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 U.S. DEPARTMENT OF EDUCATION

 PUBLIC MEETING ON GAINFUL EMPLOYMENT

 ED OOS-11-P-0005

 November 4, 2010

 Department of Education

 400 Maryland Avenue, S.W.

 Washington, D.C. 20202
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1 P R O C E E D I N G S

2 MR. KVAAL: ... these public hearings on

3 gainful employment. As I think you know, we're working

4 very hard on these rules and trying to strike the right

5 balance that takes advantage of the strengths of the

6 for-profit sector while avoiding some of the pitfalls

7 that we've seen.

8 The Department is working very hard to get

9 public input on these proposals. They began with

10 public hearings we had over a year ago. We had three

11 public hearings, a series of public negotiated

12 rulemaking sessions. We received over 90,000 comments

13 on our Notice of Proposed Rulemaking. So these

14 hearings are just the latest step in our process to try

15 and get as much feedback as we can and subject these

16 proposals to as much scrutiny from the public as we

17 can, because we think in the end all of this feedback

18 will help us improve the final product. So we really

19 appreciate the time of those who came today and will be

20 sharing their thoughts with us. We want you to know

21 we'll be considering those thoughts very carefully.

22 Over the course of the next two days we
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1 expect to hear about 80 presentations. I'm pleased to

2 say that we were able to include every organization

3 that requested time, so everyone will have an

4 opportunity to speak. Each presenter will be given

5 about -- will be given five minutes -- precisely five

6 minutes, not about five minutes. There is a timer on

7 the podium. I think you'll see it when you are up

8 there. The light will turn yellow when you have two

9 minutes left, and it will turn red when you are out of

10 time. I'd appreciate it if people would do their best

11 to observe that. We have a lot of speakers. We

12 haven't built in a lot of extra time. So if people

13 could try and keep their comments to those five minutes

14 strictly, we'd appreciate that. There may be occasions

15 on which we ask clarifying questions, so just be

16 prepared for that, as well.

17 And I just sort of want to let you know that

18 we're also transcribing this event. So there will be a

19 written transcript, and we hope to make that publicly

20 available in the coming weeks.

21 To introduce those of us from the Department

22 who will be listening, I'm James Kvall, Deputy
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1 Undersecretary. To my right is David Bergeron, who is

2 Acting Deputy Assistant Secretary in the Office of

3 Postsecondary Education, and Georgia Yuan, who is

4 Deputy General Counsel. Some of the Department

5 officials may rotate over the course of the two days.

6 In general, at all times we're going to have a career

7 policy person from the Office of Postsecondary

8 Education, a lawyer, and a political policy official up

9 here listening at all times.

10 So that's the ground rules. Thank you again

11 for your engagement, and we look forward to hearing the

12 comments. So would the first speaker like to come up

13 to the podium? And if you could please introduce

14 yourself and the organization you're representing.

15 MR. ROGERS: Certainly.

16 Good morning, ladies and gentlemen. I'm

17 Scott Rogers, and I'm the President of Ohio Valley

18 College of Technology in East Liverpool, Ohio. I'm

19 probably the guinea pig for my colleagues this morning

20 by going first.

21 I'd like to first thank the Department for

22 this opportunity in these meetings and thank Secretary
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1 Duncan for recent comments when he indicated that the

2 Department will take all necessary measures to ensure

3 that a new rule does not have significant negative

4 unintended consequences. And I'd like to talk about

5 one of those consequences today.

6 As required by today's ground rules, I will

7 limit my remarks to a single issue from page 3, item 10

8 of my submitted comments. In order to fully appreciate

9 the specific consequences of this proposed rule, it's

10 important that I first introduce our school. OVCT is a

11 traditional, small business, community school founded

12 in 1886, long before financial aid even existed. We

13 serve 200 to 300 local students annual and are a

14 respected benchmark and a tradition in our hometown.

15 Our program offerings are limited by the size of our

16 local community and its employer base. Like most small

17 traditional schools, we have just six programs.

18 We agree with testimony given in Senator

19 Harkins' recent hearings that a key component of

20 student success is personal support services. In fact,

21 this is one of our fundamental principles. We reported

22 retention and placement rates both greater than 70
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1 percent for our most recent academic year.

2 But while I have described our college, this

3 description would apply to several hundred small

4 community-based schools across this country. These

5 schools are typically family-owned with long histories

6 of training students right in their home towns. Small

7 schools such as ours comprise about 50 percent of the

8 private for-profit college system. The other half is

9 comprised of large publicly-traded chain schools, the

10 ten largest of which recently boasted of a combined

11 enrollment of 1.2 million students. While most of

12 these chains are relatively new, they have significant

13 financial resources and operate nationally with a

14 multitude of traditional as well as cutting-edge

15 programs, both residential and online. One well-known

16 chain regularly promotes the fact that it offers 125

17 different programs and degrees. These are the two

18 distinct sectors of for-profit education providers in

19 the United States.

20 Ladies and gentlemen, if this rule is adopted

21 as proposed, many, if not most of the small community22 based schools will be wiped out, and local residential
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1 training opportunities for those students in those

2 small towns will also be eliminated. Certainly this

3 must represent a significant negative unintended

4 consequence. Because small schools have a limited

5 number of programs tailored to their local community,

6 each program individually contributes a significant

7 portion of the tuition and revenue to that school. The

8 loss of one or two programs, or a third of that

9 school's total revenue, would likely result in that

10 school's closure.

11 Now, I must clarify that it's not my intent

12 to infer any qualitative judgment regarding large

13 versus small schools. It's simply a function of basic

14 mathematics. In today's economy it would be very easy

15 for a single program or two to miss the cut, especially

16 in an area with 11.2 percent unemployment. Therefore,

17 the rule as applied to small community schools is not a

18 program elimination rule, but rather will constitute a

19 school elimination rule.

20 Contrast this with a national chain offering

21 a hundred or more programs. The loss of five, ten,

22 even
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1 15 programs has a relatively modest effect.

2 That effect is simply program elimination and a reset

3 of corporation operations. We propose a simple fix: a

4 small school exemption. For example, an exemption for

5 schools with less than 500 students or ten or less

6 programs is imperative if these small schools are to

7 survive. Without this exemption, the ultimate outcome

8 of this rule will be a for-profit postsecondary

9 education delivery system comprised almost exclusively

10 of large, publicly-traded national chains operating in

11 medium to large-sized cities, and not in small town

12 America. Residential training with a high degree of

13 personal student support will simply cease to exist in

14 small communities.

