teamwork and team 
dynamics go a lot deeper than that. It's the value of altruism--really 
being selfless and understanding that some things are more important 
than you. This is understanding that regardless of what your role is, 
everyone has a role to play. One of the reasons I think this lesson is 
so incredibly important, and why its tie to the student-athlete 
experience is so valuable, is because teamwork transcends college 
athletics; teamwork is the way our country should work.
    Society initially was designed to function through teamwork. 
Teamwork is one of the reasons we are all here today, because we 
recognize the value, and more importantly, the need to work these 
problems out as a unit. On balance, I think the issues we find plaguing 
intercollegiate athletics and the complexities around college sports 
are the same complexities and problems that we deal with on a societal 
level.
    Teamwork and the relationships that I built as a track and field 
student-athlete with my relay, with the other student-athletes at my 
school, within my conference, and throughout the NCAA, are the lessons 
that all of us actually take with us and the connections that make this 
experience what it is. To this day, I still talk to my college 
roommate, and I still talk to teammates that left my team after the 
first year, many of whom are no longer competing. I couldn't imagine 
the impact on the student-athlete experience if issues like Name, 
Image, and Likeness began to put pressures on those dynamics. The 
unfortunate result of this strain would fall on coaches who have to 
manage, not only the success of the team, but the dynamics of this team 
and the overall cohesion within the program.
                        Community relationships
    Stepping the student-athlete experience outside of the 
institutions, community engagement is often the lifeline for a student-
athlete participating in intercollegiate athletics. Many student-
athletes attend institutions far away from home--away from parents, 
family, and loved ones. The communities that surround our athletic or 
academic institutions serve, not only as a great resource for fan 
support, but are often homes away from home. There is a kinship built 
between student-athletes and the communities that they're connected to. 
Many children within the community look up to student-athletes as role 
models and parents look to student-athletes with a trust that they will 
set the tone and example for success in every field of the human 
endeavor for their children. More importantly, student-athletes are 
looked to as leaders in the community, often because of the lessons 
they learn while participating in intercollegiate athletics.
    The bond between student-athletes and their communities is multi-
faceted, however. Outside of family dynamics, student-athletes also 
form relationships with many places of business that have been 
cornerstones within these communities. This is the sandwich shop owned 
by the married couple that has been in the community for thirty years. 
It's the diner that's been family owned and operated since before the 
school even had an athletic department. And it's the bakery that always 
buy seasons tickets to our games and continues to hang up posters of 
their favorite athletes in their shops. For student-athletes, this has 
never been about value in the commercial sense, but about creating 
value in other places that transcends financial compensation.
    Up until this point, most of these establishments, some of which 
struggle to stay afloat, have not needed to concern themselves with 
potential legal violations to the right of publicity when it comes to 
their student-athletes. Name, Image, and Likeness could greatly impact 
the communities that support college athletics. This is a speed bump 
that comes with now potentially holding the community responsible for 
supporting their student-athletes. It follows that NIL impacts the way 
student-athletes experience each factor tied to the student-athlete 
experience, greatly impacting the welfare of the student-athlete.
D. EDUCATION IS THE EPICENTER OF THE STUDENT-ATHLETE 
        EXPERIENCE
    The debate around a potential pay for play model and the use of NIL 
as a source of compensation for student-athletes has continued to 
persist with little to no discussion of the most important aspect of 
the student-athlete experience: education. The emphasis on academic 
scholarship and excellence is one of the many factors separating 
collegiate athletics from the professional leagues. Notwithstanding any 
of the tremendous benefits serving to illustrate the value of the 
student-athlete experience, education continues to play a substantial 
role in our interaction with these academic institutions. Acknowledging 
this reality is paramount to understanding the value of the current 
collegiate model for student-athletes and the impact NIL might have on 
this framework. The primary function for any of our academic 
institutions is--and should continue to be--the education of students.
    The potential for NIL as a means to provide compensation for 
student-athletes has grown, in part, due to criticisms that the 
collegiate model does not compensate student-athletes fairly. In order 
to truly evaluate the merits of such a claim, institutions and other 
key stakeholders have to assess, and put a price tag on, all of the 
services that student-athletes currently receive. Naturally, this would 
include putting a price tag on a college education for both scholarship 
and non-scholarship athletes. Even if we could place an accurate price 
tag on the value of education in America, we then face the situation of 
what to do about the number we see. In the event that the student-
athlete experience, education, and the like are not comparable to the 
value student-athletes bring to the table, NIL might not be the best 
vehicle to address the disparity. Rather, if we truly value this idea 
of education and the role that it plays in producing a productive and 
useful member of society, it may substantially benefit the entire 
nation to increase the value of the education and experiences student-
athletes take part in. I shudder to think, however, that notions around 
educational opportunity and value will instead be shut down because, at 
the end of the day, the viewing public has never looked at the student-
athlete as a student, but rather as a form of entertainment. Most fans 
could probably never tell you what any of their student-athletes do off 
the field. The respect and admiration fans have for many student-
athletes seems to only go as far as they can throw a football or, in my 
case, jump into a pit full of sand. This is likely the reason why 
compensation for student-athletes has centered around Name, Image, and 
Likeness, and something so closely tethered to entertainment for the 2 
percent of student-athletes that the fans actually see, rather than the 
98 percent of outstanding student-athletes who are doing amazing things 
beyond the fields of play.
Conclusion
    Today's student-athlete faces problems similar to the rest of the 
American people when it comes to the issue of modernization. Regulatory 
uncertainty and the rapid growth of technology places a strain on many 
of the factors impacting the welfare of Americans. It is no secret that 
most institutions, organizations, and legal frameworks are in desperate 
need of a new approach that takes into account important components of 
the world we live in today. Digital communications, social media 
platforms, and other advances in technology are nestled within an 
innovation economy that student-athletes must live in. NIL can only be 
understood through the lens of how it is exercised by student-athletes.
    Fairness is another common theme floating in the periphery of these 
NIL discussions. Intercollegiate athletics looks at fairness from the 
vantage point of equality between all student-athletes. By contrast, 
the public evaluates these levels of fairness by comparing scholar 
athletes to regular students. This comparison is misguided but not 
because fairness is not important to student-athletes. Most student-
athletes do not expect to receive an experience equal to the average 
student, we expect an experience that is better and our institutions 
provide that experience for all of us. The current model for 
intercollegiate athletics places us in the best possible position to 
achieve this standard because the individuals that run college 
athletics--senior women administrators, university presidents, athletic 
directors, coaches, athletic trainers, and other student-athletes--
understand our needs and the value of our experiences better than 
anyone. Our institutions see to the proper administration and equality 
of women's athletics beyond the requirements of Title IX. Our 
institutions see to it that all student-athletes have access to health 
and wellness resources on their campuses. The current efforts managed 
by the membership institutions of the NCAA see to it that roughly 
300,000 student-athletes have access to an outstanding education.
    The porous framework of NIL legislation across the country poses a 
substantial threat to the welfare of today's student-athlete. These 
upstream approaches to state legislation that neglect to consider the 
world of technology and experiences of today's student-athlete, will 
surely have downstream consequences. Student-athletes are more than the 
entertainment that fans subscribe to in between professional football 
games. The value of our education and welfare is no less important than 
those of other students on campus. Rapid growth of state legislation 
pertaining to NIL without the structural guidelines from the governing 
bodies of intercollegiate athletics creates a serious problem for 
student-athletes seeking to navigate this patchwork of state laws that 
govern their likeness. Protecting the welfare of student-athletes is 
not about getting it done, it's about getting it done right. When 
regulatory frameworks that affect the education and welfare of students 
get it wrong, the entire nation suffers. Are we--the student-athlete--
not worth protecting?

    Senator Moran. Thank you, Mr. Spencer.
    Let me start the round of questioning with a directed 
question at Dr. Emmert perhaps to set the stage of where the 
NCAA is and what this committee and Congress might envision for 
its role.
    In October 2019, the NCAA board of Governors voted 
unanimously to permit student athletes the opportunity to 
benefit from the use of name, image, and likeness in a, quote, 
manner consistent with the collegiate model. Unquote.
    While the details of the NCAA's policies will not be 
established until January 2021, after additional feedback from 
its members, are you able to describe the general principles 
that the NCAA and its members seek to preserve as they 
establish rules for name, image, and likeness compensation from 
third parties to student athletes?
    How do you foresee the NCAA's internal input-seeking and 
policymaking timeline aligning with the actions now taking 
place in states?
    As has been acknowledged, states have clearly made known 
their interests to be active in this matter. Is there a concern 
that the NCAA's deliberation process may take too long to keep 
up with the expected rate of states legislating on this issue?
    Dr. Emmert. Well, thank you for the question, Senator.
    I think the first point that needs to be made is to 
recognize that the rules of the NCAA are made by the schools 
themselves coming together through a legislative process that 
is not that dissimilar from a congressional process. The 
members meet on a quarterly basis on a multi-day period of 
time. They have a regular legislative cycle, and they are in 
the midst of that cycle right now.
    The working groups that have been established by the Board 
of Governors representing students and coaches and athletic 
directors and faculty members are meeting as we speak. They 
will be reporting back in April to the board of Governors with 
the expectation that full legislation will be drafted and then 
crafted and then passed to come into effect at January 2021 at 
our national convention of that year.
    Throughout that process, they have been working to try to 
winnow down the general ideas around what is and is not 
permissible, what could or could not be consistent with 
intercollegiate athletics, and that is a work in progress and 
we will know a lot more about as they bring out their findings 
in April.
    Senator Moran. Does the NCAA have other powers, 
opportunities to deal with this outside that deliberation 
process that is going to take the period of time that you just 
outlined? Let me suggest to you that a Member of Congress 
complaining about the slowness of the process is somewhat 
hypocritical.
    [Laughter.]
    Dr. Emmert. Well, the process can be accelerated should any 
of the three divisions--we do all these decisions through our 
three divisional structures--decide to do so. And I and the 
presidents who lead the association have been working very hard 
to try and get them to move this along as quickly as possible. 
As we have heard from the presenters, it is a complex topic. 
The answers are not cut and dried, but I believe that the 
members, the schools themselves, are working on this as 
aggressively as they can under the current circumstances.
    There certainly is a possibility that some State 
legislators could pass legislation that could go into effect 
over the course of this summer. Many states have been modifying 
their proposals to have them slow down on the implementation 
date. We were pleased to see that, and we hope that the states 
will, indeed, provide, as California did, the association with 
some time to modify their rules before their State laws are 
triggered.
    Senator Moran. Mr. Huma, in particular, addressed this 
question, but I would ask the rest of you what role for 
Congress exists to legislate on this issue? I think Dr. Emmert 
indicated there may be a role for Congress. What do you each 
envision as a request of us?
    Mr. Bowlsby.
    Mr. Bowlsby. I believe at this point our request would be 
some assistance on creating a time window within which we can 
complete our work. I serve on the task force that has been 
working on this topic, and we continue to make progress. I 
think we have a better vision of what the guardrails that have 
been mentioned look like. We have some near-term implementation 
dates that are problematic for all the reasons that have been 
noted. So I think some set-aside that would allow us an 
opportunity to have some time to work would be altogether 
appropriate.
    And then as we seek to shape the future of intercollegiate 
athletics, we ask your consideration and indulgence in allowing 
institutions to act in concert. Sadly acting in concert is 
characterized as collusion by the plaintiffs bar, but we feel 
like institutions acting together is the right way to make 
rules. It is the right way to prepare the environment for 
student athletes, and we ask that some consideration down the 
road would be given to us as to whether or not our organization 
can continue to function at the highest possible level, which 
is what we all seek.
    Senator Moran. Others want to add or subtract from Mr. 
Bowlsby's comments?
    Mr. Huma.
    Mr. Huma. I would like to just reiterate that basically 
what Commissioner Bowlsby is describing would be some kind of 
antitrust exemption, which we oppose. And if you look at the 
history of antitrust challenges to the NCAA, each of those 
challenges brought progress. They improved the industry, 
improved the lives of college athletes, starting with the 84 
Board of Regents when the NCAA used to have a monopoly on TV 
money, and now today, because Oklahoma stood up and challenged 
that, you can see that the industry has benefited very mightily 
not just the revenues but also through consumers being able to 
watch TV, watch their favorite teams virtually every single 
week perform.
    The other benefits that have come from that are the 
elimination--these are antitrust challenges against the NCAA--
the elimination on the NCAA's ban on summer workout medical 
expenses. There used to be a ban.
    There used to be a cap on the cost of attendance, the price 
tag of the school. A full scholarship fell below that by 
several thousands of dollars. In the O'Bannon case, part of the 
result was that now today colleges can provide the full cost of 
attendance.
    A current case, Austin v. NCAA, is another area as well 
that has unlocked educational opportunities as well. The U.S. 
DOJ, which we helped support an investigation into the NCAA's 
one-year cap on scholarships--there used to be four until the 
1970s when the coaches kind of pressured the NCAA to turn it 
around because the DOJ acted as a catalyst over antitrust 
scrutiny. Now college athletes can have multiyear scholarships.
    So again I reiterate if any of these issues it feels 
require guardrails from Congress, they should be enacted 
directly not through an antitrust exemption. The NCAA has been 
operating as if they had an exemption, and we have seen what 
they have done. Name, image, and likeness would not be on the 
table. The states would not be able to even bring this issue to 
light had they had an antitrust exemption. So there are a lot 
of problems with that.
    Senator Moran. Mr. Spencer.
    Mr. Spencer. Thank you, Mr. Chairman.
    I would ask this group to consider the current way student 
athletes live in today. I think the world that student athletes 
lived in when the NCAA was formed is entirely different than 
how student athletes interact with each other now. I would ask 
this group to consider the current regulatory framework that we 
exist in and, more importantly, all student athletes, not just 
the 2 percent that some of us might see during March Madness or 
during the bowl season and the role that our education plays in 
shaping that experience and how NIL fits into that equation 
more broadly.
    Senator Moran. Thank you.
    Senator Blumenthal.
    Senator Blumenthal. Thanks, Mr. Chairman.
    I want to begin by saying that I mean no disrespect to 
anyone, but I think Mr. Spencer has really made the critical 
point here. A lot of what I hear from the NCAA and coaches and 
college officials evokes the fantasy of college sports as it 
existed 50 years ago. When I was a Supreme Court law clerk, I 
once visited with Byron White who played football in an era 
when helmets were made of leather. I think a lot of the 
rhetoric and images that we hear about college sports are as 
antiquated as leather helmets. And that makes me angry because 
I think that the present state of college sports is exploited.
    And as I listen to the hand-wringing about states creating 
a patchwork of different laws, it is coming, and the reason is 
that intercollegiate programs earned a total revenue of $14 
billion, rivaling the National Football League's $16 billion. 
And the NCAA, by the way, grossed a billion dollars. So the 
states are going to fill this gap, and frankly, I am going to 
encourage them to fill it because it will provide an additional 
incentive for the NCAA to move more quickly. January 2021 is 
simply too late. The NCAA is late to this game.
    So let me ask you, Mr. Emmert, what can you do to speed and 
make more effective the NCAA's changes and initiatives so that 
we simply do not wait until sometime in the distant future and 
we can avoid the patchwork of different laws that rightfully 
will create unfair playing fields for different colleges and 
universities, as the Chancellor of the University of Kansas has 
pointed out quite correctly?
    Dr. Emmert. Senator, first of all, I happen to completely 
agree with you that many of the approaches to intercollegiate 
athletics are, in fact, embedded in history or sometimes even 
grossly inaccurate notions of what the real environment is. And 
I am delighted that Mr. Spencer is here providing the current 
balance on the life of student athletes.
    I can assure you and the members of this Subcommittee that 
I will do everything in my power to encourage the schools 
themselves in their decisionmaking processes to accelerate 
those discussions and the decisionmaking as quickly as they 
can. They are working very hard to make sure that they have 
opportunities to consult with students themselves, with the 
various levels of the association across its three divisions, 
with all of the various programs to make sure they actually do 
understand the realities on the ground to make sure that they 
do not create unintentional consequences from any of the rules 
that they modify and change.
    Senator Blumenthal. I apologize for interrupting, but my 
time is limited.
    Dr. Emmert. Certainly.
    Senator Blumenthal. Would you agree that the present system 
of compensation is unfair and outdated?
    Dr. Emmert. I certainly agree that the NIL model that is in 
place needs to be modified and is appropriate for change.
    Senator Blumenthal. Radically modified.
    Dr. Emmert. Correct.
    Senator Blumenthal. Does everyone on the panel agree with 
that point? Please raise your hands if you agree.
    [A show of hands.]
    Senator Blumenthal. The record should reflect that all of 
the witnesses today have agreed that radical modification is in 
order.
    Let me ask you, Mr. Spencer. What kinds of NIL compensation 
do you think as a future lawyer should be provided?
    Mr. Spencer. Thank you, Senator Blumenthal, for the 
question.
    I think this is an incredibly complex issue, and I think 
part of the problem with creating a structure around this is 
the definitions around name, image, and likeness are constantly 
evolving. I really appreciate you acknowledging my comment 
earlier about how the world that student athletes today live in 
is entirely different, but I do want to highlight that a key 
aspect of that statement is that this is also a world that 
society as a whole is still trying to get a grasp of. I think 
we see that in this rush to create regulations around 
technology, whereas when we look at this patchwork of State 
laws that are trying to create a boundary around this, the way 
that I use social media and that I use my likeness is on the 
Internet and the Internet does not have these boundaries. So 
that is part of what makes it a little bit difficult. And I 
think that is something that we will be taking back to our 
student athletes. You know, again, some of them are right 
behind me now. And we want to look at that a little bit 
closely.
    Senator Blumenthal. And would you agree--and I would 
welcome Mr. Huma's comments as well--one of the areas that I 
think the public finds most dismaying the discarding of student 
athletes who have injuries and cannot continue playing? Is that 
a problem that is on your mind?
    Mr. Spencer. I think the way that we take care of student 
athletes today is continuing to grow. The university students 
that I am in touch with, the way that I see athletic training 
rooms and coaching staffs take care of their athletes is quite 
frankly amazing. It is one of the reasons why I am here today 
not because of the scholarship that I would receive but because 
of how enriching that experience was and how that was able to 
propel me to where I am today.
    Mr. Huma. Thank you for asking that question.
    Under current NCAA rules, the minimum scholarship is a one-
year scholarship that can be non-renewed for any reason, 
including injury. The injury rate in Division I athletes across 
all sports is 66 percent suffer a major injury, 50 percent go 
on to have chronic. Many coaches use that as an excuse to not 
renew the scholarships, which is very difficult for those 
players, especially some of them are being forced back into 
play too early with serious medical conditions.
    And you know, if you look at--again, big picture--the 
nature of whether or not to entrust the NCAA with an antitrust 
exemption and other things, the priorities of NCAA sports do 
not align with the priorities to protect players, even on 
health and safety. So it is a big concern, yes.
    Senator Blumenthal. So athletes really deserve better 
protection physically, financially, and otherwise. Correct?
    Mr. Huma. Absolutely.
    Senator Blumenthal. Thank you.
    Dr. Girod.
    Dr. Girod. Yes, thank you.
    If I could just add a comment to that, and as a head and 
neck surgeon, it is an area that I have particular interest in. 
And I would say that we have actually come quite a ways in the 
protection of our student athletes from robust research and 
implementation of concussion protocols to most recently at our 
institution, we have created a new entity to take care of our 
student athletes, an entity that employs our physicians, our 
trainers, and most importantly probably our strength and 
conditioning coaches. They are not employed through athletics. 
They are actually employed through our health system and 
overseen by medical professionals to take that decisionmaking 
away from--that pressure away from the coach and from the 
athlete, quite frankly, to make sure that the best interests of 
the student athlete is looked after.
    Senator Blumenthal. And, Chancellor, I do not mean to imply 
that athletic programs do not care about physical injury. 
Preventing physical injury is the best way of keeping those 
players on a field. Right?
    Dr. Girod. Absolutely.
    Senator Blumenthal. So they have an economic incentive in 
making sure those players get back to the game just as 
professional sports teams do.
    My worry is about the lasting impacts after that student 
leaves and careers cut short by injuries that simply cannot be 
prevented. And I think that this whole system has to be 
fundamentally reformed, far-reaching fundamental reform. And 
the NCAA has a role to play but only if it gets into the game 
which right now it is failing to do.
    Senator Moran. Senator Fischer.

