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 UNITED STATES

 DEPARTMENT OF EDUCATION

 PUBLIC MEETING ON

 GAINFUL EMPLOYMENT

 ED-005-11-P-0005

 9:00 a.m.

 Friday, November 05, 2010

 U.S. Department of Education

 400 Maryland Avenue, SW

 Washington, D.C.
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1 P R O C E E D I N G S

2 MR. KVAAL: Good morning. Thank you all for

3 coming. This is the second day of public hearings that

4 we're having on Gainful Employment. This is a

5 continuation of our process to get public input on

6 these rules. It's a very important step. So we're

7 grateful for the time of those who came to share their

8 views with us today.

9 I just wanted to go over a few of the ground

10 rules for anyone who wasn't here yesterday.

11 We are providing each presenter with five

12 minutes to present remarks. I'd appreciate it if

13 people would try and hold to that time period to the

14 extent possible. Actually, not to the extent possible,

15 appreciate it if people would just hold to that time

16 period.

17 There is lights on the podium. Green lights

18 mean you're ready to go. Yellow light means there's

19 two minutes remaining. The red light means your time

20 is up. Steve will be our timer. He's going to keep us

21 on track.

22 There will be a transcript taken of this
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1 session. We hope to make that available through our

2 website in the next couple of weeks, and we thank you

3 for your engagement in this process. We look forward

4 to your comments.

5 I guess I should introduce the panel. My

6 name is James Kvaal. I'm Deputy Under Secretary. With

7 me is Steve Finley, who's an attorney in the Office of

8 General Counsel, and Fred Sellers, who's a policy

9 official in the Office of Postsecondary Education and

10 was one of the federal negotiators for this rule.

11 So with that, let's get started and if the

12 first speaker wanted to come up, that would be great.

13 MR. MURRAY: Good morning. Thank you for

14 providing me this opportunity to address the panel.

15 My name is John Murray, and I'm the Regional

16 Human Resource Manager for ABM Security Services. My

17 region covers the Southeast United States and has 15

18 branch offices and over 2,000 employees.

19 We provide high-end security to gated

20 communities, Class A commercial buildings, industrial

21 facilities, such as petrochemical and pharmaceuticals.

22 I came to talk to you today about all career
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1 colleges. I can't talk to you about all for-profit

2 colleges, but I can talk to you about Kaiser

3 University. I've been associated with Kaiser for the

4 past three years on their Employment Advisory Board.

5 The Board meets twice a year. It's comprised of local

6 business men and women.

7 We discuss the curriculum for the different

8 fields and we advise the faculty on how to mold the

9 courses to more what the employers are looking for in

10 the respective fields.

11 I closely work with the faculty to help

12 students get jobs in their selected fields. My company

13 also employs numerous graduates of the Criminal Justice

14 Program and current students in the Criminal Justice

15 Program.

16 I find these individuals are far better

17 prepared for the job market than many new applicants,

18 new employees that we have. I find they have far

19 better job skills and they're really able to succeed

20 far better than some.

21 I feel these schools are a great asset to the

22 community and I'm truly glad to have these students as
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1 part of my company and as part of my community and I'd

2 truly hate to see that resource disappear.

3 Thank you.

4 MS. DIEHL: Good morning, gentlemen of the

5 panel. Thank you for having me.

6 My name is Tiffany Diehl. I'm a clinical

7 physiology instructor at the Pima Medical Institute in

8 the Radiography Program, Albuquerque, New Mexico.

9 I come before you today to answer any

10 questions that you may have regarding the questions I

11 submitted to you in September.

12 Briefly, let me explain myself. In

13 Albuquerque, there are two radiography programs. At

14 the community college, students declare their major and

15 are then put on a list for that major. The student

16 then starts taking prerequisites for their chosen

17 program, in this situation radiography.

18 One of the first classes that they may take

19 is A&P, Anatomy and Physiology. I spoke with a student

20 from the Radiography Program at CNM on October 28th.

21 She told me she declared her major in radiography in

22 2005. She then proceeded to take prerequisites for the
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1 program, including the Anatomy and Physiology. That

2 program accepts one new class each year. She

3 petitioned for three years to start her program. Each

4 time she petitioned, there were more than 100

5 applicants that petitioned for the program, as well. In

6 2010, she was finally admitted into the program.

7 It had been so long since she took her A&P

8 initially that she's forgotten what she's taken.

9 Obviously this can present a problem when you're

10 training to image different parts of the body.

11 Pima, where I work, we start classes every

12 eight months in the Radiography Program. During our

13 two-year program, students are required to take general

14 core classes as well as program-specific training

15 classes within the two years enrolled. There's not a

16 lag in time when they initially take their A&P until

17 they apply the knowledge that they have learned.

18 There is obviously a need to provide this

19 education to the community. Students want to learn the

20 science and the technology. Gentlemen, I consider this

21 career education.

22 At Pima, we do have an application process.
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1 Applicants are tested and interviewed and ranked to

2 find qualified applicants. Students do fill out the

3 FASFA form. They meet with a financial aid officer and

4 look at other financing options if there's a gap in

5 their funding.

6 The students at our facilities are told the

7 costs of the program, the costs of the attendance,

8 graduation rates, and placement rates. Students are

9 provided with small class sizes, tutoring at no cost.

10 The school has a food bank to help the students that

11 are in need. So we're very supportive of our students.

12 We have staff to help students find resources

13 if they're struggling financially. The bottom line:

14 we help our students succeed.

15 In my program, we have a 100 percent pass

16 rate on our boards. We are programmatically accredited

17 by the Joint Review Committee on Education and

18 Radiological Technology and institutionally accredited

19 by the Accrediting Bureau of Health Education Schools.

20 We have community support and our students are learning

21 valuable marketable skills.

22 The JRCERT makes sure that our program abides
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1 by the policies that our program has set forth. To

2 maintain our accreditation with ABHES, we are required

3 to maintain a 70 percent employment rate for our

4 graduates in their field of study. We are also

5 required to maintain a 70 percent student retention and

6 graduation rate.

7 The community supports us by providing

8 clinical sites for our students to train and provides

9 our students with real-world experience. A couple of

10 months ago, one of our sites donated a C-Arm, which is

11 a fluoroscopy, and a portable x-ray unit which both can

12 take images to the patient. The C-Arm is usually in

13 the operating room and the portable you can use

14 anywhere, as long as there is proper protection from

15 the exposure. This equipment is estimated to cost

16 roughly $60,000.

17 We, myself in particular, search for clinical

18 sites that will help my students develop their skills

19 and put them in the area that fits their personality

20 and their abilities. By working closely with the

21 community, I hear about job openings as they become

22 available and alert recent graduates immediately of the
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1 openings.

2 In the case of a student I wrote about in my

3 comments, the student was interested in learning

4 cardiac cath. We heard of a few openings at a local

5 hospital. Because of Pima's good reputation in the

6 community, I was able to contact the lead technologist

7 for the department and explain the benefit of having

8 the student work in their facility. The site was happy

9 with the student and did hire them after they

10 graduated. This is a common occurrence in our program.

11 There are other things with that, as well.

12 My concern is if you take away funding to our

13 students, that there will be less opportunities. It

14 could take them a decade to get the education they

15 need.

16 Thank you.

17 MS. LEARY: Good morning. My name's Kathy

18 Leary, and I'm the Director of Financial Aid at Rocky

19 Vista University.

20 Rocky Vista University is located in Parka,

21 Colorado, and we operate the nation's only privately22 held for-profit Graduate School of Medicine.
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1 Because of the nature of our program and

2 physician licensing requirements, we are requesting

3 that the department exempt all graduate medical

4 schools, including both MD and DO degrees, from these

5 regulations.

6 The rationale for our request is twofold.

7 First, we maintain that the medical school education

8 process is unique and the proposed rules are not the

9 best way to measure either gainful employment or undue

10 debt burdens.

11 Secondly, all medical schools should be

12 required to adhere to the same rules and regulations

13 for the public nonprofit or for-profit. Requiring the

14 graduate level medical school to comply with rules that

15 are targeted at for-profits, certificate and under16 graduate programs is neither appropriate nor do we

17 believe in the best interests of our country.

18 The rationale for our position is based upon

19 the nature of medical education. All medical students

20 follow a common sequence of coursework, clinical

21 training, internships to residencies, and completion of

22 national board exams.
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1 Each student doctor must pass at least three

2 separate examinations before they're even allowed to

3 graduate from medical school. Upon graduation, medical

4 students still cannot be licensed to practice medicine.

5 They first must complete a residency or internship of

6 three to seven years and during and after this period,

7 they also have to take additional national board exams

8 in order to become licensed. Only then can they begin

9 to earn a substantial salary.

10 During residency, a medical school graduate

11 will earn an average stipend of $46,000 per year. Given

12 the large amount of debt incurred by the typical

13 student doctor, this income is not sufficient to make

14 full student loan payments, plus manage their living

15 expenses.

16 In fact, many medical school graduates who

17 are eligible under Title IV(a) are going to take

18 advantage of all the different extended repayment

19 options that are out there.

20 Salaries during residency are not at all

21 representative of a doctor's income potential or an

22 indication of their eventual ability to repay their
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1 student loans. History demonstrates that practicing

2 physicians do earn good salaries and they rarely

3 default on their student loans. In fact, we took a

4 sampling of 56 Title IV-eligible medical schools from

5 the 2007 Cohort Default Rates and we found that their

6 default rates were one percent.

7 Underlying the gainful employment proposal is

8 the assumption that students can easily attend a lower

9 cost public nonprofit school and thereby accumulate

10 less debt for the same education. This is not true for

11 medical school students.

12 Over 3,400 applicants applied to Rocky Vista

13 for 150 positions last year. There are insufficient

14 medical school slots to provide an education for even a

15 fraction of the qualified applicants and this is at a

16 time when our nation is facing a critical shortage of

17 primary care physicians.

18 Furthermore, our tuition at Rocky Vista is 98

19 percent of the tuition of other private nonprofit

20 osteopathic medical schools. So we submit that our

21 students do not have a lower cost alternative.

22 We request that our students be treated the
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1 same as students at other medical schools. Our

2 students utilize the National Medical School

3 Application System and must meet the same competitive

4 entrance requirements as all other medical school

5 students in this country.

6 During and after medical school, our students

7 have to pass the same licensing exams and they will

8 compete with their peers for residency slots through

9 the same system.

10 Appended to our comments you'll find an

11 analysis of the estimated repayment rate for 59 medical

12 schools as published by the Department of Education.

13 Only 57 of the 59 schools or 97 percent would have

14 repayment rates of less than 45 percent.

15 Some of our nation's best medical schools,

16 such as Harvard and Johns Hopkins, would not meet the

17 minimum requirements of the gainful employment rules if

18 they were implemented to all types of medical school

19 institutions.

20 Both ACOM and AAMC have submitted comments in

21 support of this to the department, stating that, "If

22 these regulations are applied to the nonprofit as well
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1 as the for-profit U.S. medical schools, potentially all

2 institutions would be deemed ineligible for Title IV

3 student financial aid programs."

4 So we respectfully ask how can you hold Rocky

5 Vista, the nation's only for-profit medical school, to

6 a measurement few, if any, public or nonprofit schools

7 can meet?

8 We understand that the gainful employment

9 rules are intended to establish standards to ensure

10 programs are graduating students who will find jobs and

11 not have undue debt burdens and we applaud the

12 department's efforts to hold schools accountable for

13 the outcome of their students.

14 But for all the reasons I just stated, we

15 request that the department exempt graduate medical

16 education, both MD and DO, from these regulations.

17 Thank you very much for your time and

18 attention.

19 MR. McINTYRE: Good morning. My name is Jim

20 McIntyre with the McIntyre and Lemon Law Firm here in

21 Washington, D.C., and I am here today on behalf of the

22 American University of the Caribbean School of Medicine
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1 or AUC.

2 AUC is located in St. Martin and has been

3 operating for over 30 years and graduated over 4,500

4 physicians in that time.

5 AUC's alumni have attained full physician

6 licensure in all 50 states, the District of Columbia,

7 the U.K., and Canada. Ninety-five percent of the

8 student body are U.S. citizens or permanent residents

9 who return to the U.S. to practice medicine, and AUC

10 students even perform slightly better than the average

11 domestic medical student on the U.S. Medical Licensing

12 Exam, Step 1.

13 AUC's Medical Education Program is cost

14 effective, offering a tuition at the rate of almost

15 $40,000 below the average U.S. private medical school

16 and slightly below the average U.S. public medical

17 school, according to the GAO's June 2010 Report on

18 Foreign Medical Schools.

19 These relatively low tuition costs have

20 allowed AUC students to pay back their loans with

21 historically low default rates, which, in the past

22 seven years, have never exceeded one percent.
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1 The AUC is accredited by the Accreditation

2 Commission on Colleges of Medicine, whose medical

3 education standards have been determined to be

4 comparable to those in the United States by the

5 National Committee on Foreign Medical Education and

6 Accreditation.

7 Considering AUC's tuition costs, along with

8 the fact that AUC does not receive tax subsidies or

9 allocations that domestic public and nonprofit

10 institutions receive, AUC offers a much more efficient

11 means for American taxpayers to increase the supply of

12 much-needed doctors for the United States, and there

13 is, indeed, a huge need for doctors in our country.

14 A June 2010 study by the Association of

15 American Medical Colleges shows that by 2020, the

16 United States is expected to have a shortage of over

17 91,000 patient care physicians and 45,000 primary care

18 physicians. These shortages are expected to increase

19 dramatically by 2025.

20 AUC is helping to solve this problem. The

21 GAO reported that 68 percent of international medical

22 school graduates entered primary care fields in 2009,
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1 compared to only 37 percent of domestic medical school

2 graduates.

3 We believe that the department's gainful

4 employment rules should exempt foreign medical schools

5 because their eligibility to participate in Title IV

6 programs is based upon specific statutory provisions

7 carefully crafted by the Congress over the past 20

8 years which establish alternative standards designed to

9 measure the success and ensure the quality of these

10 medical education programs.

11 The proposed rules fail to consider the

12 extensive regulation of foreign medical schools that

13 exist independent of proprietary career or vocational

14 school regulation.

15 While the Department of Education has imposed

16 unique requirements upon foreign medical schools that

17 ensure their credibility, including citizenship

18 standards, comparable accreditation oversight,

19 evaluation of academic outcomes, including the

20 performance on national licensure examinations and

21 required clinical programs in the United States.

22 None of these requirements or similar quality
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1 metrics currently apply to domestic career schools as a

2 condition to Title IV program eligibility, and, finally

3 and most importantly, the statutory authority for

4 gainful employment regulation is in a part of the U.S.

5 Code, Section 1002(b), that specifically refers to

6 domestic proprietary institutions, not foreign

7 institutions, which are regulated under Section

8 1002(a)(2).

9 Finally, I would also like to point out that

10 the rules fail to consider the required residency

11 requirements for physician licensure. Medical

12 residency is a period of mandatory continued education

13 where doctors obtain real-life work experience and have

14 the opportunity to obtain a specialty. A doctor is

15 required to work as a resident for a minimum of three

16 years before becoming licensed as a physician and to

17 obtain a specialty, a doctor can spend up to eight

18 years as a resident.

19 The draconian results of the gainful

20 employment formula can be seen when they're applied to

21 domestic medical schools. As has been pointed out,

22 Harvard and Johns Hopkins, two of the country's most
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1 prestigious schools, would fail the department's

2 gainful employment test.

3 American University of the Caribbean

4 encourages the department to recognize that the

5 existing regulations and accreditation of foreign

6 medical schools address the question of whether the

7 schools are adequately preparing their students for

8 gainful employment as doctors and to recognize the

9 distinctions from other career education schools and

10 properly excluding them from all gainful employment

11 regulations.

12 AUC urges the department to specifically

13 exempt foreign medical schools from the proposed

14 gainful employment rules.

15 Thank you.

16 MS. WHITEHEAD: Good morning. I'm happy to

17 be here.

18 My name's Rebecca Whitehead. I'm the Dean of

19 Academic Affairs at the University of Advancing

20 Technology. We're a second-generation family-owned and

21 operated university offering Bachelor's and Master's

22 degrees in advancing technology disciplines.
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1 In my comments, I applauded the department

2 for holding schools to standards. I think that schools

3 should deliver on what they promise. Schools should be

4 held accountable but these proposed changes do not do

5 this effectively and, in fact, they create larger

6 issues.

7 Applying this rule only to for-profit

8 institutions makes it poorly targeted. If you want to

9 genuinely protect the student and the taxpayer, you

10 look for performance across the entire sector and if

11 you do this, you'll find that, while there are some

12 for-profit schools that don't pass muster, there are

13 many nonprofits, publics, and community colleges that

14 do not, as well. So this isn't addressing the issue.

15 In the Estimated Repayment Rates by

16 Institution, Fiscal Year 2009, as published

17 by the department, the following was a partial list of

18 schools that would not meet the proposed standard if it

19 was applied to them: Columbia University in the City

20 of New York, Physicians and Surgeons; Drexel University

21 College of Medicine; George Washington University

22 School of Medicine in Health Sciences; Harvard
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1 University, Division of Continuing Education, and

2 Harvard Medical School; Johns Hopkins University School

3 of Medicine; New York University School of Medicine;

4 Kentucky State University; Pennsylvania State

5 University College of Medicine; several schools in the

6 University of Arkansas System; University of Central

7 Oklahoma; Virginia State University; and many local

8 community colleges, both in my region in Arizona, in

9 Washington, in Texas, and even your local Prince

10 George's Community College.

11 Those are just a few schools that don't meet

12 the standard as expressed and yet are not targeted by

13 this rule, and it should be considered that any rule,

14 if applied appropriately, that would put institutions,

15 such as Drexel, Columbia, Johns Hopkins, and Harvard,

16 in jeopardy is poorly considered.

17 In my original comments, I additionally

18 emphasized that the same two degrees offered at

19 different institutions should not be held to two

20 different standards. Regardless of whether these

21 degrees are completed at a for-profit institution, a

22 state school, or a community college, if the outcomes
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1 of the degrees are academically similar, then the

2 repayment rates, same repayment rates should apply.

3 By enacting this ruling as it is, you create

4 a double standard in the industry that will not take

5 care of the students and it won't fix the problem.

6 On another point from my comments, I would

7 reiterate that there is currently no way for an

8 institution to control a student's debt. It's up to

9 the student to decide how much money they borrow.

10 Students use aid to cover expenses unrelated to tuition

11 and fees, no matter how they're advised by the schools.

12 Student aid programs are not consumer lending programs

13 and the proceeds of the former should remain

14 concentrated on true postsecondary expenses.

15 Implementing the proposed rule without

16 changing the regulation to allow schools to limit Title

17 IV borrowing is unreasonable, impractical, and will

18 lead to practices seen in state and independent private

19 schools where admissions favors those students who can

20 pay the full price of tuition.

21 If the department continues to pursue this

22 rule in the current form, it needs to allow schools to
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1 control individually and per program the amount of aid

2 students may apply for. Also, recall that an

3 institution has no control over the debt a student

4 brings with them from prior institutions but,

5 currently, schools will still be held accountable for

6 that prior debt as noted in the debt-to-income

7 calculations. This will force enrollment decisions

8 based on debt, not merit. This same will occur in the

9 relation to students' FICO scores and schools will

10 admit students with the higher likelihood of repayment

11 in order to manage their repayment rates.

12 Based on this, the rule will result in

13 enrollment prejudices against poor-to-middle-income

14 families. This is counter to the President's goal to

15 better the middle class.

16 As a matter of social policy, we are better

17 off providing educational advantages and opportunities

18 to the economically disadvantaged, to improve their

19 status and contribution to society through greater

20 skills attainment.

21 Therefore, the ultimate ramifications of the

22 proposal as it stands now are contrary to the nation's
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1 education and employment goals and will harm us as a

2 country. Please don't enact this rule as it stands.

3 You're going to hurt the students, you're going to hurt

4 the schools, and you're going to hurt the nation.

5 I thank you for your time.

6 MR. STEINBRUNNER: Good morning. I want to

7 thank you for the opportunity to come here and address

8 the department.

9 My name is Adam Steinbrunner. I'm with

10 Rasmussen College. I'm the Director of Student

11 Economics there and that sounds like a made-up name for

12 someone who is dealing with gainful employment. That's

13 exactly what I am.

14 What we came here to do is really be a part

15 of the process, right? So we wanted to engage in a

16 dialogue, engage in a partnership with the department

17 because we're looking to look out for the benefit of

18 the student, for the nation, for, you know, our own

19 institution. We want everyone to come out winners with

20 this and the way that the proposal is designed right

21 now, I don't know that that is actually what's

22 happening.
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1 There's four points that I want to make. I

2 submitted about 10 pages worth of comments and the four

3 points kind of summed up into Systems, Visibility,

4 Control, and Time, and I think all of those issues are

5 not well addressed in the current NPRM.

6 For Systems, right now we as an institution

7 can't track progress and I think the issue is again

8 related to time. This is brand new and we don't know

9 if what we're trying to do to address the concerns of

10 the department is actually going to work because we

11 don't have any way to track that and manage that as an

12 institution.

13 Additionally, coming down to the programmatic

14 level, it's something that's brand new and so the

15 ability of the department to have a system where, you

16 know, today NSLDS, I have to run a report that it takes

17 me 24 hours to get. I'm skeptical as to whether in a

18 year we can have a system where we're integrating

19 social security data with programmatic data and

20 servicer data and so I think giving some runway to that

21 to get the systems right is an important consideration

22 for the department.
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1 The second piece is Visibility. Right now we

2 have no clue where we stand on either one of these

3 metrics at the programmatic level. So as an

4 institution, we don't know social security data. We

5 track and place as a regionally-accredited institution,

6 we track starting salaries for the people that we

7 place, but again the NPRM is more around a three-year

8 look at their earnings as opposed to starting salary

9 and we have no idea if that's an accurate

10 representation of where we stand compared to their debt

11 levels.

12 Additionally, LRR, Loan Repayment Rate, is a

13 black box. I mean, we have not been able to obtain

14 data either from the department or the servicer in

15 order to get that and the servicers have indicated that

16 the department doesn't want us to have special access

17 to that information, and for us, again trying to work

18 as a partner with the department, we have smart people,

19 everyone in this room has smart people that want to

20 work with you on this and figure out whether loan

21 repayment is the right way to go. I mean, if it is,

22 then let's do it, and if it's not, let's figure out a
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1 better way.

2 One of the things that we're suggesting is

3 using BLS as an interim piece until earnings -- kind of

4 we can see how that relation works because it's a

5 targeted number that's published by the Government

6 compared to the earnings that you can have as you

7 implement this and integrate it.

8 The second piece for LRR is right now we are

9 working with CDRs at an institutional level and so our

10 suggestion is to use CDRs as a phase-in until LRRs are

11 proven to be representative of not just Pell status and

12 student behavior but actually of successful outcomes

13 from the program.

14 The third piece, Control, to the previous

15 speaker's point, right now the regulations require that

16 we allow the student to draw down as much as they're

17 eligible for. So there's a significant portion of

18 their debt that doesn't go to the actual costs of

19 tuition and it's more around their discretion on

20 borrowing against, quite frankly, cheap money.

21 I mean, the debt bets allowed for education

22 is inexpensive and we can't expect that we can control
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1 student behaviors. In an economic time like this, it's

2 very likely that, if we are teaching the student to be

3 financially literate, they're going to subordinate

4 their student debt. If I have a car payment, if I have

5 a credit card payment, if I have a mortgage to pay, if

6 I'm smart about money, I'm going to subordinate debt

7 because the department offers deferments and

8 forbearance and it is cheaper money and so because of

9 that, the loan repayment rate, I think, is just as

10 influenced by the economy as it is through the outcomes

11 of the program.

12 The final piece around Timing, right now, if

13 you're going to measure for 12, that means earnings are

14 11 and that means that the grads are out and so that

15 retrospective nature of the actual NPRM is very

16 concerning for us, again working, trying to work as a

17 partner with the department.

18 If these are the right outcomes and we are

19 off on what we're doing, we want time to fix that. We

20 want the best outcomes for the students and doing this

21 retroactively is not a way that that's going to work.

22 It's more of a punitive measure as opposed to a
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1 progressive measure to get good student outcomes.

2 The final piece is that we would recommend a

3 three-year phase-in period where we are getting the

4 systems, the visibility, and the control in alignment

5 so that we can again work towards the best outcomes for

6 the students.

7 Thanks for your time.

8 MR. GUIDA: Good morning, Deputy Under

9 Secretary, Mr. Finley, Mr. Sellers.

10 My name's Tony Guida. I'm the Senior Vice

11 President for Regulatory Affairs for Education

12 Management Corporation, and I appreciate the

13 opportunity to be able to testify here today concerning

14 the proposed Gainful Employment Rule.