15 I pose a simple question. Is this the

16 outcome that was intended and the outcome that is best

17 for the educational system as a whole? I am certain

18 that this clearly represents what Secretary Duncan

19 referred to as a significant negative unintended

20 consequence. For the sake of all students,

21 particularly those who are disadvantaged, I ask that

22 the Department withdraw this rule. However, as an
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1 alternative, I ask for an exemption for schools with

2 less than 500 students or ten or less programs.

3 My written comments today are available for

4 the record. I'd like to thank the Department for their

5 time and this opportunity.

6 MR. FRANK: Good morning. Thanks very much

7 for allowing me to speak today. My name is Lincoln

8 Frank. I'm the founder with Governor Tom Kean of Quad

9 Partners, which is a private investment firm in New

10 York focused on innovative K through 12 businesses and

11 building great postsecondary companies. In that

12 capacity, I serve on the board of directors of career

13 college organizations that are educating over 14,000

14 students in 80 campuses in a broad range of programs.

15 We teach medical, legal, business, cosmetology,

16 culinary degrees. We do certificates; we do

17 associate's; we do bachelor's; we do master's; we even

18 do doctorates.

19 I also am the co-chairman of the Coalition

20 for

21 Educational Success, which is a group of

22 like-minded postsecondary school owners serving over
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1 350,000 students at 478 campuses in 41 states. In

2 building our schools, we have focused relentlessly on

3 student outcomes: graduation and placement rates.

4 You're going to hear tomorrow from Patricia Fisher, who

5 is the CEO of our schools in Detroit, the Dorsey

6 Schools. Pat is do an amazing job in that very

7 difficult employment market educating and placing

8 students in the careers for which they are trained at

9 her schools.

10 Reggie Moore, who runs our Blue Cliff schools

11 in the South, will also be in the audience tomorrow.

12 Reggie is doing a tremendous job with students in that

13 territory that come from mostly minority background and

14 low income backgrounds. In what we do not only are we

15 focused on student outcomes, but we are highly focused

16 on what we have called value proposition, which is I

17 think what you guys have called gainful employment, in

18 that what we do is we really try to make sure that the

19 amount of tuition that we charge for our programs bears

20 a fair relationship to the jobs that we place them into

21 and the incomes that those students will command.

22 So when we got gainful employment, we ran the
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1 numbers. We ran the numbers for all of our 80

2 campuses. And I must tell you, I was surprised,

3 because I know we run good schools; I know we have

4 great student outcome. And a lot of our programs

5 didn't pass. And I said, why? How can these programs

6 not pass? How can these students be displaced? How

7 can these teachers be displaced? How can the employers

8 that we serve not have students to hire from our

9 schools? And the reason is, with all due respect -- I

10 know you've all put a lot of work in this -- there are

11 some key faulty components of Gainful Employment which,

12 when taken together, create massive unintended

13 consequences. And with that will be a very significant

14 displacement of students, of jobs, of staff, and really

15 of employers' opportunities to fill key jobs. So let

16 me go through what I think are the faulty provisions,

17 if I can.

18 The first is the repayment rate. The

19 definition counts as non-payers students who are

20 complying with the terms of their loans, so students

21 who have opted for an income-based or an interest-only

22 loan or who properly qualify for deferments or
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1 forbearances. If they are not to be counted in the

2 repayment rates, they should not be offered those as

3 repayment plans. The Department's own data shows that

4 the definition would catch the majority of nonprofit

5 institutions serving minority students, were it applied

6 across the board. If it's a bad regulation for one

7 group of institutions with a certain tax status, it's a

8 bad regulation for all. I think to take any different

9 approach to this is simply a discriminatory, anti10 business focus.

11 Second, income. Under the debt-to-income

12 test, income is proposed to be the actual income

13 reported to the IRS, Social Security Administration, or

14 similar data set. Does -- I certainly don't, I don't

15 think I'm allowed to find out, but does anybody in the

16 room know what a graduate of a college makes, what they

17 report to the IRS? It's not there. What about the

18 female graduate who gets through a program, who gets a

19 great job, and decides to work part-time to raise a

20 family? We graduate a very high percentage of women.

21 If they all graduate with the right skill sets and get

22 placed in a great job but then go part-time or
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1 temporarily withdraw from the work force, the program

2 will fail the test. Pat Fisher is really hot on this.

3 She's going to talk to you tomorrow about it.

4 Three: debt amortization. In the test, the

5 debt burden assumes a ten-year amortization schedule.

6 It's just not reality. You know, the research shows

7 that the average debt maturity, debt amortization that

8 people pay is 19 years. Let's use that.

9 Total student debt: This includes debt that

10 schools are not able to control.

11 MR. BERGERON: Your time has expired.

12 MR. FRANK: Can I take another ten minutes --

13 ten seconds here?

14 MR. BERGERON: Ten seconds.

15 (Laughter)

16 MR. FRANK: Thank you. That was negotiation.

17 Under the regulations, our students can draw cost of

18 living funds. We're not in control of that. That's

19 extra debt; we can't tell them not to. Please don't

20 regulate what you can't control.

21 And finally, graduate students. If there

22 ever were a case of a sophisticated student making a
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1 long- term investment decision, it's the graduate

2 student.

3 Okay. Thank you very much.

4 MS. BROFF: Good morning. I'm Nancy Broff

5 with the law firm Dickstein Shapiro. I'm here today

6 representing ITT Educational Services, Inc., and we

7 appreciate the opportunity to make a brief public

8 presentation today based on our comment on the Notice

9 of Proposed Rulemaking.

10 I planned on starting off with a joke, but

11 then I realized there's no joke in our comment, so

12 we'll just have to skip that part. And it was a good

13 joke.

14 Unfortunately, we believe the proposed

15 Gainful Employment rule suffers from serious flaws that

16 will adversely affect students, potential students, and

17 the regulated community if adopted in a final rule.

18 The proposed regulatory approach of defining gainful

19 employment in relation to complex formulas measuring

20 loan repayment and debt to income ratios is flawed as a

21 matter of law and as a matter of public policy. It

22 would harm the very students it purports to protect and
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1 increase the cost of postsecondary education to

2 American taxpayers.

3 The first issue I'd like to talk about is the

4 retroactive nature of the proposal. The retroactive

5 nature of the proposal is a problem in terms of both

6 legal authority and in the fact that it doesn't give

7 schools an opportunity to modify their operations to

8 come into compliance with the new regulation. If

9 adopted in its current form, the regulation would apply

10 to Title IV award year beginning July 1, 2012, and

11 could have negative impact on schools, including the

12 loss of Title IV eligibility for certain programs,

13 based on data that is already locked in. Even if

14 schools have some power to affect the performance on

15 the proposal's metrics in a going-forward basis,

16 schools cannot in reality alter repayment rates from

17 the three most recently completed award years prior to

18 the earnings year or for the four most recently

19 completed federal fiscal years.