                STATEMENT OF HON. DEB FISCHER, 
                   U.S. SENATOR FROM NEBRASKA

    Senator Fischer. Thank you, Mr. Chairman.
    On football game days at Memorial Stadium in Lincoln, 
Nebraska, we have over 90,000 fans. It becomes the third 
largest city in the State of Nebraska. We have sold out every 
single Husker home game since 1962, and although we are blessed 
with a very incredible football history, we are also a very 
rural state that is built around an agricultural economy.
    I have questions about the impact of NIL on recruiting in 
college athletes, particularly on the marketing and sponsorship 
opportunities for star players, which may be enhanced in states 
that have those larger urban areas.
    Dr. Girod, how could NIL impact recruitment for schools in 
rural communities with smaller media markets and less business 
infrastructure?
    Dr. Girod. Thank you for the question, Senator.
    And as your neighbor to the south, I share entirely what 
your concerns are, which is this has a strong possibility to 
create a big market-small market problem where frankly states 
like mine with 3 million people in it will struggle to be able 
to compete in an environment where the biggest media package 
for an athlete is going to win the day. And so we have serious 
concerns about that, and we have serious concerns about then 
what happens with the economic imbalances that follow and our 
ability to support our non-revenue sports. To be quite honest 
with you, I am blessed. Our athletics department is largely 
self-sufficient. They take the revenues and they pump it into 
the non-revenue sports. And if that dynamic changes, 
particularly through an employment model, then really that 
landscape will change dramatically as will our Olympic training 
system.
    Senator Fischer. And, Dr. Emmert, what could an imbalance 
for urban versus rural-based campuses do to the concept of fair 
competition in college sports both in revenue and in those non-
revenue sports that Dr. Girod mentioned. We have that in 
Nebraska as well. We have successful football, volleyball. 
Money is pumped back into other sports, into the university. 
What is going to happen there?
    Dr. Emmert. Well, Senator, I think you are asking one of 
the most important and complex questions.
    Again, the support that we have within the association 
around finding a better model for NIL is predicated on our 
ability to make sure that recruitment inequities do not occur, 
and there may well be ways of doing that, but under an 
unrestricted and unfettered model, you would simply wind up 
with those institutions in urban areas having an extraordinary 
competitive advantage both in terms of garnering sponsorship 
deals which they would use as part of the recruiting 
inducements for student athletes to come to those marketplaces. 
And similarly, you could see--as Chancellor Girod said, if 
there were no guardrails around this model, there could be some 
severe disadvantages to the Olympic sports in particular 
because the resources that flow into a big program like your 
football program in Nebraska would no longer be available for 
programs like your marvelous volleyball program.
    Senator Fischer. You know, with our volleyball program--
five time national champions, one of the best in NCAA history--
Mr. Bowlsby, could NIL have any Title IX implications? I am 
very concerned about that and what is going to happen with 
risks that we are going to see to Title IX. Also, how are we 
going to be able to preserve its integrity?
    Mr. Bowlsby. Thank you very much for the question.
    If you will allow me a bit of time, I really think----
    Senator Fischer. You have less than a minute.
    Mr. Bowlsby. I might not be able to do it in that time.
    But I think what I am raising as an issue is really the 
heart of the matter. The recruiting environment is absolutely 
critical on this, and it will have Title IX implications, 
Senator. But we will also see student athletes that come to 
campus with agents and managers, and their representatives will 
participate in many aspects of their life on campus. Recruits 
will come to campus with preexisting agent relationships and 
established business ventures, and coaches will be forced to 
recruit both the player and the family as well as the agent 
representative.
    Boosters and donors and third parties will inevitably be 
involved in the recruitment and transfer decisions, including 
without the knowledge of institutional representatives, and 
much of that will happen on the Internet.
    Non-scholars and walk-on players will receive support from 
boosters and donors and third parties and effectively increase 
the scholarship allocations beyond agreed-upon numbers.
    The project will commence with student athletes not using 
institutional marks and logos but will eventually transition, 
and the negotiations will be part of the recruitment process.
    It goes on and on and on. The intersection with the 
recruiting environment is the absolute epicenter of this 
consideration. And given the entrepreneurial nature of coaching 
staffs, they will find very effective ways of having third 
party inducements to enroll and transfer a big part of the NIL 
environment. And it is that integrity that I worry about the 
decline of.
    Senator Fischer. We need to make sure we get this right so 
that every student athlete, male, female, whatever sport they 
are going to be in, is going to be able to be treated fairly, 
be able to have a good experience for themselves, their family 
and for the school that they attend.
    Mr. Bowlsby. That is absolutely correct, Senator.
    Senator Fischer. Thank you.
    Mr. Bowlsby. And I think also the extent to which 
institutional representatives become involved in helping with 
NIL reintroduces Title IX to the root of your question into the 
conversation because the 13 components of Title IX certainly 
bear on the recruitment.
    Senator Fischer. Thank you.
    Thank you, Mr. Chairman.
    Senator Moran. You were slightly more effective than the 
Chairman in enforcing the time limits.
    Senator Tester.

                 STATEMENT OF HON. JON TESTER, 
                   U.S. SENATOR FROM MONTANA

    Senator Tester. Thank you, Mr. Chairman, Ranking Member. I 
appreciate you holding this hearing as always. It is one of the 
best hearings we will have today because of the good work of 
the Chairman and Ranking Member.
    I also noticed that when you pointed out all the advantages 
that Kansas had in the sporting arena, you failed to mention 
Kansas' Super Bowl champion, the Kansas City Chiefs.
    [Laughter.]
    Senator Tester. But we will set that aside.
    Senator Moran. Senator Tester, we do appreciate the 
President pointing out the Chiefs and its relationship to 
Kansas.
    [Laughter.]
    Senator Moran. And second, I have told most of the 
witnesses today they were all my second choice for a witness. I 
was hoping for Mahomes as a witness to talk about this.
    Senator Tester. That would have been good too.
    So, look, I mean I think we can all agree that what is 
going on right now is not working. If you want to dispute that, 
I would love to hear the dispute.
    I think we also agree that if you have 50 different states 
having 50 different sets of rules, that is not going to work 
too well either. In fact, that is not going to work at all. And 
my concern here is that as tuition in colleges continue to go 
up, it is whoever has the biggest wallet to pay these athletes 
could really screw things up badly.
    So before I get to my question that I really want to know, 
I just want to say that I want to confirm what I have heard, 
that if an athlete gets injured, that potentially the 
scholarship could or would be taken away and that they are on 
their own after that. Is that true? Go ahead, Mark.
    Dr. Emmert. Senator, thank you for asking the question 
because it is a very, very important one.
    No, it is not true. Indeed, schools are expressly 
prohibited from pulling a scholarship from a student because of 
an injury.
    Senator Tester. So they can make up another excuse 
potentially. They are not doing that?
    Dr. Emmert. Well, can you clarify what you are asking?
    Senator Tester. So what I am saying is that there are a lot 
of ways to skin a cat. You could figure out ways to make their 
GPA go down. There is probably things in it. But the point is 
this if in fact the intent of the law or the intent of the rule 
is--and I assume there is an NCAA rule or you would have 
responded to this, Mark. But I would assume that they are not 
allowed to jerk a scholarship if a student gets hurt.
    Dr. Emmert. That is correct, Senator.
    Senator Tester. All right. Go ahead. Make it quick.
    Mr. Huma. Because they are in the period of award. If it is 
a one-year scholarship and they are injured during that year, 
it cannot be removed. But as soon as that scholarship ends for 
that year----
    Senator Tester. It is over.
    Mr. Huma.--the college can non-renew it. So a non-renewable 
is a big deal.
    Senator Tester. I got you.
    So that is a problem. OK? I think that is a problem. If a 
kid gets hurt and he is playing football, basketball, 
volleyball, it does not matter. They should be taken care of.
    The more important point is this. Patchwork is not going to 
work. What is currently out there is not going to work.
    Mr. Emmert--and by the way, sorry I called you Mark. We got 
a list of states here, Kansas and Connecticut and Tennessee and 
Nebraska and West Virginia. I come from Montana. Mark knows 
this because he worked at Montana State University. And quite 
frankly it is great athletics. It is incredible. You guys have 
done a marvelous job in the NCAA making this what it is today. 
But the truth is I would hate to have to compete with Alabama 
or Duke because I do not think we have got thick enough wallets 
to do that.
    So the question is, how advanced are the talks within the 
NCAA to solve this problem, this problem of students creating 
an economy that is so good and not getting much, if any, reward 
for it? Do you want to tell me where you are at in 
conversations about solutions? Because I am going to tell you, 
to be honest with you, you do not want us to solve this. You 
want us to help you solve this. So the question is, where are 
we at in talks? Where are we at as far as putting stuff on 
paper? Because time is a'clickin' and we cannot stop the states 
from doing what they are doing. So we have got to figure it 
out.
    Dr. Emmert. Yes, Senator Tester. Well, as I was explaining 
earlier, there is a timeline in place with a target of having 
this resolved by January 2021. Whether that is sufficiently 
aggressive or not is in large part dependent upon----
    Senator Tester. And do you have anything on paper right 
now?
    Dr. Emmert. We do not but we will by April.
    Senator Tester. You will in a few months?
    Dr. Emmert. Yes.
    Senator Tester. Are you willing to share that with other 
folks, the folks that are at this table and with us?
    Dr. Emmert. At that time?
    Senator Tester. Yes.
    Dr. Emmert. Certainly.
    Senator Tester. And you are willing to take input on how 
you can make it better?
    Dr. Emmert. Absolutely.
    Senator Tester. OK.
    Could you just very quickly--20 seconds--Mr. Bowlsby, just 
tell me what impact a patchwork solution like California would 
have something, Montana might have something, North Carolina 
might have something, Texas might have something--what does 
that do to the ecosystem?
    Mr. Bowlsby. Well, thank you for the question.
    Once again, this is the very epicenter of the challenge.
    I think the coin of the realm becomes what can you offer 
under the State laws that you have in effect. The description 
of the California-Arizona situation that was mentioned earlier 
is a good example. That is one that is within an individual 
conference. But when Oklahoma comes to Texas to recruit in my 
conference, if the laws are different in Oklahoma than they are 
in Texas, you will find a disparate recruiting environment, and 
that is problematic.
    Senator Tester. So I am going to wrap this real quick, Mr. 
Chairman. It was touched on a little bit about the pay of 
coaches. I think we are going to end up doing the same thing 
for the players if we are not careful. You are going to have 
schools that can pay players a lot of money and they probably 
should earn it, but the truth is that if we are not careful 
what we are doing, it might on somebody else's back. I think 
right now it is on all the student athletes' backs. So we got 
to figure out how to make it fair for everybody moving forward.
    I am not even going to get into northern latitudes or rural 
schools because I think if we do not do it right, it further 
puts them behind. And I do not want to see that. Education is 
education. I think athletics is a part of education. I hope it 
remains that way, although in a lot of cases if you are playing 
football or basketball in these bigger schools, it is hard to 
get an education. You can get an education, but it is hard to 
get an education because so much of your time is dedicated to 
that sport. And that is why we are here.
    Thank you, Mr. Chairman.
    Senator Moran. Senator Tester, thank you.
    Senator Thune.

                 STATEMENT OF HON. JOHN THUNE, 
                 U.S. SENATOR FROM SOUTH DAKOTA

    Senator Thune. Thank you, Mr. Chairman, for having this 
important hearing on a subject that many on this Committee and 
all around the country care deeply about.
    And I will get into northern latitudes and rural schools. 
The Summit League, Dr. Emmert, is comprised, as you know, of 
nine schools throughout seven States, and it is home to South 
Dakota State University and the University of South Dakota. 
Several of the states where the Summit League has schools are 
contemplating legislation to address student athlete 
compensation.
    Are conferences today equipped to comply with a patchwork 
of State laws that seek to address the issue of name, image, 
and likeness?
    Dr. Emmert. Thank you for the question, Senator. And I 
think your question applies to both urban and rural 
environments, and the answer is, in short, no, they are not. In 
large part, most conferences--indeed, virtually all of them--
have interstate boundaries as does the Summit Conference. 
Having conferences with multiple State rules within them would 
be incredibly dysfunctional for the reasons we have been 
discussing. And it is also true that it brings to bear 
competition between rural and urban areas even within those 
conferences that currently exist that would be very, very 
problematic.
    Senator Thune. Commissioner Bowlsby, the Big 12 conference, 
another good example of that. Is the Big 12 prepared to comply 
with several State laws?
    Mr. Bowlsby. We are not.
    Senator Thune. Dr. Emmert, as I understand it, the NCAA ban 
on athletes profiting from the use of their names, images, and 
likenesses violates Federal antitrust law. But the Federal 
appellate court in the Ninth Circuit has ruled that the NCAA 
essentially holds an antitrust exemption so long as it allows 
its member schools the chance to offer college athletes the 
full cost of attendance.
    How would the name, image, and likeness rules that you are 
considering likely impact the NCAA's antitrust exemption?
    Dr. Emmert. Part of the conversation that is going on right 
now, Senator--and again, thank you for that equally important 
question. Part of the discussions that are going on right now 
is to try and address precisely the question you are asking. 
The association schools are deeply committed to maintaining the 
college model and making sure that we can adhere to the values 
that are consistent with the legal precedents that exist and 
how college sports has gone on for a great deal of time. So, 
threading the needle is trying to determine how can we expand 
opportunities because there is a general agreement that 
providing greater opportunity for students around their name, 
image, and likeness is a very good thing, but doing that in a 
way that does not immediately provoke antitrust litigation 
around the actions of the association. How can we make sure 
that we can do good without immediately being back in court is 
one of the greatest problems that we have right now.
    Senator Thune. I will direct this to you, Dr. Emmert, but I 
want to open it up to members of the panel. It has been 
suggested that there should be a limit on the amount of funds a 
potential name, image, and likeness sponsor can offer a student 
to protect students from inappropriate predatory actions. Do 
you agree with that? And then I would like to hear others on 
the panel comment on that as well. Dr. Emmert?
    Dr. Emmert. Senator, I think again the question is what can 
and cannot be done in the current legal context. The current 
legal context in the litigation environment that we have found 
ourselves in makes it extraordinarily difficult to determine 
what boundaries can, indeed, be set on those forms of 
compensation that might come toward a student athlete and for 
what they are being compensated without turning that student 
into an employee of an institution. That is part of the debate 
that is in front of us today.
    Senator Thune. Others?
    Mr. Huma. We do not want to see caps. I mean, caps do not 
protect the players. A cap would reduce the opportunity 
economically.
    And I think getting at the idea of competitive equity is 
kind of one of the issues. But under the current rules, there 
was a study over the course of 10 years that found that 99.3 
percent of the top 100 football recruits chose teams in the 
power conferences. That is under current NCAA rules. The power 
conferences have advantages with alumni. They are the bigger 
schools, bigger alumni, richest donors, and they continuously 
pull the best recruits across different sports.
    So one of the points I made earlier today was that to cap 
players and still allow booster payments to flow to these Power 
Five conferences, to allow them to continue gaining the lion's 
share of the TV revenue in order to further outspend on 
recruiting, outspend on coaches, outspend on facilities--they 
will continue to get the recruits.
    So without addressing those other issues especially--and we 
are not advocating. We are just talking about what reality is. 
The reality is that you are not going to change the migration 
of recruiting by blocking players' opportunities. The Power 
Five conferences are going to get the best recruits year in and 
year out.
    Senator Thune. I would just close, Mr. Chairman--my time 
has expired--by saying that, Dr. Emmert, we look forward to 
your working group as those activities continue--feedback from 
you and hopefully on a timeline that enables us to stay ahead 
of what is happening in all the states. So we look forward to 
hearing more from you on this subject. Thank you.
    Senator Moran. Senator Thune, thank you very much.
    Senator Blackburn.

              STATEMENT OF HON. MARSHA BLACKBURN, 
                  U.S. SENATOR FROM TENNESSEE

    Senator Blackburn. Thank you, Mr. Chairman.
    And I want to say thank you to each of you for taking the 
time to be here today and to work with us on this issue.
    And, Mr. Spencer, I wish you well. I have a son who was a 
track runner and ran in college and still, as an adult, is out 
there competing in triathlons. And I know how important that 
training is. So we wish you well in that endeavor.
    I have to tell you I think that Senator Blumenthal and I 
are kind of on the same page. I think that this is something 
that, Mr. Spencer, you are closest to this. We have got 
athletes that are coming to your schools with YouTube channels, 
their Internet, social media influencers. So it is different. 
And it is very important that you all get this right.
    Fair, consistent, transparent. Mr. Emmert, you say that is 
your priorities. But I have to tell you I was really 
disappointed with our meeting last week. And I think we are 
looking at a time when the NCAA has failed when it comes to 
women in sports, sexual harassment, sexual assault, sexual 
abuse that has occurred. And I think a question that must be 
going through a lot of minds of student athletes and their 
parents is how in the world are they going to be able to trust 
you to get this right.
    And I have to tell you I look at the issue around James 
Wiseman at University of Memphis. And this is a situation where 
in 2017 Penny Hardaway gave a star Tennessee player, James 
Wiseman's mother $11,500 to help the family move to Memphis. 
And this young man would go on and play for University of 
Memphis. And then in 2018, Hardaway became the head coach at 
Memphis. In 2019, Mr. Wiseman chose to play at Memphis. The 
NCAA cleared him. In November 2019, NCAA suspended this 
freshman basketball player from 12 games because of concerns 
over the $11,500.
    And I will tell you I think there has been little, if any, 
transparency between James Wiseman, the University of Memphis, 
and your organization. And the way you arrived at your 
decision--I think when you talk student academic success, 
wellbeing, and fairness, this has been a failure for you all in 
the way that you have handled this.
    So we are looking at a time where now student athletes are 
going to be trying to figure out if they are better off going 
straight to the pros and skipping college because of situations 
like James Wiseman and because of a lack of transparency and a 
lack of consistency and a lack of fairness that is being doled 
out to them.
    Dr. Girod, I see you nodding your head. Would you like to 
comment?
    Dr. Girod. I guess I would just comment that as probably 
most of you know, we are in an episode of notice of 
allegations--what is in the NCAA. I guess I would just say that 
as a member organization, we are part of the organization that 
makes the rules. We understand those rules. We support those 
rules. Our current situation is we do not believe the evidence 
necessarily supports the allegations, but actually we support 
the system.
    Senator Blackburn. Thank you.
    Mr. Emmert, if there was a potential conflict of interest, 
why was the university and the Wiseman family not informed 
earlier in the process?
    Dr. Emmert. Senator, first of all, I respect and appreciate 
the concern that you expressed over this issue. No one anywhere 
in the intercollegiate system takes any pleasure in sanctioning 
or punishing a university or especially a young man or a young 
woman around these issues through an enforcement action.
    I am not involved in the details enough of that particular 
case to be able to answer your specific question.
    Senator Blackburn. But you are the CEO, and when there is a 
lack of transparency or subjectiveness, the objectivity should 
come to you.
    I yield back my time.
    Senator Moran. Senator Capito.

            STATEMENT OF HON. SHELLEY MOORE CAPITO, 
                U.S. SENATOR FROM WEST VIRGINIA

    Senator Capito. Thank you, Mr. Chairman.
    And thank you all for coming today. It has been a very 
interesting hearing.
    I am going to diverge a little bit from what the Chairman 
requested that we stay strictly on message because I have 
Commissioner Bowlsby here and I wanted to ask him a question, 
and Dr. Girod will probably know exactly what I am talking 
about.
    You recently signed a Big 12 deal to stream on ESPN Plus. 
Rural State, West Virginia. We are playing Kansas tomorrow. I 
have my Mountaineer colors on. And you can only view the game 
in West Virginia if you pay the $4.99 monthly streaming fee and 
if you have connectivity. And it has been a source of very deep 
concern to West Virginia.
    So I want to give you a chance to respond what a rural 
state--we have no pro states. These teams are our pro teams, 
and we want to see that WVU victory on our TVs on Wednesday. 
And then we play Baylor, again number one team in the country, 
same thing. So could you respond to that please?
    Dr. Emmert. I would be happy to. And, Senator, I have had 
the opportunity, not surprisingly, to respond to this question 
previously.
    We took a leap of faith with a new technology. We believe 
that streaming and the ESPN platform is best in class. So it is 
a voyage of exploration. There is not any doubt about that. We 
live in states, the five of them, that have 35 million people, 
and as such, we really do not have the option of a linear 
network as some of the other conferences have done. And so the 
digital process is the best we have available to us, and 
frankly it is quite good. We are up to 8 million subscribers. 
We are part of a package with Disney Plus that now has almost 
30 million subscribers. We think it is an environment where the 
cable universe is shrinking about one and a half to two and a 
half percent a year, that we are going to end up with a lot 
fewer cable households down the road than we have today, and 
the digital platforms are the future.
    So I was involved in the rollout of the Big 10 network and 
I was involved in the rollout of the Pac 12 network. And I have 
to say the number of complaints we have had have been much less 
than those two rollouts.
    But the objection you raise is exactly the right one. If 
you do not have broadband that is capable in a rural area, it 
is difficult to get it. But it is available on a multitude of 
different platforms, and for the most part, that level of 
broadband is available just about everywhere if you want to go 
pursue it and then subscribe.
    Senator Capito. This is a source of contention. You 
obviously talked with our West Virginia University folks. And 
maybe it is a little bit before its time, but it is a source of 
irritation for us back home.
    Dr. Emmert. It is.
    Senator Capito. And I am sure you understand that.
    Dr. Emmert. Certainly.
    Senator Capito. I do not want to go back over the Title IX 
issue because Senator Fischer talked about it, but it is a 
source of concern for me. Our daughter played Division I sports 
for 4 years in volleyball. But one of the best athletes we have 
in our state is Jenny Thrasher, who was on our WVU rifle team. 
She won the first Gold Medal last year. She has since 
graduated.
    What kind of NIL opportunities would she have, and how are 
you going to keep that fair? I think that is a major challenge 
for particularly women's sports that do not generate the 
revenues, are not going to have the big sponsors coming in and 
wanting to sponsor. Even the women's basketball team is going 
to have trouble, even though they are very popular in certain 
areas. So I just want to register that complaint.
    And I want to ask Mr. Huma this question because you are a 
former football player. He is a problem I see too particularly 
if you look at football. You have got the quarterback who gets 
the ball all the time, who makes the passes. You see this in 
the pros. He makes the passes, gets the glory, gets the 
touchdowns and all that. But the quarterback cannot do what he 
does if he does not have a center who gets the ball to him. 
Now, how many opportunities is the center going to have to 
capitalize on something like this in comparison to what a 
quarterback could have? And to me, one of the beauties--and, 
Mr. Spencer, you talked about this--of intercollegiate sports 
is the team aspect, the leadership, the development, the 
intellectual, the camaraderie, the ability to overcome losses 
and triumph in games. How are you going to handle that inequity 
and keep that team element that is so critical to these team 
sports?
    Mr. Huma. Actually I am glad you asked that question.
    Really, that dynamic already exists in NCAA sports. When 
you look at many of the equivalency sports which are partial 
scholarship sports, you have on the very same team maybe a few 
players on full scholarships, you have some that are on partial 
scholarships, some that have no scholarship that desperately 
want a scholarship. And in the other leagues as well, there is 
a big variety of salary differences in all the other leagues, 
the other pro leagues. But whether it be on the college level 
or the pro leagues, you do not hear about riots in the locker 
room and that kind of discontent. It is everything you just 
said. You know, the camaraderie still exists. We see it already 
again in the partial scholarship sports. You see it in the 
other pro leagues as well.
    And I think that the opportunities for women are 
extraordinary. If you have an Olympic Medal Gold winner, they 
can have a lot of different exposures and opportunities. That 
is a blessing. That is great in her life. There was Katie 
Ledecky from Stanford, five time swimmer. She basically left 
NCAA sports which, had she stayed, she could have helped grow 
the visibility of the sport because little girls who are 
watching these swimmers and soccer players and other people--
they are seeing these popular athletes come. It is going to 
draw more attention. And historically women have not been given 
the same exposure as the male sports, specifically football and 
basketball. So it can definitely be an equalizer in terms of 
women's sports.
    Senator Capito. Thank you.
    I finished my time, unfortunately, and I know the Chairman 
wants to stick to the time.
    But I do want to work with you, with the schools, with the 
conferences to try to figure out this issue. I think having a 
patchwork of 38 different regulations is just a nightmare for 
our country, and I think we have got to figure out a way to 
even this out and make it fair. Thank you.
    Senator Moran. Senator Capito, thank you very much.
    Senator Young.

