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Subject: FW: A message fro Della Justice 

From: Margaret Re ter mail to margaret.re te-~> 

Sent: 9/ 19/ 2013 10:14 PM 

To: Belle Wheelan Private mail to:be ll .w h~> 

Cc: Sandra nne <mail to: andra .ki nne ~ameron mail :fx ameo 

John<mailto:John. >; Rory O'sullivan<mailto:rory.osulli 

Peoples<mailto: Eileen Connor<mailto:econ 

Barkley<mailto:wb Tom T,.,,,.,.,,. ,,.,,....,.. ,.,..,,. ,,.,... . ,.,...,..., 

onda (rm 

DeBiasio<mailto:Libby 

<mailto:t 

>;Warner, 

>;Jenny 

A number of important issues have been raised in this chain. A few suggest ions based on our experience in California 

with some of the issues raised in this chain: 

1. In Ca., our law allowed the time w ithin w hich a job had to be obtained to differ depending on w hether a license was 

required. In that case, the time period w as, as I recall, 180 days after the result s were posted for the first licensing 

exam available to a graduate, after they completed the program. 

2. Re part t ime w ork: Generally, a person would not take out a large loan if they thought they would not be able to get 

a full-t ime job needed to repay the loan. There are ways to deal with that, depending on whether employment is a 

gainful employment metric or a disclosure. A way we dealt with that, so that predatory schools would not load st udents 

up with loans when the only jobs available were part time was to require the student to write a statement in advance of 

starting the program that they were taking the program only to help them get part-time employment and a similar 

statement at the end of the program, if I recall the language correctly. 

3. As to issues such as the economy limit ing the availabil ity of part t ime work, military spouses not being located where 

they can work, students not communicating with the school about whether they are working, etc.: There are t wo 

alternatives to how to count employment, either, have few or no exceptions beyond an exception for death, but have a 

lower cutoff point for the percentage of st udents that need to be employed (e.g., 60%-70%), or have a larger number of 

exceptions, but a higher cutoff point for the percentage of students that need to be employed (e.g., 80%-90%). Put 

another way, having some percentage required lower than 100% automatically allows for some of those variables. Our 

task is to figure out a reasonable cut off level. We have a number of examples from w hich we can draw of how others 

have dealt w ith this. And of course, we have the original testimony before Congress, when for-profit programs were 

included, indicating that almost every student in the for-profit sector would be able to repay their loans. 

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4.  As to the issue of students taking jobs out of the field they studied, and whether they should count, the problem is

that predatory schools count jobs that are not a fit for what the student studied or borrowed, e.g., counting a janitorial

job at a hospital as a placement for medical assisting, counting a waitress job  as a placement for a culinary program, etc.

There needs to be a way to count jobs that provide an equivalent salary to the best salary a student working in the field

would get, or some other means to prevent predatory schools from using these inappropriate counts of job placement.

On Wed, Sep 18, 2013 at 6:17 AM, Belle Wheelan Private

<belle.wheelan@ <mailto:belle.wheelan@ >> wrote:

For those employed part‐time, what if that is all that is available to them?  Neither students nor institutions can predict

the job market especially in smaller communities.

Thanks for the opportunity to comment.

Belle S. Wheelan, Ph. D.

Sent from my iPad

On Sep 18, 2013, at 9:00 AM, "Sandra Kinney" <sandra.kinney@ <mailto:sandra.kinney@ >> wrote:

Della and others,

For the purposes of job placement for COE and for Perkins, most colleges do not report until one year after the student

graduates to get more accurate placement data.  In some cases, students are waiting on board tests or other

certifications before they can be employed.  By setting a date of 180 days, then you will automatically cut half of the

allied health students out of the placement rates.  If we tried to hold public liberal arts colleges under the same

standard, they would fail miserably. I'm not sure if you can enforce #3 in a placement rate and I can see where those

numbers can easily be gamed.

We may want to start with definitions that are commonly used for COE and for Perkins and then create the job

placement definition from there.

Sandra Kinney

On Tue, Sep 17, 2013 at 3:31 PM, Chip Cameron <fxcameo@ <mailto:fxcameo@ >> wrote:

Negotiators ‐‐ the following is a message from Della Justice on placement rates.  I am forwarding it for your

consideration.  Chip

Hi Chip,

Following‐up on last week's session, can you please provide the following to the Committee members:

In preparation for the September 30th deadline and the next session, I think it would be very helpful if those of you

interested in the issue could please review the below definition of job placement and provide any feedback and

comments.  This is the same definition circulated prior to the first session.  This definition is not comprehensive, but is a

good framework for offering suggestions and raising issues that you think need to be addressed.
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Job Placement means within 180 days of completion/graduation the student has been employed for at least 13 weeks

with the employer in a full‐time paid position in the field or related field of study.  In field of study/related field of study

means employment is‐‐ 

(1) Included in the list of job titles for the program published by the institution and included in the list of Classification of

Instructional Program (CIP ) job titles on O*NET crosswalk for which the programs were approved by the Department; or

(2) In a position where the routine work predominantly requires using the core skills and knowledge expected to have

been taught in the program and the position requires education beyond high school level; or

(3) In instances where completers/graduates are continuing in prior employment, the prior employment must be

reasonably related to the program training and the completer/graduate attests in his/her own handwriting at the time

of enrolling in the program and upon completion of the program, with reference to a specific written policy of the

employer, to the benefit of the training as a catalyst for maintaining or advancing in a position.

For part‐time employment to be considered as placement, there must be a handwritten statement from the

graduate/completer at time of completion that part‐time employment is his/her objective for employment including a

general explanation for such objective.

The job placement rates must be subject to regular audits by an independent entity or the Department.

Thank you,

Della Justice

<tel >

‐‐ 

Sandra Kinney