That’s
a positive development, but only if the Department uses this time to truly
engage with members of Congress, the sector and other educators in a meaningful
discussion of how to better regulate all of higher education. To date,
the discussion hasn’t been a discussion; it’s been an ideological shouting
match.
What’s
this regulation about? Designed to keep students from choosing programs
the Department deems bad investments of time and money, and primarily affecting
for-profit career colleges, it requires more comprehensive disclosure for
prospective students and a two-pronged test to measure program effectiveness.
It
makes no sense for prospective students at career colleges to get completion, placement,
debt load and other important information, while others considering the same
majors at non-profit or public institutions don’t. That would be like
requiring nutritional information on packages of food, but only in some
grocery stores. Why not require it be available everywhere for everyone
to see? Oh wait, we do.
Second,
the test embedded in the regulation is flawed. A test that predicts which
programs are worthwhile would be valuable. But, if the test can be made to
work, why not apply it to all career education programs at all institutions as
well? Here are a few important facts. University of Phoenix (UOP), a
for-profit, has a reported repayment rate of 44% and median student federal
debt burden of $14,299. Georgia State University, a public university, has a
reported 44% repayment rate and median debt burden of $17,935. Both are
regionally accredited. Both miss a 45% USDOE repayment rate threshold.
Shouldn’t students at both institutions have the same protections?
Should
a student and his or her parents considering Alabama State (a public
university), which is regionally accredited, know that its repayment rate is
14% – among the worst in the nation? Under Gainful Employment, because Alabama
State is a public university, the student and parents would not know that. Yet,
an identically accredited for-profit offering the same career education majors
with the same student debt and a repayment rate of 28% – twice that of Alabama
State — would be subject to termination from or limitations in federal student
aid programs, denying its students access. Shouldn’t Alabama State be subject
to the same sanctions?
The
obvious answer: of course.
Bottom
line: the notion that we should do a better job of helping students make more
informed choices that will leave them in better financial shape once they’ve
earned their degree is smart. Only political or ideological
considerations would result in selectively applying the approach that does so.
In any event, Gainful Employment, as currently constructed, won’t get us there.
Here’s
what will. Commit to universally applying Gainful Employment in a way that
allows the time and provides the capability for all institutions to make
changes needed to ‘hit the mark.’ Bring a broad base of affected constituents
to the table to refine the rule. Commit to setting targets using visible data –
such as BLS wage data – for assessing each program’s potential. Recognize that
if Gainful Employment (or any other regulation) has a built in tendency to
pressure institutions to accept fewer otherwise qualified high financial need
or high risk students it must be changed to eliminate that tendency. Give
students credit for performing as expected (and encouraged by the Department)
against loan repayment time frames and terms, not against some arbitrary odd
metric. Ensure innovation is not impeded. And, commit in the process to using
real, comparable data to assess all schools’ efficacy.
Gainful Employment needs to be changed –
so it helps fix what’s broken without breaking what works. Then, it needs to be
applied to all
career education majors at all institutions. Only then will it achieve its potential to
be the single test of efficacy that simplifies accountability and obviates the
need for other indirect tests and limitations.
And,
only then will it result in sound oversight that improves the landscape for its
critical beneficiaries: students. All of them.
Randy Proto is the President and CEO of the American
Institutes school group, which specializes in health care career education and
serves over 2,000 students annually. It includes the American Institute College
of Health Professions, American Institute and American Institute School of
Health Careers located in Florida, and the Fox Institute schools in Connecticut
and New Jersey.