15 EDMC's institutions include the Art

16 Institutes, Brown Mackie Colleges, Argosy University,

17 South University, and the Western State University

18 College of Law, and we serve more than a 158,000

19 students. We're proud of our long and proven track

20 record of student success, particularly with students

21 who otherwise may have gone unserved by traditional

22 models of higher education.
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1 Let me begin by saying that we understand the

2 department's desire to limit student indebtedness. EDMC

3 already has in place a number of measures concerning

4 enhanced student financial literacy to encourage

5 students to borrow responsibly.

6 We're here today to express our continuing

7 concern that the proposed Gainful Employment Rule will

8 have a negative and significant impact on our students,

9 particularly our low-income students and minority

10 students.

11 Estimates are that the rule, as proposed,

12 would deny 400,000 students per year access to post13 secondary education, the majority of whom will be women

14 and minorities.

15 We are also concerned that the rule

16 discriminates against high-quality degree programs

17 which is a significant issue for our students because

18 94 percent of our students are enrolled in degree

19 programs.

20 We believe that the rule as written will

21 worsen an already large Bachelor's degree attainment

22 gap that exists in this country for many minorities,
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1 including blacks and Hispanics.

2 In an effort to engage constructively with

3 the department, EDMC has proposed several modest

4 modifications to the proposed rule that we believe will

5 substantially improve the rule and limits its

6 unintended consequences.

7 These modifications will appropriately

8 refocus the rule on addressing outlier institutions and

9 outlier programs and will help to ensure that we

10 achieve our shared goal of lessening student debt

11 burdens while continuing to provide all students,

12 especially those from traditionally underserved

13 populations, with a high-quality postsecondary

14 education.

15 The problem is, as we sit here today over one

16 year into the rulemaking process, we have yet to run

17 data through the -- real data to determine the actual

18 impact on students and the programs they attend. The

19 department's regulatory impact analysis falls far short

20 of providing an accurate window into what students who

21 attend our institutions will face when the rule becomes

22 effective.
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1 The department readily admits that the

2 Missouri data significantly underrepresents minority

3 students. The department's analysis could not and

4 accordingly did not address how many at-risk students

5 will be displaced as a result of the rule, how many of

6 those students have other realistic educational choices

7 and whether the negative effects on at-risk students

8 are justified in light of other regulatory alternatives

9 that are available.

10 Isn't it absolutely critical that these

11 questions are definitively answered before a rule of

12 this magnitude is instituted?

13 It's as if, given this lack of data analysis,

14 you load up an airplane with people that's been newly

15 developed and on its maiden flight, you determine

16 whether it's going to be able to fly.

17 The department's analysis also didn't address

18 the notable alternative explanation for the performance

19 of proprietary institutions under the proposed Gainful

20 Employment Rule, that it is simply a reflection of the

21 high number of low-income and other disadvantaged

22 students that proprietary institutions enroll.
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1 Financial aid expert Mark Kantrowitz analyzed

2 the department's August 13th repayment rate data and

3 noted "that graphing this data demonstrates an almost

4 linear relationship between the percentage of Pell

5 Grant recipients and he average loan repayment rates,"

6 and he concluded that "a college that enrolls primarily

7 at-risk students who qualify for the Pell Grant is

8 extremely unlikely to have a loan repayment rate in the

9 eligible or restricted zones."

10 Rather than adjust for these correlations and

11 setting appropriately-tiered thresholds for compliance,

12 the proposed rule instead creates a perverse incentive

13 for proprietary institutions to avoid enrolling low14 income students and minority students.

15 This proposed rule -- actually, the financial

16 aid system is designed to help disadvantaged students

17 achieve their educational objectives and their highest

18 potential. This rule does the exact opposite by

19 limiting access to students who are disadvantaged based

20 on the very factors that causes them to be

21 disadvantaged in the first place.

22 The program skills and experience that
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1 proprietary schools deliver to students who need us

2 most are critical to this country's economic recovery,

3 to the creation of jobs, and to the attainment of

4 President Obama's goal of becoming a world leader in

5 college graduates by the year 2020. The potential

6 negative consequences of the proposed rule to our

7 students and to our country, if we get this wrong, are

8 momentous.

9 We urge the department to make sure that it

10 has the facts right before launching this unguided

11 missile. The stakes are too high to do otherwise.

12 Thank you.

13 MR. BARTO: Thank you, gentlemen, for the

14 opportunity to speak this morning.

15 My name is Christopher Barto. I'm the Dean

16 of Student Financial Services and Chief Compliance

17 Officer at LIM College, which is a third-generation

18 family- owned institution in New York City that focuses

19 on degrees in the business of fashion, a unique

20 institution within higher ed in occupying a niche where

21 the institution was developed to serve women and

22 provide opportunities for entry into the fashion
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1 industry.

2 At the time we were founded in 1939 that was

3 a male-dominated industry in New York. We have grown

4 to an institution of 1,500 students who are primarily

5 baccalaureate degree students. We have recently

6 launched an MBA program in the Spring of 2009.

7 Since 1997 we have been a Middle States8 accredited institution. Some of our metrics, just to

9 share with you, our placement rate historically at six

10 to 12 months out has been 90 percent and above. That

11 continues to be the case, even in our current economy.

12 We think we have a unique formula for success, of

13 experiential education, paired with a strong liberal

14 arts core.

15 We have looked at the department's loan

16 repayment data and are pleased to find that, based on

17 your information that you've released, our

18 institutional rate is at 61 percent. Recently in the

19 2008 Cohort Default Rate, our institutional CDR dropped

20 to 2.4 percent while, as you know, the national rate

21 went up to 7.0.

22 We were also recently featured in the U.S.
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1 News and World Report article as one of two proprietary

2 institutions in the country who had a higher-than3 predicted loan repayment rate, given the fact that we

4 had at least 20 percent of our students who are Pell

5 Grant recipients and a graduation rate of over 50

6 percent.

7 With all of those great metrics, you may

8 wonder why am I here, why is gainful employment a

9 concern for us as an institution. On a number of

10 levels, it's a concern.

11 First and foremost, as other speakers have

12 mentioned, as we mentioned in our comments, the ability

13 to predict where we stand on debt-to-income ratios is

14 very difficult. As others do, we survey our graduates

15 upon placement. We have self-reported income data on

16 them. We compare that obviously with median debt

17 levels.

18 We believe we're okay but clearly we don't

19 have the ability to predict what social security

20 information you're going to pull and whether or not any

21 of our programs might not meet the required eight

22 percent.
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1 With that said, we also have serious concerns

2 about the inequity of these measures. If you take a

3 look at some of our programs, as we noted in our

4 comments, if you look particularly at associate degrees

5 in the area of fashion merchandising and you look at

6 some of our competitive institutions within the New

7 York marketplace, in particular Kingsborough Community

8 College, who, in the data released by the department,

9 had a loan repayment rate, I believe, of 31 percent, if

10 any of our programs or our associate in fashion

11 merchandising was deemed to not meet the debt-to-income

12 ratios, let's say we were in between eight and 12

13 percent, we would be required to give public

14 disclosures to prospective students and current

15 students.

16 Kingsborough College, at the measurement

17 where they stand right now, would not be required to

18 make any disclosure to their prospective and current

19 students. They would be allowed to continue to grow

20 their program, even if their metrics indicated that the

21 outcomes of their students, both in terms of loan

22 repayment rate, debt-to-income ratios, their default
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1 rate were far worse than our institution, there would

2 be no sanctions to that institution while we would

3 again be required to release public disclosures and

4 possibly to curtail the enrollment in our program.

5 We believe that's a serious inequity that

6 demands the attention of the department. In the NPRM,

7 the department referenced GAO statement that said,

8 "Occupation-specific training programs that lacked a

9 general education component made graduates of for10 profit institutions less versatile and limited their

11 opportunities for employment outside their field."

12 That statement grossly undervalues what's

13 happened in the proprietary sector over the last 30-40

14 years as many of our institutions are primarily

15 associate, baccalaureate and graduate level

16 institutions.

17 To apply this rule similarly to our

18 institutions and those programs really does not address

19 the department's effort to increase transparency of

20 consumer information. We support the public disclosure

21 of all of these measures by all institutions and urge

22 the department to either make a decision to limit the
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1 scope to certificate and non-degree programs or

2 appropriately apply these measures to all institutions

3 and all programmatic levels.

4 Thank you for your time.

5 MS. FISCHER: Good morning. My name is

6 Patricia Fischer, and I'm the President and CEO of

7 Dorsey Schools, located in Detroit, Michigan.

8 I am also President of the Michigan

9 Association of Career Colleges and Schools and have

10 served as a commissioner with ACICS for six years.

11 My September 8th, 2010, submission to you,

12 along with 600 letters from students, graduates, and

13 those who employ them, was intended to show the

14 department examples of the value and the success of our

15 programs.

16 My fear is that thousands of students will be

17 locked out of worthwhile programs if this rule goes

18 through. This would be particularly detrimental in

19 Michigan because we have a dire need there to retrain a

20 number of workers who, through no fault of their own,

21 have lost their jobs. Their jobs, the positions that

22 they worked in for years, are gone.
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1 Fifty percent of our students have attended

2 another educational institution and you can ask why did

3 they make a decision to take on debt and attend a

4 proprietary school like ours. Their answers are in the

5 letters that I sent you and there are three reasons.

6 One, they feel they need smaller class sizes,

7 and, two, they need instructors who care, who have a

8 determined attitude to help students succeed, and,

9 three, they know they need discipline and structure. We

10 monitor attendance very closely and we call students

11 when they're absent.

12 Thirty percent of our students come from

13 referrals. Why would a student refer a family member

14 or a friend to our institution? Because they know that

15 they're getting a good thing, they're happy with what

16 they're receiving, and they want to share it.

17 Dorsey's eight campuses are honor roll

18 schools with ACICS. We have been in business since

19 1934. We have achieved a documented and double20 verified placement rate of 70 percent in a state that

21 has the highest unemployment rate in the United States.

22 In programs, such as patient care technician,
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1 medical assistant, and medical billing, 70 percent. We

2 have an amazing 91 percent placement rate in our

3 culinary arts program. In our area, we find a diverse

4 population that is economically disadvantaged, they're

5 first-time students, first-time attending a post6 secondary education, single head of household women,

7 and people with multiple barriers, those that have

8 never worked or have only worked in an industrial

9 situation.

10 In the 1980s, the proprietary schools left

11 big urban city areas. They were driven out by default

12 regulations. Historically, a high minority population

13 has a significantly higher loan default in all types of

14 loans. Schools left, populations struggled, crime

15 increased, academic scores fell, K through 12, and a

16 vicious cycle continued.

17 We've seen it in Detroit. It's happened

18 there, and one is forced to ask really what is the

19 role, what role was played in the lack of educational

20 programs for those inner city people?

21 I am here today to urge you to re-evaluate

22 the proposed Gainful Employment regulations in view of
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1 all that you've heard. Though it is quite clear that

2 it is not your intention to do harm, the unintended

3 consequences would in fact lead to a demolition of

4 worthwhile programs and careers.

5 I respectfully request a modification of the

6 proposed Gainful Employment Rule proposed by the U.S.

7 Department of Education and, if I can be a further

8 resource with my 30+ years of experience, it's my hope

9 that you'll call upon me.

10 The lifeline of many depend upon the decision

11 that you make as you continue to guide us towards

12 educational excellence and accountability to the

13 taxpayers. I encourage you to develop a uniform method

14 of evaluating educational outcomes for all

15 institutions, require uniform reporting of retention

16 and placement percentages and graduation rates. These

17 are really the things that count. Take a broad look at

18 the outcomes for all and judge us all by the same

19 standards.

20 I thank you for your time.

21 MR. GOPLERUD: Good morning. My name's Peter

22 Goplerud. I'm Dean and Professor of Law at Florida
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1 Coastal School of Law, a bricks and mortar for-profit

2 American Bar Association-accredited law school in

3 Jacksonville, Florida.

4 I'm here on behalf of the Infolaw system, the

5 operator of our school, and two of other ABA-accredited

6 schools in Phoenix and Charlotte. We share the

7 concerns of the department and the Senate HELP

8 Committee about abusive practices and student debt

9 loads.

10 In my experience in American legal education

11 over the last 30 years, I've had the honor of being

12 dean at three other law schools, two public schools,

13 and one private not-for-profit. I've been involved in

14 ABA accreditation site visits and evaluations for over

15 20 years.

16 At Florida Coastal, our mission is providing

17 a student-centered outcome education, narrowing the

18 chasm between law school and the realities of law

19 practice, and serving the underserved.

20 How do we do that? We do it by attention to

21 metrics and by being accountable to our students. We

22 have Bar pass rates consistently above the statewide
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1 pass rates and above the ABA accreditation standard

2 threshold.

3

4 We have placement rates consistently over 90

5 percent. In the last two years, Florida Coastal and

6 Phoenix School of Law have both been honored by the

7 American Bar Association with its Prestigious Gambrell

8 Award for Professionalism for programs that we offer to

9 students.

10 Florida Coastal has been ranked in the top 10

11 in the country in moot court competition in the last

12 two years and our three-year cohort default rate is

13 right at two percent currently.

14 The one size fit all approach of the NPRM

15 unfairly and unreasonably targets professional and

16 postgraduate educational programs. It does not

17 consider the fact that law schools are unique. It

18 ignores law students, that law graduates typically

19 consolidate their loans and amortize them out to 20-to20 30-year periods.

21 A national study conducted by the National

22 Association of Legal Professionals indicates that
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1 lawyers rationally defer payment of principal while

2 studying for the Bar exam and that most, as with

3 physicians, don't reach true earning potential until at

4 least year seven after graduation. It's been pointed

5 out by several speakers that the rule would not allow

6 many not-for-profit law schools, including Harvard and

7 Duke, to comply with the rule and that medical schools

8 would have equal difficulty complying with the rule.

9 The proposal does nothing to address the

10 abusive tactics. ABA accreditation standards, however,

11 do. They regulate marketing and admissions practices.

12 They prevent schools from admitting those who they deem

13 cannot succeed and from continuing those enrolled who

14 have already demonstrated that they can't succeed. They

15 require all of us to have academic success programs, to

16 provide debt counseling and consumer information to

17 meet Bar-passed metrics and to have meaningful career

18 services programs.

19 The rule, as has been pointed out, will have

20 a very adverse impact on underserved communities.

21 Florida Coastal is currently populated with over 30

22 percent students of color. Indeed, the first year
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1 class this year has 236 students of color. That's more

2 than the entire first year classes at my three previous

3 institutions.

4 We urge the department to consider that

5 there's a major conflict between gainful employment and

6 other legislatively-provided programs allowing for

7 deferral, allowing for additional borrowing through the

8 Grad Plus Program.

9 We urge the department to look to accrediting

10 bodies, such as the ABA, for rigorous accreditation

11 standards that can be adopted as best practices. We

12 urge the department to deem law schools and other

13 professional schools that demonstrate quality outcomes

14 in compliance with the best practice level

15 accreditation I just referred to as being in compliance

16 with the final rule.

17 We urge the department to account for income18 based repayment in its metric and to include all loan

19 payments in the metric. We urge the use of a 30-year

20 payback in the debt-to-income ratio and years 7 to 10

21 in the income calculation for law schools and

22 professional schools and, as others have done, we
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1 suggest a three-year phase-in period.

2 I'd be happy to answer any questions. Thank

3 you.

4 MR. BURTON: Good morning. My name is Ben

5 Burton. I'm the Chief Student Financial Resources

6 Officer for Ivy Tech Community College of Indiana.

7 Ivy Tech is Indiana's largest public post8 secondary education institution and the nation's

9 largest singly-accredited statewide community college

10 enrolling more than 200,000 students annually.

11 As a statewide open access community college,

12 Ivy Tech provides the residents of Indiana with

13 professional technical transfer, lifelong education for

14 successful careers, personal development, and

15 citizenship opportunities.

16 Ivy Tech has 29 campuses throughout the

17 state, is within a 30-minute drive of most Hoosiers'

18 homes.

19 At Ivy Tech, we agree that no student's

20 financial aid situation should be worse for attending a

21 postsecondary educational institution. However,

22 hopefully we can agree that all individuals should have
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1 the opportunity to attend a postsecondary educational

2 institution and, further, these regulations unduly

3 affect the low-middle-income and, importantly, the

4 adult learn.

5 Both the Gates and Lumina Foundations have

6 stressed the need for new creative approaches to help

7 students successfully contain postsecondary education

8 credentials. We believe the use of stackable

9 credentials is one such approach that is extremely cost

10 effective for both the student and the taxpayers.

11 Thus, we ask that when a certificate or

12 diploma programs that are part of a stackable

13 credentials track leading to an associate's degree at

14 the same or state-approved public or not-for-profit

15 affiliated institution be excluded from the Gainful

16 Employment regulations.

17 Although building on successfully-completed

18 credentials should be a common practice at all

19 institutions of postsecondary education, the first step

20 starts with the attainment of their certificate or

21 diploma certification.

22 An April 1st, 2010, document by Jamie
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1 Merisotis, President of Lumina Foundation, identifies

2 stackable credentials as a "promising practice in

3 helping adult learners complete their educational

4 objectives."

5 At Ivy Tech, 73 percent of our students are

6 independent, 60 percent of our students that receive

7 financial aid are over the age of 25, 20 percent are

8 single mothers, over 10,000 are on some sort of public

9 assistance, and 35 percent of our students report

10 earning under $16,000 a year.

11 Life circumstances often get in the way of

12 these individuals meeting their goals. In many cases,

13 the one-year program is the individual's only realistic

14 approach to restarting their education and we believe

15 they deserve that opportunity.

16 Again, to quote Lumina, a recently-published

17 Lumina document, "for many adult degree-completers

18 returning to college means overcoming past failures and

19 fears of contemporary learning environments,

20 remediation of essential skills and developing

21 effective study habits and time management. Successful

22 completion of the certificate program builds
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1 confidence, encourages the students to continue their

2 education. Successful completion means the student is

3 well on their way to completing their associate's

4 degree, starting their Bachelor's degree in a third

5 year or junior status. Success does generate success."

6 Not only does this approach beef up self7 confidence in the student's ability to succeed, but it

8 is also extremely cost effective. Neither the student

9 nor the taxpayer should be forced to repay tuition

10 costs nor should be academically stymied by being

11 forced to retake courses that should be integrated into

12 a well-thought-out academic plan that includes building

13 upon prior successes.

14 I would also like to briefly address the

15 program approval. As a public institution, we

16 recognize our fiduciary responsibility not only to the

17 Department of Education but to the State of Indiana and

18 their taxpayers.

19 We also recognize that the significant role

20 community colleges play in helping build a strong

21 economy and providing a trained workforce. To quote

22 Indiana Governor Mitch Daniels, "Indiana's economic
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1 future depends heavily on doing all we can to increase

2 the numbers of Hoosiers with postsecondary education

3 and Ivy Tech's role is critical in that part."

4 Requiring additional layers of federal

5 approvals in the process of offering programs or the

6 expansion of current programs in unique locations is

7 unnecessary and redundant and will hamper the

8 institutions' agility in moving in concert with the

9 demands of industry and the economic climate of our

10 state.

11 There are numerous steps that we must

12 currently complete in order to offer new programs that

13 are Title IV-eligible at any of our locations across

14 the state, including obtaining approval from the

15 Indiana Commission of Higher Education.

16 As a state-funded organization, we are forced

17 to be very judicious when considering our decisions and

18 already work diligently with local employers and

19 businesses in making these decisions.

20 Employers evaluate the state's workforce when

21 making decisions on where to locate. To be

22 competitive, we must be able to respond quickly to
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1 their demands, otherwise we will continue to lag behind

2 other countries in the area of technology and

3 manufacturing.

4 A recent Lumina study determined that in

5 order to obtain their "big goal" and in order to meet

6 President Obama's education goal for the country, we

7 must look to the adult learner or our economic progress

8 will continue to be stymied. We are concerned that

9 these regulations would in fact hinder our adult

10 learners continuing education and increase in the

11 marketplace.

12 Thank you.

13 MR. KVAAL: 15-minute break. Thank you for

14 your time. We look forward to continuing the

15 conversation.

16 (Recess.)

17 MR. OCHOA: Good morning. We're going to

18 resume. We have a slight turnover here in this panel.

19 I'm Eduardo Ochoa, Assistant Secretary for

20 Postsecondary Education. Steve Finley from the Office

21 of General Counsel and David Bergeron from Office of

22 Postsecondary Education.
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1 So if we could have our first speaker,

2 please.

3 MR. LOPEZ: Good morning. My name is Jose

4 Pedro Lopez. I'm from the Latin Chamber of Broward

5 County. I also speak for the Latin Chamber of Lee

6 County and West Palm Beach and some of the other

7 associations and here we represent everyone.

8 The Latin Chamber of Commerce of Broward

9 County, we like to express concerns regarding the

10 proposed Gainful Employment regulation. Our local

11 Broward County colleges and universities annually

12 graduate skilled professional adults who contribute

13 greatly to our state economy.

14 During a recent scholarship lunch, the Latin

15 Chamber of Commerce of Broward County recognized

16 several students from the colleges and universities and

17 the important part they play in advancing Florida's

18 workforce talent.

19 Florida has a service-based economy and the

20 aging population relies on graduates in healthcare

21 education, nursing, culinary services, hospitality, and

22 business administration.
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1 Florida colleges and universities are

2 critical resources as Florida develops a class

3 workforce. As you know in Florida, we have a lot of

4 minorities, especially where I come from in South

5 Florida. We do believe that this is going to affect

6 the people. The people have taken the most advantage

7 of most of the colleges right now if you look at

8 minorities.

9 We implore you to think about this because

10 what's going to happen here is that maybe with good

11 intentions you're going to really destroy the hopes of

12 a lot of minority students that usually in a private

13 college they could do it faster and they could do it

14 better and they are coming out and making good money

15 because most of those private colleges make sure they

16 get employed.

17 If you send them to like Broward County

18 Community College, I hate to tell you they ain't going

19 to find no jobs and they're going to take a long time

20 and we're back to the same old stuff that we want to

21 fix it but nobody does it.

22 Please rethink this. Thank you.
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1 MR. OCHOA: Thank you. Next speaker, please.

2 MS. FIKE: Good morning, Panel Members. I'm

3 Lucky Speaker Number 13.

4 My name is Andrea Fike, and I am the Senior

5 Vice President and General Counsel of Regency Beauty

6 Institute.

7 Previously, I was the general counsel of a

8 publicly-traded software and analytics firm and before

9 that a partner at a major regional law firm in

10 Minneapolis.

11 I joined Regency in 2008 because of the

12 company's innovative approach to vocational education

13 and because of its focus on preparing students for

14 successful careers.

15 Regency is privately-held and headquartered

16 in Minneapolis. We have 6,000 students in 80 campuses

17 in 19 states, all of whom are engaged in cosmetology

18 certificate programs of about a year in length. We are

19 committed to providing training in a physical

20 environment that is convenient, looks and feels like an

21 upscale and professional salon, and that enables our

22 faculty to maintain a laser-like focus on student
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1 education.

2 Regency supports the goal of ensuring that

3 students receive a quality education that prepares them

4 for employment in their field and at a cost justified

5 by their earnings potential.

6 In our written response to the second NPRM,

7 we laid out a number of concerns with the proposed

8 Gainful

9 Employment Rule. Today, we would like to

10 highlight the two most important: the construction of

11 the metrics and the implementation of the timing.

12 First, the two metrics, as constructed, will

13 restrict access to education for at-risk students and

14 discourage schools from investing in quality and

15 addressing tuition rates.

16 Why? Because schools cannot accurately

17 predict how we will score on the metrics two years from

18 now and, most importantly, how changes that we might

19 make today will impact our scores at that time and

20 beyond.

21 The loan repayment metric gets at the

22 relationship between program cost and earnings
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1 indirectly at best. The SSA data used in the debt-to2 income metric are not predictable or visible to

3 schools. Both metrics put schools serving at-risk

4 students at risk because of the lower average

5 performance of certain demographic segments on both of

6 those metrics.

7 By using debt-to-income data and BLS data as

8 the sole metric, the department could remove the

9 incentive to abandon at-risk students and provide the

10 certainties schools need to set tuition rates

11 appropriately.

12 Using the mean rather than the 25th

13 percentile, the department could more accurately

14 reflect career-earning potential and encourage

15 investment in education that provides a good return

16 over time.

17 This is particularly important in service

18 industries, like cosmetology, where 44 percent are

19 self-employed. Many go on to own salons and guest

20 bases and earnings are built over time, not immediately

21 upon graduation.

22 Our second concern with the proposed
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1 regulation is in the implementation timeline. Given

2 the March 31st, 2011, cutoff for entering repayment,

3 every student, every student that will be measured in

4 the cohort on July 1st, 2012, left our schools by

5 September 30th of this year.

6 Therefore, we have no ability to impact

7 repayment rates by improving our programs, modifying

8 tuition policy or investing and advising, loan

9 counseling, or career services.

10 In summary, we offer the following amendments

11 to the proposed rule with the opinion that they are

12 critical to achieve the department's objectives.

13 1. Make the sole metric a debt-to-income

14 test based on mean BLS earnings.