                 STATEMENT OF HON. TODD YOUNG, 
                   U.S. SENATOR FROM INDIANA

    Senator Young. Well, thank you, Mr. Chairman. I appreciate 
you holding this hearing. It is big of you, seeing as you lost 
the headquarters of the NCAA a number of years ago.
    [Laughter.]
    Senator Young. Just responding to your earlier commentary.
    We are grateful to have the NCAA in Indianapolis. I thank 
our entire panel for your testimony today. It is a really 
important issue that comes down to a question of fairness and 
equity, and we need to tackle it intelligently.
    We are trying to strike a balance here. We want to maintain 
the fundamental notion of college sports, if at all possible, 
while addressing this issue of name, likeness, and image that a 
number of states have already gone out and proactively 
addressed in different ways.
    I think about a Hoosier teenager, maybe the first one to 
attend college, and they go out onto the court or the field and 
are able to make a real impact and create some value for the 
institution, for their conference, for the NCAA.
    Dr. Emmert, how can we create opportunity for kids that 
bring this value to an institution to the broader constellation 
of entities that are involved here without doing harm to the 
collegiate model that provides so much value to roughly a half 
million kids around the country?
    Dr. Emmert. Well, thank you, Senator.
    I think the question that you have raised is also central 
to this topic, and I think this is true of all of the witnesses 
before you. What we would like to do is find ways in which that 
individual you are talking about can be able to take advantage 
of the name, image, and likeness whether they brought it with 
them from high school or whether they developed it while they 
were in college, but at the same time, do so in a way that 
creates sufficient guardrails that the recruiting issues that 
Mr. Bowlsby raised and others have talked about, the 
involvement of the institution in providing recruiting 
inducements are not constrained and that indeed what we are 
seeing is the real market value, if you will, of that 
individual. But crafting that particular model is a challenge 
and that is indeed why we are having this conversation.
    Senator Young. So as we reflect on--perhaps it is premature 
to ask this question, but as we reflect on what success might 
look like after we have worked this out, will it be qualitative 
in nature or will there be some things that we think we can 
actually measure to determine whether or not we have arrived at 
a fairer outcome?
    Dr. Emmert. I am sorry. Could you elaborate on your 
question a bit? I am not quite sure----
    Senator Young. Sure. How do we measure success?
    Dr. Emmert. Well, I think first of all, if we can craft a 
model collectively that again provides some opportunity for 
students--I cannot put a quantitative number on it--but 
provides a greater level of opportunity for students so that 
they can engage in activities that look and feel more like the 
rest of the student body and that they are not prohibited from 
participating in those kinds of activities while at the same 
time providing guardrails that prevent inappropriate recruiting 
inducements or the conversion of these students de facto into 
employees, I think somewhere between those two parameters, 
Senator, is where we want to be.
    Senator Young. That is helpful. Thank you.
    Commissioner Bowlsby, I keep hearing there are concerns 
about California's Fair Pay to Play Act and the patchwork of 
State laws that may present a challenge to the NCAA if other 
states enact their own versions of NIL laws.
    Can you elaborate on your specific concerns about the 
California law?
    Mr. Bowlsby. Thank you for the question, Senator.
    I have specific concerns about the breadth of the 
California law. Many of the subsequent proposals share those 
same characteristics. Others have included amendments that 
render something that is akin to guardrails.
    But my concern has always been around the recruitment 
environment. I believe that we will essentially find ourselves 
in an unregulated recruitment environment because what is NIL, 
name, image, and likeness, owned by the individual student 
athlete or recruit will quickly become currency in the 
recruiting environment, and one institution will play off the 
other. The same will happen in the transfer environment. There 
will be inducements made that sometimes institutional officials 
will not even know about.
    Senator Young. Thank you, Commissioner.
    Just very briefly, does anyone disagree with the 
Commissioner's concerns?
    Mr. Spencer. Senator Young, I do not. Student athletes--
this is a very realistic pressure.
    Senator Young. You do not disagree.
    Mr. Huma. I would just say the inducements on recruiting--I 
absolutely agree that there are ways to solve that. But the 
whole premise that it has to be done on a Federal level--the 
states are just getting started. 28 are already involved. I 
think it is only a matter of time before the rest of the Nation 
handles it. Our concern is that there is going to be an 
overreach by the NCAA and they are going to turn it right back 
to what it looks like today because in reality, they would have 
never been here at this table without the states pushing.
    The other thing actually, if you let me. The Board of 
Governors has express authority to settle legal issues. So all 
the talk about how long it would take the NCAA to come up with 
something--the Board of Governors--they do not have to go 
through that route that takes a long time. California has a 
law. That is a legal issue. They could wake up tomorrow and 
actually put uniform policies in place structured around what 
is going on in the states.
    Senator Young. Thank you, Chairman.
    Thank you, all.
    Senator Moran. Thank you, Senator Young.
    We are going to have another round of questions, and I am 
going to yield my time at the moment to Senator Thune.
    Senator Thune. Thank you, Mr. Chairman.
    Just as kind of a follow up to the discussion we were 
having about how these rules might work among different sized 
institutions, say, Division I, Division II, Division III, would 
you envision--I guess, Dr. Emmert, starting with you--these 
rules having one set of rules for all divisions, or would you 
have different rules for each division?
    Dr. Emmert. Currently the way NCAA legislation, the rules, 
are put together is on a division-by-division basis. It is only 
each individual division that has authority to pass rules 
within their division.
    The board of Governors can set broad parameters. The board 
of Governors includes representatives, university presidents, 
from all three divisions. They have the authority to set the 
policy parameters, and that is what they are trying to do now. 
I believe that most people are comfortable today saying if 
these parameters are extant and those are well enough defined, 
individual divisions can have some variations within them as 
suits those divisions' philosophies and approaches to college 
sports. That is what exists today. But the differentiation 
between a Division III school and a Division I school is not 
just financial. It is also what does that school want, what 
level do they want to participate in intercollegiate athletics. 
And there could be variation in how this is applied as well 
depending on where those schools wanted to go.
    Senator Thune. This has been suggested and, Mr. Huma, Mr. 
Spencer, maybe comment on this. But this has been socialized 
with the professional sports leagues, for example, the NBA or 
the NFL, some discussion about perhaps removing anything that 
would impede an athlete from going pro right out of high school 
and just allow them to go up and take advantage and get paid 
right away. Has there been discussion about that? And does that 
make sense? And if not, why would it not make sense?
    Mr. Huma. That is definitely something we support. Players 
should have options. They should not be forced into college if 
they do not want to go to college and if they have the talent 
to go on another level. I know that is not an NCAA issue. It is 
actually a collective bargaining agreement issue between the 
unions and the sports leagues.
    Now what is an NCAA issue is that if a player enters the 
draft and gets drafted low, does not like where they are 
drafted or does not get drafted at all, those players are not 
allowed to stay in NCAA sports. And this is supposed to be 
about education. Entering the draft is more of a testing the 
waters kind of thing, seeing where you can be. This is about 
education. Why kick those players out when they have not 
stepped foot at a pro level contract, pro level practice, pro 
level competition? So those are the concerns around drafting.
    Senator Thune. But is there a way that that could be 
structured so that athletes who have the skill level to go to 
that next--I understand it is about education, but a lot of 
cases, the one-and-done schools--their athletes are going up 
after they fulfill their requirements at the collegiate level. 
Is there not a way in which you could allow some of these 
athletes, if they have that skill set--I know what you are 
saying is it would take changes within leagues and in the 
unions. But would that partially help solve the problem we are 
talking about here, which would be allowing athletes to capture 
the value of their skill?
    Mr. Huma. I do not think it comes close to solving the 
problem for college athletes as a whole. You know, at the end 
of the day, these are freedoms that every player across all 
divisions--if they want to go and throw a camp at their old 
high school--if you are a college athlete, you are somebody at 
your old high school. You can throw a camp at your old junior 
high or elementary school, do an autograph signing back home. 
You can start a small business.
    And we have not got into it, but some of the restrictions 
impede on freedom of speech. If you are a Christian athlete--a 
fellowship of Christian athletes--and someone wants to pay you 
to write a blog about your experience as a college athlete, the 
NCAA would prohibit that. That is highly protected speech. We 
are talking about religious speech. It is restricted by NCAA 
rules.
    So this is far beyond just the elite athletes. This is the 
everyday athlete that really deserves the same freedoms and 
rights as every other student and every other American.
    Senator Thune. And I know it is a challenge for all the 
reasons we are talking about this morning, but it does seem, as 
someone who represents a state with major universities that are 
not part of the Power Five conferences, how you structure this 
in a way that is fair and that does not create disincentives 
for some of those smaller but very good schools to attract and 
recruit good athletes to their program. So I am sure this will 
be an ongoing discussion.
    Thank you, Mr. Chairman.
    Senator Moran. You are welcome.
    Senator Blumenthal.
    Senator Blumenthal. Thanks, Mr. Chairman.
    This has been a very, very instructive hearing, and I want 
to thank all of you for being here today, especially the 
Chairman for his leadership in bringing us together.
    You know, John F. Kennedy famously said life is unfair, and 
life is unfair. Not all of us are born with the athletic 
prowess that others have, which I say as a college athlete of 
very, very limited ability as a swimmer who never would have 
had any access to any NIL compensation. But there are ways to 
overcome some of these challenges in a way that is fair.
    And, Dr. Emmert, let me just ask you. In 2018, the NCAA 
implemented new rules to allow basketball players to sign with 
agents, but those rule changes did not apply to women. Is that 
unfair?
    Dr. Emmert. Senator, I think the question of representation 
is a very, very important one. The rule that you are talking is 
an evolution that came out of our trying to address some of the 
issues that Mr. Huma was just mentioning, trying to line up 
more effectively the professional draft system with the 
opportunities that may or may not occur for student athletes. 
So the athletes in men's basketball to be able to have 
representation when they go into a draft conversation with 
professional sports ranks and still have the opportunity then 
to go undrafted, come back and continue to compete--that was 
the very first time that it has ever been done. It is my hope 
that we can have a model put in place for women and all student 
athletes that mirrors and models that approach. It is one that 
has been tried. It has been working successfully now for a 
year. I think the members saw it as a pilot project, and I hope 
that we can extend it to all----
    Senator Blumenthal. Well, coming from a state that takes 
great pride in our women basketball players, I think it is 
desperately unfair, and I hope you will correct it.
    Let me ask you, Dr. Emmert. When a school gives a one-year 
scholarship and then kicks the young athlete out of school 
because of an injury at the end of that scholarship, if that 
injury prevents him or her from playing, that is unfair. Is it 
not?
    Dr. Emmert. It is in my mind, yes, sir.
    Senator Blumenthal. And the kinds of practices, it seems to 
me, where an athlete works hard and the name and image and 
likeness become of such value that the school can make money 
from it but the athlete gets nothing strikes me as unfair. Do 
you agree?
    Dr. Emmert. Senator, I believe that is precisely why we are 
sitting here is to try to find a way to address that issue.
    Senator Blumenthal. And the fact that very often athletes 
exceed the 20-hour limit in practice, in fact exceeded by a lot 
I am told in many schools, just compounds the unfairness. Does 
it not? Because they work hard to gain that athletic ability.
    Dr. Emmert. Yes, Senator. Student athletes work incredibly 
hard at both their athletic and their academic endeavors. We 
strive very hard to create a rules structure that creates a 
more appropriate balance between their academic and their 
athletic lives. Indeed, the rules were changed just this last 
year to do exactly that, and we will continue to strive to do 
so.
    Senator Blumenthal. And in a lot of schools there is no 
provision for insurance paid by the school. In other words, 
athletes may be covered by insurance, but they have to pay for 
it themselves. That strikes me as unfair.
    Dr. Emmert. The requirement, Senator, for student athletes 
is that they have insurance coverage. In many cases that is 
their family's insurance policy that is already existing. In 
many others, it is by the schools' insurance policies 
themselves, and in all cases there is an umbrella covered by 
the NCAA for catastrophic injury.
    Senator Blumenthal. But as you said, many families have to 
cover their athletes' insurance out of their own pockets, and 
that seems unfair to me.
    I want to just finish by saying that there are various 
different models for dealing with the issues that Senator 
Capito raised, for example, the financial inducements to 
athletes who may not be stars. New York has a bill that focuses 
on NIL compensation but it allows athletes to receive 15 
percent of revenue made from ticket sales. If that were 
distributed evenly among the team, there would be some 
financial compensation even for the athletes whose names do not 
become marquis attractions. There are all kinds of ways to deal 
with some of these complexities.
    And I think that the challenges here, although they are 
difficult and complex, are less so than the challenges athletes 
overcome every day to provide the performances on the field 
that they do. The mental and physical challenges of athletes 
doing what they do on college teams these days certainly are 
extraordinarily impressive, and I think we ought to match their 
courage and skill with what we do in this Congress and on this 
committee. And if we do not at the Federal level, they will at 
the State level. And those Florida and New Jersey and New York 
bills that I mentioned are on their way to passage, if not 
there, in other states. So the leadership that we need in this 
area is very much urgent and immediate.
    Thank you.
    Senator Moran. Senator Blumenthal, thank you.
    Let me run through a series of questions that I have and 
perhaps we will conclude then.
    Mr. Huma, first of all, you promote states making the 
decisions and pursuing their path in their state. What we were 
designed to talk about today was name, image, and likeness. I 
would take from your testimony that if we were successful or 
the NCAA was successful in developing a program that rewarded, 
compensated athletes for NIL, that would be insufficient and 
that would then lend itself toward the next step of additional 
compensation or other ways of compensating what are today 
amateur athletes?
    Mr. Huma. No. My only concern with Federal law is that it 
rolls back what the states are doing. And really, though there 
are about 28 states in play, the legislation looks very 
similar. It is independent representation and it is freedom on 
name, image, and likeness. While there could be some additional 
guardrails in terms of recruiting incentives, incentives for 
transfer, there is not any artificial caps. It looks like what 
America looks like. It looks like--you know, it is similar to 
the other leagues. If you are a free agent and you go 
somewhere, you are on a team, you are free without restrictions 
to get endorsements in whatever area that team happens to be 
in.
    But the concern is if the Federal Government acts and 
acquiesces and grants the NCAA an antitrust exemption, which it 
has already abused without an exemption, there is an extreme 
trust gap. We have seen what the NCAA has done as if it had an 
antitrust exemption. So those are the issues.
    But it could be positive. If it was a good bill, it could 
be definitely positive.
    Senator Moran. Let me ask the question a different way. If 
NIL became the rule of the land, however that comes about, 
Congress, the NCAA, and amateur athletes were compensated for 
their name, image, and likeness, then would there be other 
steps that the athletes would take for additional compensation? 
And while you said the states generally have similar kinds of 
legislation that are pending, New York and ticket revenue would 
be and outlier. And my question is intended to get to would 
this be sufficient to satisfy the problems you see for college 
athletes today if NIL was addressed and addressed 
appropriately.
    Mr. Huma. That basically is economic justice from our 
perspective. We have been advocating for. I think a lot of it 
would be in the details because as we have said, this is a 
multibillion industry. So if we are talking about crumbs, then 
absolutely not. If players truly got real economic justice that 
reflected their value, that might be a whole other 
conversation. It would be hard to say without any details.
    Senator Moran. I am not trying to prejudge anything. In 
many of the things I get involved in, the argument against 
something is do not do it. It is the camel's nose in the tent. 
And I was trying to figure out if there is something more on 
the horizon that then is required beyond NIL. And I take it 
your testimony is NIL, if done appropriately, provides economic 
justice that you are looking at for the players.
    Mr. Huma. It does. Again, without the details--I think we 
have different opinions about what that justice would look 
like, but potentially.
    Senator Moran. Thank you.
    Mr. Spencer.
    Mr. Spencer. Yes. Thank you, Chairman Moran.
    That idea assumes that every single athlete is going to 
have the brand to capitalize off of NIL. What we end up looking 
at is the truth that NIL, while it might be a solution, it is a 
solution to a different problem. Quite frankly, when it comes 
to the compensation, if we are looking at that as the broader 
issue here, we have to really evaluate how much compensation a 
student athlete is actually going to be able to receive if we 
go to that type of model.
    Individuals earlier mentioned the New York situation. That 
15 percent then would probably roll out of either the 
university or other different parties, and that means that 
money is not going into those athletic facilities. And for me 
as a student athlete, I want that. I really appreciate having 
upgrades to my facilities. They have got a new toy at 
Georgetown University, when I go lift, that measures your bar 
speed, and for a track and field student athletes to be able to 
know how fast I am moving the weight is incredibly beneficial. 
So these are the kind of things that we are looking at, but as 
we move forward, we have to really examine whether or not NIL 
is the appropriate model to give student athletes the adequate 
compensation that is discussed.
    Senator Moran. Well, Mr. Spencer, you lead me into my 
second question, which is my concern is--you are in front of a 
committee that has lots of members from rural states with small 
schools. You, from New Mexico, have an understanding of those 
schools. I want to make certain we take care of athletes who 
are not necessarily in the sports that generate significant 
revenues or profits at universities. And I think Mr. Huma--as 
we have had this conversation, he has come back to many of my 
concerns to tell me, to tell the Committee that those 
disparities already exist.
    So when I began the hearing, toward the top of my priority 
is how do you take care of places that the schools are small, 
the programs do not generate a lot of revenue, there are sports 
within those schools that are not moneymakers? You want to take 
care of women and the issues of Title IX.
    And the question is to me is, does this, does NIL, solve--
does it create more problems in that regard? Does it create 
greater disparities between the tops schools and the top 
athletes and the top programs in the top sports? Is there a 
greater disparity that occurs because of NIL, or do all those 
problems--that disparity that I am worried about that comes 
from compensation--already exist and this is not a relevant 
topic to that disparity?
    Mr. Spencer. Chairman Moran, if I may. You hit the nail 
right on the head. Even if some of these disparities exist, we 
do not create something that then exaggerates those issues.
    Senator Moran. The question is this would then exaggerate 
those issues.
    Mr. Spencer. Absolutely. This is also one of the reasons 
why this is such a complex discussion that involves all hands 
on deck, the student athletes, the senior women administrators. 
This is one of the reasons why it takes as long as it does 
because in order to adequately answer the question of what 
success looks like, you need all of the stakeholders at the 
table having that discussion, and that is something that cannot 
be done overnight.
    Senator Moran. Mr. Huma has been strong in outlining his 
belief that the disparities exist today. And I do not have any 
reason to dispute that they do exist. Is there anyone, Dr. 
Girod or Dr. Emmert or Mr. Bowlsby, that would comment on NIL 
and those disparities? Are they exacerbated? Are the challenges 
made more difficult? Or does this help address the issue?
    Dr. Emmert. Yes, Senator. Well, I will ask my colleagues to 
address it as well, since they are on campuses, directly.
    Yes, indeed, it would exacerbate it, and that is part of 
the conversation about how can we create a model that has some 
form of guardrails that can mitigate some of those issues. But 
there is little doubt that it would, in fact, create greater 
disparities between schools and in some cases between the 
athletes themselves. That in and of itself may not be a reason 
not to pursue it, but it has to be done in a very thoughtful 
manner.
    Senator Moran. Mr. Bowlsby, you talked about Texas and 
Oklahoma, a couple of schools that we are well familiar with, 
and the difficulty they would have within the conference if 
Texas had different rules than Oklahoma in regard to NIL 
compensation. So do those advantages and disadvantages exist 
today?
    Texas to me is the place where the TV markets are within 
our conference. So are we solving a problem or adding to a 
problem with name, image, and likeness? Is recruitment more 
difficult one place than another already?
    Mr. Bowlsby. Thank you for the question, Senator.
    I believe recruitment will be made infinitely more 
contentious. There will be more disagreements among 
institutions as to who did what and who offered what, or was it 
the institution or was it an outside entity? Was it a third 
party?
    Essentially my thoughts on this are we need to modernize, 
and there is not any doubt about it. We need to continue broad-
based programming that takes Title IX into account. We are not 
the NFL or the NBA. We do not have a draft and we are not the 
Olympics. You do not have the prerogative to compete for 
anybody other than your own country. The liberalization and the 
modernization is something we should absolutely do, but it 
should not be per se pay for play and it should not be a proxy 
for pay for play.
    And so with that caveat, as I said in my statement, between 
the idea and the reality there is a shadow. How do you treat 
student athletes fairly? How do you put more money in their 
pocket? How do you allow them to use their name, image, and 
likeness without it entering into the choice of institutions or 
the choice of transfer?
    I would have hoped that Senator Thune was in the room for 
this comment, but one of the practical outcomes of this will be 
when you get to be a high profile athlete at the University of 
South Dakota, you will be recruited away with inducements to 
play at a higher level. And if there is no penalty for 
transfer, it will be an open market of recruitment. The concept 
of an unregulated recruitment environment and an unregulated 
transfer environment I think is an absolute certainty in this 
environment.
    Senator Moran. The issue of amateurs--in other words, that 
is not an employer-employee relationship--does NIL itself, with 
whatever we define as appropriate guardrails--does it change an 
athlete from being an amateur to an athlete being an employee 
of the university or the athletic department? Is there enough 
in NIL that legally changes the relationship between team and 
player?
    Dr. Emmert. Senator, if I might address that one. I think 
it depends. Should it be the case that the institution, that a 
university, was in fact orchestrating the NIL payment, if a 
university was in the midst of brokering those sponsorship 
arrangements, for example, I believe it would be extremely 
difficult to differentiate that from an employee-employer 
model. With sufficient guardrails to assure that this is being 
conducted by a truly independent third party, it is certainly 
possible that it might not, but that again is one of the 
details and challenges of working out this model.
    Senator Moran. The notes I have made today that NIL would 
have a consequence on recruitment inducements is my note. What 
would occur in nonprofitable areas of the country or in 
specific teams, the employer-employee relationship, not 
amateur, consequences to Title IX. Somewhat related to the 
issue of profitability but large schools and small schools, the 
consequence, the recruitment that you just outlined in regard 
to South Dakota. I do not know that that list is all 
encompassing, and rather than take the time of the moment, I 
would ask any of you to lengthen that list or shorten that list 
for me as to what concerns we ought to have about NIL.
    I think I am just about done. Let me ask Dr. Girod one 
question. You indicated, Dr. Girod, in your testimony about 
inextricably linked with the university model, and you 
highlighted some of the things that were involved in that and 
what athletics means to your university or to a university in a 
number of areas. I want to give you the chance to reiterate or 
highlight that component of why an amateur team or teams on 
campus is important to a university. We have talked about what 
this means to an athlete, the ability to get an education and a 
wider array of benefits. Why is having a sports team at a 
university important to the university community?
    Dr. Girod. Thank you, Senator, for the opportunity to 
reiterate that and recognize that collegiate athletics is 
unique in the world. It does not exist anywhere else in the 
world. It is part of what makes our universities the envy of 
the world. It is part of what keeps--it attracts students. It 
attracts faculty. It keeps our alumni engaged. It keeps our 
donors engaged, and it creates a campus life that really cannot 
be replicated anywhere else. That benefits earlier student 
athletes, and we have talked about how that is so today. But 
certainly it creates tremendous benefit for our students and 
the experience that they have while they are pursuing their 
education and equally growing into adults.
    Our athletics department does not fund the university. 
Fortunately, our university does not fund our athletics 
department either. So we are blessed in that regard.
    But the benefits that the university gains, again, being a 
Midwest university where we are reliant on out-of-state student 
recruitment, being on a national stage on a regular basis--you 
cannot replace that.
    Senator Moran. Let me ask a question specifically related 
to the University of Kansas and how it would then have a 
broader consequence or an understanding. So we are a successful 
basketball program at the University of Kansas historically and 
currently. And the concern has been the ability for schools to 
recruit athletes in other places. Even though the University of 
Kansas has such a successful basketball program, what is the 
consequence in regard to the ability for the University of 
Kansas to compete for athletes to come play basketball with 
NIL?
    Dr. Girod. Well, I would not disagree with some of the 
comments, that there are some disparities in the system today. 
Those do have somewhat to do with the size of athletic budgets. 
They also have to do with history and they have to do with the 
success of student athletes that come to our institutions.
    But reality is today we all play by the same rules, and 
that does not completely eliminate the disparities but at least 
we are recruiting on the same rules. And we could just as 
easily lose a student athlete to any of the other conferences 
or to non-power conferences because we all play by the same 
rules, and it is about student choice and student fit.
    Potentially going into an unregulated environment, as 
Commissioner Bowlsby has mentioned, I think profoundly limits 
the ability of a school in a town of 100,000 people to compete 
in a media market.
    Senator Moran. Thank you.
    Mr. Huma, my last question is to you. Your testimony makes 
clear that you have concerns with the NCAA representing student 
athletes in NIL commercial agreements. You indicate that--I 
think this is a quote--is not necessary for government to 
appoint a college group licensing entity. What type of entity 
is appropriate for that role?
    Mr. Huma. So there are group licensing organizations. 
Actually in the run-up to the California bill, when it was 
imminent that the bill would pass, I wanted to make sure that 
college athletes had a good vehicle for group licensing like in 
some of the other leagues. So I reached out to the NFL Players 
Association. They have their own licensing company called 
Players, Inc. It turns out they were in the middle of a kind of 
a big collaboration with major league baseball players 
associations, licensing company because name, image, and 
likeness globally is under-utilized. So when I discussed these 
options with them, they said they would be happy to help.
    If these opportunities opened up for college athletes, 
group licensing is a powerful vehicle. You know, if you are 
familiar with the video games, for instance, it is one of those 
things where players receive an equal share of distributions 
regardless of if they are the first string quarterback or the 
third string lineman.
    In college sports, it is very critical. In the O'Bannon 
case, as matter of fact, a law, there was a group licensing 
market that was recognized, which includes video games. It 
includes TV broadcasts. It includes archival footage, 
advertisement, merchandise. And I think it sounds like we agree 
that the school should not be providing those kinds of 
representations. It is possible maybe there would be an 
employee-employer relationship established so they get 
involved.
    But in those instances, for instance, if there was 
merchandise and there is a jersey, it could be up to the 
apparel company to initiate some kind of a communication with 
the school and with the licensing company to say, hey, we would 
not be able to do these things. We are willing to pay. The 
apparel company pays the licensing company. So the players get 
their distribution, and they also pay separately the schools or 
whatever entity, collaboration, whether it be other forms of 
group licensing opportunities. But the third party is the 
source of payment.
    And our concern with the NCAA is that there is a big 
conflict of interest that they have already acted on because by 
de facto, which was also in the rulings, it showed that the 
colleges, the conferences, and the NCAA are already selling 
players group licenses in all these different areas. They have 
given the players absolutely no money. And so that is a big red 
flag when the NCAA mentions the opportunity to group licensing 
as a matter of congressional Federal law.
    Senator Moran. It is my practice to always give the 
witnesses any opportunity to say anything that they were not 
asked that they wish they were or something they were asked 
they wish they were not and would like to clarify. If any of 
you have anything you would like to make sure is on the record, 
I would be glad to hear from you before we conclude the 
hearing.
    Mr. Spencer.
    Mr. Spencer. Thank you, Chairman Moran.
    Just a few things responding to the last comments.
    First and foremost, student athletes do not know the NCAA 
as the gentleman, Mark Emmert, to my right here. They know it 
as the people we have on campus, our administrators, our 
athletic directors, our coaches, and our staff. There is no way 
that you are going to be able to convince me or any other 
student athlete that group licensing organizations know more 
about our welfare than the individuals that we have on campus, 
and those are the individuals that I would much rather see 
handle that type of issue.
    Second of all, when we talk about NIL and the potential 
impact that it might have on the employer-employee 
relationship, we have to remember that when it comes to social 
media, that is where us as student athletes are going to 
leverage some of that. And so your compensation comes from NIL 
in the form of the content that you produce. The content that 
you produce is going to be the stuff that you demonstrate on 
the field, which is going to be through your institution. So 
that could have a bit of a legal issue in terms of how that 
relationship actually works.
    Finally, we really have to think about the way that our 
rights are executed right now when it comes to technology and 
the way that it comes executed when it comes to the right of 
publicity, which is NIL. We live in a framework that is 
digitally driven. We live in an innovation economy driven by 
social media and our influencers. And we really have to 
consider that playing field.
    More importantly, in all of these discussions--and I know 
we talked a lot about some of the failures of the system, but 
one of the best successes is the simple fact that student 
athletes--we are involved in each and every one of these 
discussions. The student athlete advisory committee is present 
on every campus in every division across the country, and that 
is why it is important to make sure that we consider that 
because in order to recognize the differences between schools 
that are in rural neighborhoods and schools that perhaps are in 
more affluent areas, we have to give student athletes the 
chance to actually help craft some of these rules. And that is 
what we do when we come together. For the student athlete 
advisory committee at the institutional, conference, and 
national level, that is what we do, and that is why we have 
been able to make the strides that we have made.
    Senator Moran. Mr. Huma.
    Mr. Huma. I just wanted to talk about the question you had 
about exacerbating the advantages and disadvantages currently. 
There is really not much room to really exacerbate it. 99 
percent of the top 100 football recruits go to the Power Five, 
and that is a reflection of the migration all the way around.
    But let us just say there are 2,500 recruits in football. 
Most of the top ones end up in the Power Five. Whether or not 
the Power Five--you know, and within the Power Five, there are 
65 schools. Let us just say 30 to 40 of them typically get the 
stronger recruits. The reason why it will not be exaggerated is 
because there are still roster limits. There are still 
scholarship limits. So no matter how many players want to be on 
one particular basketball team, they cannot go there--or 
football or basketball or any other sport. There is still going 
to be a limit of where they can go. So it is not going to 
magically produce double the amount of talented athletes. So 
that is a built-in mechanism.
    And I would suggest that Congress looking at this, knowing 
there are advantages, disadvantages of today, whether that 
changes a bit because of any given factors, I do not know that 
it would be Congress' job to cement the status quo in whatever 
power structures. We can see Clemson in the national 
championship football game with Alabama or LSU--I do not know 
that that should be the concern especially when we are talking 
about opening up freedoms and opportunities for players. It is 
much more important I think to weigh the rights of these 
players rather than any particular migration of recruits that 
is limited anyway and where those recruits end up.
    Senator Moran. Thank you. Mr. Huma, thank you. Mr. Spencer, 
thank you. Anyone else?
    Dr. Girod.
    Dr. Girod. Yes. I guess I would just like to, first of all, 
say thank you, Senator, for your leadership and willingness to 
take on this obviously incredibly complicated topic and would 
just reiterate that as we look at these issues, let us not 
forget the 98 percent of the student athletes who get an 
education and a great launch on life and will not go into 
professional athletics and have very limited ability to 
generate revenue off their name, image, and likeness.
    Senator Moran. Thank you.
    Dr. Emmert. Mr. Chairman, just let add my words of thanks 
and also let you know again that we stand ready to work with 
you and the rest of the Committee to make sure that we can move 
forward with this issue to provide greater opportunities for 
our students and preserve all those things we love about 
college sports.
    Senator Moran. Thank you.
    Mr. Bowlsby, you do not have to speak if you do not want 
to.
    Mr. Bowlsby. I will be brief. Thank you, Senator.
    I think almost remarkably we agree on a number of things. 
First, I think we all agree on the modernization of the model. 
I think we agree about broad-based programming and compliance 
with Title IX and all the opportunities that has created. I 
think we all agree with fair national competition and disagree 
a bit on how we get there. Indeed, one in five college athletes 
is a first-generation college student. The college athletic 
scholarship program is the second largest scholarship program 
in the history of our country, second only to the GI Bill. And 
so what we are seeking is a safe harbor to allow us to 
modernize and cling to the things that we find important about 
college athletics and yet make the progress that is required.
    Senator Moran. Thank you.
    My view is that each and every one of you have been 
exceptionally helpful to us, to the Commerce Committee in 
developing thoughts and about how we proceed going forward. My 
personal view is that the burden lies with those of you at that 
table at the moment, not us. But we stand--I was going to say 
able. We stand ready and willing to be helpful as we try to 
figure out how we appropriately change the status quo to the 
benefit of all athletes who attend college and get an 
education. So I appreciate what you all had to say, and it is 
very useful for me in understanding what is ahead of us.
    With that, the hearing record will remain open for two 
weeks. What that means is that members of this committee can 
submit questions to you during that time. Upon receipt of those 
questions, we would ask you as witnesses to submit your written 
answers to the Committee as soon as possible, just as we would 
hope that you would do in resolving this issue just as soon as 
possible.
    With that, the hearing is concluded and we are adjourned.
    [Whereupon, at 12:24 p.m., the hearing was adjourned.]