20 As a result, the Department proposes to

21 subject schools to severe penalties and negative

22 consequences based on events that took place before the
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1 rule was published or is scheduled to go into effect.

2 Promulgating a rule with retroactive effect is

3 illogical, unfair, and beyond the Agency's authority.

4 I won't bore you with the legal citations,

5 but there is clear legal precedent noting a presumption

6 against retroactive rulemaking authority and supporting

7 the presumption that a new regulation has an

8 impermissible retroactive effect where its application

9 would increase a party's liability for past conduct or

10 impose new duties with respect to transactions already

11 completed.

12 The second issue I'd like to talk about is

13 the lack of access to necessary data. This lack of

14 access to data is a problem in two aspects. One is

15 that there has not been sufficient ability to do data

16 analysis in order to comment on this proposed rule.

17 And second, there will be an ongoing lack of ability to

18 bring yourself into compliance and stay in compliance,

19 because on an ongoing basis, schools will not have

20 access to the data that lets them determine whether

21 they are maintaining compliance on an ongoing basis.

22 With respect to the data that was used in
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1 developing the rule, schools were not given access to

2 this complete data and still don't have access to the

3 data, for instance in determining what the repayment

4 rate of their different programs would be.

5 With respect to the going forward issue,

6 because schools will never have access to the income

7 data the Department will use to make eligibility

8 determinations, the proposal does not give schools a

9 meaningful ability to challenge the accuracy or

10 completeness of the Department's eligibility

11 determination prior to having sanctions imposed.

12 The final issue that I would like to talk

13 about is an issue relating to the new program approval

14 process. The new program approval process was

15 published in partial form in the Gainful Employment

16 Rule on October 29. But the Department made clear that

17 it is going to issue additional regulations on this

18 area in the final reg on the larger Gainful Employment

19 package.

20 We believe that the requirement of

21 documentation from unaffiliated employers stating that

22 the program's curriculum aligns with occupations and
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1 the number of projected job vacancies could be

2 administratively burdensome, is beyond the reasonable

3 exercise of the Department's statutory authority, and

4 is bad public policy. It's not the purview of the

5 Department to regulate the labor supply of persons, nor

6 is it really within realistic ability of institutions

7 or employers to predict labor markets several years in

8 advance. This would be a very imperfect science.

9 In conclusion, we believe that the current

10 approach is so flawed that the best approach would be

11 for the Department to craft a new proposed regulation

12 that adheres to the statutory framework, is based only

13 on data that is fully available to schools, and will

14 better serve students and the schools of their choice.

15 MR. PROTO: Good morning. Thank you for the

16 opportunity to speak. I'm Randy Proto, CEO of American

17 Institute. I've been involved in for-profit education

18 for 32 years. I began as a student, then a teacher,

19 then virtually every other position in the school.

20 I've worked with many types of students at

21 many types of colleges: regionally accredited,

22 nationally accredited, publicly traded, and privately
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1 held. I know our students, and I know our schools.

2 I absolutely support outcomes and other

3 disclosures that help students make sound choices. I

4 also support establishing metrics to assess every

5 program's success or failure. Create a level playing

6 field where all students get the same information and

7 all institutions meet the same outcome standards, and

8 students, taxpayers, and quality will win. As crafted,

9 Gainful Employment doesn't adequately promote this.

10 Today I'll focus on a few concerns for my comments.

11 First, it will have larger detrimental

12 effects than the Department estimates. It must be

13 changed to minimize this. Second, it shouldn't be

14 selectively applied, because it deals with issues of

15 universal concern to all students in career-oriented

16 majors. Third, if it's implemented, structural changes

17 are needed to make it more effective, safe, and fair.

18 The effect of its debt warning is one of many

19 examples of my first point. About two and a half

20 million for-profit students will be confronted only

21 with a debt warning upon implementation. This warning

22 alone will certainly deter our students. Yet the
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1 Department estimates that no students will give up on

2 college or shift to public colleges solely as a result

3 of it. That's unrealistic. I estimate that several

4 hundred thousand will be dissuaded from attending

5 college, and more will attempt to shift to public

6 colleges at higher taxpayer cost. Someone's wrong. I

7 truly hope it's me.

8 Regarding my second point, universal

9 application would make this a better rule, in part

10 because many nonprofit and public programs fail the

11 currently proposed test. So universal application

12 would force broader and more balanced community input

13 and more effective provisions. Further, more than 12

14 million students enrolled in career and technical

15 education majors at all types of colleges all expect to

16 achieve a positive return on investment from their

17 education. Taxpayers who support them expect similar

18 results. But the rule applies only to a fraction of

19 these students. They all have the right to equal

20 protection and comparable information. To meet its

21 promise, the rule should help students considering

22 schools like mine decide if incurring $13,000 of debt
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1 for a degree program with a given graduation rate and

2 given employment rate is better or worse than incurring

3 $5,000 of debt for a community college degree program

4 with a different graduation rate and a different

5 employment rate. But it won't, because it doesn't

6 apply to the community college's degree program. It

7 should.

8 Regarding my third point, structural issues,

9 first, the repayment rate counts negatively to students

10 opting for repayment plans the Department promotes,

11 like interest-only RBR. Instead, they should be

12 counted positively. Second, the debt test uses

13 individual wage data schools can't access. Schools

14 can't predictably hit an invisible target, and this

15 data allows negative and differential impacts based on

16 factors unrelated to program quality. One example:

17 women earn 20 percent less than comparably

18 employed men according to the GAO. So all else being

19 equal, programs serving higher percentages of women

20 will correspondingly be more prone to sanctions. The

21 Department should use BLS wage data for this test.

22 Also, the debt test's ten-year repayment term
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1 doesn't represent the actual repayment term students

2 choose. Instead, the test should average the actual

3 terms of students' loans to reflect graduates' true

4 debt payment burden.

5 Finally, for-profit colleges fuel the work

6 force, providing 23 percent of career and technical

7 program graduates. As crafted, Gainful Employment's

8 metrics are retroactive, threatening programs which, if

9 given the next two years, could adjust to comply. To

10 maintain needed capacity instead of wastefully

11 abandoning it, Gainful Employment's program termination

12 provisions should become effective later than its other

13 provisions, in 2014.

14 I hope my verbal and broader written comments

15 have been constructive. Thank you.

16 MS. MOODY: Good morning. I'm Sheryl Moody

17 from Anthem Education Group. I would like to thank you

18 for the opportunity to speak to you regarding comments

19 submitted by our Chairman of the Board, our Chief

20 Executive Officer, and our Chief Financial Officer.

21 My first observation is that this proposal

22 was presented as one to address student loan defaults,
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1 but then it is not based on existing data about student

2 loan defaults. If you wanted to measure student loan

3 defaults, you would use the cohort default rate.