15 2. Implement the regulation prospectively

16 rather than retrospectively to give schools the

17 opportunity to make necessary changes.

18 Thank you for the opportunity to be here

19 today. We look forward to continuing to work with the

20 department to identify common sense approaches to meet

21 your objectives.

22 MR. OCHOA: Thank you.
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1 MR. ARTHUR: Thank you for the opportunity

2 today to present comments on the Gainful Employment

3 Proposed Regulations.

4 My name is Jeff Arthur, and I'm the Chief

5 Information Officer for ECPI College of Technology, a

6 privately-held skills-based regionally-accredited

7 college with 12,000 students, mostly in IT and

8 healthcare, of which 2,500 are in nursing programs and

9 a small number of culinary arts.

10 Twenty-five percent of ECPI's students are

11 referrals and we reject 15 to 20 percent of all

12 applicants.

13 I have managed financial operations for

14 multi- campus colleges for 27 years, served on several

15 advisory boards and been a negotiator in the neg-reg

16 process.

17 One week ago, final program integrity issue

18 regulations were published that will provide prominent

19 and significant information that will result in well20 informed consumers and, given that the department sees

21 these disclosures are important enough to codify and

22 develop a master disclosure form, it is only logical
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1 that all institutions should be strongly encouraged to

2 disclose this information.

3 I disagree that these disclosures are

4 inadequate, as was noted in the final regulations. A

5 significant percentage of persons looking at

6 institutions covered by these regulations are adults or

7 they have attended other higher education institutions

8 before. The average age of ECPI's students is 28 and

9 50 percent have attended other colleges. These

10 disclosures will ensure that they enroll in programs

11 and institutions that work for their career goals.

12 Achieving a college degree is a considerable

13 achievement and those with the aptitude should be

14 afforded the opportunity to choose their educational

15 path. Not all will make it, but our programs are often

16 their best chance, regardless of whether they pay

17 principal on their loans early in their loan repayment

18 or what their debt-to-income ratio is soon after

19 graduating.

20 The collective cost to students not

21 attempting the program is far greater than the minimum

22 cost associated with variant repayment rates on non-
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1 dischargeable student loans.

2 We've gone several decades without defining

3 gainful employment. So let's at least take a

4 relatively brief time to see the trends from the

5 disclosures, study the data that is going to be

6 collected, and dedicate negotiated rulemaking time to

7 consider whether it's proper and necessary to implement

8 these formulas and properly vet these formulas, if so.

9 Little time was spent in the neg-reg process

10 on this formula, mostly at the end, and I think with

11 the magnitude of this package that we should really

12 refocus on this and look at it as a group.

13 With regard to the specific proposed

14 formulas, it's not appropriate to hold institutions

15 accountable to formulas that are greatly impacted by

16 student borrowing over which an institution is afforded

17 little influence.

18 Higher education financial aid offices are

19 full of expertise in finance and financial aid, yet are

20 not allowed to implement policies to minimize excessive

21 borrowing by students. Even an institution's tuition

22 costs may not affect how much a student can borrow.
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1 Whether a student attends a low-cost highly-subsidized

2 institution with lower student success rates or an

3 elite private institution, the adult student often has

4 access to the same debt levels.

5 For 20 years, I've asked that the experts in

6 financial aid have the ability to craft loan limit

7 policies that afford each student the best opportunity

8 to manage their debt. Yet in the absence of such

9 policies, we're held accountable for default rates and

10 now proposed debt-to-income rates and repayment rates.

11 It's time we all work together to come up with

12 effective student borrowing policies while affording

13 each student the opportunity to choose the education

14 that best meets their needs.

15 These regulations effectively apply to

16 certain institutions while pretending that students

17 attending other institutions are doing so for reasons

18 other than gainful employment.

19 Congress should decide any laws to be taken

20 to address the concerns that these proposed rules

21 address beyond what has been finalized in last week's

22 regulations.
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1 I'd like to point out a few flaws in the

2 formulas themselves, in addition to the burdensome

3 complexity of the package as a whole.

4 Any formula that measures the success of

5 students repaying loans should not consider any period

6 that is within three years of graduation. When a

7 student graduates from college, it is a dramatic period

8 of maturing and transitioning to a career. There is

9 much financial and emotional turmoil while we try to

10 find our way and often financial goals revolve around

11 paying as little as possible on any debt.

12 I sure didn't concern myself with such

13 matters as how much principal I paid on my student

14 loans after I graduated and I doubt it's the focus of

15 many recent graduates.

16 For me and my wife, car payments and new

17 family obligations were the top priorities. Paying as

18 little as possible on a student loan at minimal

19 interest was our preferred repayment plan.

20 For this reason, repayment rates should look

21 to the middle of the repayment period, no sooner than

22 four years after graduation.
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1 The same concern applies to debt-to-income

2 measurements. Where we should be looking at the 50th

3 percentile of stable Department of Labor data, an

4 institution shouldn't be penalized because they happen

5 to have a population that's most likely to take FMLA

6 leaves in the periods their wages are being measured

7 while they start their families. My wife took a few

8 months off for each of our two children but this

9 formula would penalize for these scenarios where actual

10 income earned from work would be measured, nor should

11 any formula be subject to the economic factors that are

12 cyclical and greatly impact these metrics beyond the

13 control of the institution.

14 At a minimum, up to 10 percent of students on

15 forbearance should be removed from calculations to

16 accommodate for these economic influences.

17 I appreciate your time and consideration of

18 these comments.

19 MR. OCHOA: Thank you. Next speaker, please.

20 MR. GASAWAY: Good morning. My name is Kent

21 Gasaway. My occupation is money management. I work

22 for a mutual fund company, Buffalo Funds, based in a
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1 suburb of Kansas City.

2 For full disclosure, several of the funds I

3 help manage own publicly-traded for-profit education

4 stocks. Also for full disclosure, two of my daughters,

5 ages 19 and 20, attend a for-profit fashion college in

6 Los Angeles, California.

7 For a person in my position, I may be in the

8 minority but let me start by saying I believe the new

9 rules encompassing gainful employment, while they may

10 need some changes, are generally a step in the right

11 direction for the for-profit industry longer term.

12 Why? The new rules will create higher

13 barriers to entry for the survivors. While they may

14 not grow as fast or in the same profit margins in the

15 past, they will be viewed as higher quality and more

16 sustainable companies.

17 The education programs and degrees they

18 provide will be viewed with more respect, more valuable

19 to prospective students and adults and more competitive

20 with not-for-profit companies.

21 Additionally, the proven ability to serve

22 working adults and other non-traditional students via
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1 online and flexible hours will continue to fill a void

2 not well represented by not-for-profits. Under the

3 above scenario, everyone should win, students,

4 employers, the universities, and shareholders.

5 However, I want to highlight and expand a

6 little on the keyword I used above, that word is

7 survivors. In order for everyone to win under the

8 proposed new rules, there must be survivors. I'm quite

9 concerned that the department has not fully considered

10 the near-term macro economic ramifications of the

11 timeline chosen for the implementation of these

12 thresholds.

13 Under the proposed rules, they would be

14 effective and backward-looking from July 2012. Thus

15 the rules would effectively bake in periods of time

16 that are impacted by the highest unemployment rate

17 since the Great Depression.

18 At the current pace of job growth, it appears

19 that 2011 may not show much improvement. Some

20 economists estimate the current underemployment rate,

21 those unemployed, plus those working part-time, plus

22 those who've given up working, is near 20 percent.
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1 This clearly is not the appropriate and fair

2 time to be measuring whether students are gainfully

3 employed. In reality, most recent college graduates

4 are lucky to have any job, much less one in a field of

5 study earning an average starting salary. Most recent

6 graduates, including working adults, are struggling to

7 pay their rent, their mortgage, the utilities, the car

8 payments, and their credit cards.

9 Current high default rates on the above

10 obligations are well documented. Thus, it would seem

11 quite illogical that one would expect any kind of

12 normal or true repayment rate on student loans during

13 this same period.

14 During difficult times like these, it is

15 highly likely that students view their loans near the

16 bottom of their priority payment list. Dare I say they

17 probably view paying their iPhone bill far more

18 important than paying their student loan right now?

19 Nor can anyone expect that actual incomes

20 measured during this period represents anything close

21 to normal. How could they when some one in five adults

22 currently are underemployed? This is reality. In my
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1 opinion, something the department must take into

2 greater consideration.

3 I'm highly fearful that the current timeline

4 or measurement period proposed for the new rules will

5 result in far more casualties than projected.

6 For-profit colleges can and will change and

7 improve their programs and they will reduce tuitions,

8 but if adequate jobs aren't available, they will simply

9 fail your test. If current economic trends persist

10 into 2011 and 2012, and the department must concede

11 that this is quite possible, the casualty list could

12 include some very fine institutions.

13 Let me give you a real-life example. One of

14 my daughters attended Johnson County Community College

15 last semester. Johnson is one of the most affluent

16 counties in Kansas and the nation, with a median family

17 income of over $76,000. With a student population of

18 over 35,000, it's a very successful and highly19 respected community college. Yet the department

20 reported this college had a repayment rate below the 45

21 percent threshold.

22 If the economy is impacting the ability of
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1 Johnson County graduates and their parents to repay

2 their federal student loan debts, which are likely much

3 lower than average, I assure you the impact, the

4 economic impact today is very widespread.

5 In summary, I can't imagine the intention of

6 these new rules is to shut down programs with good

7 results. Thus, what should the department do? If you

8 intend to move forward with gainful employment near its

9 current form, I would propose that the implementation

10 be phased over a longer period of time, perhaps use the

11 12 percent debt-to-income threshold and/or the 35

12 percent repayment levels rather than eight percent and

13 45 percent as the thresholds for continued unrestricted

14 Title IV eligibility at July 2012.

15 This would provide for some cushion for

16 programs that might not make it due to the bad economy.

17 The department could then set a later date, say July

18 2015 or 2016, to make currently-proposed thresholds

19 effective.

20 In my opinion, this would be a win-win

21 compromise for all parties. The tougher rules would

22 still loom on the horizon, make it imperative that all
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1 colleges begin work towards complying with these new

2 standards.

3 Also, if the economy remains difficult, the

4 department would avoid the severe criticism that would

5 likely have been placed on you for the closing of

6 programs, if not entire schools, due to the

7 unreasonable implementation or timing of well-intended

8 rules.

9 Thank you very much.

10 MR. OCHOA: Thank you. Next speaker, please.

11 MS. KEISER: Good morning and thank you for

12 the opportunity to speak with you today.

13 I am Belinda Keiser, and I am speaking

14 against the Gainful Employment Rule.

15 I'm a principal of Keiser University. Our

16 family started the university 33 years ago. Today,

17 we're a Level 5 SACS-accredited institution. We offer

18 two-year Master's, baccalaureate, and Ph.D. programs.

19 We are also located in Shanghai and Moldova. Our

20 18,000 students go into diverse different types of

21 careers.

22 The first point that I would like to make,
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1 I'd like to speak to you about our industry and the

2 first point I would like to make is that private career

3 colleges are the creators of talent, are critical

4 economic drivers which define our nation's ability to

5 compete, something that I know we hold as a value

6 that's dear. In fact, I noticed it on your Mission

7 Statement.

8 There are over 1,500 private postsecondary

9 schools, institutions, colleges and universities

10 serving over three million students in diverse fields.

11 This is the organization known as formerly the Career

12 College Association and today it's the Association of

13 Private Sector Colleges and Universities.

14 As the former chair of Workforce Florida, I

15 have served as a leader in workforce development for

16 over 14 years. I believe that the Gainful Employment

17 regulation, as currently written, will limit student

18 choice and cripple our country's ability to compete.

19 The career college sector is instrumental in

20 ensuring the competitiveness of our country. I'm from

21 Florida. We have a staggering unemployment rate of 12

22 percent. Normally a 120,000 people visit our one-stops
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1 daily. In October, roughly two million Floridians went

2 to the online system looking for assistance, for job

3 assistance help.

4 Career colleges are one of the most effective

5 industries in times of economic distress, creating new

6 jobs and also resolving the needs as our jobs and our

7 economy shift.

8 You may find it interesting that Benjamin

9 Franklin started a printing school. Many of us like to

10 think of his school as the first career college and

11 later you would recognize this school as the University

12 of Pennsylvania.

13 At Keiser University, according to your data,

14 we are nationally ranked as the third largest producer

15 of associate degrees in health professions and related

16 clinical sciences for two-year associate degrees and

17 nationally 42 percent of all two-year health degrees

18 and certificates are awarded by career colleges.

19 Keiser University ranks fourth nationally in

20 the production of associate degrees in criminal justice

21 and protective services and nationally, since 9/11,

22 there's been a 35 percent in the need for professionals
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1 in this field.

2 Second point is career colleges, that our

3 sector is very effective in educating working adults.

4 Our students are older. They work full time. A

5 greater percentage of them, 60 percent of them are

6 female. More than 40 percent are racial minorities.

7 Most are first-generation students and the first to

8 achieve a college degree in the history of their family

9 and many go to school without any sort of family

10 support.

11 Statistics demonstrate that working adults

12 are better served by our sector, completing their

13 program of study more often whether they pursue a two14 year or four-year degree. The Imagine American

15 Foundation states that 54 percent of African American

16 students attending two-year career colleges graduate

17 within three years compared to 23 percent of the

18 graduates when they attend public institutions, and,

19 secondly, 63 percent of the Hispanic students graduate

20 in the same period when they attend our schools

21 compared to 30 percent at community colleges.

22 Students with two or more barriers to
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1 graduation are twice as likely to complete their degree

2 in our sector than when they attend public and

3 traditional colleges. That was from the Imagine

4 America study.

5 In crafting the Gainful Employment

6 regulation, we must continue to focus on student needs,

7 and the third point I would like to make, ladies and

8 gentlemen, is the proposed regulation respectfully

9 offered is short-sighted.

10 A program study, even in a career college,

11 does not always determine the graduate's career path.

12 All over the country, we have successful people who are

13 doing something other than they were trained for. We

14 have music majors who become government analysts. We

15 have criminal justice majors who become life insurance

16 salesmen and women. Those iterations take time.

17 Expecting all graduates to enter the field

18 that they have studied in and stayed there for the

19 first three or four years is expecting something

20 dramatically different than the American experience.

21 I know that we would agree that education is

22 the key to allowing people to seek and obtain their
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1 dreams. Why would we limit an individual's access and

2 choice as they pursue their personal educational path

3 that leads to professional goals and their American

4 dream?

5 In effect, although likely very much

6 unintended, the rule can be perceived as determining

7 that the dreams of wealthy children attending the elite

8 institutions of America and studying art history,

9 French literature and a wrath of other subjects for

10 which entry level pay is probably lower than registered

11 nurses, are deemed good dreams, but the dreams of

12 single mothers, like my mom, first in household to

13 attend college, and those in minority communities are

14 not considered as worthy in terms of their dreams when

15 they become teachers, medical assistants, and security

16 workers.

17 The Gainful Employment Rule will have

18 unintended consequences. Colleges and universities nor

19 graduates determine starting wage of any career field

20 and linking students' debt to a starting salary without

21 considering its propensity to rise in the third, fifth,

22 or 10 year of the job is a disservice to students
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1 pursuing their dreams.

2 If our concern is generally about wages, then

3 I ask let's take a longer view of earning and ability

4 to pay. Yes, sir.

5 Thank you. On behalf of three million

6 students and the 200,000 Americans our sector employs,

7 I respectfully request that the department step back

8 and reconsider the linking of earnings required to loan

9 debt for students. This rule, if implemented in the

10 current form, will not serve our country well.

11 Thank you very much.

12 MR. OCHOA: Thank you.

13 MR. GILL: Thank you for the opportunity to

14 speak here today.

15 I am Ian Gill, President of the International

16 Academy of Design and Technology in Orlando, Florida.

17 I am concerned about the devastating impact

18 the proposed rule could have on my students. They have

19 made informed decisions to pursue their professional

20 passions and I'm sure that the Department of Education

21 both underestimates the rigor of our programs and the

22 efforts of my students.
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1 Many are first in their families to attend an

2 institution of higher education. Many are single

3 parents or come from low-income families. Some are

4 veterans looking to find a career after serving our

5 country. Many are adults seeking new skills to find

6 more fulfilling employment. Many have come to us from

7 first having been enrolled in traditional colleges and

8 universities where their needs were not met.

9 Our students strive to better themselves, to

10 improve their lives and to contribute to their

11 communities. If you don't believe me, then you should

12 come to one of our graduation ceremonies. The pride of

13 the parents, spouses, and children as they watch their

14 loved one walk across the stage is every time

15 overwhelming.

16 While I applaud the department's interest in

17 addressing student debt, I don't agree that the right

18 way to do this is by pushing low-income students,

19 including a significant number of minorities, out of

20 school all together.

21 Sure, if these students don't go to school,

22 they can't over-borrow, but keeping students out of
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1 college downsizes their dreams and damages an economy

2 in need of well-educated and highly-skilled

3 individuals.

4 The only outcome of your proposal will ensure

5 that the President will never reach his 2020 goal.

6 Your proposed definition of gainful

7 employment departs from the agency's past practice and

8 that of other government agencies. Further, the

9 formula appears to have been designed to put the intent

10 of making our institutions seem more expensive and my

11 students less successful than they are. Let me

12 explain.

13 First. The department's proposal relies on

14 total student debt as a proxy for institutional costs.

15 This is unreasonable since students are allowed by

16 statute to borrow amounts that significantly exceed the

17 costs of tuition and fees.

18 We know that students over-borrow and not

19 just our students and it's just not for educational

20 expenses, as well. While we discourage them from doing

21 so, we are prohibited by law from interfering with

22 their borrowing rights. Yet the sad reality is that
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1 many of our students don't have parents who contributed

2 to a 529 plan, you know, or the parents saving for a

3 child's education or having a parent willing or able to

4 borrow on a student's behalf.

5 But as bad as the borrowing might be, the

6 reality is that without borrowing, these students could

7 not attend school at all.

8 Secondly, as mentioned by previous speakers,

9 the calculation of debt-to-income ratio is based on an

10 earnings window that is focused on the first three or

11 four years of an individual's career. This goes

12 against every accepted economic model for determining

13 return on investment.

14 Thirdly, the former includes no mechanism to

15 address economic downturns which impacts all workers,

16 not just our graduates.

17 Fourth. The proposal fails to explain how

18 the department will collect actual wage data or

19 differentiate between a student who couldn't get a job

20 and one who chose to take time off to raise children or

21 pursue additional educational credentials.

22 The department insists that whatever the data
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1 sources ends up being, we have no right to examine or

2 challenge the accuracy of those data, thereby

3 forfeiting our right to due process which is very un4 American.

5 And fifth, the department's proposal departs

6 from past practice in its definition of repayment

7 rates. It portrays students who are meeting their

8 legal obligations as deadbeats simply because they

9 chose to participate in one of the many debt management

10 programs that Congress created and the Department of

11 Education promotes.

12 Low-income and nontraditional students do not

13 need regulations that treat them as second-class

14 citizens. We deny them level of institutional,

15 programmatic, and career choice that more advantaged

16 students take for granted.

17 We need a reasonable discussion on how to

18 reduce student debt and help our students succeed at

19 the same time. It's time for the Department of

20 Education to go back to the drawing board and let the

21 discussions begin.

22 Again, I'd like to thank you for my time here
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1 today and look forward to, you know, further

2 improvements and revisions with the proposal.

3 Thank you very much.

4 MR. OCHOA: Thank you.

5 MR. HARDIMAN: Good morning, gentlemen. My

6 name is Joe Hardiman, and I'm the President of Le

7 Cordon Bleu College of Culinary Arts in Orlando.

8 We graduated our first class in 2004 and

9 since then have graduated more than 3,600 students.

10 I'm here to speak on behalf of those students and

11 graduates. They are hard-working people who love to

12 cook and bake, whose lifelong dream is to work in

13 restaurants, resorts, hotels, and need the skills and

14 credentials that we provide through hands-on learning

15 and flexible schedules.

16 Many of our students work nights to manage

17 school, family, and life. They are striving to climb

18 up the ladder of success and we fear that your proposed

19 Gainful Employment Rule would pull up the ladder out of

20 their reach.

21 I know the industry, I know our students, and

22 I know what we offer. We offer what they need to find,
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1 to keep and move ahead in their careers.

2 Before becoming President of Le Cordon Bleu,

3 Orlando, my entire career has been in the hospitality

4 industry, managing chefs and cooks. I worked for 21

5 years for the Walt Disney World Resort, in addition to

6 while living in New York City, I was the general

7 manager of a hotel and a member of the Board of

8 Directors of the New York State Hospitality and Tourism

9 Association.

10 My campus currently has 1,230 students. We

11 serve sectors of the population who many traditional

12 colleges overlook and underserve. Fifty-six percent

13 are between 20 and 29 years old, 15 percent are between

14 30 and 39 years old, and 11 percent are 40 years and

15 older. Twenty-eight percent of our population is

16 Hispanic and 13 percent is African American. We have

17 94 veterans in our population.

18 We offer two Associate in Science degrees,

19 one in Culinary Arts and the other in Patisserie and

20 Baking. In 2008, we added a Diploma Program in

21 Culinary Arts which we deliver entirely in the Spanish

22 language. Just this month, we began offering a
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1 Patisserie and Baking Diploma Program entirely in the

2 Spanish language.

3 We are nationally accredited by the

4 Accrediting Council for Independent Colleges and

5 schools, ACICS, and our programmatic accreditation is

6 from the American Culinary Federation, the ACF. They

7 have designated the college's program as exemplary

8 programs.

9 Our graduation rate is 62 percent on all

10 programs which is substantially above the rate for our

11 IPEDS comparison group. Our annual placement rate last

12 year was 91 percent, even in a bad economy. The year

13 before, it was 96 percent. Our cohort default rate for

14 2008 is 5.8 percent.

15 Great companies come to our college to

16 recruit our students: the Walt Disney World Resort,

17 Hilton, Marriott, the Waldorf-Astoria, the Ritz,

18 Emeralds, Universal Studios, just to name a few.

19 Permit me to brag about the college, the

20 honors we've received, for just a minute. In 2007, we

21 were designated by the Florida Association of

22 Postsecondary Colleges and Schools as the College of
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1 The Year. We're in the Guinness Book of World Records.

2 We earned the distinction for the world's largest cr?me

3 Brule. It tasted good and we invited the health

4 department. Nobody invites the health department. We

5 wanted to demonstrate to our students that setting the

6 world's record and doing it right is important.

7 In September, our Culinary Competition Team

8 earned the Gold Medal and took the first place in the

9 State of Florida Culinary Federation Postsecondary

10 School Competition. Our team is coached by Certified

11 Master Chef Klaus Friedenreich, who's a member of our

12 faculty.

13 There are approximately 70 certified master

14 chefs in the United States. Probably less than 10 are

15 involved in education. When I go by Chef Klaus's

16 class, the students are riveted on the chef's

17 interaction with them.

18 The proposed Gainful Employment Rules could

19 limit access to programs at our school. The focus on

20 entry-level wages for evaluating gainful employment is

21 a misguided measurement. Like most skilled workers,

22 few of today's students will realize the full economic
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1 benefit of their educational investment during the

2 first four years of their career. That is why the

3 Census Bureau in its report, The Big Payoff, looked to

4 cumulative work life earnings to measure the return on

5 an educational investment.

6 The focus on early career earnings is

7 especially harmful to graduates in fields, such as

8 culinary arts, but most important of all, the

9 department should ask employers how culinary school

10 graduates begin their careers in the kitchen. The chef

11 will tell you they need to arrive for work bright-eyed

12 and bushy-tailed. They must be ready to work hard,

13 professionally attired and demonstrate to the chef that

14 they can work every station in the kitchen, and they

15 must demonstrate advanced human relations

16 communications skills, food safety and food cost

17 knowledge. Then and only then do they begin to earn

18 more than a highly-skilled cook.

19 That's what the department needed to know

20 before proposing the new rules that would harm these

21 passionate professionals' dreams of personal success

22 and meaningful employment.
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1 Thank you for the opportunity to be here.

2 Come visit my college.

3 MR. OCHOA: Thank you.

4 MR. GUTIERREZ: Good morning. How are you?

5 My name is Allen Gutierrez, and I'm here today to --

6 I'm the National Executive Director of the Latino

7 Coalition, and I'm here to present on behalf of the

8 Latino Coalition, a national nonprofit established to

9 address policy issues that directly affect the well10 being of Hispanics in the United States.

11 As an organization, we work to develop

12 initiatives and partnerships that will foster economic

13 equivalency and enhance overall business, economic, and

14 social development to Latinos.

15 My purpose to speak here today is to point

16 out, unfortunately, the proposed Gainful Employment

17 Rule will not expand higher education opportunities for

18 the Latino community. Instead, it stands to restrict

19 them from thousands of career college students across

20 the country.