                            A P P E N D I X

    Response to Written Questions Submitted by Hon. Jerry Moran to 
                              Bob Bowlsby
    Question 1. Your testimony mentioned the utility of the new 
autonomy structure of the NCAA, which provides specific decision-making 
authority to the ``Power 5'' conferences related to governance of 
student athlete policies. What categories of issues or policies are 
eligible for this type of autonomy structure model determinations?
    Answer. In August of 2014, the NCAA Division I Board of Directors 
adopted a new governance structure (the ``Autonomy Structure'') 
pursuant to which the Atlantic Coast Conference, The Big Ten 
Conference, The Big 12 Conference, Pac-12 Conference, and Southeastern 
Conference, who comprise the ``Autonomy 5'' conferences in the NCAA, 
were allowed the autonomy to determine future changes in the following 
types of NCAA rules:

   Cost of attendance stipends

   Insurance benefits for student-athletes

   Non-coaching staff members and volunteer coaches

   The use of agents and their interaction with student-
        athletes

   Medical expenses during enrollment and two-years post-
        enrollment

   Mental health services and resources

   Management of student-athletes' time in light of required 
        practice schedules

    The following are some of the types of rule changes that must still 
be adopted under the shared NCAA governance rules and cannot be adopted 
under the Autonomy Structure:

   Amateurism

   Transfer eligibility rules

   Academic eligibility rules

   Enforcement and scholarship limits

   Financial aid limits

   Name, Image and Likeness (``NIL'') payments

   Recruiting rules

   Mandatory limits on time spent on sport related activities

   Division membership requirements

    NCAA rules to be adopted under the Autonomy Structure must be 
sponsored by at least one of the Autonomy 5 Conferences, approved by a 
group made up of presidents from the Autonomy 5 Conferences, and then 
adopted by the vote of either:

  (a)  60 percent of the representative 65 member schools in the 
        Autonomy 5 Conferences plus 15 student-athletes that are 
        appointed to that group (at least 52 of those 80 
        representatives) plus a simple majority of the members of at 
        least three of the Autonomy 5 Conferences; or

  (b)  51 percent (41) of the 80 representatives plus a simple majority 
        of the members in four of the Autonomy 5 Conferences.

    Question 1a. How are policies that are implemented at the ``Power 
5'' conferences through the autonomy structure considered and 
translated, if appropriate, to the other NCAA conferences?
    Answer. The NCAA conferences other than the Autonomy 5 conferences 
may decide to opt-in on any NCAA rule changes adopted by the Autonomy 5 
conferences under the Autonomy Structure so that they are applicable to 
their conference members.

    Question 2. In the case that NIL payments were permitted to be 
paid, what are appropriate or necessary protections for our student 
athletes?
    Answer.

   Academic services, academic counseling and tutoring because 
        even if student-athletes are permitted to commercialize their 
        NIL, they are not professionals, and it is critical that the 
        academic mission of collegiate athletics remain a point of 
        emphasis

   Top quality medical care, including mental wellness support, 
        which could be particularly important with the added pressures 
        that come with receiving compensation from third parties

   Career services and professional counseling

   Financial literacy training because student-athletes who 
        receive NIL payments may not have experience managing such 
        large sums of money

   Personal development support, coaching and mentorship

    Question 2a. Is it possible these payments open our student 
athletes up to wider predatory circumstances?
    Answer. Yes, particularly if agents are permitted to interact with 
student-athletes. Unscrupulous agents may seek to incentivize student-
athletes to enroll at particular universities for the benefit of the 
agents themselves, instead of acting in the best interest of their 
clients, the student-athletes. We have already seen several incidences 
of such behavior in recent years. Indeed if agents are permitted, we 
may find ourselves in an environment with even more unscrupulous third 
parties (including agents, financial advisors and the like) than exist 
today because more and more individuals consider themselves to be 
qualified agents. A much more vigorous agent preparation and 
certification process would be vital, but likely of marginal success.
    Even if agents are not permitted to participate in the collegiate 
model, boosters or sponsors who have relationships with a given school 
will be involved in recruitment and transfer decisions and may 
similarly attempt to induce recruits or transfer students to initially 
enroll in or transfer to a given school, as applicable. Such an open 
system would be very difficult to regulate.

    Question 3. While California's Fair Pay for Play Act does not 
authorize payment by the educational institution to student athletes, 
there are examples of other state legislation that do. The New York 
Collegiate Athletic Participation Compensation Act would require a 
percentage of revenue from tickets sales be distributed among the 
student athletes. Do you believe student athletes should receive 
compensation in any form from the institution or its athletic 
department?
    Answer. NCAA rules allow the school at which a student-athlete is 
enrolled to provide extensive benefits allowing schools to provide 
student-athletes up to the full cost of attending and pursuing 
completion of a degree at that institution in his or her chosen course 
of study. The rules defining what benefits can be provided by the 
school within this standard has been reviewed and revised by the NCAA 
membership from time to time, and additional changes can be considered 
in the future by the NCAA membership. However, I believe that it would 
be inconsistent with the collegiate sports model for those changes to 
allow payments to be made to student-athletes that constitute direct or 
indirect ``pay to play'' compensation, payments to induce them to 
initially enroll in or transfer to a specific school, or payments that 
would make them employees of the school.

    Question 4. In 2015, the ``Power 5'' conferences, including the Big 
12 Conference, voted to increase scholarships to include the full cost 
of attendance for student athletes, and these reforms also included 
coverage of medical care for athletics-related injuries at least two 
years out of college, increased reimbursement to family members to 
attend certain events, and allowing student athletes to borrow against 
their future professional earnings to purchase loss-of-value insurance 
to protect athletes financially should a potential career-ending injury 
occur. These all appear to be appropriate benefits to offer student 
athletes, and while I understand that the institutions that make up the 
``Power 5'' conferences are more likely to be able to offer such 
benefits to their student athletes, is it the policy of some 
institutions outside of the ``Power 5,'' including non D-1 programs, to 
offer any of these types of benefits to their student athletes?
    Answer. I completely concur that the list of additional benefits 
for student athletes you've listed are entirely appropriate and were 
long overdue when enacted by the Autonomy 5 in 2015. As I referenced in 
my earlier response to Question 1 above, the member institutions within 
the Autonomy 5 are required to offer the full cost of attendance to 
student-athletes. The other colleges and universities in Division I 
outside of the Autonomy 5 are given the option of providing the same. 
It is my understanding that the majority of those schools and an 
additional number of ``non D-1 programs'' do, in fact, offer full cost 
of attendance to many of their student-athletes.

    Question 5. If Congress decided to pursue Federal legislation 
regarding NIL payments to student athletes, a critically important 
component of such legislation would be determining what types of 
arrangements, activities, and agreements would be eligible for the 
categorical definition of an NIL payment. Do you have suggestions for 
this subcommittee as it relates to defining the NIL in statute?
    Answer. The California Fair Pay for Play Act and other proposed 
state laws require that the NCAA allow student-athletes to receive 
virtually unlimited compensation relating to their NIL, which could 
undermine the current collegiate sports model. If Federal legislation 
is enacted to preempt an unworkable patchwork of potentially 
inconsistent if not contradictory state laws, then it will be critical 
that the Federal legislation establish which existing or new body will 
determine which types of NIL compensation will be permitted, the 
limitations (or ``guardrails'') on these payments to ensure that they 
are consistent with the collegiate sports model, and how these 
determinations may differ for NCAA members of different sizes and 
resources in the three Divisions of the NCAA, consisting of 347 
colleges and universities.
    I am a member of a Federal and State Legislation Working Group 
appointed by the NCAA Board of Governors in May of last year to focus 
on exactly these NIL issues. We have collectively spent thousands of 
hours on conference calls, in in-person meetings, and in consultation 
with our members to consider many very complex and rapidly evolving 
issues involving NIL and the interrelated rules that permit student-
athletes to transfer from one school to another on a conditional basis 
after beginning their eligibility. Based on this work, I can only tell 
you at this point that I am confident that progress can be made within 
the spirit of the college sports model to modernize our rules for the 
benefit of student-athletes, but the analysis is complex, the possible 
unintended and interdependent consequences of any one action are hard 
to predict, and the best path forward has not yet become clear.
    Therefore, I respectfully suggest that instead of putting the 
burden on Congress to draft into legislation the specifics of a 
permissive NIL structure, Congress ``deputize'' in this legislation an 
existing or new body to establish and oversee this new NIL structure 
and to modify it as circumstances change in the future (without the 
need--within certain parameters -to come back to Congress) based at 
least in part on the work of the three divisional NCAA working groups 
when it is complete. If the Federal statute provides 1) the appropriate 
framework for mandating that permissive NIL compensation rules be 
adopted by this body within a reasonable time frame, 2) appoints the 
body to define the framework for these rules and any limitations 
thereon and future changes thereto, 3) provides preemptive protection 
from a patchwork of inconsistent and possibly contradictory state laws 
and safe harbors from ongoing antitrust attack of actions taken in 
compliance with the rules adopted under this Federal legislation, and 
4) a framework for and body authorized to enforce the statue's mandate, 
then I believe that prompt and constructive progress can be made toward 
adopting a modernized NIL compensation structure that aligns the 
benefits that can be earned by student-athletes for use of their NIL 
going forward with the corresponding rights of other students that are 
not athletes in a manner consistent with the underlying principles of 
the college sports model.
    You asked: ``Do you have suggestions for this subcommittee as it 
relates to defining the NIL in [the] statute.'' I find it interesting 
that few, if any, of the enacted or proposed state NIL statutes define 
what constitutes a student-athlete's ``name, image, and likeness,'' and 
to my knowledge no other state laws define these terms in the context 
of collegiate sports.
    However, the NCAA working group referred to above, of which I am a 
member, has discussed this extensively without definitive resolution to 
this point and based in part on that discussion, I offer the following. 
The concept of a student-athlete's ``name'' is relatively clear in its 
basic form: ``Jane B. Athlete.'' However, does it include nicknames 
taken by the student-athlete, nicknames proclaimed by the press or 
other outside persons, stylized adoptions of the name (such as ``J-
Bee'')--or the like? What types of uses of the name are covered: use in 
typed and broadcast print, Internet blogs, sponsorship advertisements, 
signing autographs, placement of the name on the back of souvenir 
uniforms (using the school's proprietary logos and colors), the 
student-athlete's name being used in product promotions or the student-
athlete appearing in ``influencer'' Facebook videos for which 
advertisers pay the student-athlete a fee for each ``click''?
    The concept of the ``image'' of a student-athlete also may appear 
to be fairly straight forward, such as any still photograph or moving 
video of or in which the student-athlete is included. Many of the same 
questions noted in the preceding paragraph of the types of uses of a 
student-athlete's name that are permitted could also apply to the use 
of his or her image. However, care must be taken to differentiate use 
of a student-athlete's name and image in legitimate news and 
promotional activities relating to his or her voluntary participation 
as a public figure in the sporting and other related activities of his 
or her team and school. Payment to the student-athlete for these 
traditional ``news'' and ``publicity'' purposes would clearly cross the 
line into ``pay for play.'' In contrast, certain uses of names and 
images could be commercialized without undermining the traditional 
concepts of collegiate sports, such as when a student-athlete gives 
lessons to youngsters in his or her sport at ``market rates'' or 
publishes a book on subjects not related to his or her sport.
    The ``likeness'' of a student-athlete could include much broader 
concepts and potential uses that may be much more challenging to 
define. Presumably it would include drawn or painted (in any medium) or 
virtually-created electronic depictions of a student-athlete that are 
clearly recognizable representations of what he or she looks like, 
perhaps in uniform, perhaps in sports action. Beyond this, does it 
include stylized depiction of an athlete that do not attempt to 
recreate his or her image, but include certain characteristics of the 
athlete (hair style, size or shape, characteristic athletic move, etc.) 
that could cause a viewer to conclude that likeness as being of a given 
student-athlete? Or, does it include non-stylized images, such as stick 
figures or ``automaton'' robot-like figure that just happens to use the 
jersey number of, hair and skin color of, and have statistics similar 
to those of a real student-athlete, such as might be used in an online 
or video game?
    These just illustrate a few of the complicated issues that would be 
involved in a compressive definition of what falls within the ``name, 
image, or likeness'' of a student-athlete. As a result, although a 
Federal NIL statute could include a broad and general definition of the 
concepts of ``name, image, and likeness,'' I respectfully suggest that 
the detailed evaluation and definition of these many permutations may 
be beyond the scope of a legislative structure and perhaps also could 
be delegated to the entity that is ``deputized'' to create the overall 
NIL structure and guardrails, as I described earlier in this answer to 
Question 5.