4 Instead you have proposed new metrics. One of the new

5 metrics is the repayment calculation. As my colleague

6 has suggested, the repayment measurement counts

7 students as non-payers when they are complying with all

8 of their student loan obligations. They may be in

9 forbearance or have a deferment. They could have opted

10 for income-based repayment, or they could have

11 consolidated loans, which don't count as paid until the

12 last loan consolidated has been paid. They may be

13 paying principal first, which the law requires them to

14 do, but they would be counted as non-payers.

15 You have also proposed a measure of gainful

16 employment that is based on salaries. The problem with

17 that is that salaries reported on W-2s may not

18 accurately reflect starting salaries. If a graduate

19 lands a first job that pays $60,000 a year and begins

20 working on December 1st, that graduate reports income

21 of $5,000 for that year.

22 You also have not made clear that you will be
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1 able to measure self-employment income. More than 50

2 percent of our graduates in massage therapy are self3 employed, and they make a very good income. It's a

4 popular program. A majority of our computer networking

5 graduates are independent contractors. How will we be

6 able to provide data about that, or where will you get

7 it?

8 I'm also concerned that you have

9 misunderstood the effect of restricted programs. Mr.

10 Bergeron commented during the conference call that you

11 expected we would improve programs that fell into the

12 restricted category. With respect to Mr. Bergeron, you

13 have not presented evidence that our programs lack

14 quality. We're continually working on improving the

15 quality of our programs, but we believe they are good.

16 There is no evidence that they're not.

17 Students default for many reasons. The most

18 common predictor of defaults is that the students are

19 Pell-eligible. That means students who do not have

20 financial resources to carry them through major life

21 events that may derail their plans after they complete

22 a program. It is likely that restricted programs will
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1 not continue to be operated, but will be discontinued.

2 This will wipe out an entire option for programs such

3 as computer networking and massage therapy if the

4 repayment metrics are not accurate.

5 Restricting programs and having them

6 discontinued will result in the closure of schools.

7 Anthem Education Group operates 23 schools in 15

8 states. We have run the numbers. The fact of the

9 matter is that the schools most likely to close are

10 those serving the most economically disadvantaged

11 students. If we had to close a program at one of those

12 schools, we might very well close a school. If we

13 cannot be successful in the markets serving the most

14 disadvantaged students, neither can our competitors.

15 There will be no one to offer programs to students in

16 those demographic areas.

17 I predict that this will happen because I saw

18 the same thing happen after the enactment of the 1992

19 Higher Education Act amendments. Those amendments made

20 it difficult for schools to serve students in

21 economically disadvantaged areas, and the schools fled

22 inner cities and rural areas where they could not
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1 continue to serve students.

2 I urge you to go back and refigure this

3 approach to Title IV regulation, because the most

4 disadvantaged students are the ones who are most likely

5 not to be served. You have already heard my colleagues

6 talk about discontinuing their service to students who

7 have graduated -- who come to us with no high school

8 diploma. If these students are not served, given the

9 deplorable high school graduation rates in this

10 country, then I question whether or not this is what

11 you intended.

12 Thank you for your time.

13 MR. SWARTZWELDER: Good morning. My name is

14 Roger Swartzwelder. I'm the general counsel and Chief

15 Compliance Officer with Education Corporation of

16 America, based in Birmingham, Alabama. Thank you for

17 the opportunity to appear.

18 Let me just touch on a couple of the points

19 that I've made in my written comments, and begin my

20 respectfully asking the sort of overarching question,

21 which is whether the Department in fact does have the

22 authority to propose these Gainful Employment
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1 regulations as they've been promulgated. The

2 authorizing statute, the Higher Education Act, provides

3 that programs of study at for-profit colleges must

4 prepare students for gainful employment in a recognized

5 occupation in order to be eligible for the Title IV

6 program. These proposed regulations, which address

7 student debt loads and loan repayment rates, are not

8 reasonably founded on that statutory language.

9 Moving on to some of the specific elements in

10 the proposal, talking first about loan repayment rates,

11 as some of the other speakers have noted, the Congress

12 and the Department have created and emphasized

13 alternative loan repayment options that are designed to

14 help struggling student loan holders manage their debt

15 repayment obligations. With so many Americans

16 unemployed or underemployed, in fear of losing their

17 jobs, under water or mortgages and otherwise facing

18 economic challenges, many loan holders have taken

19 advantage of these alternative repayment options. The

20 Gainful Employment regulations unfairly count these

21 loans against the college in the loan repayment

22 calculation. I suggest that the only fair way of
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1 looking at this would be to count any loan that is in

2 good standing under the terms of the loan and the

3 requirements of the lender as a loan in repayment.

4 Moving to the question of student debt

5 levels, any assessment of the level of student debt for

6 which a college is accountable should include only the

7 debt, I suggest, that is necessary to pay the expenses

8 directly attributable to the college. Current

9 regulations allow student to borrow more, sometimes

10 considerably more, than is necessary to pay direct

11 educational costs, and colleges are explicitly

12 prohibited from limiting a student's borrowing. If

13 colleges can't control the amount of money that

14 students borrow, then I suggest they should not be

15 punished if in fact students choose to over-borrow.

16 Regarding income data, if we're going to have

17 a debt-to-income measurement, as other speakers have

18 suggested, it would seem only fair that the Department

19 use BLS or other objective aggregated data that are

20 publicly available for review. To use Social Security

21 Administration or IRS data that are not available to

22 colleges would not allow colleges to set their policies
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1 in order to comply with the regulations, because they

2 won't know the underlying data on which the application

3 of the regs would be calculated. This would not -- the

4 Social Security Administration and IRS data would not

5 necessarily capture all the income that is not

6 reported, for whatever reason, and it would not account

7 for inconsistent income when graduates enter and leave

8 the employment market for reasons that are not

9 attributable to the quality of the education they

10 received.

11 Another element that doesn't get, I think, as

12 much attention as it should is the contradictory nature

13 or the counter-purpose between the Gainful Employment

14 proposal and the 9010 regulations. We find that many

15 for-profit schools, particularly those serving low

16 income students or in areas of the country where there

17 are not state-supported financial aid programs, for

18 many of those schools adjusting tuition to account for

19 changes in Pell eligibility and loan limits is the only

20 way to remain in compliance with the 9010 regulations.

21 But the Gainful Employment regulations, in fact, would

22 work at cross-purposes to the only way of managing the
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1 9010. I would respectfully suggest that figuring out a

2 way of writing regulations so that you don't have two

3 regulations that are contradictory to one another would

4 be a very useful exercise.