21 This issue is especially important for us in

22 the Latino community. As minority students are
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1 disappropriately represented in career colleges,

2 currently over 50 percent of students attending career

3 colleges are minority students compared to

4 approximately 34 percent at public and 32 percent at

5 private not-for-profit four-year institutions.

6 Therefore, if the Gainful Employment Rule

7 were to take in effect as written, minorities would be

8 some of the first ones to lose out on their education.

9 In the Latino community, career colleges are highly

10 valued as educational institutions. For most students,

11 attending these schools, the combination of flexible

12 schedules, career-oriented curriculum, and affordable

13 tuition makes career colleges a popular choice, and the

14 quality of the graduates make them popular to would-be

15 employers.

16 Just take Marcus Gonzalez, a 2004 graduate of

17 the Art Institute of California in Orange county, which

18 is not too far from the Latino Coalition's headquarters

19 in Irvine, California, who is a graphic design manager

20 for the Walt Disney Parks and Resorts. He credits the

21 Art Institute for exposing him to more media

22 preparations for employment in this diverse field.
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1 Or Melody Blue Torres, who also received a

2 degree from the Art Institute of California in Orange

3 County. Educated in the art of cooking, she now serves

4 as an assistant general manager at Wolfgang Puck

5 Bistro, helping manage the kitchen while assuming

6 responsibilities for food costs, labor control, and

7 profit and loss.

8 As you can see, students in these schools,

9 especially Latinos and other minority students, make

10 connections, learn skills, and receive degrees in a

11 dozen of disciplines that help to propel them into

12 successful careers, careers they want to pursue.

13 The Latino Coalition believes that the career

14 colleges and their students are holding up to their end

15 of the bargain by working hard to improve educational

16 opportunities for students and by encouraging students

17 to attend higher levels of education.

18 More importantly, we believe that the

19 department should do the same rather than make it

20 harder for students to attend college.

21 Unfortunately for students, the proposed rule

22 could let decisions about an individual's future be
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1 based on a one size fit all debt-to-income ratio. In

2 our economy, complete with rising college tuition

3 prices, low-income students must secure to a certain

4 amount of debt to attend college. However, we should

5 not limit their educational opportunities in an attempt

6 to stave off rising student debt with a blanket fix.

7 In short, the Latino Coalition asks that you

8 reconsider the details in the proposed Gainful

9 Employment Rule regarding availability of requirements

10 in Title IV loans to students who attend nontraditional

11 career colleges.

12 For us and the many Latino students that

13 would be affected by this rule, the implementation

14 would create a situation wherein students with

15 identical financial situations and backgrounds in the

16 educational achievement would be treated differently if

17 they applied for federal student aid.

18 While the proposed Gainful Employment Rule is

19 well intentioned, we fear that inevitably the end

20 results will be perceived as discriminatory, arbitrary

21 and unfair to career college students and encourage you

22 to re-examine the proposed Gainful Employment Rule.
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1 Thank you very much.

2 MR. OCHOA: Thank you. Next speaker, please.

3 MR. STASCHAK: Good morning. My name's John

4 Staschak. I'm the President and CEO of Bryant and

5 Stratton College in Buffalo, New York.

6 Bryant and Stratton is one of the oldest

7 proprietary colleges in the country. We were founded

8 in 1854. We offer 25 Bachelor's programs and associate

9 degrees in New York, Ohio, Virginia, and Wisconsin in

10 the area of health, business, criminal justice,

11 information technology, human resources. We provide

12 courses in a classroom-based manner and also online,

13 and we strive to continuously enhance our curricula and

14 program offerings to ensure that graduates have

15 marketable skills.

16 As a result of what we have done over the

17 past, we continually look at programs and have

18 eliminated numbers of programs that no longer meet

19 employer needs and do not provide graduates with salary

20 growth opportunities.

21 We are proud that over 90 percent of our 2009

22 graduates have commenced careers in their chosen or
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1 related fields.

2 We are accredited by Middle States and a

3 number of other agencies, including the National League

4 of Nursing, and given the college's headquartered in

5 New York State, we're a member of the Association of

6 Proprietary Colleges or APC. Each of our states we

7 operate in provides significant regulatory oversight

8 with New York leading the way.

9 We structure operations to meet the highest

10 state regulatory threshold which is typically New York

11 in our system.

12 We share the department's concern over

13 student borrowing and like to see it reduced. As an

14 officer of the college, I sign excess loan refund

15 checks for students and see the large amounts of money

16 that students borrow beyond the cost of tuition and

17 books.

18 The college in recent years has reduced its

19 cost of education, reduced its Title IV aid,

20 particularly loans, available to students. In

21 addition, the college, for a number of years, has and

22 does provide students scholarship aid, which is merit-
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1 based, and institutional aid, which is need-based, to

2 our students. That amount totaled or exceeded $5.2

3 million last year.

4 I would just like to speak on a couple of

5 issues that we highlighted in our previous comments.

6 Urban campus students. Our campus network

7 includes four campuses that are located in urban core

8 areas of Buffalo, Syracuse, New York, Cleveland, Ohio,

9 and Milwaukee, Wisconsin. These four campuses

10 represent 26 percent of our student body. Our urban

11 students utilize a high level of Title IV aid, both

12 grants and loans.

13 Third party evidence suggests that loan

14 repayment rates for at-risk students, as measured by

15 Pell Grant utilization, across all sectors of higher

16 ed. Our internal data and assessment shows that urban

17 students have lower outcomes in terms of retention and

18 graduation and higher loan default rates. However,

19 upon graduation, urban graduate placement outcomes are

20 not significantly different than our non-urban student

21 populations.

22 Given the standardization of systems and
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1 curricula across the Bryant and Stratton system of

2 schools, one can conclude that the socioeconomic

3 demographics of urban students is a significant factor

4 in the number of outcome measurements. The lack of

5 success, along with higher projected cohort default

6 rates, has caused the college to hesitate on additional

7 urban core locations.

8 The implementation of the draft Gainful

9 Employment regulations will increase Bryant and

10 Stratton's apprehension of urban locations, including

11 our existing ones. The end result of implementing

12 Gainful Employment as drafted is the potential

13 reduction of educational opportunities for low-income

14 students.

15 Female population. The college has a rich

16 history of providing education and training for women.

17 Our current student population is 75 percent female.

18 Various students indicate that women in general have

19 lower incomes than their male counterparts. In

20 addition, the female in the family unit is the most

21 likely person to be the caregiver when raising a family

22 or if illness strikes the family. The result is that
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1 the female is more likely to be the family member not

2 working in the above scenarios.

3 The lack of income will impact both the

4 repayment rate and the debt-to-income metrics within

5 the draft Gainful Employment regulation. The GE Rule

6 would use actual average annual earnings for students

7 to determine the debt-to-income ratio. Clearly, the

8 average income number will be significantly reduced if

9 individuals not in the workforce for reasons noted

10 above or because students may have other valid reasons

11 for not being in the work place, such as disability,

12 illness, or perhaps they elect not to work at all.

13 Lifetime earnings and macro economics. The

14 regulation as drafted uses relatively short time frames

15 of three- and four-year windows after graduation in

16 which to measure compliance with debt-to-income and

17 loan repayment rates. Three-year window in particular

18 is not representative of what a college grad would earn

19 over a 40-year career.

20 One can also argue the most lucrative years

21 in terms of earnings is mid to late career. An

22 investment in debt incurred in the early years should
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1 be assessed based upon long-term income stream of that

2 asset, in this case a working individual, basic

3 economic in theory.

4 The proposed regulation ignores the impact of

5 macro economic conditions, such as the current

6 recession, high unemployment rates, proprietary

7 educations covered by this regulation, the effect of

8 being penalized for general economic conditions.

9 We also have concerns about data integrity

10 based upon our merger and previous experiences that

11 we've had with cohort default rates and question the

12 data integrity of the NSLDL.

13 I'd like to thank you for letting me appear

14 today. Thanks.

15 MR. OCHOA: Thank you. No more speakers?

16 Okay. We will adjourn until after lunch.

17 SPEAKER: Just a real quick announcement for

18 everyone. Some of you all were confirmed just for the

19 morning session but we invite you to come back for the

20 afternoon session. Your badges that you have, you can

21 use those throughout the building. There is a

22 cafeteria around the corner, so you can go there, and
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1 we encourage you to come back then.

2 Thank you.

3 (Whereupon, at 10:47 a.m., the meeting

4 was recessed for lunch, to reconvene at

5 1 o'clock p.m.)

6 AFTERNOON SESSION

7 (1:00 p.m.)

8 MR. OCHOA: Good afternoon. We're going to

9 begin the last session of this Public Hearing on

10 Gainful Employment Regulations, and I'm Eduardo Ochoa,

11 Assistant Secretary for Postsecondary Education.

12 With me here, we have John Kolotos from the

13 Office of Postsecondary Education and Georgia Yuan from

14 the Office of Legal Counsel.

15 Could we have our first speaker, please?

16 MR. COLLINS: Greetings. My name is Bob

17 Collins, Vice President of Student Financial Aid for

18 the Apollo Group, the parent company of the University

19 of Phoenix. I've been a practicing aid administrator

20 since 1981.

21 Thank you for the opportunity to provide oral

22 testimony today.
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1 The university has formally submitted

2 comments under both NPRMs as well as the OMB Request

3 for Information Collection which was transmitted to the

4 Office of Information and Regulatory Affairs.

5 The university embraces the objective of full

6 transparency to encourage students to borrow

7 responsibly. As currently proposed, these regulations

8 penalize future students for current students'

9 entitlement to borrow the maximum annual and aggregate

10 loan limits.

11 Therefore, we are concerned that the rule, as

12 currently proposed, does not achieve public policy

13 objectives. The proposed regulation has many

14 unintended consequences. We believe the unintended

15 consequences of this action will harm public service

16 occupations, such as nursing, education, and criminal

17 justice to the lowest starting salaries critical to our

18 nation.

19 It will deny access to lower socioeconomic

20 minority groups. The proposed rules will drive

21 educational institutions to re-evaluate serving these

22 segments. It will be discriminatory. Although we
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1 understand the department does not have the statutory

2 authority, any good public policy should be applied

3 consistently across all students. What is good for one

4 student should be good for all students.

5 Additionally, the debt-to-earnings test uses

6 discretionary income on the poverty guideline for a

7 single person, yet many nontraditional students are

8 single parent families. Also, by relying on data from

9 the Social Security Administration, the current

10 proposal excludes household income in the debt-to11 earnings calculation, even though the loan may have a

12 reduced principal balance.

13 Additionally, economists have demonstrated it

14 takes well beyond three years after graduation for

15 those with higher degrees to begin to experience the

16 real financial advantage of additional education. Also,

17 current and future economic recessions are

18 unpredictable and adversely affect the debt-to-income

19 ratio.

20 Finally, post-baccalaureate graduate and

21 professional programs seem to fall outside of the

22 concept of training programs. Therefore, post-
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1 baccalaureate degrees and certificate programs should

2 be excluded from these regulations.

3 The proposed regulation is too vague to

4 assess the impact or effectiveness. For example, CIP

5 codes will be used to link specific students with

6 specific programs at an institution. If an institution

7 has multiple programs with the same CIP code, how will

8 the department perform program level calculations?

9 Many institutions have developed unique

10 student ID numbers in lieu of social security numbers.

11 How will the department obtain income information from

12 the Social Security Administration without a social

13 security number if the student and/or employer paid

14 cash for the program?

15 Consolidation loans are excluded from loans

16 paid in full but the proposed rule does not explain how

17 to treat them and reduce principal balance.

18 The proposed regulation is overly-complex.

19 Our submitted comments gave examples to demonstrate

20 how, even if a student may be in good standing repaying

21 their debt, they would still be counted against the

22 program's loan repayment ratio.
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1 I want to emphasize, because of the economic

2 recession and the combination of recent legislation,

3 the vast majority of current students will require loan

4 consolidation, deferment and forbearance entitlements,

5 and/or income-based repayment options, all of which are

6 unable to be tracked under the proposed loan repayment

7 calculation.

8 The proposed regulation uses non-verifiable

9 income information and offers no ability to cure. The

10 proposal lacks due process because the income data

11 provided by the Social Security Administration is non12 verifiable.

13 Furthermore, institutions have no ability to

14 view draft rates and challenge the data integrity prior

15 to the official public release, unlike the cohort

16 default rate regulations. Moreover, the time frame has

17 a retroactive application with no opportunity for

18 institutions to cure any problem.

19 The proposed regulation is administratively

20 burdensome. Considering the significant economic

21 impact of these proposed regulations, the overall cost22 benefit analysis is debatable. As a practicing aid
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1 administrator for nearly 30 years, I firmly believe the

2 estimated burden is significantly under-estimated.

3 According to a recent GAO study, the

4 Financial Aid Survey, it was rated the most burdensome

5 IPED survey. The proposed regulation on Gainful

6 Employment will only exacerbate the complexity and

7 administrative burden as reported in the GAO study.

8 Our recommendation. We are concerned that

9 the rule as currently proposed does not achieve sound

10 public policy objectives and we respectfully request

11 the department to withdraw the proposal until

12 congressional intent has been revisited and

13 established.

14 Thank you.

15 MR. OCHOA: Thank you. Next speaker, please.

16 MR. SIMPSON: Hello. My name is Jim Simpson.

17 I'm Associate Vice President for Degree and Career

18 Programs at Florida State College at Jacksonville and

19 was the primary negotiator during the department's

20 recent Negotiated Rulemaking Process for Title IV

21 Program Integrity.

22 Florida State College at Jacksonville
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1 applauds the department's decision to propose measures

2 on what constitutes gainful employment for educational

3 programs. The proposed Gainful Employment regulation

4 is a significant departure from existing federal

5 student aid policy that required little accountability

6 for the use of funds or the outcomes of students.

7 Formally acknowledging the link between

8 training and earnings is an important codification of

9 the promises about jobs and salaries that all

10 institutions highlight in their marketing materials.

11 Establishing a clear connection between jobs, wages,

12 and training-oriented programs is a welcome way of

13 thinking about education, not just in terms of quality

14 but also in terms of value.

15 We do suggest a clarification to the proposed

16 rules is needed in the following areas. Regarding

17 actual wages, what would be the lag time in calculating

18 the data? How will small programs of only a few

19 graduates be regulated under the proposed regulations?

20 Will continued Title IV eligibility for small programs

21 be based solely on repayment rates? What is the

22 definition of a small program? How will payment on the
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1 principal on a student's debt be calculated when the

2 student has loans from multiple institutions? And how

3 will the repayment rates be calculated if loans from

4 more than one institution are consolidated by the

5 borrower?

6 In our filed comments to the department's

7 proposed rules, we agree with the American Association

8 of Community Colleges' recommendation that the final

9 regulation should not apply to certificate programs at

10 nonprofit institutions of higher education that are

11 fully embedded within and lead to an existing associate

12 degree.

13 It's common for a community college to

14 structure programs so that the students are encouraged

15 to continue pursuing their studies by gaining

16 incremental credentials as they progress towards their

17 degree attainment.

18 Our college experience shows that students

19 who complete an incremental credential are 33 percent

20 more likely to graduate from an associate degree within

21 three years. Therefore, the certificate programs

22 should not be classified as a program of gainful
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1 employment under the regs.

2 In closing, the Gainful Employment standard

3 proposed by the U.S. Department of Education is a gain

4 for students as consumers. Requiring institutions to

5 publish repayment rates, debt ratios, and cost warnings

6 give potential students information that can be

7 compared across all types of institutions.

8 The greatest consumer benefit with the

9 Gainful Employment standard is providing students with

10 information on a program by program basis rather than

11 aggregating information across the institution.

12 Potential students will now be able to see how an

13 institution program actually performs without getting

14 the results that are compromised by dissimilar programs

15 within that institution's program mix.

16 Florida State College at Jacksonville

17 supports the accountability these new rules will

18 provide and the additional consumer protection that the

19 proposed new rules will offer to students.

20 Thank you.

21 MR. OCHOA: Thank you. Next speaker, please.

22 MR. RUSSELL: Hello. I'd like to thank the
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1 Department of Education for hearing us today.

2 My name's Brian Russell, and I'm a small

3 business owner in Florida.

4 I'm here to express my concern regarding the

5 Gainful Employment regulations that are proposed by the

6 Department of Education.

7 I believe that enacting this rule against

8 for- profit career colleges, based on the arbitrary

9 debt-to- income thresholds, is unrealistic. I think

10 typical starting salaries do not accurately reflect the

11 value of one's income potential.

12 My company, Computer Input, provides computer

13 services ranging from low voltage cabling to networking

14 and installing small phone systems. In general, what

15 we do falls under the heading of Information Technology

16 or IT.

17 As can be demonstrated, starting salaries in

18 high-tech fields are not a true measure of one's income

19 potential. Employers, such as me, will always pay more

20 to the candidate who has the most relevant work

21 experience.

22 In addition, starting salaries do not include
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1 benefits, such as health insurance or 401(k) matching

2 and their equations. To an employee, these paid

3 benefits may be the equivalent of hundreds of dollars

4 extra to their monthly income, yet not appear as

5 salary.

6 There could be other perks that are included

7 which could be having a company vehicle or even

8 performance bonuses based on sales or performance which

9 do not appear as the base salary for your calculations.

10 All these serve to increase a graduate's overall

11 standard of living above their base listed salary.

12 So there's many factors that need to be taken

13 into account but the one I'm most familiar with is the

14 work experience. Computer Input and Keiser University

15 have been business partners for over nine years and we

16 are proud to be associated with them.

17 IT and the related fields are just one of the

18 high-growth areas that colleges, such as Keiser,

19 specialize in. IT also happens to be one of those

20 careers where actual experience in the field is

21 invaluable.

22 IT is such a fast-evolving field, it requires
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1 successful employees to constantly update their skills.

2 I know at Keiser, they strive to stay ahead of the

3 curve by introducing new courses of study, such as

4 computer security, to ensure that their students have a

5 relevant education.

6 Unlike many public institutions who, due to

7 budget cuts, cannot obtain the new hardware, private

8 career colleges incorporate latest technologies into

9 their classrooms. Their goal is to place as many of

10 their students into good jobs as quickly as possible.

11 There's basically two groups of students who

12 pursue degrees at career colleges: those looking to

13 enhance or update their skills and those who are

14 seeking out new careers. Neither group would probably

15 be there if they already had high-paying jobs. So both

16 groups are there for the same reason: to establish

17 themselves in a long-term career.

18 A student's prior work experience can greatly

19 affect his starting salary, especially in IT. The

20 focus of employers today is on skills. Not

21 surprisingly, starting salaries are lower for graduates

22 with no experience than for one who has spent a few
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1 years in the field, but without the IT training that

2 Keiser and others offer, doors would never open for

3 these new technicians in the first place.

4 So the end result of being trained in current

5 technologies is a better-prepared student that may be

6 gainfully employed quickly. Does this mean they will

7 receive high salaries immediately? Not necessarily. No

8 one starts at the top. Actual experience in any field

9 of endeavor is valuable, but it does mean that they are

10 more likely to be successfully employed in a dynamic

11 field that will serve them well for the rest of their

12 lives and with that experience, higher pay will follow.

13 In my business, IT technicians with three

14 years' experience make about one-third more than a

15 fresh graduate. Therefore, I suggest a more realistic

16 plan might be based on a graduate's third year salary

17 or by which time he is earning closer to his true

18 market value. Another possibility might be to use the

19 average of the first three or first five years of

20 income.

21 I strongly feel that basing this proposed

22 Gainful Employment regulation on today's starting
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1 salaries is misguided. In these tough economic times,

2 we know that starting salaries are not at an historic

3 high, but the scarcity of high-paying jobs should not

4 deter those who wish to pursue their dream.

5 The economy will turn around and these high6 tech jobs will need to be filled. I applaud those

7 individuals who are willing to learn a valuable new

8 skill or to return for certifications and emerge as

9 successful, productive members of our community.

10 I ask you to reconsider this regulation as

11 many livelihoods are at stake, and thank you again for

12 this opportunity.

13 MR. OCHOA: Thank you. Next speaker, please.

14 MS. MAISON: I'd like to thank you for

15 letting me come here today and speak to you in regards

16 to the proposed regulation for the Gainful Employment.

17 My name is Carolyn Maison, and I am a

18 personal chef. I am the Executive Sous Chef at My

19 Secret Chef in Tallahassee, Florida, and wanted to

20 speak to you guys in regards to two things that really

21 bother me about this legislation.

22 The first is I'm a graduate of a career
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1 school. After being an at-home mom for five years,

2 found myself with two children that I needed to feed by

3 myself. Going to a four-year university was not an

4 option. Time, you know, starting out and getting into

5 a new field, trying to find a way to feed my kids and

6 myself. So I went to a career college and became a

7 chef, graduated top of my class and went to London,

8 England, to work in a restaurant where I learned lots

9 and lots and lots of really wonderful things, brought

10 back to Tallahassee and got right into the career.

11 I was an executive chef at a retirement

12 community in Tallahassee and then moved on to being

13 executive sous chef at My Secret Chef.

14 We cannot hire your average chefs. We need

15 chefs that have real hands-on educational training. We

16 need them to be educated in nutrition. We need for

17 them to be educated in sanitation. We also need chefs

18 that we don't train in the sense of we work alone. We

19 go in alone. Nobody is there making sure that these

20 people do what they're supposed to do.

21 So that being said, taking away, you know,

22 funding for these chefs to go to college, there are no
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1 other options. If somebody is passionate about

2 pursuing their career as a chef, most of those classes

3 are offered at a career college.

4 So by doing this, I think that it's going to

5 be detrimental to the culinary profession, the food

6 service industry because it will really provide a sad

7 lack of really qualified applicants for the jobs that

8 we offer and for our business, as well as restaurants

9 everywhere, it takes the average person who walks in

10 off the streets to become a chef 10 to 20 years to work

11 their way up to an executive chef position.

12 After I graduated from a career college, I

13 managed to do that in three. So I really feel that it

14 would be terribly wrong and tragic to deny basically a

15 whole career rights to an education, and thank you.

16 MR. OCHOA: Thank you. Next speaker, please.

17 MS. MIRACLE: Good afternoon. My name's Lisa

18 Miracle. I represent Madison Adult Career Center which

19 is an Ohio postsecondary adult vocational program, and

20 I'm here representing my school but also the other

21 postsecondary adult vocational education programs, the

22 public schools, in Ohio. Thank you for having me.
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1 I would like to speak to the effect that this

2 regulation could have on our small public postsecondary

3 vocational schools in Ohio.

4 Our postsecondary vocational education

5 programs in Ohio are on the cutting edge. We continue

6 to forge articulation and concurrent enrollment

7 agreements with our local community colleges. WE feel

8 that degree completion is an important attainment in

9 students' lives and our program completion rates are

10 over 80 percent in our schools.

11 We have skill attainment or certification

12 credential rate attainment of over 80 percent for our

13 students. Every day we see more of our completers

14 enrolling in college through programs. Our schools

15 collectively are encouraging students to move on the

16 education train but often we are the first step on that

17 education train.

18 Students who may not otherwise step foot on

19 to a college campus will come to our schools looking

20 for skills, looking for some help to get started and a

21 lot of support which we're able to provide to them.

22 Our schools are located centrally to serve
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1 our students in communities who may not ever realize

2 that a college education could be a reality.

3 I would like to see some consideration added

4 for programs that have concurrent enrollment or

5 articulation agreements forged with our local colleges

6 to encourage those college degree attainments.

7 I would like some consideration and further

8 definition into what encompasses a small school. Many

9 of our schools in Ohio are public postsecondary

10 vocational schools are small. We have responsible

11 enrollment rates of 10 to 16 students per program for

12 most of our programs and we feel that we don't flood

13 the local market with too many of our graduates.

14 Our local labor market data are used when we

15 plan our programs and they have to be approved as such

16 at our state level. So we feel that our public schools

17 are very well regulated in the State of Ohio.

18 We would like to add some consideration to

19 this regulation for small schools. In some of the

20 reporting data, if you have three years of data with 10

21 to 16 students per program, you're basing those numbers

22 on 30 to 48 students and a couple students that may
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1 have to file forbearance in a tough situation,

2 depending on at what point in time you're collecting

3 that data, could have a big impact on your numbers. So

4 I would like to see some consideration to small

5 schools.

6 And also, if we could add some consideration

7 for -- I know in Ohio, our state has lost over 400,000

8 jobs and it's been a very difficult economy. In my

9 local area, we've had quite a few. We lost the GM

10 plant, things like that. So our economy's constantly

11 churning and it's going to take awhile to get out of

12 that, but at a point in time when education is the most

13 important, I don't want to see us lose our programs

14 that can help turn our economies around, and I don't

15 want to see the legislation penalize students who are

16 responsible when they do come into a tough situation

17 filing forbearances and economies that are very, very

18 depressed.

19 And in a lot of cases in small schools, your

20 financial aid staff is one person. This regulation can

21 add an immense reporting burden on those institutions

22 and I would like to see some consideration for those
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1 smaller schools where there's reporting and also -- I'm

2 sorry.