    Question 5a. What types of commercial arrangements, activities or 
agreements should this subcommittee remain wary of?
    Answer. The NCAA Federal and State Legislation Working Group on 
which I participate has identified a number of types of commercial 
arrangements that could be misused to damage the collegiate sports 
model. These include arrangements that would undermine the bilateral 
national recruiting model on which colleges and students have 
traditionally and successfully used to determine the schools at which 
students will matriculate and participate in the co-curricular activity 
of intercollegiate sports. Unlike most professional sports leagues, 
which force athletes to play for a specific pro team without them 
having any choice through a unilateral ``draft'' structure, or the 
Olympic model, in which an athlete may play only for the team of the 
country of citizenship, the long-standing, highly-competitive and 
highly-regulated collegiate model allows any student (regardless of 
where they live) to be recruited by any college that is a member of the 
NCAA.
    This bilateral choice structure (much like the graduate medical 
education residency matching program by which future doctors decide 
where to serve their medical residencies and which is subject to a 
congressional antitrust exemption), allows the student to decide to 
accept an offer to play at a given school based on the level of 
competitive experience, academic program, size, location, and student-
athlete experience that best fits his or her vision for their future. 
If the rules were to change to allow boosters or sponsors who have 
relationships with a given school to provide direct or indirect 
``compensation'' to a recruit or transfer student to induce him or her 
to initially enroll in or transfer to a given school, then the benefits 
to student-athletes of this open and bilateral recruiting process would 
be undermined.
    Other types of structures with student-athletes that masquerade as 
commercial ``endorsement'' or ``sponsorship'' arrangements that do not 
bear an economic relationship with the market value of the services 
provided by the student-athlete may in fact be arrangements disguised 
to compensate the student-athlete to play or continue to play for a 
given school, thus constituting ``pay for play'' arrangements that are 
clearly inconsistent with the traditional collegiate sports model.
    Although possibly an exceptional example, it is not at all 
inconceivable that a sponsor (such as a sports equipment supplier) that 
has strong sponsorship ties with a given school might tell a top high 
school recruit that if he enrolls in and plays at that school through 
his eligibility period, then upon graduation (or the later completion 
of his professional career) they would hire him for a four year ``paid 
internship'' (at a pay level significantly above the market rate for 
other graduate interns) to advance education.
    I am of the firm opinion that these and many other similar types of 
commercial arrangements constitute ``pay for play'' arrangements that 
would significantly damage the very underpinnings of the collegiate 
sports model that is so popular with collegiate sports fans.

    Question 6. According to the 2018 financial data collected by USA 
Today, there were only 12 athletic departments in the country that did 
not receive any support from its own institution or the state in which 
it is located. Furthermore, approximately 90 percent of athletic 
departments received over $1 million in support, and for nearly 80 
percent of departments, this support accounted for more than a quarter 
of their revenue. For instance, 91 percent of the revenue for the 
University of California-Riverside came from outside the athletic 
department, and James Madison University athletics received $41.7 
million in assistance. This demonstrates that the vast majority of 
athletic departments rely upon funding resources outside of the 
department. How will legislation like that of California affect the 
operation of athletic departments?
    Answer. As noted by the question, it has been well-documented by a 
variety of reputable sources that very few athletic departments make a 
profit and that most athletic departments rely upon a number of funding 
sources outside of the department, including student fees. I suggest 
those interested to consult the essay attached to my written statement 
by Dr. Kevin Blue, Director of Athletics at the University of 
California-Davis, which lays out the dramatic increases in expense 
trends.
    On the revenue side of the equation, mine is a discordant voice as 
I believe we have nearly reached the pinnacle of revenue growth for 
Division I intercollegiate athletics. Legislation like the newly-
enacted law in California could negatively impact the operation of 
athletic departments by diverting monies intended for athletic budgets 
directly to student-athletes and to their unregulated agents. Moreover, 
if laws like that of California become a proxy for pay-to-play and 
student-athletes are actually compensated for their performances, I 
believe you will see a further decline in attendance, season ticket 
sales and donor donations as college sports fans will balk at 
supporting what they deem to be professional athletes at their alma 
mater or home-state school.

    Question 6a. What are the negative impacts you foresee?
    I anticipate any number of negative implications in an open NIL 
system. Boosters, donors and other third parties will be involved in 
the recruitment and transfer decisions and we will find ourselves in a 
largely unregulated recruitment system. Non-scholarship and walk-on 
players will receive support from boosters, donors and third parties to 
effectively increase scholarship allocations beyond agreed upon limits.
    In addition to the tax consequences of outside income from NIL, 
there will be legitimate questions regarding taxation of other elements 
of the athletics scholarship, creating a business transaction for a few 
players and the potential for an unfunded obligation for a large 
majority of non-NIL scholarship recipients. A few football and 
basketball players will capture the vast majority of NIL opportunities 
greatly diminishing the shared experiences of the team environment.
    I believe the number of sports offered on campuses will eventually 
decline and Olympic and non-revenue sports will give way to the reality 
of Division I schools competing in a few high popularity sports causing 
an overall reduction in scholarship opportunities. As such, the 
academic priorities of some student-athletes will become an even lower 
priority on the path to the subsequent professional opportunities.
    I also envision the limitations on when student-athletes can enter 
the professional drafts will be eliminated in favor of open access 
beginning in high school.
    Lastly, while many dismiss Title IX implications as a nonissue, 
some legal experts are raising red flags. (Please see ``What Title IX 
Fallout Might NIL legislation Pose,'' Paul Steinbach, Athletic 
Business, January 2020.). I foresee institutional personnel at 
universities, acting in the best interest of a school's student-
athlete, will participate in arranging NIL opportunities for selected 
players and will thereby reintroduce questions about the 13 components 
of Title IX.

    Question 7. Amateur athletics has major participation through the 
NCAA but it also covers many athletes who participate on our Olympic 
teams. What impact could these NIL payments have on U.S. Olympics?
    Answer. Having served two terms on the United States Olympic 
Committee, I have significant concerns that an open, unregulated NIL 
system will weaken our Olympic sports on campus and compromise our 
Nation's desire to send our country's best athletes to international 
competitions. As my written statement predicts, while all college 
sports participants might be alleged to have equivalent opportunities 
to profit from name, image and likeness activities, I believe that the 
present discussion is principally about football and men's basketball 
players. It is my strong belief the participants in these two sports 
will harvest the vast majority of NIL opportunities. It follows that 
this disparity in NIL payments will ultimately diminish other sports on 
campus. This diminishment could come in the form of reduced 
scholarships, budget declines or even sport eliminations. Because more 
than 80 percent of our Summer Olympians come through college programs, 
any damage to Olympic sports on campuses could have a profoundly 
negative outcome for our international Olympic efforts.
                                 ______
                                 
    Response to Written Question Submitted by Hon. Dan Sullivan to 
                              Bob Bowlsby
    Question. What role do you foresee Sports Agents playing in college 
athletics after the State laws begin taking effect?
    Answer. Senator, your question suggests the absence of a uniform 
Federal standard and that scenario is extremely problematic. Some of 
the state initiatives share similar provisions with each other; others 
are radically different. Many of the proposed measures at the state 
level have effective dates well in the future and provide the NCAA 
Working Group with ample time to create a workable NIL system. Other 
states have immediate effective dates. Such a patchwork of disparate 
laws would present an enormous challenge to the NCAA and its member 
institutions. My concern has always been focused on the unique national 
recruitment environment currently in place and an NIL system with 
unregulated sports agents will favor an institution in one state over 
another, depending upon that state's law.
    In addition, the real-world impact of ``sports agents playing in 
college athletics'' are significant and disturbing. Student-athletes 
will have agents and managers and their representatives will 
participate in many aspects of their lives on campus. College recruits 
will come to campus with pre-existing agent relationships and 
established business ventures. Coaches will have to recruit the player, 
his family, and the prospective student-athlete's agent. Boosters, 
donors and other third parties will develop relationships with sports 
agents in an effort to impact the student-athlete's recruitment and 
transfer decisions. An open NIL/pay-for-play model evokes unscrupulous 
and unworkable scenarios. It is my belief that a patchwork of state 
laws will not be successful in governing interstate competition and, 
therefore, Federal regulation will eventually be required.

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                                 ______
                                 
    Response to Written Questions Submitted by Hon. Roger Wicker to 
                            Dr. Mark Emmert
    Question 1. There are a growing number of states that have adopted, 
introduced, or signaled plans to introduce legislation similar to the 
law in California. How would the NCAA handle a potential situation 
where there are 50 state laws governing the use of student-athletes' 
name, image, and likeness?
    Answer. Conducting intercollegiate athletics with a patchwork of 50 
state laws is untenable. Absent a national standard, the NCAA would 
need to examine a variety of options, including a potential 
constitutional challenge based on violations of the commerce clause. 
Collegiate athletic competition and the recruitment of student-athletes 
is an inter-state activity, and the success of intercollegiate 
athletics is based on the concept of national competition and national 
championships.
    For example, if a prospective student-athlete who lives in Oklahoma 
is being recruited by institutions in Oklahoma, Florida, and Maryland, 
it is unclear which state's rules would apply. The student might be 
subject to inconsistent rules, which would be difficult and unfair for 
the student to navigate without jeopardizing his or her eligibility to 
play. An institution might be subject to one set of rules when 
recruiting a student in one state and another set of rules when 
recruiting a student in another state, creating confusing and 
burdensome compliance obligations, jeopardizing the eligibility of 
individual players and even the entire team. And any discrepancies 
between states would advantage or disadvantage an institution based on 
its location or the location of a recruit. That uneven playing field 
would then undermine the fairness of intercollegiate athletic 
competitions.

    Question 2. How will athlete compensation impact non-revenue 
generating sports at universities?
    Answer. As the NCAA works to modernize its rules to allow student-
athletes to take advantage of NIL opportunities, we worry about the 
consequences to student-athletes playing non-revenue generating sports, 
including whether women would have equitable opportunities. There is 
the possibility that student-athletes in sports attracting larger fan 
bases would dominate the NIL opportunities. Further, those few students 
might detract from an institutions overall athletics budget, which 
could result in the elimination of varsity sports.

    Question 3. What policies and procedures does the NCAA have 
implemented to prevent and eliminate doping in college athletics?
    Answer. The NCAA is committed to the prevention of drug and alcohol 
misuse and to protecting the integrity of its competitions. The NCAA 
Drug Testing Program, clear policies, and education programs protect 
and deter student-athletes from using both performance-enhancing and 
recreational drugs.

   As a condition and obligation of membership, institutions 
        must abide by the requirements set forth in NCAA legislation 
        (Constitution 3.2.4.8) which requires, among other things, that 
        all active member institutions educate athletics staff (e.g., 
        administrators, coaches) and student-athletes about banned drug 
        classes and banned substances including the risks of 
        nutritional supplement use.

   The NCAA Drug Testing Program is robust, executing well over 
        12,500 tests annually. Testing occurs year-round (including 
        summer), and during championships. Individuals selected for 
        testing are given less than 24-hour notification. Should a 
        student-athlete fail to appear or provide a sample, they are 
        sanctioned as if they had a positive test for a performance-
        enhancing drug.

   The NCAA Committee on Competitive Safeguards and Medical 
        Aspects of Sports (CSMAS) is an Association-wide committee 
        which has oversight of the NCAA drug testing program. This 
        committee includes physicians and other health care providers 
        with expertise in drug testing and drug education. CSMAS, 
        working in concert with the NCAA Sport Science Institute (SSI) 
        staff consistently reviews and evaluates data and emerging 
        science to ensure that the NCAA drug testing program policies 
        and procedures reflect contemporary and appropriate standards.

   The NCAA Drug Program Booklet includes all NCAA drug testing 
        program policies and procedures and is used by those on campus 
        responsible for assisting with execution of the drug testing 
        program. Campus personnel are made aware of any changes to the 
        program prior to the start of each academic year. In addition, 
        the booklet provides a drug education framework for member 
        schools to use and assists them in conducting adequate drug 
        education for their student-athletes.

   SSI has also developed a Substance Abuse Tool Kit, which is 
        endorsed by 14 leading higher education and medical 
        organizations in the country. It provides recommended 
        approaches and evidence-based resources for administrators to 
        address the use of alcohol, cannabis, prescription drug abuse 
        and more.

    Question 3a. How are the NCAA's anti-doping policies different from 
those of the U.S. Anti-Doping Agency?
    Answer. The NCAA generally aligns with the U.S. Anti-Doping Agency 
because it understands the importance of shared and internationally-
recognized standards. It also regularly consults with the director of 
UCLA's drug testing lab (one of only two WADA-accredited labs in the 
United States) regarding emerging trends and evidence-based science 
related to banned substances and lab analysis.
    For reasons that are unique to the NCAA, like the fact that our 
athletes are also students, or because our 1,100 member institutions 
have unique and varying philosophies, the NCAA drug testing program has 
some differences in purpose and policy from USADA. Such differences 
include:

   USADA tests only Olympic-level athletes. In contrast, the 
        NCAA oversees drug testing for 500,000 student-athletes, and 
        only one-percent of these student-athletes become Olympic or 
        professional athletes

   USADA provides advanced notice to those Olympic athletes who 
        may be tested year-round. The NCAA provides no advance notice 
        to ANY student-athlete, and we conduct year-round out-of-
        competition testing in addition to championships testing.

   The NCAA tests more athletes out-of-competition than does 
        USADA.

   The NCAA has a more rigid marijuana/cannabis policy in place 
        than USADA, and uses a threshold that aligns with professional 
        sports. This means that a student-athlete will be disqualified 
        at a lower level than USADA, and it is a threshold that has 
        more evidence basis than that of USADA.

   The NCAA has in place a more rigorous pain management/opiate 
        deterrence model in place--one that was created by the NCAA 
        Chief Medical Officer, who was also co-Chair of the 
        International Olympic Committee's summit on pain management in 
        elite athletes.

   The NCAA does not share information in the same way as USADA 
        because of FERPA rules.

   The NCAA utilizes a different threshold for testosterone, 
        which is based on the scientific analysis of thousands of test 
        results. However, for any world record, the NCAA works with 
        USADA and they oversee drug testing in these circumstances.

   The NCAA does not perform blood tests at present because of 
        concerns with the general student-athlete body. We are actively 
        investigating performing finger sticks as an alternative to 
        venous blood drawing. Because of blood drawing concerns, we do 
        not test for human growth hormone at present but hope to do so 
        once we can utilize the finger stick method. However, for world 
        level athletes, as noted above, blood testing under the 
        direction of USADA may be performed.

   The NCAA widely socializes the Substance Abuse Prevention 
        and Intervention Tool Kit (referenced above). This tool kit is 
        endorsed by 14 of the leading higher education and medical 
        organizations in the country. USADA does not have in place such 
        an endorsed educational program.

    Question 3b. Has the NCAA considered aligning its anti-doping 
policies with those developed by the U.S. Anti-Doping Agency?
    Answer. Please see answer to previous question. Despite the 
identified distinctions, the NCAA is very aligned with USADA. Both 
organizations test for and ban the same category of drugs. It is 
especially noteworthy that both organizations ban and test for 
erythropoietin.
                                 ______
                                 
    Response to Written Questions Submitted by Hon. Jerry Moran to 
                            Dr. Mark Emmert
    Question 1. In the case that NIL payments were permitted to be 
paid, what are appropriate or necessary protections for our student-
athletes?
    Answer. The NCAA Board of Governors provided its initial direction 
about the safeguards necessary to preserve college athletics, but some 
of those potential safeguards may leave the NCAA vulnerable to legal 
attack without Congressional action. The NCAA believes that the 
following safeguards will help protect the student-athlete:

   Transparency around the NIL activity.

   Avoidance of transactions intended to induce a young person 
        to choose to play for an institution based on financial 
        motives.

   Avoidance of using NIL activities as a means to pay a 
        student for his or her athletic performance.

    Question 1a. Is it possible these payments open our student 
athletes up to wider predatory circumstances?
    Answer. Unfortunately, there are those who already try to lure 
student-athletes to sign long-term contracts with onerous terms without 
visibility and accountability and allowing student-athletes to benefit 
from certain NIL activity may bring the temptation to engage in similar 
predatory conduct in the NIL context. To help protect student-athletes 
from such practices and to help them achieve financial benefits in a 
more equitable manner across the race, gender, and economic spectrums, 
the NCAA would impose transparency requirements on any permitted NIL 
activities and allow student-athletes to use professional services with 
appropriate institutional and NCAA oversight.

    Question 2. While California's Fair Pay to Play Act does not 
authorize payment by the educational institution to student athletes, 
there are examples of other state legislation that do. The New York 
Collegiate Athletic Participation Compensation Act would require a 
percentage of revenue from tickets sales be distributed among the 
student athletes. Do you believe athletes should receive compensation 
in any form from the institution or its athletic department?
    Answer. Any compensation by an institution raises structural 
challenges, as all agree that the intent of allowing NIL opportunities 
is not to make student-athletes employees of his or her institution. 
New York's legislative proposal to compensate student-athletes based on 
athletics department revenue would lead to a variety of unintended 
consequences, including employment consequences. A state law 
requirement to compensate student-athletes beyond permissible benefits 
amounts to ``pay for play,'' which the NCAA's governing bodies do not 
believe is appropriate. For the vast majority of athletics programs, a 
revenue sharing model with student-athletes could divert funds now used 
to provide educational and sports participation opportunities resulting 
in a reduction in both.

    Question 3. If Congress decided to pursue Federal legislation 
regarding NIL payments to student athletes, a critically important 
component of such legislation would be determining what types of 
arrangements, activities, and agreements would be eligible for the 
categorical definition of an NIL payment. Do you have suggestions for 
this subcommittee as it relates to defining the NIL in statute?

    Question 3a. What types of commercial arrangements, activities or 
agreements should this subcommittee remain wary of?
    Answer. The NCAA believes that legislation does not need to have 
specific provisions that regulate the permissible NIL transactions of a 
student-athlete. Rather, Congress can recognize the extensive 
engagement by the NCAA's governance boards and validate their 
discretion to make reasonable rules. Further, rapid advancements of 
technology could make NIL definitions outdated at the time of passage 
or soon after. Congressional recognition of the NCAA's authority to 
regulate in this space would allow for more nimble adjustments to 
student-athlete opportunities as circumstances change.

    Question 4. According to the 2018 financial data collected by USA 
Today, there were only 12 athletic departments in the country that did 
not receive any support from its own institution or the state in which 
it is located. Furthermore, approximately 90 percent of athletic 
departments received over $1 million in support, and for nearly 80 
percent of departments, this support accounted for more than a quarter 
of their revenue. For instance, 91 percent of the revenue for the 
University of California-Riverside came from outside the athletic 
department, and James Madison University athletics received $41.7 
million in assistance. This demonstrates that the vast majority of 
athletic departments rely upon funding resources outside of the 
department. How will legislation like that of California affect the 
operation of athletic departments. What are the negative impacts you 
foresee?
    Answer. Most institution athletics budgets rely upon third-party 
program and sport sponsorships to provide maximum participation 
opportunities for their male and female students. Individual, 
permissible NIL payments from third parties to student-athletes will 
not go to benefit the program and there is some concern that those 
individual payments will reduce sponsorship opportunities for the 
institution. The NCAA should be given the authority to protect campus 
athletics budgets or allow conferences and institutions to pass 
policies that would protect maximum participation opportunities so that 
new sports can continue to be added and student-athletes' academic, 
health and safety, equipment, and nutritional needs will continue to be 
met.

    Question 5. Your testimony mentions the unique principle of 
student-athlete recruitment in which the student-athlete is empowered 
with the choice of where to attend school, and that no other model in 
sports is like it, professional sports nor the Olympics. Why is this 
such an important fact to consider? How could laws at the state or 
Federal level impact this principal unintentionally?
    Answer. Many of the NCAA rules on student well-being and 
competitive balance address aggressive school booster and coach 
recruiting tactics. There are bad actors for whom regulation is needed, 
just like in any other environment. Techniques to ``buy'' student-
athlete participation, to choose to play for a school or to transfer to 
a new school, are especially pernicious. Inducing students through 
payment disrupts their school choice and perhaps even their progress 
toward graduation. These impermissible payments devalue the academic 
mission of our campuses. Federal legislation giving the NCAA clear 
authority to prohibit NIL payments that are disguised ``pay for play'' 
payments will be vital to the success of offering appropriate NIL 
opportunities to students.

    Question 6. The NCAA has a process of determining the amateurism 
status of a current or prospective student-athlete at a Division 1 or 2 
institution. This process includes an ``amateurism certification'' 
initiated by registration with the NCAA's Eligibility Center. What are 
the major functions of the Eligibility Center, particularly as it 
relates to the'' amateurism certification?''
    Answer. The NCAA Eligibility Center is charged with certifying the 
academic and amateur status of incoming NCAA Divisions I and II 
student-athletes in accordance with NCAA Bylaws 12 and 14. For 
amateurism certifications (NCAA Bylaw 12), students respond to a series 
of Eligibility Center registration questions regarding their sports 
participation history. Upon review, additional information may be 
requested. Students must also submit a request for their final 
amateurism certification beginning April 1 (fall enrollees) or October 
1 (winter/spring enrollees). Outcomes of the amateurism review are 
either Final Certified, Final Not Certified or Final Certified with 
Conditions. A member institution may submit a waiver request if it 
believes relief from the application of NCAA legislation is warranted 
for a particular student.