5 And then finally, as other speakers have

6 noted, there is a certain element of unfairness in the

7 retroactivity that's proposed in the way the rule is

8 written. And I suggest that any rule that's based on

9 three years of data should only be made effective three

10 years after the final rule is adopted, thereby giving

11 colleges the opportunity to understand the regulations

12 and the data and to make the appropriate adjustments.

13 Thank you very much.

14 MR. NORTON: Good morning, everyone. Thank

15 you for the opportunity to speak this morning. My name

16 is Bill Norton, and I've been involved with the

17 administration of student financial aid for nearly ten

18 years. I represent a small or proprietary school that

19 is locally owned in the state of Utah, (inaudible)

20 College and Provo College.

21 Thank you for engaging in meaningful dialogue

22 with the higher education community. While the intent
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1 of the proposed rule is to protect taxpayers and

2 students, we feel the public policy does not

3 sufficiently extend its reach or penetrate the full

4 sector of higher education. By targeting all degrees

5 of proprietary schools and only certificate programs at

6 institutions of higher education, the proposed rule is

7 perceived as discriminatory.

8 Students who choose a private institution are

9 merely electing to utilize their portable federal

10 student aid entitlement at the institution of their

11 choice. By selecting a proprietary institution, many

12 are essentially paying their own way for their

13 education without overly burdening the states,

14 taxpayers, other education sectors. So while the

15 proposed rule suggests that loan defaults may be higher

16 at a proprietary institution, any associated taxpayer

17 costs after collection and recovery efforts should be

18 directly compared with the sum costs society pays in

19 the form of subsidies to public and private nonprofit

20 institutions, plus their relative portion of FSA

21 defaults.

22 Please follow the intent of Congress. Await
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1 ongoing investigations, Senate hearings, potential new

2 legislation. The definition of gainful employment

3 should be argued by Congress and included in statutory

4 law. The proposed rules are deemed to be economically

5 significant and come at an extremely inconvenient time

6 for the economy of our nation.

7 The Department has suggested that all a

8 school needs to do to comply with the debt to income

9 ratio is to reduce tuition or place graduates in jobs

10 with higher-paying salaries. In recent years, schools

11 have been unable to reduce tuition due to the 9010

12 rule. Significant increases in the Pell grant limits

13 and loan limits continue to drive up 9010 rates. So

14 Congress must consider repealing this rule to allow

15 institutions to lower tuition.

16 With the reauthorization of the Higher

17 Education Act, please remember that many proprietary

18 schools were already offering accelerated year-round

19 education. Therefore, it's unfair to criticize them of

20 consuming increased portions of year-round Pell and

21 student loan funds made available to students. During

22 the recession, the Department encouraged state
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1 workforce agencies to refer the unemployed to college

2 and also encouraged financial aid administrators to

3 exercise professional judgment when evaluating their

4 incomes.

5 Please consider that according to sub6 regulatory guidance, all institutions of higher

7 education are precluded from engaging in a practice of

8 limiting borrowing or certifying loans only needed to

9 cover direct institutional costs. Therefore, the

10 Congress and Department have taken the position that

11 students are entitled to loan proceeds pursuant to

12 statute. As such, we feel this responsibility for

13 student borrowing must be shared by the student, the

14 school, the Department, and the Congress.

15 Please allow me to cite a few remaining

16 comments.

17 Number one, the proposed phase-in timeline is

18 inappropriate, since most of the time has already

19 elapsed. The rule is retroactive and punitive. Schools

20 will be prohibited from making any necessary

21 adjustments in time.

22 Number two, since the analysis for the NPRM
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1 was conducted at the institutional level in the

2 Missouri data set, small schools may have much more

3 difficulty meeting the proposed metrics, like ours. The

4 true impact may be significantly higher than originally

5 anticipated when analyzing each school on a per-program

6 basis, with smaller number of graduates per program.

7 Three, all sectors of higher education should

8 be required to disclose graduation rates, loan

9 repayment rates, debt to income ratios. Rather than a

10 sanction for poor performers, students should be

11 presented with consumer information and be entitled to

12 make their own decisions, informed decisions, when

13 choosing any college or any university.

14 Number four, the NPRM does not adequately

15 address situations where students continue their

16 studies at higher levels of education. So if the

17 cumulative debt must be considered, a school may soon

18 have an incentive to teach only certificates and

19 diplomas, and avoid master's or bachelor's programs. So

20 we suggest, please allow schools to isolate debt at

21 each level of education where the regulations will have

22 significant unintended consequences.
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1 Five, the proposed regulations are most

2 likely going to affect a disproportionate share of Pell

3 grant recipients, low income students, minorities,

4 first time college attendees, and single parents.

5 These students are more likely to attend a proprietary

6 institution for the smaller class sizes, for job7 specific training, personal support, and a caring

8 environment.

9 Lastly, an entire school should not be placed

10 upon provisional certification due to the failure of a

11 single program's compliance with the gainful employment

12 calculation as proposed. Institutions must be afforded

13 the opportunity to remedy the situation without facing

14 extreme sanctions such as limiting the organization's

15 ability to achieve recertification, add new programs,

16 or increase enrollments.

17 In conclusion, please remember that

18 proprietary institutions have a vested interest in the

19 long-term success of their graduates. It would be very

20 difficult to enroll future students if the college had

21 a reputation for poor performance or poor measurable

22 outcomes. To assume that for-profit institutions do
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1 not bear any of the future financial risk is a

2 misstatement of private enterprise. Schools provide

3 entrance loan counseling, default management, and

4 personal finance at their own expense.

5 Together we can provide additional

6 disclosures to students, meaningful measurements of

7 outcomes, and the quality of education students

8 deserve.

9 Thank you again for your time.

10 MR. DRAGER: Good morning, and thank you for

11 the opportunity to speak today. I appreciate the

12 Department's willingness to take the necessary time to

13 fully examine these regulations.

14 My name is Justin Drager. I'm from the

15 National Association of Student Financial Aid

16 Administrators. We represent more than 18,000 aid

17 administrators at some 2,800 colleges and universities

18 around the country. And my members live in the realm

19 of regulatory implementation, and that's where I'd like

20 to focus my remarks today.

21 We don't challenge the concepts behind what's

22 being proposed by the Department. We believe that we
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1 should be measuring to ensure that programs lead to

2 gainful employment. But I think we want to move

3 forward with an eye towards careful implementation that

4 avoids any unintended consequences. And specifically,

5 we're looking at using -- asking the Department to use

6 existing measures of workforce placement, student loan

7 indebtedness, and successful loan repayment before

8 implementing new, untested measures. In our comments

9 dated September 9th, we suggested a hierarchal approach

10 to this using existing criteria that would act as

11 filters.