3 Our public schools have lower fees, greater

4 access, and I don't want to see our schools be out of

5 business if, by a couple of students who would miss the

6 reporting deadline or the reporting -- I'm sorry. I

7 would hate to see our schools lose programs at a time

8 when it's essential to have programs in our communities

9 based on reporting regulations and employment income10 to-debt ratios at a time that we need those programs to

11 be in existence.

12 Thank you.

13 MR. OCHOA: Thank you. Next speaker, please.

14 DR. SMITH: My name is Dr. Peter Smith, a

15 licensed psychologist in both Washington, D.C., and the

16 State of Maryland.

17 Thank you to the Department of Ed for the

18 chance to speak regarding Gainful Employment.

19 Currently, federal law requires career

20 education programs that receive federal funds, federal

21 student aid to "prepare students for gainful employment

22 in a recognized occupation."
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1 The department's proposal would finally

2 enforce the statutory requirement. Covered programs

3 include most for-profit programs and all public and

4 nonprofit programs of at least two years.

5 The urgent need to protect students and

6 taxpayers from programs that may promise a lot and

7 struggle to deliver is well documented by the July

8 26th, 2010, Notice of Proposed Rulemaking. Everyone

9 loses when taxpayers subsidize programs that routinely

10 saddle students with debts they struggle to repay.

11 Students of minority status are particularly

12 vulnerable because they disproportionately attend for13 profit programs, accounting for at least half of all

14 students enrolled.

15 As the NPRM notes, the career education

16 industry's own research indicates its graduates default

17 on federal student loans at twice the rate of other

18 sectors, even after controlling for demographic

19 differences.

20 When these programs do not prepare for jobs

21 that enable them to repay their loans, the resulting

22 debt can literally haunt these students for the rest of
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1 their lives, resulting in subjecting them to harassment

2 by collection agencies, ruining their credit, making it

3 difficult to buy a car or to qualify for home

4 mortgages, and also making it difficult to begin to

5 return to school in the future.

6 I urge that the regulations set a higher

7 student loan repayment standard for programs receiving

8 federal aid, that they require poor performing programs

9 to improve to keep receiving student aid, provide equal

10 protection for families with children, and start

11 protecting students effectively next year.

12 Thank you for your time.

13 MR. OCHOA: Thank you. Next speaker, please.

14 MR. ALFORD: Harry C. Alford, National Black

15 Chamber of Commerce.

16 Good afternoon. I am President and CEO of

17 the largest black business association in the world,

18 and I'm very grateful to have this opportunity to come

19 here and speak today about a concerning rule that, on

20 behalf of the National Black Chamber of Commerce, I

21 believe will limit education and economic opportunities

22 for thousands of African American and other minority
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1 students throughout the nation.

2 Unemployment rates have hovered around 10

3 percent for the past two years. What is more

4 disconcerning is that black unemployment numbers are

5 even higher. The latest figures show 16.1 percent in

6 September.

7 Today's workforce is more competitive than

8 ever and it's harder and harder for people to get jobs.

9 The National Black Chamber of Commerce represents

10 200,000+ black-owned businesses with a 160 affiliated

11 chapters operating internationally to sustain black

12 communities through opportunity.

13 Some of our local chapters have weighed into

14 this debate, including the 22 chapters of the Illinois

15 State Black Chamber of Commerce, from Secretary

16 Duncan's home state.

17 We recognize that opportunity is built

18 largely on getting a good education and obtaining the

19 skills necessary to gain employment. We recognize the

20 department's desire to act in the best interests of

21 students while ensuring that they fulfill their

22 obligation to repay government loans.
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1 However, we believe that the rule will have

2 the opposite effect and in reality will discriminate

3 against the students, particularly those of minority

4 and lower income and other at-risk backgrounds.

5 We need financial aid to get a good education

6 and get a job. Gainful Employment is an inappropriate

7 response to a very complicated issue that will have

8 serious repercussions in the black community. Students

9 who receive Pell Grants often have less payment

10 resources and face a tougher time paying back loans

11 than many of their peers.

12 If you look across the board, the default

13 rates based on background, regardless of the school

14 they attend. Because private sector schools enroll

15 more low-income and minority students, there are higher

16 default rates, making entire programs ineligible for

17 Title IV financial aid if they fail to meet two

18 arbitrary formulas derived from a debt-to-income ratio

19 and loan repayment rates is overly-simplifying a

20 problem that is rooted much deeper.

21 Minority students, as a group, tend to use

22 student aid to meet their college expenses and are far
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1 more likely to fall short of the gainful employment

2 guidelines.

3 This rule is aimed at career-oriented schools

4 but if the same test were run on students at

5 traditionally not-for-profit black colleges and

6 universities, 93 percent, 93 percent would fail the

7 gainful employment test rule to unacceptable payment

8 rates.

9 As a country, we should be working to open

10 the doors for students to go to college and pursue

11 degrees in fields about which they are passionate. We

12 should be looking for every conceivable pathway to get

13 African Americans off the unemployment lines and into

14 the classroom. Unfortunately, this rule is going to

15 serve as a roadblock, limiting options and access.

16 Career colleges are a success story when it

17 comes to minority students. At private not-for-profit

18 colleges, 17 percent of the graduates are minority. At

19 public not-for-profit institutions, the percentage is

20 better higher than one in five. However, at career

21 colleges and universities, 39 percent of all students,

22 of all graduates are minority students.
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1 These schools are able to cater to

2 nontraditional students and help them to acquire skills

3 that will translate into a job. Many local businesses

4 and businesses that the NBCC represents really rely on

5 students who attend career colleges. For example,

6 Illinois, Jared Elliot, the Vice President of

7 Operations for americaneagle.com, relies on graduates

8 of the Illinois Institute of Art-Schamburg, because he

9 believes that art institute students have become

10 fantastic assets in his organization and that the areas

11 that the students are exposed to within the program are

12 very well suited for the real world workflow.

13 americaneagle.com has been hiring several

14 students from many institutions over the last several

15 years and he is more pleased with the students coming

16 out of the Illinois Institute of Art who are always the

17 students at the top of the list.

18 Although there are thousands of stories like

19 Jared's, the press is busy telling a different story,

20 casting a dark shadow on these schools, making them out

21 to be much worse than what they are. While there may

22 be bad actors in the field, there are numerous schools
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1 that provide quality training and skills to help

2 African Americans succeed and businesses count on them

3 year after year when recruiting for new positions.

4 I urge you to reconsider the Gainful

5 Employment Rule and to help our struggling minority

6 communities get degrees that will better their lives.

7 Thank you very much.

8 MR. OCHOA: Thank you. Next speaker, please.

9 MS. RIVERA: Good afternoon. I'm Veronica

10 Rivera, Legislative Staff Attorney with the Mexican11 American Legal Defense and Educational Fund.

12 On behalf of MALDEF, I'm here to provide

13 testimony in support of the regulations. Founded in

14 1968, MALDEF is the nation's leading Latino Legal Civil

15 Rights Organization. MALDEF promotes social change

16 through legislative and regulatory advocacy, community

17 education, and high-impact litigation in the areas of

18 education, employment, immigrant rights, political

19 access, and public resource equity.

20 MALDEF has long been committed to ensuring

21 that Latino students not only have access to high22 quality postsecondary programs but that also
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1 successfully complete these programs, ready to enter

2 the workforce and apply their newly-acquired knowledge

3 and skills.

4 As highlighted in Appendix A of the proposed

5 regulations, a high percentage of Latino postsecondary

6 students are attending nonprofit and for-profit

7 institutions, 33.5 and 35.1 percent, respectively, that

8 offer programs that are two-year or less.

9 Overall, MALDEF applauds the department's

10 initiative to hold many postsecondary institutions

11 accountable for suspect programs offered to students by

12 requiring reporting that should trigger greater

13 attention by the institutions to curriculum content

14 and, by extension, career services offered to their

15 students.

16 However, MALDEF offers the following

17 suggestions to strengthen the proposed regulations

18 before they are finalized.

19 First. Regarding the debt thresholds, more

20 often than not Latino students, due to socioeconomic

21 circumstances, incur high debt when seeking a post22 secondary education. Requiring programs to
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1 meaningfully measure and report on proxies for gainful

2 employment will assist prospective Latino students and

3 their families in making wiser choices and better

4 inform Latino taxpayers and advocates where certain

5 programs are failing our students.

6 The department's decision to include options

7 by which programs can measure gainful employment

8 provides programs a greater choice to determine what

9 data they will collect and report back.

10 For example, Section 668.7(a) defines three

11 tests for debt thresholds which are cast in the

12 alternative. All three formulations strike us,

13 however, as invaluable datasets.

14 MALDEF recommends that programs be required

15 to collect and report on all three calculations to the

16 department for informational purposes only. The

17 program, however, would retain the ability to select

18 which of the three tests they will use to make the case

19 that they have met the annual debt threshold required.

20 Second. In terms of warning disclosure, as

21 mentioned in Appendix A, nonprofit and for-profit

22 institutions offering programs that are two-year or
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1 less heavily recruit and market to low-income students

2 of color, including Latino students, urging their

3 enrollment in programs that they may not complete or,

4 once completed, may not lead to gainful employment.

5 More can and should be done to shed light on

6 the choices and indebtedness a prospective or current

7 student faces at nonprofit and for-profit institutions

8 offering programs that are two-year or less. Requiring

9 suspect and failing programs that are under restricted

10 status to include a prominent difficulty in repaying

11 loans obtained warning and a most recent repayment rate

12 disclosure and promotional enrollment in registration

13 materials will greatly assist all students, including

14 Latinos, make wiser college choices.

15 MALDEF, however, would encourage a slight

16 additional to Section 668.7(d) that would encourage

17 plain speak and duty to narrowly tailor interpret

18 and/or translate the warning and disclosure in an

19 understandable and uniform format and, to the extent

20 practicable, in a language that students can

21 understand.

22 Finally, regarding additional programs,
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1 MALDEF generally agrees with the department's move to

2 require institutions that are subject to the proposed

3 regulations to apply to the Secretary for approval of

4 the programs.

5 We recommend, however, that public nonprofit

6 institutions be given priority review over pending

7 private nonprofit and for-profit submissions when

8 application is submitted to the department.

9 Public nonprofit institutions, specifically

10 two-year public institutions providing vocational

11 training programs, are more likely to be subject to

12 state and local government scrutiny when responding to

13 market demand by establishing cutting edge programs.

14 To avoid nonprofit institutions from being

15 stymied from exploring and establishing new programs

16 that students, including Latino students, could benefit

17 from, MALDEF recommends that priority review be given

18 to new programs submitted by public nonprofit

19 institutions.

20 Thank you.

21 MR. OCHOA: Thank you. Next speaker, please.

22 MR. MODICA: Thank you and good afternoon.
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1 My name is Charles Modica. I'm the Chancellor of St.

2 George's University. We're based in Grenada. One of

3 the programs we have there is the School of Medicine

4 and that has been participating in the federal program

5 for many years, now over three decades.

6 I was privileged to be a member of Team 2 in

7 the Negotiating Rulemaking and I have a greater

8 understanding now of what the department has to go

9 through in trying to balance all of the interests in a

10 responsible way.

11 I was one of the few participants that

12 supported not only the recommendations of the

13 department but felt they should be made even stricter

14 in regulating some of the institutions involved.

15 With that and in the spirit of disclosing the

16 principal concern I have today with the Gainful

17 Employment, you should recognize that at that

18 particular meeting, Team 2 did not deal with that

19 issue, as you know, and we were led to believe, at

20 least from our discussions there, that it would not

21 affect our types of institutions.

22 I certainly, after hearing some of the
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1 previous speakers, understand their passions and needs

2 and even though that doesn't directly concern us, I

3 support in general what they are asking for and what

4 they are passionate about and that is access to

5 education, especially for minorities that in general

6 could not be expected to have the same default rates as

7 some of the higher-level institutions. So I certainly

8 support that, even though it doesn't affect us.

9 With the Gainful Employment provisions, we

10 went into Team 2, certainly at my institution, St.

11 George's University, not particularly worried about it

12 because we have always had a default rate of one

13 percent or less, some years zero. So it wouldn't be

14 something that would have kept me up at night, needless

15 to say.

16 What did happen, though, is when the

17 regulations were published, instead of the term

18 "default rate" being used which was that two-year

19 cohort, it was a repayment rate, and we did not know

20 ours. In fact, we looked at it when it was published

21 by the department for the first time and we noticed

22 that it was lower than the threshold which we thought
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1 was a rather fair one when we heard it was only 45

2 percent. With a one percent default rate, we didn't

3 think we would be anywhere near that level.

4 So our rate would not be consistent with

5 continuing in the program right now as published, but

6 the reason for that is, particularly with medicine, the

7 graduation date does not necessarily mean the start of

8 gainful employment, a day later, and that is

9 particularly -- this profession -- I assume there's

10 some other ones similar but certainly with medicine,

11 you graduate into a residency. You don't graduate into

12 a profession yet. In fact, there's no state that will

13 license a graduate of any medical school, including

14 Harvard, without a residency required from one to three

15 years, depending on which state minimum and specialty

16 training even greater.

17 So our default rate kicks way up because our

18 students go into a period during their residency

19 training where they can repay interest only and they do

20 that and that's why our default rate is so low, they're

21 doing that, but the repayment rate, I presume, needs

22 some capital paid in to the loan itself and none of
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1 them elect to do that and they are permitted not to do

2 that. All medical school graduates are permitted to

3 pay interest only.

4 So this kicks in a situation for our

5 graduates which doesn't reflect what they will be doing

6 in terms of rate repayment and in fact is

7 understandable with all institutions.

8 When we looked at some of the American

9 schools that report their medical schools separately,

10 we were within three or four or five percent at most of

11 Harvard< Yale, Jefferson Medical College, New York

12 Medical College. In fact, we were better than some of

13 those schools. So we now know this is just a little

14 quirk, we believe, in the way it's written and I am

15 hopeful that the department can rewrite it so that it

16 reflects the start of the occupation or the profession

17 itself which would be after residency and so I think a

18 solution for our institutions would be, for medicine,

19 that the repayment rate be calculated upon licensure.

20 As you know, a resident is not licensed.

21 They're permitted to do a residency under the auspices

22 of a hospital in their residency training program. So
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1 licensure would be the start point and with that, we

2 will easily comply with any reasonable default rate,

3 repayment rate.

4 So I'm done with 12 seconds, and I want to

5 thank you. I appreciate the opportunity.

6 MR. OCHOA: Thank you. Next speaker, please.

7 MR. FERNANDEZ: Good afternoon. My name is

8 David Fernandez, and I thank the panel and the guests

9 for allowing me to express my thoughts and position on

10 this very important position.

11 I wear multiple hats here. My background is

12 pretty diverse. I went to Georgetown Law School here.

13 Most of my life has been fighting for civil rights. I

14 worked for MALDEF and one of my areas of expertise was

15 education.

16 In that role, I gave testimony on the Hill

17 approximately 1974 on behalf of maintaining the

18 Department of Education and its programs. In that

19 effort, there was a coalition that I represented of 50

20 minority and women organizations during that testimony.

21 I'm also the former U.S. Hispanic Chamber of

22 Commerce Legislative Chair. I was in that position for
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1 six years. So I have a pretty good well-rounded, I

2 think, background.

3 In addition to that, I'm an Adjunct Professor

4 at one of these institutions that we're speaking of,

5 and one of the things that I would like to point out is

6 that education is the pillar of our working class. It

7 is an opportunity that we need to have for underserved

8 individuals. The statistics clearly show that many of

9 these institutions serve our veterans, our veterans

10 that are coming back from fighting and protecting us

11 throughout the world. They're coming back to try and

12 adjust their lives into productive lives here in the

13 U.S. They're also minority students who can't go to

14 traditional schools.

15 I was fortunate. I was fortunate to go to

16 Georgetown and Columbia, but I've seen throughout my

17 life that many people like me are not. I also took

18 loans, as well, just like these individuals are, as

19 well, but it gives them an opportunity. An education

20 is worth that. Education is worth taking that loan.

21 Now, what we might want to do is look at

22 other options, look at other options in terms of
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1 internships, forcing better standards to these

2 institutions and actually recognizing good institutions

3 that provide good education and not restrict them or

4 put them down or terminate their programs.

5 Also, we should seek better data collection

6 throughout the system. We also need to differentiate

7 good and bad institutions, two-year versus four-year,

8 what the end result is of these programs, but more

9 importantly, we need to look at what the repayment

10 terms are. Why don't we look at getting more creative

11 repayment terms?

12 Everybody who takes a loan doesn't start off

13 taking a loan not wanting to pay. They just can't pay

14 under the circumstances. The circumstances today is

15 the economy. The economy is hurting all of us and it

16 reflects on what's going on in terms of some of the

17 repayment issues, but it also reflects on why we have

18 unemployment and what we can do to address

19 unemployment.

20 We need to educate our workforce. We need to

21 educate our workforce in a way that they can

22 participate in strengthening the U.S. again and
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1 strengthening our markets and strengthening our

2 economy.

3 We don't want to close doors. This country

4 was made on supporting and promoting education. Our

5 forefounders were not high school students that came

6 just right out of high school. Our forefathers were

7 farmers, some were merchants, and they had education.

8 They had their experience before they went into these

9 career schools.

10 So let's take what we have and let's make it

11 better. Don't restrict the system. Don't keep people

12 out, but let's keep people in and let's work with what

13 we have to make it a better system. We're not talking

14 about restructuring the whole thing but just taking a

15 better view of these items and concentrating on what

16 the real problems are and not just having these

17 standards that are not even applied equally on all

18 institutions. It's not fair that certain institutions

19 don't have to apply to this and others do.

20 In addition to that, these institutions

21 actually do affect our economy, do affect and respond

22 to veterans. For example, at Keiser, we have 14.4
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1 percent that come from the military, 40 percent are

2 minorities, 70 percent are women, 61 percent are 25

3 years of age or older, 15 to 18 percent are recent high

4 school graduates, 76 percent are full-time and part5 time employees, 68 percent have prior college

6 experience. That's a red flag, also. These

7 individuals that need these programs need these

8 programs to continue and we cannot afford to restrict

9 them.

10 Thank you very much.

11 MR. OCHOA: Thank you.

12 MR. AMADOR: Hello. Good afternoon. I'm

13 Angelo Amador. I'm the Vice President for Labor and

14 Workforce at the National Restaurant Association, and I

15 thank you for the opportunity to testify today.

16 Yesterday, you heard from two of our state

17 chapters, the South Carolina and Nevada Chapters, and

18 they gave some specifics as to how some of the

19 institutions and some of these programs affect their

20 hiring and their economy in the particular states.

21 I want to talk today about the broader

22 nationwide perspective that the National Restaurant
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1 Association has been able to gather after listening to

2 our members.

3 We know, like everybody else, that if

4 students were able to complete their education with no

5 student loan debt, we know the subsequent income would

6 be devoted to home purchases, retirement savings, or

7 serving the community. However, the availability of

8 federal student aid not only increases the likelihood

9 that a student will enroll at an institution of higher

10 education but it may also be the only way that a

11 student will be able to afford higher education that

12 will lead to his dream career.

13 However, at the National Restaurant

14 Association, we're very concerned that the proposed

15 regulations call for a consume protection approach that

16 would result in the elimination of some very important

17 programs leading to rewarding careers in our industry.

18 Specifically, the restaurant and food service

19 industry needs the culinary arts programs at for-profit

20 educational institutions to help provide training for

21 our workforce.

22 Our industry is composed of 945,000
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1 restaurants and we employ 12.7 million people in the

2 country. Even those made out of mostly small

3 businesses, we're the second largest private sector

4 employer in the country.

5 In the next 10 years, restaurants are

6 expected to add 1.3 million additional jobs. These new

7 jobs will be across all occupations in the industry.

8 Some of the strongest gains will be on some of the

9 occupations, such as food preparations and service,

10 expected to be around 15 percent, where postsecondary

11 education training is very valued.

12 Training is also very important for

13 management positions where eight percent job growth is

14 expected. In addition, by 2020, the industry will grow

15 chef and head cook positions by 11 percent and first16 line supervisors food preparation and server managers

17 by 12 percent, and again yesterday they talked about

18 some of the training that goes into that that deals

19 also with safety.

20 For-profit education institutions serve as an

21 important training ground for many of those who pursue

22 a career in our field. For example, for-profit
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1 education institutions award 59 percent of all

2 Bachelor's degrees in culinary programs, more than the

3 number of Bachelor's degrees awarded by private

4 nonprofit education and public institutions combined.

5 If these programs are eliminated or limited,

6 many of the culinary arts students will not be able to

7 receive the training they desire and may not have the

8 careers they want and might not even join the

9 restaurant and food service industry.

10 Even if formal training is not required to

11 enter the restaurant and food service workforce, it can

12 help advance and maintain a career in the industry. The

13 Department of Labor's Occupational Outlook Handbook

14 states, "Although certification is not required, it can

15 help to improve accomplishment and lead to advancement

16 in higher-paying positions." Now this doesn't happen

17 overnight.

18 The National Restaurant Association does

19 support, as most of the speakers have before me, some

20 disclosure requirements and programs with regards to

21 potential debt-to-income ratios and loan repayment

22 rates. I hope you will be able to work with MALDEF in
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1 figuring out what those would be.

2 However, once we assure that students are

3 fully informed of the potential debt burden, it makes

4 sense to allow the students the freedom to make an

5 intelligent decision for themselves and their families.

6 Furthermore, the test metrics used to

7 evaluate programs should not ignore the quality of the

8 programs. Many tests being discussed are arbitrary and

9 bear no relationship to the quality of the education

10 the student receives. Higher-quality degrees, such as

11 Bachelor's degrees, versus an associate's degree or

12 certificate, usually will come with higher costs.

13 For example, just preparing one of these

14 kitchens that are used for training people for

15 Bachelor's degree can cost up to $1 million.

16 We're also concerned with the test metrics

17 being proposed that would make it extremely difficult,

18 if not economically infeasible, for our institutions to

19 offer some of these programs.

20 Now, finally, I would say that another

21 concern we have in the debate is the repayment of the

22 loans. In this regard, whether the former student
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1 completed the program or not, I can assure you that if

2 I had not finished my law degree, it would have been a

3 heck of a lot more difficult for me to pay my student

4 loans.

5 Finally, I would just tell you that we are in

6 agreement that some disclosure could happen, you know,

7 to educate students, but we think that the rule and the

8 metrics that would deny education to some of these

9 students is not something that we could support.

10 Thank you.

11 MR. OCHOA: Thank you. Next speaker, please.

12 MS. MISHORY: Hi. My name is Jennifer

13 Mishory, and I'm the Deputy Director of Young

14 Invincibles.

15 As an organization that advocates for young

16 adults ages 18 to 34, an age range that encompasses

17 nearly 80 percent of students at for-profit colleges,

18 we have obvious concerns about the extent to which

19 career education programs provide value through their

20 curriculum or, more specifically, the disturbing

21 frequency that young people leave some career education

22 programs having received little valuable but saddled
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1 with enormous amounts of debt.

2 For this reason, we support a strong and

3 effective gainful employment regulation taking effect

4 in 2012.

5 Our age cohort faced a 13.4 percent

6 unemployment rate last year and the numbers for the

7 younger half of that age group are even more

8 staggering, somewhere around 18 percent. Unfortunately,

9 the recession is just a high point along a continuing

10 trendline of employment struggles.

11

12 Wages have stagnated or fallen for entry13 level workers over the past 20 years and job

14 instability has increased. Our constituency is

15 struggling and it is crucial that we get federal grant

16 and loan money flowing through programs that will help

17 to dig us out of this hole.

18 Indeed, the point may be obvious but it's

19 nonetheless worthwhile to state the proposed rules are

20 needed to protect our country's future and reverse this

21 overall negative trend. Improving higher education is

22 one of the most important ways that we can address this
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1 problem.

2 Federal investment of grant and loan money

3 must be a step forward for our generation. I know that

4 you've heard from numerous speakers, so I'll be very

5 brief and highlight certain specific points that have

6 been largely stated but could use repetition.

7 Some have raised concerns about retroactivity

8 and I just wanted to highlight that the proposed rule

9 wouldn't start until July 2012 and wouldn't be fully

10 effective until 2013. It's not retroactive and it

11 gives schools plenty of time to improve their programs.

12 The proposed rule also doesn't single out any

13 one sector. It actually applies to more public

14 programs than for-profit programs. The proposed rule

15 will increase access to quality higher education for

16 all while protecting vulnerable students and taxpayers.

17 Good programs will benefit and only poor-performing

18 programs will be affected, and, finally, it will ensure

19 that students are prepared for in-demand jobs and able

20 to repay their loans.

21 Beyond those points, we believe that more can

22 be done through these regulations and by the Department
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1 of Education and just two points in particular. We

2 think that poorly-performing programs should be

3 required to improve or lose eligibility for federal

4 aid. Programs should not be permitted to stay in the

5 restricted category indefinitely, and the department

6 should improve the discretionary income metric. Using

7 a family size of one is inappropriate for students who

8 attend for-profit colleges, many of whom have

9 dependents.