    Question 6a. Is there an ongoing eligibility oversight and 
compliance responsibility that the Eligibility Center is required to 
uphold?
    Answer. The NCAA Eligibility Center's oversight is limited to 
initial academic certifications (based on the student's high school 
academic record) and initial amateurism certifications (based on 
activities that occurred before the student's request for final 
amateurism certification or initial full-time enrollment at a Division 
I or II school, whichever occurred earlier). However, it may re-
evaluate a final academic or amateurism certification if new 
information is subsequently received that calls into question the 
information on which the final certification was based.

    Question 6b. What is done by the Eligibility Center in terms of 
educating student athletes on the rules pertaining to amateurism and 
eligibility?
    Answer. The NCAA Eligibility Center employs a variety of outreach 
measures to educate college-bound student-athletes (e.g., via the 
registration process, our website, social media, presentations at 
schools and events). Further, high school counselors and coaches 
receive educational newsletters regarding Eligibility Center resources 
and updates, and they can access resources via our high school portal. 
The Eligibility Center also conducts live presentations at a variety of 
academic and athletic organizational meetings each year.
                                 ______
                                 
      Response to Written Questions Submitted by Hon. Mike Lee to 
                            Dr. Mark Emmert
    Question 1. The NCAA was formed in 1906 after President Theodore 
Roosevelt convened a conference to address football injuries. This 
conference concluded with the presidents of 62 colleges and 
universities founding an association to create uniform rules. While 
President Roosevelt encouraged the meeting, he did not expressly ask 
that the Federal government take an active role in the regulation of 
college sports. The NCAA has now helped govern college sports for 115 
years with minimal Federal government intervention. In fact, it's well 
known that the NCAA has long resisted congressional involvement in 
college sports for numerous reasons.

    Question 1a. Is it still the NCAA's position that college sports 
should remain free of congressional involvement?
    Answer. The NCAA has supported Federal direction on matters of 
national importance, and we think attempts by individual states to 
regulate student-athlete NIL is one of them. We have supported Title IX 
legislation, and we supported Federal efforts to keep sports wagering 
regulated, among other Congressional actions that have had a positive 
impact on college athletics and higher education.

    Question 1b. The NCAA has long prided itself on having its own 
``legislative bodies'' that are made up of volunteers from all member 
schools, who debate, resolve, and set rules and standards to address 
its own emerging issues. What unintended consequences could result from 
Congress instituting ``one-size-fits-all'' Federal standards on college 
sports?
    Answer. The NCAA hopes that Congress will provide a general 
statutory framework that will allow the NCAA governance processes to 
continue to make responsible decisions regarding NIL benefit regulation 
that will preserve the collegiate model, reaffirm that student-athletes 
are not employees of the institution, and not result in a ``pay for 
play'' environment. We think the Federal solution is superior to a 
state-by-state approach, which would subject college sports to an 
unmanageable patchwork of regulation that would disrupt the 
Association's ability to conduct fair national competition and 
championships.

    Question 2. The NCAA is currently developing ``Name, Image, 
Likeness'' rules that would permit student-athletes to benefit from use 
of their name, image, and likeness.

    Question 2a. When do you anticipate completion of these rules?
    Answer. The NCAA Board of Governors has asked each division to vote 
on new rules related to NIL no later than January 2021.

    Question 2b. If Congress decides to move on legislation prior to 
the release of the NCAA's new rules, could that inhibit the NCAA's 
efforts to modernize rules?
    Answer. We urge Congressional action as soon as possible so that 
our rules are in sync with the intent of Congress.

    Question 2c. What is the NCAA's most challenging or complex 
consideration in the crafting of these rules?
    Answer. The issues are complex, but Congressional support to allow 
the NCAA to responsibly regulate NIL activity will help. The NCAA will 
need to be able to enforce transparency of NIL activities so that 
related compensation does not become a disguised recruitment incentive 
or ``pay for play.'' There are concerns that unrestricted NIL activity 
will dilute athletics budgets to shift compensation to individual 
student-athletes in a way that will diminish participation 
opportunities or resources available for supported teams. There also 
are concerns that academics will suffer through efforts by third 
parties to induce students to pursue short-term economic opportunities. 
Congressional validation of NCAA rulemaking will help alleviate those 
concerns and others.

    Question 2d. Why is it important for the NCAA to preserve student-
athlete ``amateur'' status rather than treating athletes as 
``employees''? What consequences do you foresee if you shift student-
athletes to a ``professional athlete'' status?
    Answer. Were student-athletes to be employed to perform on the 
court or field, we believe that the incentive to be compensated for 
performance--as with any job--would dominant student-athletes' and 
coaches' motives and accordingly fundamentally alter the nature of the 
experience. As amateurs, student-athletes participate in 
intercollegiate athletics for the love of the sport and to derive many 
non-pecuniary benefits, such as camaraderie, the opportunity to develop 
discipline, leadership, and teamwork skills, and the opportunity to 
obtain a higher education that could be transformational but might 
otherwise be unavailable. We think there is widespread agreement in 
Congress and the public that this collegiate model is valuable and 
should be preserved.
                                 ______
                                 
    Response to Written Questions Submitted by Hon. Dan Sullivan to 
                            Dr. Mark Emmert
    Question 1. As you may or may not know, the University of Alaska 
Fairbanks has won eleven National Rifle Championships. How should we 
regulate those student athletes who want to endorse, or pose with a 
rifle or ammunition manufacturers' product?
    Answer. We do not foresee Congress regulating at a level that would 
determine permissible and impermissible categories of student-athlete 
sponsorship. In our view, the Association and its members are best 
situated to identify permissible categories and rules of NIL activity, 
and that--within that regulatory framework--decisions about specific 
endorsements would be made by the student-athlete and his/her 
institution.

    Question 2. What role do you foresee Sports Agents playing in 
college athletics after the State laws begin taking effect?
    Answer. We do not believe that sports agents, whose primary mission 
is to negotiate and secure a professional sports career for an athlete, 
should have an expanded role with NIL opportunities. However, we do 
recognize that a student, whether an athlete or not, may need 
professional services of lawyers, accountants, business advisors, and 
others to navigate NIL proposals in a manner that fairly protects the 
student. Students engaged in business ventures and entrepreneurial and 
artistic activities already are entitled to utilize these types of 
services, and the NCAA is considering adopting rules that would allow 
for such services specific to NIL opportunities.
                                 ______
                                 
                Supplemental Information for the Record:
Sen. Blumenthal:
    In 2018 the NCAA implemented new rules to allow basketball players 
to sign with agents, but those rule changes did not apply to women. 
Isn't that unfair?
    In response to the September 2017 announcement of a Federal 
investigation into fraud in college basketball, the NCAA formed an 
independent Commission to examine critical aspects of Division I men's 
basketball. The Commission, chaired by Dr. Condoleezza Rice, developed 
a range of recommendations to improve the environment for prospective 
and current student-athletes and member schools. Among the legislative, 
policy and structural changes put forth by the Commission was a 
recommendation that men's basketball student-athletes be allowed to 
contract with NCAA-certified agents without jeopardizing their 
eligibility. The Commission found that due to the NBA's draft 
eligibility rules, many students were considering whether to declare 
for the draft during the early stages of their collegiate athletic 
experience. Allowing Division I men's basketball student-athletes to 
contract with an agent would enhance their access to beneficial 
information to better assess their professional prospects. This 
recommendation was unanimously endorsed by the NCAA Board of Governors, 
approved by the Division I Board of Directors and took effect August 
2018.
    While this rule currently applies to only Division I men's 
basketball student athletes, NCAA member schools continue to discuss 
whether Division I women's basketball student-athletes should be 
afforded the same opportunity. As these discussions continue, member 
schools will examine whether the issues that led to changes in men's 
basketball also exist in women's basketball. This includes examining 
whether earlier agent involvement would be beneficial based on factors 
such as the draft eligibility rules of the WNBA. For example, to be 
eligible for the NBA draft, a player must be at least 19 years old 
during the calendar year in which the draft is held and at least one 
NBA season must have elapsed since the player's graduation from high 
school. In contrast, to be eligible for the WNBA draft, a player must 
be at least 22 years old and have no remaining NCAA eligibility or have 
renounced remaining eligibility.
Sen. Blumenthal:
    Let me ask you, Dr Emmert, when a school gives a one-year 
scholarship and then kicks the young athlete out of school because of 
an injury at the end of that scholarship. If that injury prevents him 
or her from playing, that's unfair, isn't it? It is in my mind.
    Current Division I bylaws do not allow any institution to reduce or 
cancel athletics aid for an injury or other athletically related reason 
during the period of the award. The period of an athletics aid 
agreement must be at least one academic year, and may be up to a 
student's full five-year period of eligibility. Further, autonomy 
conferences adopted legislation prohibiting the non-renewal of 
athletics aid for any athletics reason or injury. This effectively 
ensures that student-athletes at autonomy institutions are provided a 
financial aid agreement for the student's full period of eligibility 
unless the student fails to meet academic or other institutional 
standards.
    Institutions outside the five autonomy conferences may be required 
to adopt this legislation by their conference governance board, may 
choose to adopt this legislation at their own initiative, or may 
continue to follow bylaws that allow institutional discretion on 
renewing awards on a yearly basis. However, if an institution outside 
the five autonomy conferences elects to not renew the athletics aid of 
a student-athlete, or renews at a reduced amount, the institution's 
financial aid authority is required to notify the student-athlete in 
writing by July 1 and provide the student-athlete with written policies 
and procedures to appeal the athletics department decision to an 
institutional authority outside of athletics. The athletics department 
decision to not renew athletics aid is not final until the outside 
appellate authority reviews and affirms the decision.
    Additional Division I bylaws are also in place to minimize any 
competitive incentive to exercise nonrenewal or reduced renewal 
discretion relative to a student-athlete with an injury or medical 
condition. Athletics aid received by a student-athlete who suffered a 
career-ending injury or illness (including mental illness) will not 
count against team financial aid limitations during the academic years 
following the medical determination that he or she is unable to 
participate. Further, the Division I Academic Performance Program 
incentivizes institutions to renew the athletics aid of all student-
athletes through penalties for institutions that fail to retain 
scholarship student-athletes. These penalties are assessed on a team-
by-team basis and have included ineligibility for NCAA championships.
Sen. Moran:
    And rather than take the time of the moment I would ask any of you 
to lengthen that list or shorten that list for me as to what concerns 
we ought to have about NIL?
    Disrupting the Recruiting Environment: The recruitment process is 
unique to college athletics, where prospective and transfer student-
athletes have the ability to select an institution that offers the best 
academic and athletic opportunities for that individual. It is 
distinctly different than professional leagues, where athletes are 
drafted, and the Olympics, where participants compete for their 
country. NCAA rules have been designed to protect this freedom of 
choice and to ensure that each of the NCAA's 1100 diverse institutions 
has a fair chance of pursuing recruits by adhering to a uniform set of 
regulations.
    If NIL opportunities are not carefully and uniformly regulated, 
they could undermine the fairness within the recruiting environment and 
exacerbate competitive imbalance that exists between institutions due 
to a range of factors including geographical location and booster 
involvement. The lure of the best financial NIL prospects--likely from 
schools with the greatest name recognition or in the largest media 
markets--may add a detrimental layer to the decision-making process for 
student-athletes about which school to attend. As a result, recruits 
may prioritize where they have the most marketing opportunities--and 
diminish the focus on the best academic and personal fit. The focus on 
financial gain could lead some student-athletes to move from school to 
school in search of the best earning possibilities instead of being 
focused on the best personal and academic fit. This could inevitably 
have a negative impact on a student-athlete's progress toward a degree.
    Carefully crafted and uniform guardrails are necessary to allow 
student-athletes an opportunity to benefit from their NIL, while 
preserving the collegiate model, protecting student athletes from bad 
actors, ensuring student-athletes' freedom and incentives to choose the 
educational institution that will serve them best overall, and 
preserving competitive equity in the recruitment of prospective and 
transfer student-athletes.
    Converting Student-Athletes into Employees: College athletics is 
about competition between participants who are students first but who 
also participate in athletics as a co-curricular activity. Allowing 
student-athletes to use their NIL to in effect be paid to play or 
otherwise treating them as employees would fundamentally alter their 
athletic and academic experience and harm the nature of intercollegiate 
athletics.
    Title IX and Gender Equity: One of the NCAA's principles of conduct 
for intercollegiate athletics focuses on gender equity. Some 
legislatures are considering NIL models that would have Title IX 
implications, particularly if the NIL payments were to be made by the 
educational institutions. Even without institutional involvement, there 
could be gender imbalance of opportunities.
    Team Dynamics: College athletic teams succeed in large part due to 
the philosophy that all team members receive access to the same 
coaching, facilities, health and safety resources, and tutoring 
resources. Competition among teammates to land an endorsement deal 
could lead to self-promotion and create division within the team.
    Impact on Athletic Department Budgets and Opportunities for 
Student-Athletes: Allowing student-athletes to be compensated for their 
NIL could lead to conflicts with an institution's existing endorsement 
contracts (e.g., a school with an apparel contract could have student-
athletes enter into contracts to wear apparel from another company). 
This could result in a reduction in value of existing endorsement 
contracts, which would inevitably have a negative impact on athletic 
department budgets and force schools to reduce the number of sports and 
participation opportunities.
    Tax Implications: Some state legislatures are considering NIL 
models where money would be passed through an institution to student-
athletes. These models could have adverse tax implications for student-
athletes, including making athletic scholarships taxable or student-
athletes ineligible for important educational benefits.
                                 ______
                                 
 Response to Written Questions Submitted by Hon. Richard Blumenthal to 
                            Dr. Mark Emmert
    Our Committee has heard testimony that the NCAA anti-doping program 
is deficient. As we evaluate what the NCAA's role should be, if any, in 
coordinating lucrative licensing deals for college athletes, I am 
concerned about conflicts of interest exacerbating the NCAA's deficient 
oversight of its anti-doping program.

    Question 1. Why does the NCAA not use blood testing in its anti-
doping program?
    Answer. The NCAA does not believe the inclusion of blood testing is 
justified in its drug testing program because the advantages provided 
by blood testing (primarily the detection of human growth hormone) do 
not outweigh the privacy interests of NCAA athletes, all of whom are 
students first and foremost. Unlike USADA, which tests only Olympic-
level athletes, the NCAA oversees drug testing for 500,000 student-
athletes. Of these, only one-percent will become Olympic or 
professional athletes.
    The NCAA conducts extensive survey data of our student-athletes, 
and these data have been validated by multiple mechanisms, including 
how they match with random, out-of-competition testing for numerous 
substances. For NCAA student-athletes, 0.5 percent have used hGH in the 
past year. The detection window of hGH is less than 24 hours, and there 
remain scientific discrepancies as to its validation accuracy. We 
continue to monitor hGH use through our validated surveys, while also 
exploring less invasive ways to obtain blood samples (e.g., a finger 
stick).
    At present, given the much larger pool of athletes subject to NCAA 
drug testing as compared to USADA, the very low rate of hGH use among 
our student-athletes, the cost and privacy issues of venous blood 
draws, the extremely narrow window of detection coupled with validation 
accuracy issues, and the methodological certainty of our monitoring of 
drug use among student-athletes, we are continuing with urine sample 
testing while exploring alternative methods of drug use detection, 
including saliva and finger stick analysis.
    It is also important to note that NCAA athletes who go on to 
compete at the Olympic level, or who set American/world records, are 
automatically subject to blood testing under the direction and 
authority of USADA.

    Question 2. In the absence of blood testing, how do you ensure that 
athletes are not using human growth hormone?
    Answer. The NCAA conducts very detailed surveys of drug use among 
student-athletes. The methodology and results of our surveys have been 
validated, including by comparing the survey results with drug-testing 
results for substances that are detectable in urine. We monitor both 
the incidence and prevalence of hGH use and are confident that use of 
this substance remains very low and is not increasing over time.

    Question 3. The USADA program and the world standard for the ratio 
of testosterone to epitestosterone is 4:1 whereas the NCAA uses a 10:1 
ratio. Why do you use a different, more lenient ratio?
    Answer. The purpose of establishing a T/E ratio is to accurately 
screen those samples that should be subjected to subsequent IRMS 
testing. IRMS is a very expensive and time-intensive test, and so it is 
important that it be employed judiciously and intentionally. The NCAA 
T/E threshold was established at 10:1 as a result of a focused 
scientific analysis of the results of thousands of NCAA drug tests. 
That analysis demonstrated that a T/E ratio of 4:1 was producing too 
many false positives--in other words, samples with a T/E ratio of 4:1 
were not being confirmed by subsequent IRMS testing. The frequency of 
these false positives was effectively reduced with a T/E ratio of 10:1.
    It is also important to note that for any situation in which a 
world record is ratified, the NCAA works collaboratively with a WADA 
signatory (e.g., USADA), who then directs doping control in these 
circumstances.

    Question 4. Does the NCAA test for erythropoietin? If not, why not?
    Answer. Yes, the NCAA does test for EPO, which it recognizes as a 
banned substance in the category of peptide hormones, growth factors, 
related substances and mimetics. A full list of substances banned by 
the NCAA can be found here.

    Question 5. Is it true that the NCAA has not implemented an Athlete 
Biological Passport program, testing an individual athlete over time 
and comparing the results?
    Answer. The NCAA does not employ an Athlete Biological Passport 
program. There are several reasons for this. First, ABPs include a 
hematological component, and for reasons described above, the NCAA has 
chosen to not include testing requiring venous blood draws. Moreover, 
ABPs can require an average of three annual blood tests, and if an 
athlete's passport is atypical/suspicious, they are subject to more 
testing than those with normal passports.
    Lastly, the NCAA population of athlete poses several unique 
challenges to the ABP concept. First, the typical college career is 
usually 4-5 years, a relatively small window of time in which to 
maximize the advantages offered by ABPs. Second, the selection process 
for the biological passport pool is quite complex and would be 
difficult to implement in the current NCAA organizational structure. 
Lastly, the timing of sequential testing may be difficult to coordinate 
considering the multitude of factors that impact the student-athlete 
educational experience (e.g., campus calendars, academic obligations, 
professional internships, travel, etc.). That being said, the NCAA 
utilizes a deterrence model for its year-long, out-of-competition drug 
testing. Unlike USADA, which selects their athlete pool for out-of-
competition drug testing (and therefore this pool of athletes know in 
advance that they are subject to drug testing at some point during the 
year), our pool of out-of-competition drug testing includes ALL 
Division I and Division II student-athletes. With our deterrence model, 
many schools and student-athletes are randomly drug tested up to three 
times in a single academic year.

    Question 6. Does the NCAA have an out-of-school testing program? If 
not, why not?
    Answer. Yes, the NCAA drug testing program includes a year-round 
component. This means that student-athletes are subject to testing 
outside of both championship/tournament competition and outside of 
their competitive season. Indeed, the NCAA out-of-competition, 
unannounced drug testing program is the largest program in the country. 
Member schools and student-athletes receive notification of random drug 
testing within the conceptual framework of a deterrence model with less 
than 1-day notice. If an athlete does not submit to such testing, they 
receive the same penalty as testing positive for a banned substance.

    Question 7. How often are NCAA urinalysis tests conducted without 
notice to the athlete or their school?
    Answer. In any NCAA drug testing situation, notice is given to the 
school no more than 24 hours in advance. This is the minimum amount of 
time necessary to ensure that the school can inform the student-athlete 
of the pending test and to provide the facilities necessary for 
implementation of testing procedures. The NCAA conducts over 12,000 
random drug tests within the deterrence model framework. The deterrence 
model (originally developed in consultation with USADA during an NCAA 
task force that USADA attended) relies on our extensive survey data and 
analysis of drug testing results over time. This means that in addition 
to random drug testing for student-athletes, certain pools of athletes 
(e.g., Division I football) are tested up to three times in an academic 
year.

    In 2017, the NCAA released a study on college athlete time demands 
and found that it is not uncommon for athletes to exceed the 20-hour 
weekly practicing limitation.

    Question 1. How are schools currently able to circumvent the NCAA's 
weekly practicing limitation?
    Answer. There are different types of athletically related 
activities a student-athlete may be involved in at different times 
throughout the year--some voluntary and others required for 
participation in intercollegiate athletics. Members in each division 
set limits on required athletically related activities consistent with 
that divisions' values and approach to college athletics. Divisions I 
and II institutions have legislated daily and weekly limits for 
countable athletically related activities and require schools, on a 
daily basis, to record any countable individual or group athletically 
related activity. Schools educate their student-athletes and 
administrators about what activities are and are not permissible and 
head coaches have a legislated responsibility to promote an atmosphere 
for compliance within their program and to monitor activities regarding 
compliance. Failure to comply with these standards could result in a 
range of penalties through the NCAA infractions process.

    Question 2. What are the total number of hours that athletes spend 
practicing their sports in season? Include all time spent in sport 
related activities, including administrative meetings, weight-lifting, 
film study and other game preparations, voluntary activities, and 
travel.
    Answer. We do not have information that covers all activities 
listed in the question. However, information from our GOALS (Growth, 
Opportunities, Aspirations and Learning of Students in college) study 
provides some insight. The 2019 GOALS study, which will be released in 
the spring, is the study's fourth iteration. It was previously 
conducted in 2006, 2010 and 2015. For the 2019 GOALS study, 560 faculty 
athletics representatives assisted us in collecting data from more than 
22,000 current student-athletes. As part of the 2019 GOALS survey, 
student-athletes were asked to consider a ``typical'' weekday on campus 
while school was in session during their season and share the number of 
hours they spent on a variety of activities, that fall within two 
categories of sport commitments: athletic activities (practicing, 
training, competing, athletic training room etc.) and non-athletic 
activities (meetings with coaches, team functions, film study, etc.). 
Student-athletes were also asked to consider a typical weekend on 
campus during their season and share the number of hours spent on the 
same types of activities. Based on the responses received, current 
college student-athletes are generally reporting slightly less time 
devoted to athletics pursuits when compared to what was reported in 
2015. In Division I, the median time reported as spent on athletics 
decreased from 34 hours/week in-season in 2015 to 33 hours/week in 
2019. Division II student-athletes reported a decline from 32 hours/
week to 31 hours/week. And, Division III student-athletes reported a 
decline from 28.5 hours/week to 28 hours/week.