12 So first: Apply exemptions for programs with

13 few borrowers and low average indebtedness. So if a

14 program has few borrowers, and a low percentage of

15 those borrowers have low average indebtedness, in our

16 minds no further action would be required. As

17 currently proposed, the rules would treat low-cost

18 programs with few borrowers the same as higher-costing

19 programs with many borrowers that are likely borrowing

20 much more on average. And without making this

21 important distinction up front, students attending very

22 dissimilarly priced programs would end up receiving the
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1 exact same warnings. And I don't think that's the

2 intent.

3 Second: Use existing regulatory requirements

4 for completion and placement rates. Currently, short

5 loan-only training programs, programs that are well

6 under a full academic year in length, are already

7 subject to minimal completion and placement rates.

8 These are defined in federal regulations. And under

9 those regulations, those short certificate programs

10 have to have completion and placement rates of over --

11 of at least 70 percent.

12 Third: Look at using cohort default rate

13 measures, but applied to programs. Cohort default

14 rates already apply to institutions, not individual

15 programs. But in the upcoming years, the cohort

16 default rate will apply -- will capture three years

17 worth of data, not two, which will give us, I think, a

18 more accurate depiction of how well students are

19 managing their student loan debt. The benefits of

20 using the cohort default rate is that first, it already

21 takes into account low borrower participation. There

22 are exemptions already in cohort default rates for
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1 that. And second, it allows schools to verify and

2 challenge data provided by the Department, something

3 that's not awarded -- afforded to schools under the

4 proposed rule.

5 The other part of the proposed rule that's

6 taken into account with cohort default rates is under

7 the proposed rule, only a reduction in principal is

8 used as the primary measure of successful student loan

9 repayment. I think we -- our belief is, is that all

10 loans in deferment or in a valid, statutorily

11 recognized repayment plan, even if principal is not

12 being reduced, should be included in successful student

13 loan repayment. In fact, I think we have to be careful

14 that we don't introduce a perverse incentive where

15 schools would be counseling students away from the very

16 programs that we partnered with the Administration on

17 implementing, like income-based repayment.

18 I think it's also inequitable and

19 inconsistent to hold these safeguards out as viable

20 loan management tools for students who become sick,

21 disabled, decide to serve in the Peace Corps or other

22 volunteer opportunities, or simply choose not to work
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1 because of family obligations, but then another set of

2 regulations that hold them out as unviable options.

3 So in short, it's using existing completion,

4 placement, and cohort default, perhaps with different

5 thresholds, on a program-by-program basis as starting

6 points so we an ensure that students are being treated

7 fairly. And if a program doesn't meet any of those

8 existing data requirements, then it may be appropriate

9 to look at using debt-to-income and repayment

10 calculations. And I would refer you to our September

11 9th comment, where we raise several implementation

12 questions that we think have to be clarified in order

13 for proper implementation.

14 Thank you for the opportunity to speak today.

15 The only other part that I would focus on from our

16 comment is a suggestion that the Department look at

17 implementing an interim final rule that would implement

18 the regulations, but allow for additional comments, so

19 we can ensure that it goes forward correctly.

20 Thank you.

21 MS. PEOPLES: Good morning, everyone. My

22 name is Angela Peoples. I am the Policy and Advocacy
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1 Manager at Campus Progress, and I thank you all for

2 this opportunity to be here.

3 Campus Progress is the youth division of the

4 Center for American Progress, a non-partisan, nonprofit

5 progressive organization. Campus Progress advocates

6 with and for young people on a wide range of issues,

7 including immigration reform, climate change, LTBTQ

8 equality, and of course college affordability.

9 I appreciate the opportunity to address you

10 all today on the equal employment regulations. It is

11 our belief that an effective rule in this area is

12 critical to ensure that students have a chance to

13 receive a quality education at a reasonable cost; have

14 the opportunity to advance in their careers and be

15 successful if they so choose; and then also that they

16 are not overwhelmed with the certainty of unpayable

17 debt.

18 I served as an alternate negotiator in this

19 round of negotiated rulemaking on the issues of program

20 integrity. As a very passionate student advocate, I

21 was very pleased to see the efforts of the Department

22 of Education and my fellow negotiators to find
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1 solutions on a number of troubling issues plaguing

2 students at many institutions of higher education.

3 While I believe, and still do, that

4 educational institutions, all institutions, must act

5 with integrity and in the best interests of students, I

6 could not avoid the conclusion that the egregious

7 examples of misconduct took place at for-profit

8 institutions. After the negotiations ended, Campus

9 Progress became part of a broad coalition urging the

10 Department to continue the work of the negotiators and

11 propose a strong and effective regulatory definition of

12 gainful employment. As a member of the coalition,

13 Campus Progress submitted comments in response to the

14 Department's proposed definition.

15 Our comments overall express an appreciation

16 of the Department's proposed regulations. However,

17 there are a few areas where we believe the Department

18 can improve. And I will speak to a few of those today.

19 One: In terms of repayment standards, we

20 believe that the rate needs to be higher. Right now,

21 the current regulation sends a wrong message that the

22 highest bar set by the Department of Education would
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1 allow that more than half of students coming out of a

2 program would not be paying down their loans. And we

3 recommend that the repayment threshold be increased by

4 ten percent.

5 Another area is in the treatment of

6 delinquent borrowers and in the repayment calculation.

7 Borrowers who are in default and forbearance or

8 economic deferment are not the only ones that are

9 struggling, and we believe that delinquent borrowers

10 should also be excluded from the repayment rate.

11 Keeping them in the repayment numerator will give

12 institutions no reason to support them to move out of

13 that delinquent status.

14 Finally, in the discretionary income metrics,

15 we believe that there are a number of ways to improve

16 them, number one, using a single 20 percent debt to

17 discretionary income threshold to more accurately

18 reflect the real debt burden of families.

19 And then finally, we believe that it is

20 inappropriate to assume the discretionary income of a

21 single person when the reality is that most students at

22 for-profit institutions have one or more dependents. We
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1 believe that there are a number of ways, which are

2 specified in our comments, to clarify the definition of

3 discretionary debt to discretionary income.

4 In conclusion, I'd just like to speak very

5 broadly to a couple of the themes within our comments.

6 Number one, we believe that this definition is designed

7 to improve college access and will do that. Right now,

8 the definition will allow for higher education

9 institutions to be protected -- to protect vulnerable

10 students and taxpayers. We think that this will allow

11 good programs to make the adjustment and to rise and to

12 expand, and then poor performing programs will be

13 encouraged to make adjustments that are necessary and

14 better serve those students.