10 Those are just a few improvements that should

11 join the chorus of voices that you've heard advocating

12 for strong, fair, and protective regulations.

13 Thank you for your time and the opportunity

14 to speak.

15 MR. OCHOA: Thank you. Next speaker, please.

16 No? We'll take a five-minute break at this point.

17 (Recess.)

18 MR. KVAAL: All right. We're ready to get

19 started again.

20 The new faces on the panel for anyone who

21 doesn't know us by now, I'm James Kvall, Deputy Under

22 Secretary. I'm joined by Fred Sellers of Policy.
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1 MR. DAVIS: So I don't need to whistle to

2 wake all of you up, I guess.

3 Hello. My name is Lanny J. Davis. I serve

4 as counsel and public spokesperson for the Coalition

5 for Educational Success, a group of private for-profit

6 career colleges with 350,000 students at 478 locations

7 in 41 states.

8 The Coalition has four concerns with the

9 Gainful Employment regulations as they are currently

10 proposed.

11 First. They fail to hold all institutions,

12 all institutions of higher education to a single high

13 standard for program integrity and student outcomes.

14 Currently, community colleges testified and not only

15 don't want these regulations applied to them actually

16 asked you to narrow the regulations which is somewhat

17 ironic.

18 They lack fair, transparent, and public

19 metrics for measurement. They will cause underserved

20 groups to lose access to higher education and they will

21 block, fourthly, a direct path for career college

22 graduates to in-demand jobs.
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1 Let me address each of these points briefly.

2 First. Currently, the new rules are directly only at

3 for-profit institutions, a relatively small section of

4 higher education. It's as if an abuse in one place is

5 bad, an abuse in another place is not so bad, which is

6 the irony of the people who say don't regulate me, just

7 regulate somebody else.

8 Secondly. There is no reason, as far as I

9 can determine, why the department has set benchmarks

10 that select metrics that are not transparent. For

11 example, they have picked a metric that describes the

12 Bureau of Labor Statistics as not relevant to determine

13 income, rather, which is a transparent Internet14 available statistic. It was originally proposed by the

15 department.

16 Guess what happened. They got rid of

17 transparency and they went to the Social Security

18 Administration or IRS data, nontransparent. So we have

19 DOE regulators favoring nontransparent criteria. We do

20 not understand that, and I hope that people who have

21 not read this regulation will ask yourselves why would

22 the DOE favor nontransparent criteria over transparent
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1 criteria.

2 Thirdly. Career colleges have a higher

3 proportion of low-income and minority students who rely

4 on federal loans to pay for their education. Loan

5 default rates are about the economic status of

6 students, not the tax status of colleges or

7 universities.

8 An independent financial aid professional,

9 Mark Kantor, examined the department's proposed

10 regulation and concluded that colleges which do not

11 enroll minority students will generally have loan

12 repayment rates within the department's proposed

13 guidelines while colleges that do enroll more minority

14 students will fail.

15 Isn't that strange in a progressive

16 Democratic Administration to propose regulations with a

17 higher proportion of failure the higher the number of

18 minority students?

19 Finally, and I speak as a liberal Democrat

20 asking that question, confusing me why this

21 Administration would want that unintended, I'm sure

22 unintended consequence.
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1 Finally, the department's regulations do not

2 take into account the millions of success stories of

3 career college graduates who have achieved their goal

4 of finding new jobs, advancing their careers and

5 earning higher pay.

6 Let me conclude by saying that this proposed

7 regulation, if unchanged in its present wording, the

8 DOE will be making a law that will shut out the very

9 students at the underclass of our society, will

10 adversely affect them, with the most to gain through

11 their access to the programs offered by career

12 colleges.

13 Our schools provide the clearest career path

14 for nontraditional students, like full-time workers,

15 working parents and mothers, you heard one of them

16 today speaking without a script from her heart,

17 workforce returners, and, of course, minorities.

18 That would explain the broad expression of

19 unease about the department's plans among progressive

20 Democrats, such as myself, and including congressional

21 leaders, such as members of the Congressional Black

22 Caucus, Alcee Hastings, Ed Towns, Yvette Clark, Donald
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1 Payne, Bobby Scott, Rev. Jesse Jackson, and Rev. Al

2 Sharpton.

3 What are we missing? If a Republican

4 Administration proposed these regulations, we Democrats

5 would be on our feet saying what are you doing going

6 after the most vulnerable students in our society and

7 if you're going to do it, why are you leaving out

8 community colleges? Why are you leaving out not-for9 profits? Why are you leaving out Yale, Harvard, and

10 elite universities where abuses also can occur and we

11 know are dependent on federal funds just as career

12 colleges are?

13 I suggest this is time to put an amber light

14 on. We think what you're doing is doing a scalpel

15 approach to regulation and not a broad hatchet.

16 Thank you.

17 MS. HINOJOSA: Good afternoon. My name is

18 Amy Lynn Hinojosa, and I am representing MANA, a

19 National Latino Organization. We're the oldest and

20 largest national organization of Latinos, comprised of

21 chapters, affiliates, and members nationwide, who share

22 a vision of actively working to create a better quality
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1 of life for Hispanics.

2 We also administer the only national youth

3 mentoring program tailored to and specifically created

4 for Latino youth.

5 I would like to extend my sincere thanks to

6 you today for the opportunity to provide testimony that

7 further elaborates our position on the proposed Gainful

8 Employment Rule.

9 While we appreciate the Department of

10 Education's efforts to ensure private sector schools

11 provide a quality education for the students they

12 serve, we are also encouraged by the work that the

13 private higher education sector has done to provide

14 minority students with a career-focused education.

15 As a Latino organization that values the

16 importance of empowering young women to succeed, we

17 know all too well the social challenges faced by our

18 young women trying to achieve milestones many of us

19 take for granted.

20 In our community, having a higher education

21 is a way out of poverty and an opportunity to provide a

22 better quality of life for themselves and their
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1 families. We have a fragmented community consisting of

2 all ranges of socioeconomic and cultural backgrounds

3 and thus we understand the need to have different

4 avenues of higher education available.

5 Considering that current statistics show that

6 Latinos only make 53 cents on the dollar that white

7 males make, we are very concerned about the

8 consequences for Hispanic students from the

9 department's proposed Gainful Employment Rule.

10 One of MANA's core values is to ensure

11 quality and fairness for our community. As such, it is

12 critical to our mission that all students, primarily

13 Latinos, retain access to all educational, vocational,

14 and training programs.

15 Implementation of the proposed rule would

16 adversely affect Hispanic students' ability to borrow

17 money and limit Hispanic students' access to higher

18 education. Under the proposed rule, many career

19 programs would be ineligible for financial assistance

20 by failing a debt-to-service income ratio standard.

21 We share your concern of students who find

22 themselves unable to meet their financial obligations.
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1 However, efforts to lift the burden of student debt

2 should not also reduce educational opportunities for

3 Hispanic and low-income students.

4 The programs offered by the private higher

5 education sector meet the needs of students and provide

6 the skill sets they need to pursue careers in their

7 chosen fields. This issue is of great concern to our

8 organization and to other Hispanic organizations.

9 We thank you for your time and urge the

10 Department of Education to not impose the Gainful

11 Employment Rule that would limit the ability of

12 Hispanic students to achieve higher education.

13 Thank you.

14 MR. LOPEZ: Good afternoon. Thank you. My

15 name is Mario Lopez, and I'm President of the Hispanic

16 Leadership Fund, a nonpartisan advocacy organization

17 based here in the Washington, D.C., area.

18 I'm here today out of concern for the

19 proposed Gainful Employment Rule. I thank you for the

20 opportunity to be here to express some of the concerns

21 that we see with the proposed rule and why we are

22 worried that it has the potential to hurt minority
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1 students.

2 As an organization dedicated to strengthening

3 working families, we see firsthand the benefits that

4 proprietary schools offer the Hispanic population.

5 Students today are faced with a barrage of challenges

6 that make it more and more difficult to go to school.

7 Time and time again, we see Hispanic students

8 graduating from proprietary schools and getting jobs

9 that improve their life. Many of these students face

10 real-life hardships. They come from low-income

11 communities, are working full time and trying to raise

12 a family. Sometimes they may be a single parent

13 raising a family. They don't have time or the

14 resources to attend a traditional four-year university.

15 Even with all these obstacles, students, like

16 Jon Cruz, a 2007 graduate of the Art Institute in

17 Washington, D.C., gain the skills they need to be

18 successful during their career college educations. Jon

19 is currently employed as a designer for AOL Instant

20 Messenger. In his current role, he is charged with

21 serving as a lead visual designer for AIM on the

22 Windows Mobile. Jon credits the Portfolio Show at the
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1 Art Institute of Washington with helping him make a

2 name for himself.

3 Our focus should be on opening doors for

4 students that have the potential to improve the quality

5 of life for themselves and for their families. We need

6 to create more opportunities, not limit the current

7 options that are available to them right now.

8 No one wants to see students taken on more

9 debt than they can pay back, but making broad sweeping

10 regulations is going to do more harm to students than

11 it will help. Students have the right to choose the

12 education and career path that they will pursue and not

13 have it restricted by arbitrary debt-to-income ratios.

14 The department's own studies show that career

15 colleges will be the hardest hit by the Gainful

16 Employment Rule and that means the minorities will be

17 the hardest hit by its implementation.

18 The President has explicitly set a goal of

19 having the highest proportion of college graduates in

20 the world by 2020. In order to do this, we have to put

21 a special focus on helping students who are considered

22 at risk and have a harder time not only getting to
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1 college but graduating with a degree. Career colleges

2 play an extremely important role in helping those

3 students.

4 Gainful employment is going to have drastic

5 consequences on helping at-risk students to get degrees

6 because it will be hurting students who need to borrow

7 money the most. According to an assessment of National

8 Center for Education Statistics data, career colleges

9 are doing a very good job of helping minority students

10 graduate. "Four-year colleges that are predominantly

11 minority-serving exhibit a higher graduation rate than

12 public and private institutions that also serve

13 minority students, 47 percent versus 33 percent and 40

14 percent, respectively."

15 Implementing the Gainful Employment Rule is a

16 step in the wrong direction. It will move our country

17 further away from the goals set by the current

18 Administration and the Hispanic Leadership Fund

19 fundamentally believes that students of all backgrounds

20 should be able to make their own choices about what

21 programs are likely to lead to gainful employment.

22 Thank you.
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1 MR. MILLER: Thank you. My name is Harris

2 Miller. I'm the President of the Association of

3 Private Sector Colleges and Universities representing

4 approximately 1,500 institutions. I understand I'm the

5 last speaker, so I'm the only thing keeping the

6 audience from going out and having a Friday afternoon

7 libation. So I will try to be sensitive to the time.

8 I want to thank the department for engaging

9 in a dialogue recently on this topic. Maybe if it'd

10 had this much dialogue 10 months ago, we'd be a lot

11 farther down the path, but I have sensed a lot of

12 progress.

13 Our concerns with the proposed Gainful

14 Employment Rule are several.

15 1. We have concerns about the statutory

16 authority of the department. We've had a chance to

17 discuss that at length with Ms. Yuan, Mr. Rose, and we

18 continue to express that concern, even in the most

19 recent configuration of the proposed rule.

20 Secondly. We still have failed to see any

21 evidence presented by the department or anybody else,

22 for that matter, that it really is true that the
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1 programs that have a higher debt-to-income ratio lead

2 to situations where students have a harder time

3 repaying their loans.

4 In fact, the analysis we had done by

5 Professor Jonathan Kurian of Northwestern University,

6 based on about 600,000 students from our institutions,

7 showed that students who graduated from institutions

8 with a higher debt-to-income ratio than schools that

9 had lower debt-to-income ratio actually had better

10 default rates on their loans.

11 We asked ourselves why, and I think the

12 answer is those are often students who go to longer

13 programs because then they have to borrow more and when

14 they do graduate, they feel very committed to repaying

15 their loans because they've seen the value proposition,

16 but the data are pretty clear and it's not a

17 statistical fluke as far as we can tell.

18 Third. We still have concerns about the

19 particular value proposition implicit in the proposed

20 rule. All the labor economists who study these issues,

21 including one of the current members of the Council of

22 Economic Advisors, have written about the value of
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1 education is a relative value in terms of one's

2 earnings, not absolute. It's where you started from

3 and where you end up because people who start already

4 at a high socio-demographic level and end up graduating

5 and having high salaries have, as was once quoted about

6 one politician about another, have ended up on third

7 base and thought they hit a triple.

8 The fact is that those individuals have

9 already started with massive advantages and the

10 education has not contributed nearly as much to their

11 advancement, whereas students who go to our schools, to

12 many community colleges, to minority-serving

13 institutions, getting the education is a huge

14 differentiator in their lives.

15 Also, the regulation fails to consider the

16 fact that the payback to the student is over a

17 lifetime. Most labor economists and others estimate

18 that the payback for every additional year of education

19 is something like eight percent. So to them, eight

20 percent as the metric, when that is being covered just

21 by one year, seems to us to be a bad way to think about

22 this.
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1 The proposed rule also fails to recognize the

2 fact that longer-term programs are, by their very

3 nature, more expensive and require more borrowing for

4 low-income students and working adults and yet the

5 eight percent figure, the 12 percent figure run across

6 the programs, regardless of their length.

7 So we would prefer the department not do this

8 at all. We do believe it is ultra-biased, as we said,

9 but at the end of the day, my board decided that in our

10 comments, which we submitted to the department, we at

11 least ought to propose an alternative which follows

12 some of the perspectives the department has but is

13 workable and is transparent.

14 As Mr. Davis mentioned, one of our biggest

15 concerns about the proposed rule is this use of actual

16 wages reported to the Government which, of course, is

17 private information, is not available. The Bureau of

18 Labor Statistics data are available, as Mr. Davis said.

19 So that is one major proposal that we would suggest, if

20 you are going to use earnings, use something that is

21 available and transparent.

22 Secondly. We think in terms of the repayment
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1 period, the proposed rule looks at 10 years. We would

2 suggest that be extended to 15 or 20 years. Number 1.

3 that's the actual time most students take to

4 repay their loans. Secondly. It recognizes

5 intellectually again from an economic point of view

6 that the benefit lasts for a long time and is not

7 condensed into a very short period of time as is

8 implicit in the 10-year repayment period.

9 In terms of what type of data point one

10 should choose from the Bureau of Labor Statistics, we

11 suggest the 50th percentile, not the 25th percentile,

12 and the reason we're suggesting that is, as one of the

13 earlier witnesses mentioned, the fact is you don't get

14 immediate payoff from your education. Most labor

15 economists tell us that it's seven to eight or nine

16 years after your education is completed that you really

17 begin to see that divergence and advantage for people

18 with advanced degrees.

19 Someone who has an associate's degree and a

20 Bachelor's degree, the first two or three years their

21 earnings may not be that different. In some

22 professions, again, as some of the other witnesses have
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1 said, particularly in healthcare, the payoff for that

2 extra education often doesn't even really begin until

3 the fourth or fifth or sixth year out of school and yet

4 this proposal looks very much at the first three years.

5 So we think that moving up to the 50th percentile would

6 make a lot more sense.

7 The last point I'd like to mention is this

8 whole issue of share-shifting. The department has now

9 somewhat conceded that a lot of students will lose

10 their opportunities to attend career colleges which

11 will be put out of business or at least their programs

12 will be put out of business.

13 But the department believes that the 90

14 percent of those students will end up somewhere else in

15 the system, only 10 percent will be kicked to the curb,

16 so to speak.

17 We don't really see that that is accurate.

18 Our best, most optimistic projection is that 60 percent

19 will be able to and the reason is that these students

20 who we're talking about for the most part are truly

21 community-based students. They're truly community22 based students. So it's not like they're trying to
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1 decide whether to go to Ann Arbor or go to New Haven.

2 A geographical move of even a couple of miles

3 to go to a different school is very significant, plus

4 our expectation is if a program fails in one location,

5 it's going to fail in another location.

6 Thank you very much.

7 MR. KVAAL: And I wanted to thank all of our

8 speakers for the time and thoughtfulness that they've

9 put into their comments. I know a number of people

10 traveled to be here today and I appreciate that very

11 much. We've heard from close to 70 speakers over the

12 last two days. We've gotten hundreds of constructive

13 suggestions on the rules and I want people to know that

14 we'll be considering them very carefully.

15 Secretary Duncan has said that in his view

16 the majority of for-profit colleges are providing

17 valuable services to students and that they're an

18 important part of reaching the President's 2020 goal

19 and we're trying to strike the right balance that will

20 take advantage of the strengths of the for-profit

21 sector while at the same time addressing some of the

22 problems that we've heard of at a few of these
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1 institutions.

2 So the suggestions we've heard today will

3 help us as we try and strike that balance, and I do

4 appreciate everyone's attending today, especially the

5 hearty few that are still here on Friday afternoon.

6 Thank you.

7 (Whereupon, the meeting adjourned at

8 2:18 p.m.)

9

10

11

12

13

14

15

16

17

18

19

20

21

22
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1 CERTIFICATE OF NOTARY PUBLIC

2 I, JEFFREY MICKLE, the officer before whom

3 the foregoing meeting was taken, do hereby certify

4 that the testimony that appears in the foregoing pages

5 was recorded by me and thereafter reduced to

6 typewriting under my direction; that said meeting is a

7 true record of the proceedings; that I am neither

8 counsel for, related to, nor employed by and of the

9 parties to the action in which this testimony was

10 taken; and further, that I am not a relative or

11 employee of any counsel or attorney employed by the

12 parties hereto, nor financially or otherwise interested

13 in the outcome of this action.

14

15

16 ____________________________

 JEFFREY MICKLE

17 Notary Public in and for the

 District of Columbia

18

19

20

21 My commission expires: June 30, 2015

22
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basically 107:11

111:14

basing 108:21

113:21

basis 104:10

Beach 53:6

bear 139:9

Beauty 55:5

became 110:6

become 8:21 11:8

74:14,15 75:15

111:10 121:9

becomes 31:21

becoming 18:16

34:4 82:2

beef 50:6

begin 11:8 30:1

70:1 80:21

85:10,17 96:9

98:15 117:4

159:17 160:2

behalf 14:21 43:4

76:5 79:4 81:10

86:7 117:20

122:12 131:17

behavior 27:12

behaviors 28:1

behind 52:1

believe 10:17 17:3

30:20 31:4 36:18

37:9 38:5 48:8

49:14 54:5 65:8

71:16 77:11

88:18 97:14

101:1 105:7

117:21 119:1

127:19 130:14

142:21 158:8
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believes 88:13

121:9 154:19

160:13

Belinda 70:13

Ben 47:4

benchmarks 145:9

benefit 9:7 24:17

85:1 100:22

104:8 126:16

142:17 159:6

benefits 106:1,3

152:3

Benjamin 72:8

Bergeron 52:21

best 10:9,17 13:15

28:20 29:5

46:11,14 57:1

60:16 62:7,14

118:20 160:18

bets 27:21

better 4:16,19,20

15:10 23:15,16

27:1 54:14 73:12

77:9 120:20

122:6 124:3

130:12 133:1,5

134:11,13,15

148:22 149:22

156:9

better-prepared

108:5

beyond 56:20

62:21 64:12

91:16 98:14

142:21

biggest 158:14

bill 67:17

billing 41:1

Bistro 88:5

black 26:13

117:14,17,20

118:4,9,11,15

119:8 120:5

147:21

black-owned

118:10

blacks 31:1

blanket 89:6

Bleu 81:7 82:2

block 144:21

BLS 27:3 57:7

58:14

Blue 88:1

board 4:4,5 10:22

11:7 80:20 82:7

119:12 158:9

boards 7:16 59:15

Bob 96:16

Bobby 148:1

bodies 46:10

body 6:10 15:8

92:10

bonuses 106:8

Book 84:1

books 91:17

borrow 22:9 30:5

61:22 78:16 79:4

91:16 97:6,9

150:16 154:6

156:13

borrower 103:5

borrowing 22:17

27:20 46:7

61:16,21 62:12

78:22 79:5,6

91:13 158:3

bother 109:21

bottom 7:13 67:16

box 26:13

brag 83:19

branch 3:18

brand 25:8,14

break 52:13

143:16

Brian 105:2

bricks 43:1

brief 61:4 142:5

briefly 5:12 50:14

145:1

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brings 23:4

broad 42:17

147:18 148:15

153:9

broader 135:21

brought 110:9

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53:4,8,11,15

54:17

Brown 29:16

Brule 84:3

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93:1,9

budget 107:7

Buffalo 64:22 90:5

92:8

build 50:20

building 48:17

50:12 95:21

buildings 3:20

builds 49:22

built 57:20 118:17

burden 101:2,7

114:21 139:3

151:1

burdens 10:10

14:11 31:11

burdensome 63:2

100:20 101:4

Bureau 7:19 85:3

145:12 158:17

159:10

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business 4:6 34:19

40:18 53:22

86:13 90:10

105:3 106:15

108:13 111:8

115:5 117:17

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C

cabling 105:13

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calculated 103:1,3

130:19

calculating 102:17

calculation 46:21

79:9 98:11 100:7

calculations 23:7

64:15 99:8 106:9

124:15

California 65:6
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87:17,19 88:2

campus 59:14

82:10 92:6

112:19

campuses 40:17

47:16 55:16

92:7,9

Canada 15:7

candidate 105:20

capital 129:22

car 28:4 63:16

67:7 117:3

card 28:5

cardiac 9:4

cards 67:8

care 12:17

16:17,22 22:5

40:7,22

career 3:22 6:21

17:13 18:1 19:9

39:9 45:17 58:9

60:11 63:8

71:2,11,19

72:4,10,18

73:2,16 74:10,11

75:19 77:4 79:11

80:15 82:3

85:2,6 86:19

87:1,2,9,13

88:13 89:11,21

94:19,21 101:17

105:8

107:8,12,17

109:22 110:6,10

111:2,3,12,15,18

115:19 116:15

120:16,20 121:5

123:14 134:9

136:12 137:22

138:12

140:19,21

144:6,21 146:2

147:3,11,13

148:11 150:18

152:18

153:12,14

154:1,8 160:10

career-earning

57:14

career-focused

149:14

career-oriented

87:12 120:3

careers 42:4 47:14

55:14 70:21 82:1

85:10 88:12

90:22 106:20

107:14 136:17

138:8 147:4

151:6

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161:14

caregiver 93:21

Caribbean 14:22

19:3

C-Arm 8:10,12

Carolina 135:17

Carolyn 109:17

case 9:2 35:11 95:2

124:18

cases 49:12 114:19

cash 99:14

cast 124:11

casting 121:20

casualties 68:5

casualty 68:11

category 143:5

cater 121:1

cath 9:4

Caucus 147:22

cause 144:19

caused 93:6

causes 33:20

CDR 35:19

CDRs 27:9,10

Census 85:3

Center 111:18

154:8

Central 21:6

centrally 112:22

cents 150:6

CEO 39:6 90:4

117:16

ceremonies 77:12

certain 57:5 62:16

89:3 124:4

134:18 142:5

certainly 127:22

128:7,10 129:10

certainties 57:10

certificate 10:15

39:1 48:11,20

49:22 55:18 99:1

103:9,21 139:12

163:1

certificates 72:18

certification 48:21

112:11 138:14

certifications

109:8

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chair 71:14 131:22

challenge 80:2

100:14

challenges 149:17

152:5

Chamber

53:4,5,8,15

117:15,20

118:9,15 131:21

chance 60:16

115:18 155:16

Chancellor 127:1

change 68:6

122:15

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65:10

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chapters

118:11,13,14

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charged 152:20

Charles 127:1

Charlotte 43:6

chasm 43:18

cheap 27:20

cheaper 28:8

checks 91:15

chef 84:11,15

85:10,13

109:18,19

110:7,11,13

111:2,10,11

137:15

chefs 82:4 84:14

110:14,15,17,22

chef's 84:16
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Chief 34:16 47:5