    Question 3. What actions is the NCAA taking to close the loopholes 
in its 20-hour weekly practice limitation?
    Answer. Student-athlete time demands is a topic all three NCAA 
divisions recognize as an important component of student-athlete well-
being and have taken several steps to address concerns in this area. 
Beginning with the 2017-18 academic year, schools in Division I 
autonomy conferences adopted legislation requiring them to create a 
student-athlete annual time management plan for each varsity sport in 
which the Association sponsors a championship or that is an emerging 
sport for women. The plan must, at a minimum, include policies to 
ensure (1) student-athletes are provided adequate notice of all 
countable athletically related activities and other required 
athletically related activities; (2) schedules for all countable 
athletically related activities and other required athletically related 
activities are developed through a collaborative process involving 
student-athletes, coaches and senior athletics department staff members 
and (3) student-athletes are provided adequate notice of changes to a 
previously established schedule for countable athletically related 
activities and other required athletically related activities. The plan 
is required to be reviewed annually by the school's director of 
athletics, faculty athletics representative, the sport's head coach and 
at least one student-athlete representative. If a sports program acts 
in a manner that clearly demonstrates a disregard for the school's 
stated policies, the institution can be held accountable through the 
NCAA infractions process. The NCAA Division I Council recommended that 
all Division I schools create a student-athlete time management plan as 
a best practice.
    In addition to the student-athlete time management plans, other 
autonomy conference legislation that took effect for the 2017-18 
academic year prohibits student-athletes from participating in required 
athletically related activities other than competition for a continuous 
eight-hour period between 9 p.m. and 6 a.m.; prohibits a travel day 
from being considered as a day off; prohibits required athletically 
related activities for a seven-day period beginning the day after a 
student-athlete's or team's last contest of the championship segment; 
and requires an institution to provide each student-athlete with 14 
additional days off during the playing season or outside the playing 
and practice season when classes are in session.
    The GOALS study continues to provide valuable information for our 
membership as they continue to consider the time demands faced by 
student-athletes. The governance structure in each division is well-
positioned to act on future recommendations in this area from our 
student-athletes and athletics administrators.

    In 2018, the NCAA implemented new rules to allow basketball players 
to sign with agents, but those rule changes did not apply to women. 
When asked about this rule during the hearing, you acknowledged that 
the purpose of the rule is to ``allow athletes in men's basketball to 
have representation when they go into a draft conversation with 
professional sports ranks'' and that it is working successfully. It is 
highly unfair that women basketball players are not being treated the 
same as men.

    Question 1. When will the NCAA modify its representation bylaws to 
allow women basketball players the same access to agents as their male 
counterparts?

    Question 2. Why does the NCAA not allow other college athletes, 
such as football and soccer players, to have access to agent 
representation?
    Answer. In response to the September 2017 announcement of a Federal 
investigation into fraud in college basketball, the NCAA formed an 
independent Commission to examine critical aspects of Division I men's 
basketball. The Commission, chaired by Dr. Condoleezza Rice, developed 
a range of recommendations to improve the environment for prospective 
and current student-athletes and member schools. Among the legislative, 
policy and structural changes put forth by the Commission was a 
recommendation that men's basketball student-athletes be allowed to 
contract with NCAA-certified agents without jeopardizing their 
eligibility. The Commission found that due to the NBA's draft 
eligibility rules, many students were considering whether to declare 
for the draft during the early stages of their collegiate athletic 
experience. Allowing Division I men's basketball student-athletes to 
contract with an agent would enhance their access to beneficial 
information to better assess their professional prospects. This 
recommendation was unanimously endorsed by the NCAA Board of Governors, 
approved by the Division I Board of Directors and took effect August 
2018.
    While this rule currently applies to only Division I men's 
basketball student athletes, NCAA member schools continue to discuss 
whether Division I women's basketball student-athletes and student-
athletes competing in other sports should be afforded the same 
opportunity. As these discussions continue, member schools will examine 
whether the issues that led to changes in men's basketball also exist 
in other sports. This includes examining whether earlier agent 
involvement would be beneficial based on factors such as the draft 
eligibility rules that are created by the professional leagues and 
their respective players associations. For example, to be eligible for 
the NBA draft, a player must be at least 19 years old during the 
calendar year in which the draft is held and at least one NBA season 
must have elapsed since the player's graduation from high school. In 
contrast, to be eligible for the WNBA draft, a player must be at least 
22 years old and have no remaining NCAA eligibility or have renounced 
remaining eligibility.
                                 ______
                                 
    Response to Written Questions Submitted by Hon. Jerry Moran to 
                         Douglas A. Girod, M.D.
    Question 1. In the case that NIL payments were permitted to be 
paid, what are appropriate or necessary protections for our student 
athletes?
    Answer. This is an important question and gets to the heart of the 
matter. As we work to develop an NIL framework in the months ahead, our 
guiding priority must be to do what is in the best interest of student-
athletes and their families. This includes protecting them from 
external influencers and agents who may not be acting in the student's 
best interests.

    Question 1a. Is it possible these payments open our student 
athletes up to wider predatory circumstances?
    Answer. Yes, this is a real possibility if an NIL model is not 
properly constructed. That is why it is important that we get it right.

    Question 2. While California's Fair Pay for Play Act does not 
authorize payment by the educational institution to student athletes, 
there are examples of other state legislation that do. The New York 
Collegiate Athletic Participation Compensation Act would require a 
percentage of revenue from tickets sales be distributed among the 
student athletes. Do you believe athletes should receive compensation 
in any form from the institution or its athletic department?
    Answer. First, this question highlights the reality that a 
patchwork of different state laws is not workable. This is why 
President Emmert and other witnesses asked the subcommittee to consider 
national legislation to create an even playing field and unified 
standards upon which to build a new NIL framework. While there are many 
plausible NIL frameworks in which student-athletes could profit, we do 
not support any model that creates an employment relationship wherein a 
student-athlete would receive compensation from the institution or its 
athletic department. This type of arrangement could have serious 
consequences that would effectively end the collegiate athletic model, 
as we know it.

    Question 3. If Congress decided to pursue Federal legislation 
regarding NIL payments to student athletes, a critically important 
component of such legislation would be determining what types of 
arrangements, activities, and agreements would be eligible for the 
categorical definition of an NIL payment. Do you have suggestions for 
this subcommittee as it relates to defining the NIL in statute? a. What 
types of commercial arrangements, activities or agreements should this 
subcommittee remain wary of?
    Answer. There is no concise answer to this question. The reality 
is, there are many plausible NIL frameworks for our community to 
consider in the months ahead, and each framework would present its own 
unique opportunities and challenges, requiring unique policies and 
procedures. As you will recall from testimony, both the Big 12 
Conference and the NCAA have initiated working groups to consider this, 
and these processes are ongoing.

    Question 4. According to the 2018 financial data collected by USA 
Today, there were only 12 athletic departments in the country that did 
not receive any support from its own institution or the state in which 
it is located. Furthermore, approximately 90 percent of athletic 
departments received over $1 million in support, and for nearly 80 
percent of departments, this support accounted for more than a quarter 
of their revenue. For instance, 91 percent of the revenue for the 
University of California Riverside came from outside the athletic 
department, and James Madison University athletics received $41.7 
million in assistance. This demonstrates that the vast majority of 
athletic departments rely upon funding resources outside of the 
department. How will legislation like that of California affect the 
operation of athletic departments? a. What types of commercial 
arrangements, activities or agreements should this subcommittee remain 
wary of?
    Answer. Nationally there is tremendous variability in the financial 
arrangements between universities and their athletic departments. 
Therefore, I am unable to provide a succinct answer to this question. 
As I testified, Kansas Athletics is a self-sufficient entity that 
receives about 1 percent of its operating budget from the university, 
and this amount is only provided to comply with Kansas Board of Regents 
policy related to institutional control. However, your question 
highlights the key point that I addressed in my testimony: ``The 
actions we take on NIL have the potential to transcend athletics and 
impact every aspect of our university mission--from education, to 
service, to research. For better or worse, a major athletics department 
at a university like KU is inextricably linked with the entire 
university model and everything we do. For example, athletics is 
important to student recruitment, especially for Midwestern 
universities that rely on out-of-state student enrollment. Athletics is 
crucial to our engagement with donors, whose support is essential to 
our most important academic and research initiatives. In addition, 
athletics enhances our work to improve access to education and campus 
diversity by enrolling students from diverse backgrounds. Again, the 
decisions we make on Name, Image and Likeness have implications that 
extend beyond the athletic playing field and into virtually every 
aspect of what we do as universities.

    Question 5. Since Kansas is not one of the states to have 
legislation currently introduced or enacted, how could the unintended 
consequences of enacted laws that allow for NIL payments in other 
states impact the student-athlete recruiting outcomes at the University 
of Kansas?
    Answer. First, it should be noted that Kansas lawmakers did 
introduce NIL legislation earlier this year. However, this question is 
a good one and highlights the reality that a patchwork of different 
state laws is not a workable solution because it will put some states 
(and their universities) at an advantage or disadvantage relative to 
their national peers. This is precisely why President Emmert and other 
witnesses asked the subcommittee to consider national legislation to 
create an even playing field and unified standards upon which to build 
a new NIL framework.

    Question 6. What role do you foresee Sports Agents playing in 
college athletics after the State laws begin taking effect?''
    Answer. While the collegiate model has, for the most part, 
insulated itself from the influence of sports agents, we believe that 
they will become a necessity should many of the proposed state laws 
take effect. We anticipate that most student athletes lack the 
expertise and time to negotiate NIL deals with third parties, and as 
such will need agents/lawyers to protect their interests. This will 
likely necessitate the licensing/certification and oversight of sports 
agents both by States and by the NCAA. Additionally, it should be noted 
that under current proposed state legislation, it is possible that many 
prospective Student Athletes (specifically blue-chip/5-star prospects) 
will already have NIL agreements and agents prior to the recruitment 
process.
    Again, thank you for the opportunity to testify before the Senate 
Committee on Commerce, Science, and Transportation's Subcommittee on 
Manufacturing, Trade and Consumer Protection. If you should have any 
additional questions or need further clarification, please do not 
hesitate to contact me.
                                 ______
                                 
    Response to Written Questions Submitted by Hon. Jerry Moran to 
                              Ramogi Huma
    Question 1. The recently enacted Fair Pay to Play Act in California 
allows college athletes to hire agents and other representatives to 
assist them in negotiating and securing commercial NIL opportunities. 
Do you foresee any unintended consequences arising from allowing agents 
to represent student athletes?

    Question 1a. Are there ways to thoughtfully allow for agent 
representation of student athletes with certain protections to prevent 
bad actors from taking advantage of student athletes?
    Answer to 1. According to the Uniform Law Commission, 42 states 
have adopted legislation regulating sports agents. Many of the same 
states are pursuing legislation to allow college athletes the ability 
to secure sports agents and other representation, and the ability to 
earn NIL compensation. This demonstrates states' interest and 
capability to address anything they would view as an unintended 
consequence. Given these facts, I do not anticipate unintended 
consequences that the states cannot address.
    Also, I'd like to clarify that the California Fair Pay to Play Act 
does not limit athlete representation to NIL opportunities. The law 
places no limit at all on areas in which college athletes' interest may 
be advanced by their representatives. This is a positive aspect of the 
state legislation that should be protected.
    Answer to 1a. I believe proposals to protect college athletes from 
bad actors can include ensuring that college athletes know whether or 
not an agent meets any required legal standards to serve as an athlete 
agent; have access to a recent background check for a prospective agent 
and their own agent; have easy and timely access to information about 
claims made against an active agent related to college athlete 
representation (and the outcomes of such claims); and each agent should 
have a clear understanding about what will and will not jeopardize 
college athletes' intercollegiate athletics eligibility.
    In addition, prohibiting college personnel, colleges, athletic 
conferences, athletic associations, and their business partners from 
certifying agents, arranging player representation, or representing 
players themselves is a very important provision to protect college 
athletes. They currently impose and/or adhere to a prohibition on 
college athlete representation, and capitalize financially from it. 
These organizations have been bad actors in this area by any reasonable 
measure. This protection would also ensure that college athletes' 
representation does not have a conflict of interest.

    Question 2. While California's Fair Pay for Play Act does not 
authorize payment by the educational institution to student athletes, 
there are examples of other state legislation that do. The New York 
Collegiate Athletic Participation Compensation Act would require a 
percentage of revenue from tickets sales be distributed among the 
student athletes. Do you believe athletes should receive compensation 
in any form from the institution or its athletic department?
    Answer. I appreciate this question, and I have had time to consider 
the thoughtful question you posed to me during the hearing regarding 
whether or not NIL freedom would satisfy the economic equity piece of 
college sports reform. The answer to this question requires a broader 
look at important areas that affect college athletes' finances, and 
parallels to other multibillion-dollar commercial sports leagues.
    In the hearing, members of the Subcommittee raised concerns about 
the ability of colleges to end college athletes' athletic scholarship 
opportunities due to permanent injury; the prevention of injuries and 
abuse, which play a role in the 66 percent injury rate among current 
players and 50 percent chronic injury rate among former players; and 
the lack of due process and fairness in NCAA investigations that can 
end a college athlete's educational opportunity and compromise their 
athletic future. In addition, whether or not a college athlete has a 
fair and realistic opportunity to complete his or her degree--and in 
their major of choice, has a profound economic impact on that player's 
finances. College sports is a $14 billion enterprise that enjoys tax 
free money because of its educational mission. The truth is that little 
of that revenue is used to foster an environment whereby college 
athletes, especially those on football, basketball, and baseball 
rosters, can complete a quality education. In addition to Part 1 of 
Senator Chris Murphy's ``Madness, Inc.'' report on NCAA sports 
economics that I submitted as part of my original written testimony, I 
am including his second report regarding academics in NCAA sports as 
part of my response to this question.
    The NCAA's limit on the amount and types of compensation colleges 
can provide directly to players have been ruled in violation of Federal 
antitrust laws in both O'Bannon v. NCAA and Alston v. NCAA, which is 
currently under appeal in the 9th Circuit. I served as an advisor in 
each of these lawsuits. In O'Bannon v. NCAA, the court found that the 
NCAA unreasonably prevented colleges from allowing compensation that 
covers the full cost of attendance as part of a full athletic grant-in-
aid scholarship. As a result, college athletes now receive direct 
payments in the form of stipends worth several thousands of dollars per 
year. In Alston v. NCAA, the court found that NCAA bans on numerous 
forms of compensation, such as travel abroad expenses, are illegal. The 
illegal NCAA price-fixing of college athlete compensation has had a 
disastrous economic consequence for college athletes.
    In 2013, the NCPA and the Drexel University Sports Management 
Program published a joint study finding that the fair market value of 
college football and men's basketball players in the FBS Division was 
$137,357 and $289,031, respectively; the value of an average full 
athletic scholarship at an FBS college was $23,204 per year, and over 
80 percent of college athletes receiving a full scholarship lived below 
the Federal poverty line. Collectively, the study found that NCAA 
price-fixing denied college athletes $6.2 billion between 2011-2015.
    This glaring disparity is at the core of why state lawmakers from 
both parties and approximately 66 percent of the public support 
allowing college athletes to earn compensation from their NIL rights. 
It's worth noting that 52 percent of the public supports college 
athletes receiving a portion of the lucrative media rights generated by 
their talents and sacrifice.
    At the time of this submission, Florida HB 7051 introduced by 
Florida State Representative Chip LaMarca, is expected to soon receive 
a House floor vote. HB 7051 would not only guarantee Florida college 
athletes the freedom to secure representation and NIL compensation, it 
would require Florida colleges to pay for players' sports-related 
medical expenses, medical insurance premiums for uninsured or 
underinsured college athletes, and scholarships and disability benefits 
for permanently injured players. Representative LaMarca and Florida 
lawmakers deserve much praise for seeking these additional player 
protections, protections that are forms of direct compensation from 
colleges to their athletes. At times, colleges nationwide opt to 
provide such forms of direct compensation.
    Similarly, the NCPA sponsored a California bill signed into law in 
2012 requiring colleges receiving at least $10 million per year in 
media rights revenue to pay for medical premiums for low-income college 
athletes and out-of-pocket sports-related medical expenses for all 
athletes for up to two years after the expiration of their 
intercollegiate athletics ability. Colleges have had the options to 
provide these forms of compensation since the White v. NCAA class 
action lawsuit settlement in 2008, and the U.S. Department of Justice 
antitrust investigation on the NCAA's 1-year scholarship limit led to 
the NCAA's approval of allowing multiyear scholarships in 2012. Prior 
to these developments, the NCAA prohibited colleges from providing 
comprehensive medical coverage, sports-related medical expenses during 
summer workouts, and guaranteed scholarship continuation for 
permanently injured college athletes.
    State legislation that allows or requires additional direct 
compensation from colleges to their athletes, such as the proposed New 
York legislation that would give college athletes a portion of ticket 
sale revenue, are positive and I support it. I also believe that states 
have a right to address college athlete compensation in a manner that 
they deem appropriate. Such provisions can be an avenue to help resolve 
the economic inequity NCAA rules impose on college athletes.
    The focus of the Subcommittee hearing and almost all of the adopted 
and proposed state legislation nationwide has been on a 3rd party 
compensation model. I believe it is possible to implement a 3rd party 
compensation model that is the core of a financially equitable 
arrangement for college athletes, even if revenue streams such as 
ticket revenue are included. For instance, ticket transactions can be 
conducted by a 3rd party which, in turn, could distribute revenue to 
colleges and college athletes/college athlete representatives 
separately. It would be similar to how EA Sports, a 3rd party, 
distributes revenue separately to the NFL and the NFL Players' group 
licensing entity.
    When considering college athletes receiving other forms of revenue 
such as ticket sales, it is important to address the false NCAA 
narrative that such compensation would require colleges to cut 
nonrevenue sports. If significant commercial/ticket revenue is required 
for colleges to field nonrevenue sports, then NCAA Division II and III 
would not exist. The NAIA would not exist. All of the sports in these 
divisions are nonrevenue, yet they field teams with hundreds of 
thousands of athletes without any significant commercial revenue and at 
a fraction of the cost.
    Economic equity for college athletes is inextricably tied to not 
only college athlete NIL freedoms and a significant portion of 
commercial revenue that their talents generate, but it is tied to their 
freedom from medical expenses, freedom from preventable sports-related 
injury and abuse, freedom from serious obstacles that impede degree 
completion, freedom to transfer once without punishment in pursuit of 
better academic and athletic opportunities, freedom from unfair 
athletic association investigations that can harm their economic 
stability and future, and freedom from illegal, cartel activity that 
stifles their economic opportunities.

    Question 3. If Congress decided to pursue Federal legislation 
regarding NIL payments to student athletes, a critically important 
component of such legislation would be determining what types of 
arrangements, activities, and agreements would be eligible for the 
categorical definition of an NIL payment. Do you have suggestions for 
this subcommittee as it relates to defining the NIL in statute?

    Question 3a. What types of commercial arrangements, activities or 
agreements should this subcommittee remain wary of?
    Answer to 3. I suggest that, if Congress pursues Federal 
legislation, it should state that any payment to a college athlete for 
use of his or her name, image, likeness, or received because of his or 
her athletics reputation is protected with the following exceptions:

   I.  NIL payment offers and arrangements used as inducements to lure 
        high school recruits or college transfers to a particular 
        college.

   II.  NIL deals arranged by colleges. This would be similar to other 
        league's prohibitions on teams luring free agents with pre-
        arranged 3rd party NIL deals in addition to a salary as a way 
        to circumvent salary caps.

  III.  Predatory NIL loans. Perhaps legislation could exclude any loan 
        issued to a college athlete conditioned upon the use of the 
        college athlete's NIL that has a prime interest rate and lender 
        spread that exceed the United States Small Business 
        Administration's Loan limits.