15 The second is that we are not concerned that

16 this will decrease access, because this will only,

17 again, apply to programs not threatening to the closing

18 of schools, and again, having a strong definition will

19 give programs guidance on ways to make adjustments.

20 And then finally, we just want to reiterate

21 that we recognize that this reg applies to all schools,

22 not just for-profit schools. And in fact, it will
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1 apply to more public schools, which we think is

2 consistent with the statute and very appropriate.

3 Campus Progress strongly urges the Department

4 to move ahead with the Gainful Employment regulation

5 without delay before more Americans are signed up for

6 educational programs that sound great when they're

7 pitched to them by recruiters, and then they end up

8 with low educational value and low career value or

9 prospect of paying back their loans. We believe that

10 there are thousands of solid programs where students

11 can obtain knowledge and develop the skills that they

12 need to have promising careers, and our scarce federal

13 resources must go to supporting those programs, whether

14 they are at nonprofit or for-profit institutions.

15 Thank you very much for this opportunity.

16 MR. KASSA: Good morning. My name is

17 Getachew Kassa. I'm with the United States Student

18 Association. We are the country's oldest and largest

19 student-led, student-run national organization

20 advocating for access and affordability in

21 postsecondary education. We are part of a broad

22 coalition of advocates for students, consumers, higher
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1 education, civil rights, and college access that

2 support a strong definition for gainful employment.

3 The proposed rules will help protect students and

4 taxpayers from programs that routinely saddle students

5 with debts they can't repay and degrees they can't use.

6 USSA, along with our coalition partners,

7 submitted joint comments. Today I will limit my

8 comments to ineligible programs. Under the proposed

9 rules -- under the proposed regulations, specifically

10 ineligible programs, programs unable to meet basic

11 repayment rate thresholds and neither debt to income

12 measures will be found ineligible by the Department.

13 However, under the proposed programs, regulations will

14 be permitted to continue -- programs will be permitted

15 to continue to enroll students for up to two additional

16 years. We understand this additional time is balance

17 the mistreatment of students with students having the

18 opportunity to finish their programs. However, it is

19 our position that the regulations need to be

20 strengthened to adequately support students.

21 As we worked through the commenting process,

22 questions arose about how or when enrolled students in
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1 ineligible programs will be notified that the program

2 is ineligible and its consequences. It is critically

3 important that students who are enrolled in ineligible

4 programs be notified and understand the Department's

5 findings. We propose that enrolled students should be

6 provided such information within 30 days of the

7 Department's notification of the institution. We

8 strongly recommend that the Department notify students

9 directly so that the information provided to students

10 is standardized and not altered, softened, or qualified

11 by the institution losing the ineligible program or its

12 ineligibility.

13 Additionally, enrolled students who are

14 unable to choose not to complete their program for the

15 remaining period the period is eligible or those who

16 are unable to choose not to transfer to an alternative

17 program within the same institution should not be

18 accountable for their federal student loans incurred in

19 attending that program. Furthermore, the federal

20 student loan debts incurred to attend that program

21 subsequently deemed ineligible under this regulation

22 should be discharged. This is an important
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1 counterbalance to the additional years of Title IV

2 eligibility after the program is deemed ineligible.

3 Under the proposal, students have a choice to continue

4 with an ineligible program, or on the other hand,

5 students who question the value of attending the

6 program have the ability to remove themselves from the

7 program. They should do this without penalty or debts

8 that were incurred in that program.

9 Students enrolled in an ineligible program

10 will be saddled with debt, at a higher risk for

11 default, and as a consequence, these same students will

12 be at a higher risk to lose eligibility for future

13 loans, depriving them of the education they seek.

14 Lastly, the Department has the authority to

15 compromise loans, and we further urge the Department to

16 seek reimbursement from institutions for discharge

17 grants to borrowers for federal programs and any other

18 loans that were given to the students.

19 So basically, to summarize all this, if I am

20 a student and I am in a program that's found

21 ineligible, I want my Department of Education to notify

22 me and let me know that the program is ineligible and
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1 the consequences and the options that I as a student

2 have. At the same time, if I take out student loans or

3 other federal aid loans, I would hope that the

4 Department of Ed would discharge those loans and

5 forgive me for those loans because the program was

6 found ineligible.

7 Thank you for this opportunity.

8 MR. BERGERON: We're going to take a five9 minute break, I guess. Thank you.

10 MR. OCHOA: Okay. Good morning, everybody.

11 We're having a slight change of the guard here. I'm

12 Eduardo Ochoa. I'm with the Office of Postsecondary

13 Education. And this is Jennifer Woodward with the

14 Office of General Counsel. And continuing is David

15 Bergeron, also from the Office of Postsecondary

16 Education.

17 MR. WILLIAMS: Good morning. My name's Rich

18 Williams, higher education advocate at U.S. PIRG, the

19 United States Public Interest Research Group. We're a

20 network of state public interest advocacy

21 organizations, including the Higher Education Project,

22 which represents hundreds of thousands of students on
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1 hundreds of college campuses across the country,

2 primarily working to decrease the amount of student

3 loan debt students are leaving college with.

4 I want to thank the Department of Education

5 for the opportunity to speak today, but also for the

6 opportunity to serve as a negotiator in crafting

7 program integrity rules, not only for gainful

8 employment, but many other issues, as well.

9 As part of a negotiator within the

10 negotiations, both myself and Angela Peoples ask

11 Secretary Duncan and the Department of Education,

12 particularly with Gainful Employment, to craft a rule

13 that specifically takes in account the level of student

14 debt that graduates incur when leaving their programs.

15 We have seen tremendous increases in student debt

16 levels across the country, and it has profound impacts

17 on graduates' lives. We are seeing now across the

18 board students graduating with %24,000 worth of debt,

19 and that number is even higher when you look at for20 profit colleges, which are now higher than $33,000.

21 Specifically, there are several programs

22 across this country which have been under-serving
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1 students, and we would like to work with the Department

2 and try to -- to try to narrow those down. We'd like

3 to thank the Department for including in their

4 framework specific areas such as including debt from

5 all affiliated schools within the metrics; including

6 private student loans; avoiding loopholes for colleges

7 with higher borrowing but poorer outcomes, such as

8 looking at completers only; and using independently

9 verified data. We thank you for addressing our

10 concerns within the framework that's put forward.

11 Within my comments, I want to look at two

12 specific areas, and that's looking at why it's so

13 critical that MORE(ph) goes into effect before Gainful

14 Employment is implemented to protect students and

15 taxpayers, and why it's so critical that restricted

16 programs are forced to improve rather than stay

17 restricted forever.