59:4

children 64:8 75:7

77:13 79:20

110:2 117:10

child's 79:3

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80:15 87:13

124:8

choices 32:6 124:3

125:6,14 154:20

choose 60:14

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159:10

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chose 79:20 80:9

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90:22 151:7

Christopher 34:15

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CIP 99:4,7

circumstances

49:11 123:21

133:14

citizens 15:8 80:14

citizenship 17:17

47:15

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41:11,20 65:1

82:6

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clarification

102:15

Clark 147:22

class 3:20 6:2 7:9

23:15 40:6 46:1

54:2 81:8 84:16

110:7 132:6

classes 5:18

6:11,14,15 46:2

111:2

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classroom 120:14

classroom-based

90:12

classrooms 107:9

clear 42:1 102:11

156:16

clearest 147:13

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94:7 132:8

Cleveland 92:8

climate 51:9

climb 81:17

clinical 5:6 8:8,17

10:20 17:21

72:16

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161:11

closely 4:11 8:20

40:10

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closing 70:5 104:2

clue 26:2

CNM 5:20

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coalition 86:7,8

88:13 89:7

131:19 144:4,8

Coalition's 87:18

Coastal 43:1,16

44:5,10 45:21

code 18:5 99:7

codes 99:5

codification 102:8

codify 59:21

cohort 12:5 35:19

44:12 58:4 83:13

93:5 95:11

100:15 128:19

141:5

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124:9,15

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collecting 114:2

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117:2 133:5

collective 60:20

collectively 112:15

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21:5,10,22 24:10

29:18 33:6

34:5,17 37:8,16

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60:12 63:7 65:5

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71:12,19 72:10

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86:2,19 88:20

89:2,4,21 90:5

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103:13,18

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113:2,6 119:22

120:10 125:14

130:11,12 135:5

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152:18 153:19

154:1

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20:13 21:8 50:20

53:11,16

54:1,7,15 59:14

60:9 68:6 70:1

71:3,9 72:4,18

73:2,16,21 74:3

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88:14 89:11 90:7

105:8 106:18

107:8,12 112:7

113:5

120:5,16,18,21

121:5 140:17

143:8 144:6,14

146:2,6,10,13

147:12 148:8,12

153:15

154:1,8,10

157:12 160:10

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college's 83:7 91:4

Colleges 16:2,15

29:16 39:9 71:13

75:18 83:4,22

91:6 103:8 155:3

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color 45:22 46:1

125:2

Colorado 9:21

Columbia 15:6

20:19 21:15

132:16 163:17

combination 87:11

100:2

combined 138:4

comes 120:17
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coming 2:3 25:13

54:14 121:15

132:10,11

commenced 90:22

comments 3:4 9:3

13:10,20 20:1

21:17 22:6 25:2

36:12 37:4 59:2

64:18 92:5 97:2

99:19 103:6

158:10 161:9

Commerce

53:8,15

117:15,20

118:9,15 131:22

commercial 3:20

commission 16:2

51:15 163:21

commissioner

39:10

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122:20 156:14

Committee 7:17

16:5 43:8

common 9:10

10:20 48:18

58:20 103:13

communications

85:16

communities 3:20

45:20 75:13

77:11 113:1

115:8 118:12

122:6 152:11

community 4:22

5:1,14 6:19 7:20

8:7,21 9:6 20:13

21:8,10,22 37:7

47:6,9,11 50:20

54:18 68:14,19

73:21 86:18,22

87:9 103:8,13

109:9 110:12

112:7 119:8

122:16 136:7

144:14 148:8

149:20 150:1,11

157:12 160:21

community-based

160:21

companies

65:16,20 83:15

company 4:12 5:1

64:22 96:18

105:12 106:7

company's 55:12

comparable 16:4

17:18

compare 36:16

compared 17:1

26:10 27:6

73:17,21 87:3

104:7

comparison 83:11

compete 13:8

71:5,18

competition 44:11

84:7,10

competitive 13:3

37:6 51:22 65:19

118:7

competitiveness

71:20

complete 11:5

49:3 51:12 74:1

89:2 103:19

123:1 125:3

136:4

completed 21:21

125:4 140:1

159:16

completers 112:13

completing 50:3

73:12

completion 10:21

49:22 50:2

112:8,9

complexity 63:3

101:6

compliance 33:11

34:16 46:14,15

94:16

complicated 119:7

comply 10:14 45:7

131:2

complying 45:8

70:1

component 38:9

composed 136:22

comprised 4:5

148:20

compromise 69:21

compromised

104:14

computer 105:12

106:14 107:4

concede 68:10

conceded 160:9

conceivable

120:12

concentrated

22:14

concentrating

134:15

concept 98:22

concern 9:12 30:7

36:9,10 57:22

63:12 64:1 76:2

91:12 105:4

127:16 128:2

139:21 150:21

151:7,18 155:18

concerned 30:15

52:8 66:9 76:17

97:11 101:8

136:14 139:16

150:7

concerning 28:16

29:13 30:3

117:19

concerns 25:9 37:1

43:7 53:9 56:7

62:20 95:9

140:18 142:7

144:8 151:20

155:13,15

156:18 158:15

concert 51:8

conclude 93:2

147:6

concluded 33:6

146:10

concurrent 112:6

113:4

condensed 159:7

condition 18:2

conditions 95:5,8

conducted 44:21

confidence 50:1,7

configuration

155:19

confirmed 95:18

conflict 46:5

confusing 146:20
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Congress 17:7

62:19 80:10

congressional

101:12

147:20,21

connection 102:11

connections 88:10

consequence

146:22

consequences 31:6

34:6 42:3 75:18

97:14,15 150:8

154:5

consider 6:20

17:11 18:10

44:17 46:4 61:7

63:5 157:15

considerable

60:12

consideration

25:21 64:17 68:2

113:3,7,18

114:4,6,22

considered

21:13,16 66:9

75:14 153:21

considering 16:7

51:17 75:21

100:20 150:5

161:14

consistent 129:4

consistently 43:22

44:4 98:3

consisting 150:1

consolidate 44:19

consolidated

103:4

consolidation

99:15 100:4

constantly 107:1

114:10

constituency

141:14

constitutes 102:2

constructed 56:12

construction 56:10

constructive

161:12

constructively

31:2

consume 136:15

consumer 22:12

38:20 45:16

104:8,18

consumers 59:20

104:4

contact 9:6

contain 48:7

contemporary

49:19

content 123:13

continually 90:17

continuation 2:5

continue 37:19

42:11 50:1

52:1,8 66:1 74:6

103:15 112:5

135:8 155:18

continued 18:12

41:16 69:13

102:20

continues 22:21

35:11

continuing 21:1

30:6 31:11 45:13

52:10,14 58:19

129:5 141:9

continuously

90:13

contrary 23:22

contribute 53:12

77:10

contributed 79:1

157:10

contribution

23:19

control 22:8 23:1,3

25:4 27:14,22

29:4 64:13 88:6

controlling 116:18

convenient 55:20

conversation

52:15

cook 81:12 85:18

137:15

cooking 88:3

cooks 82:4

Cordon 81:7 82:2

core 6:14 35:14

92:7 93:7 150:10

corner 95:22

Corporation 29:12

correlations 33:10

cosmetology 55:17

57:18

cost 7:9 8:15

12:9,21 15:13

48:9 50:8

56:4,22 60:20,22

85:16 91:16,19

100:21 104:5

139:15

costs 7:7 15:19

16:7 27:18 50:10

61:22 78:14,17

88:6 139:12

Council 83:4

156:21

counsel 3:8 52:21

55:5,7 96:14

144:4 163:8,11

counseling 45:16

58:9

count 42:17 122:2

counted 99:21

counter 23:14

counterparts

93:19

counties 68:16

countries 52:2

country 10:17

13:5 16:13 24:2

30:22 34:7 36:2

44:11 52:6 71:20

74:12 76:10 77:5

86:20 90:7 120:9

134:3 137:2,4

154:16

country's 18:22

34:2 71:18

141:20

county

53:5,6,9,11,15

54:17 68:14 69:1

87:17 88:3

couple 3:2 8:9

92:4 113:22

115:5 161:2

course 147:17

158:16

courses 4:9 50:11

90:12 107:3
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coursework 10:20

court 44:11

cover 22:10

covered 60:6 95:7

116:2 157:20

covers 3:17

cr?me 84:2

craft 62:6

crafted 17:7

crafting 74:5

create 20:5 22:3

65:12 89:14

148:22 153:6

created 80:10

149:3

creates 33:12

creating 72:5

creation 34:3

creative 48:6

133:10

creators 71:3

credential 103:19

112:12

credentials

48:8,9,13,18

49:2 79:21 81:14

103:16

credibility 17:17

credit 28:5 67:8

117:2

credits 87:20

152:22

crime 41:14

criminal 4:13,14

72:20 74:15

90:10 97:16

cripple 71:18

criteria 145:19,22

146:1

critical 12:16

32:10 34:2 51:3

54:2 58:12 71:3

97:17 150:12

criticism 70:4

crucial 141:15

Cruz 152:16

culinary 41:3

53:21 59:9 81:7

82:19,21 83:6

84:7,9 85:8,9

111:5 136:19

138:2,6

cultural 150:2

cumulative 85:4

curb 160:15

cure 100:9,18

current 4:14 22:22

25:5 35:11

37:14,18 51:6

66:18,20 67:9

68:3,9 69:9

76:10 93:17 95:5

97:8 98:9,17

100:3 108:4

125:6 150:5

152:20 153:6

154:17 156:21

currently 18:1

22:7 23:5 44:13

45:21 51:12

67:22 71:17

82:10 87:2

97:7,12 101:9

115:19 144:9,14

145:2 152:19

currentlyproposed 69:18

curricula 90:13

93:1

curriculum 4:7

87:12 123:13

140:20

curtail 38:4

curve 107:3

cushion 69:15

cutoff 58:2

cuts 107:7

cutting 112:5

126:13

cycle 41:16

cyclical 64:12

D

D.C 1:15 14:21

115:15 151:17

152:17

daily 72:1

damages 78:1

Daniels 50:22

Dare 67:16

dark 121:20

data 25:19,20

26:4,14 31:17

32:2,13 33:2,3

35:16 36:15 37:8

57:1,7 61:5 64:3

72:13 79:18,22

80:2 92:16

95:9,12 98:8

100:10,14

102:18

113:14,20 114:3

124:9 133:5

145:18 154:8

156:16 158:18

159:9

datasets 124:13

date 69:17 129:7

daughters 65:4

68:14

David 52:21 131:8

Davis 144:1,3

158:14,18

day 2:3 112:13

129:8 158:9

days 161:12

deadbeats 80:8

deadline 115:6

deal 127:18

dealing 24:12

deals 137:18

dean 19:18 34:15

42:22 43:12

dear 71:6

debatable 100:22

debate 118:14

139:21

debt 10:10 11:12

12:10 14:11 22:8

23:3,6,8 26:10

27:18,21 28:4,6

31:10 36:16 40:3

43:8 45:16

62:4,8 63:11

75:20 76:9 77:17

78:14 80:9,18

89:4,6 94:22

99:21 103:1

104:5 116:22

123:19,21

124:11,19 136:5

139:3 141:1
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151:1 153:9

debts 69:2 116:10

debt-to 57:1 98:10

105:9

debt-to-earnings

98:5

debt-to-income

23:6 36:13

37:11,22 46:20

57:7 58:13 60:18

62:10 64:1 69:11

79:9 89:1

94:4,7,16 98:18

119:18 138:21

153:13 156:1,8,9

debt-to-service

150:20

decade 9:14

decades 61:2

127:5

decide 22:9 62:19

161:1

decided 158:9

decision 38:22

40:3 42:10 102:1

124:6 139:5

decisions 23:7

51:17,19,21

76:19 88:22

declare 5:14

declared 5:21

dedicate 61:6

dedicated 152:2

deem 45:12 46:12

deemed 14:2 37:11

75:11

deeper 119:20

default 12:3,5,6

15:21 35:19

37:22 41:11,13

44:12 62:9 67:9

83:13 92:18 93:5

95:11 100:16

116:16

119:12,16

128:6,12,18

129:2,17,20

131:2 146:5

156:10

Defense 122:11

defer 45:1

deferment 100:4

deferments 28:7

deferral 46:7

define 71:4

defines 124:10

defining 61:2

definition 78:6

80:6 102:22

113:8

definitively 32:11

degree 30:16,18,21

35:5 48:13 50:4

60:12 73:8,14

74:1 88:2 101:17

103:12,17,20

112:8 113:6

139:11,15 140:2

154:1 159:19,20

degree-completers

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122:13

fourth 72:19 79:17

160:3

fourthly 144:21

four-year 73:14

87:5 94:15 110:3

133:7 152:14

154:10

fraction 12:15

fragmented 150:1

frame 100:16

frames 94:14

Franklin 72:9

frankly 27:20

Fred 3:8 143:22

freedom 139:4

French 75:9

frequency 140:21

fresh 108:15

Friday 1:12 155:6

162:5

Friedenreich

84:11

friend 40:14

fulfill 118:21

fulfilling 77:6

full 11:14 15:5

22:20 61:19

65:2,4 73:4

84:22 97:5 99:16

152:11

full-time 135:4

147:14

fully 66:9 103:11

139:3 142:9

fund 64:22 122:11

151:16 154:18

fundamentally

154:19

funding 7:5 9:12

110:22

funds 64:22 65:2

102:6 115:20

148:11

Furthermore

12:18 100:13

139:6

future 51:1 88:22

97:8 98:17 117:5

141:20

G

gain 104:3 118:19

147:10 152:17

gainful 1:8 2:4

10:9 12:7 13:17

14:8 17:3

18:4,19

19:2,8,10,14

24:12 29:14 30:7

32:19 36:8 41:22

42:6 46:5 48:15

53:10 56:8 59:2

61:3 62:18 65:9

69:8 70:14 71:16

74:5 75:17 78:6

81:19 84:18,20

86:16 87:6

89:8,18,22

93:8,12 94:5

96:10 101:5

102:2,3 103:22

104:2,9 105:5

108:22 109:16

115:18,21 119:6

120:1,7 122:4

124:1,7 125:4

127:16 128:9

129:8 141:3

144:9 149:7

150:9 151:10,19

153:15

154:4,15,21

155:13

gainfully 67:2

108:6

gaining 103:15

gains 137:8

Gambrell 44:7

GAO 16:21 38:7

101:3,7

GAO's 15:17

gap 7:4 30:22

Gasaway 64:20,21

gated 3:19

Gates 48:5

gather 136:1

GE 94:5

general 3:8 6:13

38:9 52:21

55:5,7 82:6 88:4

93:18 95:8

105:14 128:3,5

generally 65:10

76:2 126:1

146:11

generate 50:5

generation 142:3

gentlemen 5:4

6:20 34:13 74:8

81:5

genuinely 20:9

geographical

161:2

George 20:21

George's 21:10

127:2 128:11

Georgetown

131:12 132:16

Georgia 96:13

gets 56:21

getting 29:3 40:15

104:13 110:4
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152:8 153:22

157:13

Gill 76:13,15

given 11:11 32:13

36:3 58:1 59:20

66:22 91:4 92:22

126:6,17

gives 132:19

142:11

giving 25:20

glad 4:22

GM 114:9

goal 23:14 31:10

34:4 52:5,6 56:2

78:5 107:9 147:3

153:18 161:18

goals 24:1 49:12

60:11 63:10 75:3

154:17

Gold 84:8

gone 29:21 39:22

61:2

Gonzalez 87:16

Goplerud

42:21,22

gotten 161:12

government 27:5

74:14 78:8

118:22 126:12

158:16

Governor 50:22

grad 46:8 94:18

grads 28:14

graduate 9:22

10:3,14,16

11:3,10 14:15

38:15 53:12

73:16,19 87:16

92:19 98:20

103:20 108:15

109:22

129:11,13

152:16 154:10

156:14

graduated 9:10

15:3 63:14

81:8,9 110:7

111:12 156:7

graduates 4:13

8:4,22 11:16

16:22 17:2 34:5

36:14 38:9 39:12

44:18 53:20

63:7,15 67:3,6

69:1 73:18 74:17

75:19 79:16

81:11 85:7,10

87:14

90:14,19,22

102:19 107:21

113:13 116:16

120:18,22 121:7

130:2,5 135:4

144:22 147:3

153:19

graduate's 74:11

106:10 108:16

graduating 14:10

60:19 152:8

154:1 157:4

graduation 7:8 8:6

11:3 36:5 42:16

45:4 57:21

63:6,22 74:1

77:12 83:9

92:18,19 94:15

98:14 129:7

154:11

grant 33:5,7 36:5

92:15 141:15

142:2

granted 80:16

149:19

grants 92:12 119:9

graphic 87:19

graphing 33:3

grateful 2:7

117:18

great 3:12 4:21

36:7 66:17 83:15

151:7

greater 23:19

60:21 68:2 73:5

115:3 123:12

124:8 127:7

129:16

greatest 104:8

greatly 53:13

61:15 64:12

107:18 125:13

Green 2:17

Greetings 96:16

Grenada 127:2

grossly 38:12

ground 2:9 137:21

group 61:12 83:11

96:18 107:14

119:21 141:7

144:5

groups 97:20

107:11,16

144:20

grow 37:19 65:14

137:14

grown 35:3

growth 66:18

90:20 137:13

guess 3:5 144:2

145:16

guest 57:19

guests 131:8

Guida 29:8,10

guide 42:11

guideline 98:6

guidelines 120:2

146:13

Guinness 84:1

Gutierrez 86:4,5

guys 109:20

H

habits 49:21

half 116:13 141:7

hamper 51:7

Handbook 138:13

hands-on 81:14

110:15

happen 54:10 64:4

128:16 138:16

140:6

happened 38:13

41:17 145:16

happens 106:19

happy 9:8 19:16

40:15 47:2

harassment 117:1

hard 85:12 88:15

harder 88:20

118:8 153:22

156:2

hardest 153:15,17
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Hardiman 81:5,6

hardships 152:10

hardware 107:7

hard-working

81:11

harm 24:1 42:2

85:20 97:15

153:10

harmful 85:7

Harris 155:1

Harry 117:14

Harvard 13:16

18:22 20:22

21:2,15 45:6

129:14 148:9

Harvard< 130:11

Hastings 147:22

hatchet 148:15

hate 5:2 54:18

115:7

hats 131:11

haunt 116:22

Haven 161:1

having 2:4 5:5 9:7

77:7 79:3 106:7

111:22 134:16

140:22 149:20

153:19 155:6

157:5

head 41:6 137:15

heading 105:15

headquartered

55:15 91:4

headquarters

87:18

health 7:19 20:22

72:15,17 84:3,4

90:10 106:1

healthcare 53:20

59:8 160:1

hear 8:21

heard 9:4 42:1

129:1 135:16

142:4 143:11

147:15

161:11,22 162:2

hearing 96:9 105:1

127:22

hearings 2:3

heart 147:16

hearty 162:5

heavily 51:1 125:1

heck 140:3

held 9:22 20:4

21:19 23:5 62:9

Hello 101:16

104:22 135:12

144:3

help 4:11

7:10,12,14 8:18

31:9 33:16 40:8

43:7 48:6 65:3

72:3 80:18 88:11

112:20 114:14

121:2 122:1,5

136:20

138:12,15

141:16 153:11

162:3

helping 16:20 49:3

50:20 88:5

153:1,21

154:2,5,9

hereby 163:3

hereto 163:12

He's 2:20

hesitate 93:6

Hi 140:12

high 32:21 34:11

41:12 67:9 92:11

95:6 108:7

109:3,5 122:21

123:5,21 134:5,6

135:3 141:9

144:12 157:4,5

high-end 3:19

higher 23:10 29:22

34:20 41:13

51:15 60:7 61:18

65:12,15 77:2

86:17 88:17

92:15,18 93:5

98:15 103:10

108:12 117:6

118:5 119:15

120:20 136:9,11

139:12 141:21

142:15

144:12,20 145:4

146:2,17 147:5

149:13,20

150:4,17

151:4,12 154:11

156:1,8

higher-level 128:7

higher-paying

138:16

Higher-quality

139:10

higher-than 36:2

highest 33:17

40:21 66:16 91:9

153:19

high-growth

106:18

high-impact

122:17

highlight 56:10

66:5 102:10

142:5,8

highlighted 92:5

123:4

highly 67:15

68:3,18 87:9

highly-skilled 78:2

85:18

highly-subsidized

62:1

high-paying

107:15 109:3

high-quality 30:16

31:13

high-tech 105:18

Hill 131:16

Hilton 83:17

hinder 52:9

Hinojosa

148:17,18

hire 9:9 110:14

hiring 121:13

135:20

Hispanic 73:19

82:16 131:21

150:8,16,17

151:3,8,12,15

152:4,7 154:18

Hispanics 31:1

86:10 149:1

historic 109:2

historically 15:21

35:9 41:12

history 12:1 73:8
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hit 153:15,17

157:7

hold 2:13,15

14:4,12 61:14

71:5 123:10

144:11

holding 20:2 88:14

hole 141:17

home 117:3

118:16 136:6

homes 47:18

honor 40:17 43:11

honored 44:6

honors 83:20

Hoosiers 47:17

51:2

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138:22 145:20

hopeful 130:15

hopefully 47:22

hopes 54:11

Hopkins 13:16

18:22 21:2,15

horizon 69:22

hospital 9:5

130:22

hospitality 53:21

82:3,8

hotel 82:7

hotels 81:13

hours 25:17 66:1

household 41:6

75:12 98:10

hovered 118:2

huge 16:13 157:13

human 3:16 85:15

90:11

hundreds 106:3

161:12

hurt 24:3,4 151:22

hurting 133:15

154:6

I

Ian 76:15

I'd 2:12 5:1 47:2

63:1 71:1 80:22

95:13 104:22

109:14 160:7

ID 99:10

idea 26:9

identical 89:15

identifies 49:1

identify 58:20

ignore 139:7

ignores 44:18 95:4

I'll 142:4

Illinois 118:14

121:6,8,16

illness 93:22 94:12

illogical 67:11

I'm 3:6,15 4:22 5:6

9:18 19:16,18

24:9,10 25:17

28:6 29:10 34:15

39:6 42:22 43:4

47:5 52:19 53:4

55:2 59:4 66:8

68:3 70:15 71:20

76:20 81:6,10

86:5,6,7 90:4

96:10 101:17

105:2,4 106:13

109:22 111:20

115:1,6 117:18

122:9,12 127:1

131:4,21 132:3

135:12,13

140:13

143:21,22

146:21

151:15,18

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imagine 69:5

73:14 74:3

immediate 159:14

immediately 8:22

57:20 108:7

immense 114:21

immigrant 122:18

impact 30:8

31:18,19 45:20

56:19 58:6 64:12

69:3,4 76:17

94:3 95:4 99:4

100:21 114:3

impacted 61:15

66:16

impacting 68:22

impacts 79:15

imperative 69:22

implement 27:7

58:15 61:7,20

implementation

56:11 58:1 66:11

69:9 70:7 89:13

93:8 150:15

153:17

implemented

13:18 76:9

implementing

22:15 93:11

154:15

implicit 156:19

159:8

implore 54:9

importance

149:16

important 2:6

25:21 53:17

56:10 57:17

59:21 67:18 84:6

85:8 86:21 102:8

112:8 114:13

131:10 136:16

137:12,21

141:22 154:2

161:18

importantly 18:3

48:3 56:18 88:18

133:9

impose 151:10

imposed 17:15

impractical 22:17

improve 23:18

31:5 68:7 77:10

88:15 117:9

138:15 142:11

143:3,6 152:9

153:4

improvement

66:19

improvements

81:2 143:10

improving 58:7

141:21

inadequate 60:4

inappropriate
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incentive 33:12

57:9

include 29:15

46:18 68:12

105:22 116:3

124:6 125:10

included 106:6

includes 50:12

79:14 92:7

including 6:1 10:4

17:17,19 31:1

45:6 51:14 67:6

77:19 91:3 93:10

118:14 125:2,13

126:16 129:13

147:20 156:21

income 11:13,21

33:14 36:15

46:17,21 57:2

64:10 68:17

94:3,8 95:1

98:6,10 99:11

100:9,10

105:9,11,18

106:4 108:20

115:9 119:4

136:5 143:6

145:13 150:20

income-based

100:5

incomes 67:19

93:19

incorporate 107:8

increase 16:11,18

38:19 51:1 52:10

93:9 106:10

142:15

increased 41:15

141:14

increases 136:8

incremental

103:16,19

incur 123:21

incurred 11:12

94:22

indebtedness 30:2

125:6

indeed 16:13

45:22 141:18

indefinitely 143:5

in-demand 142:19

144:22

independent 17:13

22:18 49:6 83:4

146:8

Indiana 47:6,12

50:17,22 51:15

Indiana's 47:7

50:22

indicate 93:18

indicated 26:15

37:20

indicates 44:22

116:16

indication 11:22

indirectly 57:1

individual 95:2

individually 23:1

individuals 4:16

47:22 49:12 78:3

94:9 109:7

132:8,18 135:7

157:8

individual's 49:13

75:1 79:11 88:22

industrial 3:20

41:8

industries 57:18

72:5

industry 22:4

35:1,3 51:9

65:11 71:1 81:21

82:4 111:6

136:17,19,22

137:7,14

138:9,12

industry's 116:16

ineligible 14:2

119:16 150:19

inequity 37:2 38:5

inevitably 89:19

inexpensive 27:22

infeasible 139:18

influence 61:17

influenced 28:10

influences 64:16

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information 26:17

35:17 36:20

38:20 45:16

59:5,19 60:2

90:11 97:3,4

99:11 100:9

104:6,10,11

105:15 158:17

informational

124:16

informed 59:20

76:19 139:3

initially 6:8,16

initiative 123:10

initiatives 86:12

inner 41:20

innovative 55:12

input 2:5 105:12

106:14

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instability 141:14

installing 105:14

Instant 152:19

instead 33:12

86:18 128:17

institute 5:7 55:6

87:17,21 88:2

121:8,9,16

152:16 153:1

instituted 32:12

Institutes 29:16

institution 20:16

21:21 22:8 23:3

24:19 25:6,12

26:4,5

34:18,20,21

35:4,8 36:9

38:1,2 40:2,14

47:8,21 48:2,15

50:15 61:16

62:2,3 64:4,13

70:17 77:2 99:6

103:4 104:11,13

128:10 136:9

institutional 27:9

35:18,19 78:14

80:14 92:1

institutionally

7:18

institutions 13:19

14:2 16:10

18:6,7 20:8

21:14,19 23:4

29:15 31:8,21
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32:19,22 33:13