  IV.  *Possibly. . .NIL arrangements with select industries, entities, 
        and products as discussed in 3a. below.

    As I stated in my written and oral testimony on 2/11/2020, NIL 
arrangements with boosters, alumni, and college sponsors should not be 
banned in the name of competitive equity because competitive equity 
does not exist in college sports. These same sources already give 
athletic programs money that is used to recruit the best recruits, win 
the most games, and generate the biggest TV deals that allow rich 
athletic programs to continue their dominance. In their most recent 
report to the Department of Education, Ohio State reported $203 million 
dollars in athletic revenue while Florida Atlantic reported only $28 
million in athletic revenue. They are both in the FBS Division. How can 
anyone suggest that these two colleges compete on an equal playing 
field? How can colleges, conferences, and the NCAA justify denying 
college athletes economic freedoms in the name of competitive equity 
when this severe disparity among colleges exists and is held up as the 
system that should be preserved? Colleges, conferences, and the NCAA 
have not moved to address these inequities--they haven't banned booster 
payments to colleges and they don't share athletics revenue equally in 
the name of competitive equity. In addition, other leagues do not ban 
3rd party NIL deals with fan clubs and those leagues operate very well.
    Any Federal legislation should not sacrifice college athletes' 
freedom so that the NCAA and its colleges can pretend that competitive 
equity exists. Additionally, roster and scholarship limits keep the 
inequity from getting worse. There is a finite number of recruits each 
year and the top recruits already flow to the Power 5 Conferences. If 
legislation inadvertently changes recruiting migrations to where some 
of the top recruits begin to flow away from some of the Power 5 
Conferences, it would actually increase competitive equity compared to 
where it is today. Also, Federal legislation should not exclude the 
group licensing market as described in my answer to Senator Fischer 
question 1.a. below.
    Answer to 3a. In my communication with various states pursuing 
similar legislation, I've heard concerns about whether or not college 
athletes should be restricted from NIL opportunities in certain 
industries. Most have stayed away from excluding select industries 
because it may unjustly reduce players' NIL freedoms and lead to 
conflicts in political ideology that may undermine proposed NIL 
legislation that otherwise enjoys bipartisan support. This may be a 
correct assessment, but I do not think the risk should stifle 
discussion in this area.
    The exclusion of some industries and products may have bipartisan 
support. For instance, there may be bipartisan support to exclude 
college athlete NIL opportunities in the adult entertainment industry. 
There may also be bipartisan support to exclude NIL deals related to 
prescription pain medicine like oxycodone. Exclusions that have been 
discussed by state legislators that may be more controversial include 
possible prohibitions on college athlete NIL deals with the gun, 
tobacco, and marijuana industries.
    Additionally, prohibitions on college athletes receiving some 
portion of sports gaming revenue would be controversial given players 
in the NFL and other sports leagues may soon receive a portion of 
revenue generated by legal in-stadium gambling activities, another form 
of 3rd party commercial activity that capitalizes off of players' 
commercial value. Colleges seeking additional revenue may soon include 
such activities in their stadiums, sell players' statistics to gaming 
companies, or otherwise benefit financially from gaming entities. The 
NCPA remains neutral on sports gaming, but college athletes should not 
be excluded from commercial gaming revenue from sources that have 
commercial arrangements with their colleges.
    Similarly, while a ban on college athlete NIL deals with alcohol 
companies may make sense, many would be surprised to learn that a 
number of colleges sell alcohol during college football bowl games, 
NCAA championships, and on-campus college sports events. Some colleges 
even have direct sponsorships with alcohol companies and allow them to 
place university logos on alcohol products. In short, it may be 
unjustifiable to impose industry, entity, or product-specific NIL deal 
prohibitions on college athletes if the same prohibitions are not 
placed on deals with colleges, athletic conferences, and athletic 
associations.
    The goal for Federal NIL legislation should be to maximize college 
athletes' economic freedoms with the least government regulation, and 
without giving colleges, conferences, and athletic associations the 
discretion to prohibit players' opportunities.
                                 ______
                                 
    Response to Written Questions Submitted by Hon. Deb Fischer to 
                              Ramogi Huma
    Question 1. In October 2019, the National College Players 
Association announced that it would explore a partnership to market 
college athlete group licensing rights to companies, ranging from the 
gaming to apparel industries. Would you provide the Subcommittee with 
more details of this effort and its status?
    Answer. The National College Players Association entered into a 
collaboration with ``One Team'', a partnership that includes the NFL 
Players Association and the Major League Baseball Players Association, 
to ensure college athletes of all sports have experienced and robust 
group licensing representation.
    One Team represents group licensing rights for all athletes in the 
NFL, Major League Baseball, Major League Soccer, the WNBA, the Women's 
National Soccer Team, and other professional sports.
    Proper group licensing representation is essential for college 
athletes. Federal court antitrust rulings in O'Bannon v. NCAA recognize 
that a group licensing market for college athletes' NIL rights exists 
and declared the following:

   NCAA's prohibition on athlete name, image, and likeness 
        compensation violated Federal antitrust law and deprives 
        college athletes compensation that they would otherwise 
        receive.

   If the NCAA did not have a prohibition on athlete 
        compensation for use of their name, image, and likeness, 
        athletes would be able to create and sell valuable group 
        licenses;

   3rd parties purchase groups of athletes' NIL rights for 
        commercial purposes including for use in live game telecasts, 
        sports video games, game rebroadcasts, advertisements, and 
        other archival footage to ensure they have the legal right to 
        use groups of athletes' NIL rights.

    The NCPA is positioned as a steward in this collaboration and has 
since formed an Oversight Board. Over 75 percent of the NCPA Oversight 
Board is comprised of former college athletes who are industry experts 
and notable college athlete advocates.

    Question 2. How do you plan to secure the marketing rights from the 
players and universities?
    Answer. The NCPA-One Team collaboration does not intend to secure 
any university marketing rights and any entity that represents a 
university should not represent college athletes. That would be a 
conflict of interest that truly should not be allowable.
    Securing player's group licensing rights is currently not allowable 
under NCAA rules and the California NIL law is not effective until 
January 1, 2023. Other states may choose to allow their college 
athletes the ability to secure representation prior to that date. While 
there are continuous discussions related to this question, I would not 
disclose specific details at this early stage in the process. However, 
I can assure you and members of the subcommittee that the NCPA would 
not consider being involved in any actions that would violate a law.

    Question 3. Will all universities and athletes be compensated 
similarly from group licensing contracts? Additionally, will the 
revenue from these group licensing agreements affect the competitive 
parity among Division I athletic conferences?
    Answer. To clarify, the use college athletes' group licensing 
rights should not be a source of university revenue. For instance, the 
NCAA faced an antitrust lawsuit for generating profits not only from 
licensing its own properties, but for selling college athletes' NIL 
rights in video games created by EA Sports. The court found that 
essentially, the NCAA and its colleges were operating as defacto group 
licensing representatives of their athletes, but providing their 
athletes no compensation. In the face of the lawsuit, the NCAA chose to 
terminate the video game instead of allowing the players to receive any 
group licensing compensation. This conflict of interest harmed players 
economically and underscores why college athletes must have independent 
representation--including group licensing representation. The NFL has a 
similar video game with EA Sports whereby the NFL Players Association's 
licensing company sells NFL players' bundled NIL rights to EA sports 
and distributes equal group licensing revenue checks to each NFL 
player. It's important to note that equal group licensing distributions 
among NFL players does not eliminate individual NFL players' ability to 
secure individual NIL deals that are not uniform.
    There may be a number of group licensing entities that surface 
after the effective dates of state legislation and the likelihood that 
all distributions will be similar in that environment is not likely. I 
believe some group licensing distributions may be similar from sources 
such as a video game featuring players of each school. However, Federal 
legislation would likely be necessary if the goal is to ensure that all 
athletes within each sport and division are compensated similarly from 
all group licensing contracts.
    Without Federal legislation requiring similar group licensing 
distributions among college athletes in the same sport and Division, I 
believe parity among conferences will be similar to parity among 
athletic programs as described in the last two paragraphs of my Answer 
#3 to Chairman Moran's Question #3 above.

    Question 4. What, if any, steps will be taken to ensure a clear 
distinction between collegiate athletes and professional athletes in 
such potential group licensing agreements, so as not to blur the lines 
between the two groups?
    Answer. Those who believe that these lines have already been 
blurred and those who do not will likely continue to maintain their 
beliefs regardless of any group licensing agreement or Federal 
legislation. However, college athletes receiving revenue from group 
licensing representation provided by colleges or colleges' 
representatives NIL brokers (i.e., conferences, athletic associations) 
may be additional evidence of college athletes' employee status. That 
is a designation that has not yet been clearly established as a matter 
of law.

    Question 5. Can you assure the Subcommittee that all revenue 
generated from these group licensing agreements will flow back to the 
athletes and/or the universities, or will some portion of such revenues 
be diverted elsewhere?
    Answer. Again, college athletes' group licensing revenue should not 
be a source of university revenue. Ultimately, the NCPA's goal is to 
ensure current college athletes are empowered by the NCPA's Oversight 
Board to make informed decisions related to their group licensing 
revenue. In addition to direct group licensing player distributions, 
college athletes may also want to consider using funds to make sure all 
athletes can participate in a financial skills program so that players 
can make the most of their NIL earnings, assistance for injured 
athletes stuck with sports-related medical expenses, or other 
considerations.
    However, there could be a number of group licensing entities that 
come into existence that structure things much differently. 
Additionally, group licensing entails overhead expenses needed to 
promote, secure, and execute group NIL arrangements.
                                 ______
                                 
    Response to Written Question Submitted by Hon. Dan Sullivan to 
                              Ramogi Huma
    Question. What role do you foresee Sports Agents playing in college 
athletics after the State laws begin taking effect?
    Answer. I envision sports agents playing a critical role in college 
athletics once state laws become effective. Agents can help prevent 3rd 
parties from taking advantage of unsuspecting college athletes through 
unfair or predatory contracts. Agents can also play the primary role in 
proactively pursuing NIL deals for college athletes whose time demands 
would otherwise make it more difficult to manage. Additionally, agents 
can represent college athletes in disputes with their college or 
athletic association. Finally, agents can help some players make 
important decisions about whether or not to play with potentially high-
risk injuries and whether or not to enter a professional draft. These 
examples are not intended to be an exhaustive list, but they represent 
what I see as the central roles that agents will play after state laws 
take effect.
    Thank you each again for allowing me to answer your questions. 
Again, I would like to continue these important discussions with each 
of you and the Subcommittee as ideas for Federal legislation progress.
                                 ______
                                 
 Response to Written Question Submitted by Hon. Richard Blumenthal to 
                              Ramogi Huma
    Question. Do you agree that an antitrust exemption is necessary or 
desirable? Please explain.
    Answer. I do not agree. An antitrust exemption is not necessary or 
desirable when considering NIL reform. Because the NCAA has been 
operating as if it already has an antitrust exemption, its record 
clearly demonstrates how it would negatively wield such power. Federal 
courts have determined on multiple occasions that the NCAA's 
restrictions on interstate commerce have been overly burdensome and has 
caused significant financial harm to both college athletes and 
colleges.
    In the 1984 NCAA v. Board of Regents of Oklahoma lawsuit, the U.S. 
Supreme Court ruled that the NCAA's control and restraints on college 
football television broadcasts violated Federal antitrust laws. This 
lawsuit was triggered when the NCAA threatened an illegal group boycott 
against colleges that formed an organization to broker their own TV 
deals. The NCAA argued that it's TV limits were beneficial to college 
sports because it fostered live attendance. The U.S. Supreme Court 
struck down the NCAA's restraints on TV broadcasts, which significantly 
advanced the college sports revenues and consumer benefits. Decades 
after the Supreme Court's ruling, fans can regularly watch their 
favorite college teams either on TV or through streaming services while 
college sports revenue has exploded by billions of dollars.
    In 2005, former Stanford football player Jason White filed a class-
action antitrust lawsuit against the NCAA for price-fixing full 
athletic grant-in-aids below the cost of attendance. Though the lawsuit 
was settled with no change in that price-fixing amount, the NCAA 
eliminated its limits on colleges paying for comprehensive medical 
coverage and out-of-pocket medical expenses.
    After a U.S. Department of Justice antitrust investigation into the 
NCAA's 1-year athletic scholarship limit, the NCAA relented and began 
allowing colleges to provide multiyear athletic scholarships in 2012. 
The NCAA could not defend its 1-year limit, which was clearly 
unnecessary and harmful to college athletes. In particular, college 
athletes suffering permanent injury from their sports were especially 
vulnerable. Antitrust scrutiny in this area led to an important 
advancement for college athletes.
    In 2015, the U.S. Court of Appeals for the 9th Circuit upheld a 
ruling in the O'Bannon v. NCAA antitrust lawsuit finding that the 
NCAA's rule capping full athletic grant-in-aids below the cost of 
attendance violated Federal antitrust law and struck down that limit. 
As a result, colleges nationwide can pay their athletes an additional 
$2000-$5000 per year to cover expenses deemed educationally necessary.
    In 2019, the same district court once again found the NCAA in 
violation of Federal antitrust laws for illegally price-fixing 
compensation to college athletes. In its remedy, the court struck down 
NCAA prohibitions on thousands of dollars of educational-related 
athlete compensation that exceeds the cost of attendance. This case is 
on appeal in the 9th Circuit.
    Also in 2019, California adopted SB 206, the Fair Pay to Play Act, 
which will allow college athletes to secure representation and receive 
name, image, and likeness compensation beginning in 2023. It is 
estimated that 28 other states are pursuing similar legislation, some 
of which may become effective as early as July 2020. Such legislation 
is receiving overwhelming bipartisan and public support. However, these 
laws contradict NCAA rules. If the NCAA had an antitrust exemption, the 
states would not have had the option to address this issue.
    Finally, on March 2, 2020, the National Association of 
Intercollegiate Athletics (NAIA), an intercollegiate athletic 
association comprised of more than 250 colleges and 65,000 college 
athletes, announced a NIL proposal that mirrors the pillars of SB 206 
and virtually all of the other proposed state NIL legislation. The 
proposal would allow college athletes to secure representation and 
receive NIL compensation. The only condition would be that college 
athletes would have to report such agreements to their athletic 
director in a timely manner. This is significant. This proposal 
undercuts the NCAA's notion that the ``Collegiate Model'' must impose 
overbearing restrictions and exclude various economic freedoms that the 
states are pursuing. Additionally, the NAIA embodies what the NCAA 
touts as the core of The Collegiate Model--athletes playing for the 
love of the game and prioritizing education. This proposal offers proof 
that athlete compensation and freedom can be compatible with these 
aspects of college sports. Whether or not this proposal survives the 
NAIA's vote (expected to take place on April 1), it is a strong example 
of a collegiate model that Congress should support.
    It would not be fair or reasonable for Congress to give a badge to 
the NCAA (which has regularly violated Federal law) in hopes of 
bringing justice to the college athletes who are economically harmed by 
the NCAA's illegal price-fixing. The NCAA must be subject to the law, 
not above it.
    Alternatively, Congress can address certain restraints on trade 
directly through legislation. For instance, Congress can prevent NIL 
agreements from being used as inducements to lure high school recruits 
and college transfers to a particular college. It can ensure that 
colleges do not directly arrange NIL deals for their athletes. Congress 
doesn't need to give the NCAA an antitrust exemption to accomplish 
these things.
                                 ______
                                 
    Response to Written Question Submitted by Hon. Amy Klobuchar to 
                              Ramogi Huma
    Question. In your view, what are the most important factors to 
consider in assessing proposals that would enable college athletes to 
receive this type of compensation?
    Answer. I believe that the core tenants of economic freedoms being 
pursued by the states should be upheld. They include allowing college 
athletes the freedom to secure representation and earn NIL 
compensation.
Representation
    Proposals to protect college athletes from bad actors can include 
ensuring that college athletes know whether or not an agent meets any 
required legal standards to serve as an athlete agent; have access to a 
recent background check for a prospective agent and their own agent; 
have easy and timely access to information about claims made against an 
active agent related to college athlete representation (and the 
outcomes of such claims); and each agent should have a clear 
understanding about what will and will not jeopardize college athletes' 
intercollegiate athletics eligibility.
    In addition, prohibiting college personnel, colleges, athletic 
conferences, athletic associations, and their business partners from 
certifying agents, arranging player representation, or representing 
players themselves is a very important provision to protect college 
athletes. They currently impose and/or adhere to a prohibition on 
college athlete representation, and capitalize financially from it. 
These organizations have been bad actors in this area by any reasonable 
measure. This protection would also ensure that college athletes' 
representation does not have a conflict of interest.
    According to the Uniform Law Commission, 42 states have adopted 
legislation regulating sports agents. Many of the same states are 
pursuing legislation to allow college athletes the ability to secure 
sports agents and other representation, and the ability to earn NIL 
compensation. This demonstrates states' interest and capability to 
certify athlete agents.
NIL Compensation
    I suggest that, if Congress pursues Federal legislation, it should 
state that any payment to a college athlete for use of his or her name, 
image, likeness, or received because of his or her athletics reputation 
is protected with the following exceptions:

  I.    NIL payment offers and arrangements used as inducements to lure 
        high school recruits or college transfers to a particular 
        college.

  II.   NIL deals arranged by colleges. This would be similar to other 
        league's prohibitions on teams luring free agents with pre-
        arranged 3rd party NIL deals in addition to a salary as a way 
        to circumvent salary caps.

  III.  Predatory NIL loans. Perhaps legislation could exclude any loan 
        issued to a college athlete conditioned upon the use of the 
        college athlete's NIL that has a prime interest rate and lender 
        spread that exceed the United States Small Business 
        Administration's Loan limits.

  IV.  *Possibly . . . NIL arrangements with select industries, 
        entities, and products as discussed below . . .

    In my communication with various states pursuing similar 
legislation, I've heard concerns about whether or not college athletes 
should be restricted from NIL opportunities in certain industries. Most 
have stayed away from excluding select industries because it may 
unjustly reduce players' NIL freedoms and lead to conflicts in 
political ideology that may undermine proposed NIL legislation that 
otherwise enjoys bipartisan support. This may be a correct assessment, 
but I do not think the risk should stifle discussion in this area.
    The exclusion of some industries and products may have bipartisan 
support. For instance, there may be bipartisan support to exclude 
college athlete NIL opportunities in the adult entertainment industry. 
There may also be bipartisan support to exclude NIL deals related to 
prescription pain medicine like oxycodone. Exclusions that have been 
discussed by state legislators that may be more controversial include 
possible prohibitions on college athlete NIL deals with the gun, 
tobacco, and marijuana industries.
    Additionally, prohibitions on college athletes receiving some 
portion of sports gaming revenue would be controversial given players 
in the NFL and other sports leagues may soon receive a portion of 
revenue generated by legal in-stadium gambling activities, another form 
of 3rd party commercial activity that capitalizes off of players' 
commercial value. Colleges seeking additional revenue may soon include 
such activities in their stadiums, sell players' statistics to gaming 
companies, or otherwise benefit financially from gaming entities. The 
NCPA remains neutral on sports gaming, but college athletes should not 
be excluded from commercial gaming revenue from sources that have 
commercial arrangements with their colleges.
    Similarly, while a ban on college athlete NIL deals with alcohol 
companies may make sense, many would be surprised to learn that a 
number of colleges sell alcohol during college football bowl games, 
NCAA championships, and on-campus college sports events. Some colleges 
even have direct sponsorships with alcohol companies and allow them to 
place university logos on alcohol products. In short, it may be 
unjustifiable to impose industry, entity, or product-specific NIL deal 
prohibitions on college athletes if the same prohibitions are not 
placed on deals with colleges, athletic conferences, and athletic 
associations.
Ignore the Competitive Equity Myth
    As I stated in my written and oral testimony on 2/11/2020, NIL 
arrangements with boosters, alumni, and college sponsors should not be 
banned in the name of competitive equity because competitive equity 
does not exist in college sports. These same sources already give 
athletic programs money that is used to recruit the best recruits, win 
the most games, and generate the biggest TV deals that allow rich 
athletic programs to continue their dominance. In their most recent 
report to the Department of Education, Ohio State reported $203 million 
dollars in athletic revenue while Florida Atlantic reported only $28 
million in athletic revenue. They are both in the FBS Division. How can 
anyone suggest that these two colleges compete on an equal playing 
field? How can colleges, conferences, and the NCAA justify denying 
college athletes economic freedoms in the name of competitive equity 
when this severe disparity among colleges exists and is held up as the 
system that should be preserved? Colleges, conferences, and the NCAA 
have not moved to address these inequities--they haven't banned booster 
payments to colleges and they don't share athletics revenue equally in 
the name of competitive equity. In addition, other leagues do not ban 
3rd party NIL deals with fan clubs and those leagues operate very well.
    Any Federal legislation should not sacrifice college athletes' 
freedom so that the NCAA and its colleges can pretend that competitive 
equity exists. Additionally, roster and scholarship limits keep the 
inequity from getting worse. There is a finite number of recruits each 
year and the top recruits already flow to the Power 5 Conferences. If 
legislation inadvertently changes recruiting migrations to where some 
of the top recruits begin to flow away from some of the Power 5 
Conferences, it would actually increase competitive equity compared to 
where it is today.
Group Licensing
    Federal legislation should not exclude the existing college athlete 
group licensing market which, according to Federal court rulings, 
includes but is not limited to video games, live television broadcasts, 
archival footage, and advertisements. I believe some group licensing 
distributions to college athletes from different teams would be similar 
from sources such as a video game that features players of each school. 
If the goal is to ensure that all athletes within each sport and 
division are compensated similarly from all group licensing contracts, 
Federal legislation would likely be necessary.
Economic Equity
    In the hearing on February 11, 2020, Chairman Moran asked me 
whether or not college athlete NIL freedom would satisfy the economic 
equity piece of college sports reform. The answer to this question 
requires a broader look at important areas that affect college 
athletes' finances, and parallels to other multibillion-dollar 
commercial sports leagues.
    In the hearing, members of the Subcommittee raised concerns about 
the ability of colleges to end college athletes' athletic scholarship 
opportunities due to permanent injury; the prevention of injuries and 
abuse, which play a role in the 66 percent injury rate among current 
players and 50 percent chronic injury rate among former players; and 
the lack of due process and fairness in NCAA investigations that can 
end a college athlete's educational opportunity and compromise their 
athletic future. In addition, whether or not a college athlete has a 
fair and realistic opportunity to complete his or her degree--and in 
their major of choice, has a profound economic impact on that player's 
finances. College sports is a $14 billion enterprise that enjoys tax 
free money because of its educational mission. The truth is that little 
of that revenue is used to foster an environment whereby college 
athletes, especially those on football, basketball, and baseball 
rosters, can complete a quality education.
    State legislation that allows or requires additional direct 
compensation from colleges to their athletes, such as the proposed New 
York legislation that would give college athletes a portion of ticket 
sale revenue, can also help bring forth economic equity.
    The focus of the Subcommittee hearing and almost all of the adopted 
and proposed state legislation nationwide has been on a 3rd party 
compensation model. I believe it is possible to implement a 3rd party 
compensation model that is the core of a financially equitable 
arrangement for college athletes, even if revenue streams such as 
ticket revenue are included. For instance, ticket transactions can be 
conducted by a 3rd party which, in turn, could distribute revenue to 
colleges and college athletes/college athlete representatives 
separately. It would be similar to how EA Sports, a 3rd party videogame 
maker, distributes revenue from its NFL video game separately to the 
NFL and the NFL Players Association's group licensing entity.
    When considering college athletes receiving other forms of revenue 
such as ticket sales, it is important to address the false NCAA 
narrative that such compensation would require colleges to cut 
nonrevenue sports. If significant commercial/ticket revenue is required 
for colleges to field nonrevenue sports, then NCAA Division II and III 
would not exist. The NAIA would not exist. All of the sports in these 
divisions are nonrevenue, yet they field teams with hundreds of 
thousands of athletes without any significant commercial revenue and at 
a fraction of the cost.
    Economic equity for college athletes is inextricably tied to not 
only college athlete NIL freedoms and a significant portion of 
commercial revenue that their talents generate, but it is tied to their 
freedom from medical expenses, freedom from preventable sports-related 
injury and abuse, freedom from serious obstacles that impede degree 
completion, freedom to transfer once without punishment in pursuit of 
better academic and athletic opportunities, freedom from unfair 
athletic association investigations that can harm their economic 
stability and future, and freedom from illegal, cartel activity that 
stifles their economic opportunities.
    Thank you both again for allowing me to answer your questions. 
Again, I would like to continue these important discussions with each 
of you and the Subcommittee as ideas for Federal legislation progress.

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