36:2 37:6

38:10,14,16,18,2

1 39:2 42:15

46:3 48:19 51:8

60:1,6,7,11

61:14 62:16,17

68:12 71:9 73:18

75:8 78:10

87:5,10 97:21

99:9 100:13,18

102:10 103:2,10

104:4,7 107:6

114:21 120:19

121:14

123:7,10,13

124:22 125:7

126:2,6,9,10,14,

19 127:14,21

128:7 130:7,18

132:4,9 133:2,7

134:18,20

135:19 136:20

137:20 138:1,4

139:18

144:11,12 145:3

154:12 155:4

156:6,7 157:13

162:1

institution's 61:21

104:15

instructor 5:7

instructors 40:7

instrumental

71:19

insufficient 12:13

insurance 74:15

106:1

integrate 27:7

integrated 50:11

integrating 25:18

integrity 59:17

95:9,12 100:14

101:21 144:13

intellectually

159:5

intelligent 139:5

intend 69:8

intended 14:9

39:13

intent 78:9 101:12

intention 42:2

69:5

intentioned 89:19

intentions 54:11

interaction 84:17

interest 63:19

77:16 129:19

130:3

interested 9:3

163:12

interesting 72:8

interests 10:17

118:20 127:9

interfering 78:21

interim 27:3

internal 92:16

international

16:21 76:15

internationally

118:11

Internet 145:13

internship 11:5

internships 10:21

133:1

interpret 125:17

interviewed 7:1

introduce 3:5

introducing 107:3

invaluable 106:21

124:13

investing 56:14

58:8

investment 57:15

79:13 85:1,5

94:22 142:2

Invincibles 140:14

invite 95:19

invited 84:3

invites 84:4

involved 43:13

84:15 127:14

IPED 101:5

IPEDS 83:11

iPhone 67:17

ironic 144:17

irony 145:6

IRS 145:18

Irvine 87:19

isn't 20:14 32:10

146:15

issue 20:14 25:7

30:17 59:17

86:21 119:7

127:19 151:7

160:8

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86:9 92:5 133:17

156:20

it'd 155:9

items 134:15

iterations 74:16

it's 2:6 4:5 22:8

25:14 26:22

27:4,19 28:1,22

32:13,16 36:10

41:17 42:8 45:4

61:7,14 62:11

63:14 68:18

71:12 78:19

80:19 103:13

111:4 114:8,11

115:8 118:8

130:14 134:18

141:18 142:10

145:4 156:16

157:2 159:15

160:22 161:5

IV 14:2 17:5 18:2

22:17 69:14

89:10 91:19

92:11 101:20

102:20 119:17

IV(a 11:17

I've 4:3 43:11,13

62:5 96:19

132:16

IV-eligible 12:4

51:13

Ivy

47:6,7,12,16,19

49:5 51:3

J

Jackson 148:1

Jacksonville 43:3

101:18,22

104:16

James 3:6 143:21

Jamie 48:22

Jared 121:6

Jared's 121:19

Jeff 59:4
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Jefferson 130:11

JEFFREY

163:2,16

Jennifer 140:12

jeopardy 21:16

Jesse 148:1

Jim 14:19 101:16

job 4:17,19 8:21

66:18 67:4 72:2

75:22 79:19

119:6 121:3

137:13 141:13

154:9

jobs 4:12 14:10

34:3 39:21 54:19

68:8 72:6

102:9,11

107:10,15

109:3,6 111:7

114:8 116:20

118:8 137:6,7

142:19 144:22

147:4 152:8

Joe 81:6

John 3:15 90:3

96:12

Johns 13:16 18:22

21:2,15

Johnson 68:14,15

69:1

join 138:8 143:11

joined 55:11

143:22

Joint 7:17

Jon 152:16,18,22

Jonathan 156:5

Jose 53:3

JRCERT 7:22

judge 42:18

judicious 51:17

July 58:4 66:14

69:14,17 116:7

142:9

June 15:17 16:14

163:21

junior 50:5

justice 4:13,14

72:20 74:15

90:10 97:17

justified 32:8 56:4

K

Kaiser 4:2,3

Kansas 65:1 68:16

Kantor 146:9

Kantrowitz 33:1

Kathy 9:17

Keiser 70:11,13,15

72:13,19

106:14,18 107:2

108:2 134:22

Kent 64:20

Kentucky 21:4

key 74:22

keyword 66:6

kicked 160:15

kicks 129:17 130:4

kids 110:5

Kingsborough

37:7,16

kitchen 85:10,14

88:5

kitchens 139:14

Klaus 84:11

Klaus's 84:15

knowledge 6:17

85:17 123:2

known 71:11

Kolotos 96:12

Kurian 156:5

Kvaal 2:2 3:6

52:13 143:18

161:7

Kvall 143:21

L

labor 64:3 88:6

113:14 135:13

145:12 156:20

157:17 158:18

159:10,14

Labor's 138:13

lack 32:13 41:19

93:4 94:3 111:7

144:18

lacked 38:8

lacks 100:10

ladder 81:18,19

ladies 74:7

lag 6:16 52:1

102:17

laid 56:7

language 82:22

83:2 125:20

Lanny 144:3

large 11:12 30:21

91:15

largely 118:18

142:6

larger 20:5

largest 47:7,9

72:14 84:2

117:17 137:3

148:20

laser-like 55:22

last 12:13 38:13

43:11 44:5,11

62:21 68:15

83:11 92:3 96:9

121:14 141:6

155:5 160:7

161:12

lasts 159:6

late 94:21

later 69:17 72:11

129:8

latest 107:8 118:5

Latin 53:4,5,8,14

Latino

86:6,8,18,22

87:9,18 88:13

89:7,12

122:14,21

123:5,20 124:2,4

125:2 126:16

148:19 149:4,15

Latinos 86:14 88:9

125:14 148:20

150:6,13

launched 35:6

launching 34:10

law 14:20 29:18

42:22

43:1,2,12,18

44:6,17,18 45:6

46:12,21 55:9

78:21 115:19

131:12 140:2
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laws 62:19

lawyers 45:1

layers 51:4

Le 81:6 82:2

lead 9:6 22:18

42:3 103:11

125:4 136:12

138:15 152:21

154:21 156:1

leader 34:4 71:15

leaders 147:21

Leadership

151:16 154:18

leading 48:13 91:8

122:14 136:17

leads 75:3

League 91:3

learn 6:19 48:4

88:10 109:7

learned 6:17 110:8

learner 52:7

learners 49:3

52:10

learning 7:20 9:3

49:19 81:14

Leary 9:17,18

least 11:1 36:4

45:4 61:3

116:4,13 127:20

158:11 160:11

leave 140:21

leaves 64:6

leaving 148:7,8,9

led 127:19

Lee 53:5

legal 43:10 44:22

80:8 96:14

122:11,14

legislation 100:2

109:21 114:15

legislative

122:10,16

131:22

legislativelyprovided 46:6

Lemon 14:20

lending 22:12

length 55:18

155:17 158:6

less 9:13 12:10

13:14 38:10 67:4

78:11 84:14

119:9 123:8

125:1,8 128:13

lessening 31:10

let's 3:11 26:22

37:12 61:3 76:3

134:10,12

letters 39:12 40:5

letting 95:13

109:15

level 10:14 25:14

26:3 27:9 38:15

46:14 70:17

75:10 80:14

92:11 99:8

113:16 129:3

141:13 157:4

levels 26:11

36:10,17 39:3

62:4 69:12 88:17

libation 155:7

liberal 35:13

146:19

license 129:13

licensed 11:4,8

18:16 115:15

130:20

licensing 10:2 13:7

15:11

licensure 15:6

17:20 18:11

130:19 131:1

lieu 99:10

life 49:11 74:15

81:17 85:4

131:13 132:17

149:1,22 152:9

153:5

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lifelong 47:13

81:12

lifetime 94:13

157:17

lift 151:1

light 2:18,19 32:8

125:5 148:13

lights 2:17

likelihood 23:10

136:8

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67:15 69:2 70:5

74:1 75:5 93:21

94:1 103:20

108:10 120:1

126:11 154:21

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limit 22:16 30:2

38:22 62:6 71:17

75:1 84:19 89:5

117:21 150:17

151:11 153:6

limited 38:10

138:5

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120:15

limits 31:5 97:10

line 7:13 137:16

linear 33:4

lines 120:13

link 99:5 102:7

linking 75:20 76:8

Lisa 111:17

list 5:15 20:17

67:16 68:11

121:17

listed 106:11

listening 136:1

literacy 30:4

literally 116:22

literate 28:3

literature 75:9

litigation 122:17

little 61:9,17

63:11,18 66:6

102:5 130:13

140:22

livelihoods 109:11

lives 77:10 108:12

112:9 117:1

122:6 132:12

157:14

living 11:14 82:6

106:11

load 32:14

loads 43:9

loan 11:14

26:12,20 28:9

33:5,8 35:15
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41:13 46:18

56:21 58:8 60:17

62:6 63:18 67:18

69:2 76:8 91:14

92:13,18 94:17

97:10 98:11

99:22 100:3,6

117:7 119:19

129:22 132:20

133:12,13 136:5

138:21 141:16

142:2 146:4,11

loans 12:1,3 15:20

41:14 44:19

60:17 61:1

63:5,14 67:12,15

89:10 91:20

92:12 99:15

103:2,3

116:17,21

118:22 119:10

125:11 132:18

139:22 140:4

142:20 146:4

156:3,10,15

159:4

local 4:5 9:4 21:7,9

51:18 53:10

112:7

113:5,13,14

114:9 118:13

121:3 126:12

locate 51:21

located 9:20 15:2

39:7 70:19 92:7

112:22

location 161:4,5

locations 51:6,13

93:7,10 144:6

locked 39:17

logical 59:22

London 110:7

long 6:7 8:14

29:19 54:19

122:20 159:6

longer 65:11 69:10

76:3 90:18

156:12

longer-term 158:2

long-term 95:1

107:17

loom 69:22

Lopez 53:3,4

151:14,15

Los 65:6

lose 87:8 114:13

115:7 143:3

144:20 160:9

loses 116:9

loss 88:7

lost 39:21 114:7,9

lot 54:3,12 112:21

114:19 116:6

140:3 155:10,11

160:6,9

lots 110:8,9

love 81:11

loved 77:14

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105:13 129:20

low-cost 62:1

lower 12:8,21 57:4

62:2 69:3 75:10

92:17 93:19

97:19 107:21

115:3 119:4

128:22 156:9

lowest 97:17

low-income 30:9

32:21 77:3,18

80:12 89:3 93:13

119:15 125:1

146:3 151:3

152:10 158:4

low-middleincome 48:3

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LRRs 27:10

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lucrative 94:20

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lunch 53:14 95:16

96:4

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M

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95:5

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Madison 111:18

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61:11

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10:7 55:22

138:12

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131:17

Maison 109:14,17

major 5:14,15,21

46:5 55:9 158:19

majority 30:13

100:3 161:16

majors 74:14,15

MALDEF

122:12,14,15,20

123:9,16 124:14

125:15 126:1,17

131:14 138:22

male 93:19

male-dominated

35:3

males 150:7

MANA 148:18

manage 11:14

23:11 25:11 62:8

65:3 81:16 88:5

managed 59:13

111:13

management

29:12 49:21

64:21 80:9

137:13

manager 3:16 82:7

87:19 88:4

managers 137:16

managing 82:4

MANA's 150:10

mandatory 18:12

manner 90:12

manufacturing

52:3

March 58:2

Marcus 87:16

margins 65:14

Mario 151:15

Mark 33:1 146:9

market 4:17
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113:13,14 125:1

126:13

marketable 7:21

90:15

marketing 45:11

102:10

marketplace 37:7

52:11

markets 134:1

Marriott 83:17

Martin 15:2

Maryland 1:14

115:16

massive 157:9

master 59:22

84:11,13

Master's 19:21

70:18

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materials 102:10

125:13

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23:16 155:22

matters 63:13

maturing 63:8

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29:21 36:7 61:22

65:7,9,13 66:19

72:8 94:10 98:11

99:20 106:3

108:5 112:18

113:1,22 116:6

121:21 125:3,4

136:10 138:7

141:18 152:12

159:21

maybe 54:10

155:9

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McIntyre 14:20

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mean 2:18

26:13,21 27:21

57:12 58:14

108:6,9 129:7

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85:22

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124:1

means 2:18,19

16:11 28:13,14

49:18 50:2

153:16

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28:13,22 29:1

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105:18 124:1,7

measured 58:3

64:6,10 67:20

92:14

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37:16 68:4 84:21

144:19

measurements

64:2 93:4

measures 30:3

37:2 38:21 39:2

63:4 102:1

measuring 67:2

mechanism 79:14

Medal 84:8

media 87:21

median 36:16

68:16

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129:6,10 130:18

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36:21 37:11

45:17 52:5 58:20

90:18 91:9

119:17,22

150:22 151:5

meeting 1:7 49:12

80:7 96:3 127:18

162:7 163:3,6

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Melody 88:1

member 40:13

82:7 84:11 91:5

94:1 127:6

members 55:2

109:9 136:2

147:21 148:21

156:21

men 4:6

mention 160:7

mentioned 36:12

79:8 124:21

158:14 159:13

mentoring 149:3

merchandising

37:5,11

merchants 134:7

merger 95:10

Merisotis 49:1

merit 23:8 91:22

Messenger 152:20

met 77:8 124:19

method 42:13

metric 46:18,19

56:21 57:2,8

58:13 143:6

145:11 157:20

metrics 18:1 26:3

35:8 36:7 37:20

43:21 45:17

56:11,12,17

57:3,6 64:12

94:4 139:6,16

140:8 144:19

145:10

Mexican 122:10

Mexico 5:8

Michigan

39:7,8,19

MICKLE

163:2,16

mid 94:21

middle 23:15 35:7

63:21 91:2

miles 161:2

milestones 149:18

military 135:1
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Miller 155:1,2

million 71:10 72:1

76:5 92:3

137:1,6 139:15

millions 147:2

Milwaukee 92:9

minimal 63:18

minimize 61:20

minimum 13:17

18:15 60:21

64:14 129:15

Minneapolis

55:10,16

minorities

30:14,22 54:4,8

73:6 77:19 87:7

128:5 135:2

147:17 153:16

minority 30:9 32:2

33:14 41:12

54:12 65:8 75:13

86:22 87:3 88:9

97:20 116:11

117:22

119:3,15,21

120:17,18,22

122:5 131:20

132:13

146:3,11,13,18

149:14 151:22

154:9,13

minority-serving

154:11 157:12

minute 83:20

minutes 2:12,19

Miracle 111:17,18

misguided 84:21

109:1

Mishory

140:12,13

miss 115:5

missile 34:11

missing 148:3

mission 43:16 71:6

150:12

Missouri 32:2

Mitch 50:22

mix 104:15

Mobile 152:22

model 79:12

models 29:22

modest 31:3

Modica 126:22

127:1

modification 42:5

modifications

31:4,7

modifying 58:7

mold 4:8

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mom 75:12 110:1

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28:6,8 54:14

64:21 91:15

141:16 142:2

150:17 154:7

monitor 40:10

month 82:22

monthly 106:4

months 6:12 8:10

35:10 64:8

155:10

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Moreover 100:16

morning 2:2 3:13

5:4 9:17 14:19

19:16 24:6 29:8

34:14 39:5 42:21

47:4 52:17 53:3

55:2 64:20 70:11

81:5 86:4 90:3

95:19

mortar 43:1

mortgage 28:5

67:7

mortgages 117:4

mostly 59:7 61:10

137:2

mothers 49:8

75:12 147:15

move 69:8 82:1

112:15 126:1

154:16 161:2

moved 110:12

moving 51:8 160:5

much-needed

16:12

multi 59:14

multiple 41:7 99:7

103:2 131:11

Murray 3:13,15

music 74:14

muster 20:12

mutual 64:22

myself 5:12 8:17

63:12 110:2,3,6

147:20

N

name's 9:17 19:18

29:10 42:21 90:3

105:2 111:17

narrow 144:16

narrowing 43:17

narrowly 125:17

nation 12:16

24:4,18 68:16

97:18 118:1

national 10:22

11:7 13:2 16:5

17:20 35:20

44:21 86:6,8

91:3 117:14,20

118:9 135:14,22

136:13 138:18

148:19,20 149:2

154:7

nationally

72:14,17,19,21

83:3

nation's 9:21

13:15 14:5 23:22

47:8 71:4 122:14

nationwide 135:22

148:21

nature 10:1,19

28:15 158:3

NBCC 121:4

nearly 101:1

140:17 157:10

near-term 66:10

necessarily 108:7

129:7

necessary 58:17

61:7 118:19

need-based 92:1

needless 128:14

negative 30:8 32:7

34:6 141:21
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negotiated 61:6

101:20

Negotiating 127:7

negotiator 59:15

101:19

negotiators 3:10

neg-reg 59:15 61:9

neither 10:16 50:8

107:14 163:7

network 92:6

networking

105:13

Nevada 135:17

newly 32:14

newly-acquired

123:2

News 36:1

niche 34:20

night 128:14

nights 81:16

nine 106:15

159:15

Ninety-five 15:7

nobody 54:21 84:4

110:19

non 60:22 100:11

non-degree 39:1

none 17:22 129:22

nonetheless

141:19

nonpartisan

151:16

nonprofit 10:13

12:9,19 13:22

14:6 16:9 86:8

103:10 116:4

123:6 124:21

125:7

126:5,7,9,14,18

138:4

nonprofits 20:13

nontraditional

80:12 89:10 98:7

121:2 147:14

non-traditional

65:22

nontransparent

145:18,19,22

non-urban 92:20

non-verifiable

100:8

nor 10:16 50:9,10

64:10 67:19

75:18 163:8,12

normal 67:12,21

Normally 71:22

Northwestern

156:5

notable 32:18

Notary 163:1,17

noted 23:6 33:3

37:3 60:4 94:9

notes 116:15

not-for 148:8

not-for-profit

43:13 45:6 48:14

65:20 87:5

120:5,17,19

not-for-profits

66:2

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Notice 116:8

noticed 71:6

128:21

November 1:12

NPRM 25:5 26:7

28:15 38:6 44:14

56:6 116:15

NPRMs 97:2

NSLDL 95:12

NSLDS 25:16

numerous 4:13

51:11 121:22

142:4

nurses 75:11

nursing 53:21 59:8

91:4 97:16

nutrition 110:16

O

Obama's 34:4

52:6

objective 97:5

objectives 33:17

49:4 58:12,21

97:13 101:10

obligation 118:22

obligations 63:17

67:10 80:8

150:22

obstacles 152:15

obtain 18:13,14,17

26:13 52:5 74:22

99:11 107:7

obtained 125:11

obtaining 51:14

118:18

obvious 140:18

141:18

obviously 6:9,18

36:16

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115:22 130:16

Occupational

138:13

occupations 97:16

137:7,9

Occupationspecific 38:8

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occur 23:8 148:10

occurrence 9:10

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55:1 58:22 64:19

70:10 76:12 81:4

86:3 90:2 95:15

96:8,10 101:15

104:21 109:13

111:16 115:13

117:13 122:8

126:21 131:6

135:11 140:11

143:15

o'clock 96:5

October 5:20 72:1

offer 44:8 51:12

58:10 70:17

81:22 82:18 90:8

104:19 108:2

111:8 123:8

139:19 152:4

offered 21:18 74:9

111:3 123:11,14

147:11 151:4

offering 15:14

19:21 51:5 82:22

124:22 125:8

offerings 90:14

offers 16:10 28:7
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100:9 123:16

Office 3:7,9

52:20,21

96:13,14 97:4

officer 7:3 34:17

47:6 59:5 91:14

163:2

offices 3:18 61:18

official 3:9 100:15

Ohio 90:9 92:8

111:19,22

112:3,5 113:9,17

114:7

Oklahoma 21:7

old 54:20 82:13,14

older 73:4 82:15

135:3

oldest 90:6 148:19

OMB 97:2

ones 87:8 93:11

129:10

one's 105:11,18

157:1

one-stops 71:22

one-third 108:14

one-year 49:13

online 66:1 72:2

90:12

open 47:11 108:2

120:9

opening 153:3

openings 8:21

9:1,4

operate 9:21 91:7

operated 19:21

operating 8:13

15:3 118:11

operations 59:13

91:9 121:7

operator 43:5

opinion 58:11 68:1

69:20

opportunities 9:13

23:17 34:22

38:11 47:15

86:17 88:16 89:5

90:20 93:13

117:21 151:2

153:6 160:10

opportunity 3:14

18:14 24:7 29:13

34:14 48:1 49:15

58:17,18 59:1

60:14 62:7,13

70:12 76:13 86:1

96:21 100:17

109:12 117:18

118:12,17 131:5

132:7,19 135:15

143:13 149:6,21

151:20

opposed 26:8

28:22

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119:2

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option 110:4

options 7:4 11:19

100:5 111:1

120:15 124:6

132:22 153:7

oral 96:21

Orange 87:17 88:2

order 11:8 23:11

26:15 51:12 52:5

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organization

51:16 71:11

86:11 121:10

122:15 140:15

148:19,20

149:15 151:8,16

152:2

organizations

131:20 151:8

original 21:17

originally 145:14

Orlando 76:16

81:7 82:3

osteopathic 12:20

others 36:14 46:22

108:2 134:19

157:17

otherwise 29:21

34:11 52:1

112:18 163:12

ought 158:11

ours 40:4 128:20

ourselves 156:11

outcome 14:13

43:17 78:4 93:4

163:13

outcomes 17:19

21:22 27:12

28:10,18,20

29:1,5 37:21

42:14,18 46:13

92:17,19 102:6

144:13

outlier 31:8,9

Outlook 138:13

outside 38:11

98:21

overall 86:13

100:21 106:10

123:9 141:21

over-borrow

77:22 78:18

overcoming 49:18

overlook 82:12

overly-complex

99:18

overly-simplifying

119:19

overnight 138:17

oversight 17:18

91:7

overwhelming

77:15

owned 34:18

owner 105:3

P

p.m 96:5,7 162:8

pace 66:18

package 61:11

63:3

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paid 63:13

99:13,16 106:2

129:22

paired 35:13

Palm 53:6

panel 3:5,14 5:5

52:18 55:2 131:8

143:20

parent 79:3 96:18

98:8 152:12

parents 69:1

77:3,13 79:1,2
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147:15

Parka 9:20

Parks 87:20

partial 20:17

participants

127:11

participate 17:5

80:9 133:22

participating

127:4

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37:7 94:17

127:18 135:20

143:1 156:19

particularly 29:20

30:9 37:4 39:18

57:17 91:20

116:11 119:3

128:11 129:6,9

160:1

parties 69:21

163:9,12

partner 26:18

28:17 55:9

partners 106:15

partnership 24:16

partnerships

86:12

part-time 66:21

party 92:13

pass 7:15 11:1

13:7 20:12 43:22

44:1

passionate 85:21

111:1 120:11

128:4

passions 76:20

128:1

past 4:4 15:21

17:7 49:18 65:15

78:7 80:6 90:17

118:3 141:13

path 60:15 74:11

75:2 144:21

147:13 153:12

155:11

pathway 120:12

patient 8:12 16:17

40:22

Patisserie 82:19

83:1

Patricia 39:6

pay 15:20 22:20

28:5 60:16 67:7

75:10 76:4

105:19 108:12

130:3 133:13

140:3 146:4

147:5 153:9

payback 46:20

157:16,18

paying 63:11,17

67:17,18 119:10

payment 28:4,5

45:1 67:16

102:22 119:9

120:7

payments 11:14

46:19 63:16 67:8

Payne 148:1

payoff 85:3 159:14

160:1

Pedro 53:4

peers 13:8 119:11

Pell 27:11 33:4,7

36:4 92:15 119:9

penalize 64:9 97:8

114:15

penalized 64:4

95:8

pending 126:6

Pennsylvania 21:4

72:12

people 2:13,15

26:6,18,19 32:14

41:7,20 54:6

71:22 74:12,22

81:11 110:20

118:8 132:17

134:11,12 137:1

139:14 140:21

145:6,20 157:3

159:17 161:9,13

per 11:11 23:1

30:12 113:11,21

perceived 75:6

89:20

percent 7:15 8:3,5

12:6,19 13:13,14

15:7,22 16:21

17:1 30:18

35:10,18,20

36:4,6,22

37:9,13

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