18 So disclosures and placement for completion

19 rates are not enough. There's been recent stories by a

20 Texas news station which is looking at an institution

21 within their state which was falsifying graduation rate

22 -- placement rates, where the school was quoted as
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1 saying a 70 percent placement rate, rather than its

2 actual 40 percent placement rate. It also has a 17

3 percent repayment rate; a two-year cohort default rate

4 of 26 percent; and a three-year cohort default rate of

5 37 percent. In a new set of stories just in the past

6 few days, they documented cases of schools recruiting

7 felons to train in their programs for programs that

8 they'd never be able to use because of their felon

9 status, and also giving bonuses to recruiters to make

10 students break down and cry.

11 For schools like these, it's simply not

12 enough to report unreliable placement and graduation

13 rates until Gainful Employment metrics go in effect in

14 2012. The Department of Education should take whatever

15 administrative enforcement measures it can immediately,

16 rather than waiting for the Gainful Employment metrics

17 to go in effect in 2012.

18 Also, it's important to make sure that

19 restricted programs improve, rather than stay in

20 restricted forever. We think that it is a right thing

21 to include debt disclosures and warnings and also limit

22 enrollment for programs based on the previous three
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1 years of enrollment. But that, as well, does not go

2 far enough. We are giving a lifetime pass to many of

3 these programs. There's an old saying that C's get

4 degrees for students. But many programs now have basic

5 requirements for students to graduate, like getting a B

6 or better. Within the proposed rules, we are allowing

7 programs which could be qualified as a D to continue

8 giving degrees.

9 We have two concerns: large programs which

10 enroll thousands of students, even though they'll have

11 an enrollment cap, will still be able to enroll

12 thousands of newly Title IV-eligible students each and

13 every year. We also think that programs that rely on

14 G.I. benefits -- eight of the ten top G.I. benefiting

15 schools are for-profit schools. Just because you can

16 change your enrollment strategies doesn't mean that you

17 should avoid regulation. I would think these should be

18 improved.

19 Thank you for the opportunity to speak, and

20 thank you for moving forward with this rule on gainful

21 employment rules.

22 MR. OCHOA: Next speaker, please.
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1 MR. SPONSELLER: My name's Tom Sponseller.

2 I'm President and CEO of the South Carolina Hospitality

3 Association, speaking on behalf of employers, and the

4 first to do so this morning.

5 Giving you a little background, the South

6 Carolina Hospitality Association is the leading

7 business trade association for the restaurant, food

8 service, and lodging industry in our state. Our

9 mission is to help our members in the industry

10 establish customer loyalty, build rewarding careers,

11 achieve financial success. In our state, small as it

12 is, we have over 8,000 restaurant and food service

13 outlets, employing over 200,000 people. Despite being

14 an industry of predominantly small businesses, the

15 restaurant industry is the nation's second-largest

16 private sector employer.

17 The restaurant and food service industry are

18 unique, for several reasons. First and foremost, small

19 businesses dominate the industry, with more than seven

20 out of ten eating and drinking establishments being

21 single unit operators. Our work force is typically

22 young, with nearly half under the age of 25. In
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1 addition, the industry operates under relatively low

2 profit margins of four to six percent before taxes,

3 with labor costs being one of the most significant line

4 items for the restaurant. Just in our state, we're a

5 $6 billion industry.

6 We appreciate the opportunity to be here

7 today in opposition to the Gainful Employment proposed

8 rule to amend the student assistance general provisions

9 by setting new debt to income standards that would

10 determine whether students in certain postsecondary

11 educational programs remain eligible to obtain student

12 financial assistance under Title IV of the Higher

13 Education Act of 1965. We agree with the suggestion

14 that if students were able to complete their education

15 with no student loan debt, more of their subsequent

16 income could be devoted to home purchases, retirement

17 savings, or serving the community. However, the

18 availability of federal student not only increases the

19 likelihood of a student that will enroll in an

20 institution of higher education, but may also be the

21 only way the student will be able to afford higher

22 education that could lead to his dream career. As a
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1 parent of three students that are still paying back

2 federal loans to public institutions, I can attest to

3 the fact that a lot of kids could not go to school

4 without federal student loans.

5 The restaurant and food service industry

6 needs culinary arts programs at proprietary

7 institutions to held provide postsecondary training for

8 our workforce. In South Carolina, our association has

9 an educational foundation we'd established ten years

10 ago. We did it to address workforce development issues

11 and to encourage high school students to consider the

12 hospitality industry as a career choice. In that short

13 period of time, we brought the National Restaurant

14 Association's Pro-Start Culinary Arts Restaurant

15 Management Program to our state and are now serving

16 over 70 public high schools and over 3,000 high school

17 juniors and seniors who want to make the restaurant

18 industry a career. We also as an association provide

19 thousands of dollars of scholarships as students from

20 these programs are going on to postsecondary for their

21 degrees in either culinary arts or

22 hotel/restaurant/tourism management. A large
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1 percentage of those students are looking to attend

2 culinary schools to fine-tune their knowledge and

3 education in hopes of becoming a chef, a restaurant

4 owner, or even maybe becoming the next Food Network

5 star.

6 In our state, there are only four

7 postsecondary culinary arts degree programs, three of

8 which are at state-supported two-year technical

9 colleges and one at the Art Institute of Charleston.

10 Only the international culinary school at the Art

11 Institute of Charleston offers a bachelor of science, a

12 four-year degree, in culinary arts.

13 Over the next seven years, we anticipate over

14 46,000 new jobs will be created in South Carolina's

15 restaurant industry, and across all job categories.

16 Restaurant and food service workers who obtain

17 postsecondary culinary training can earn a lot more

18 than those without the formal training in their

19 occupation. The proposed rule ignores real-life

20 successes. Graduates of the international culinary

21 schools at the Art Institute, with more than 12,000

22 students currently enrolled, will earn significantly
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1 above the Bureau of Labor Statistics salary projections

2 in culinary arts. For example, the average starting

3 salary for individuals graduating from the Art

4 Institute in culinary is $28,000, while the salary

5 projection for the 25th percentile by the Bureau of

6 Labor Statistics used by the proposed rules for its

7 determination is just $19,319.

8 The Art Institute in Charleston was created -

9 - was recruited by the City of Charleston, its mayor,

10 and the business community to fill a void when another

11 nonprofit four-year culinary institution announced in

12 2002 that they were leaving our state to go to North

13 Carolina. They opened in April 2007, just three and a

14 half years ago, and they've got over 800 students

15 already. Obviously, the proposed rule could create a

16 void where that college might have to consolidate, and

17 our state would have no four-year postsecondary.

18 Thanks very much for your time.

19 MR. OCHOA: Thank you. Next speaker?

20 MR. HINCHLIFFE: Thank you. My name is John

21 Hinchliffe. I represent the Nevada Restaurant

22 Association. I am the immediate Past President. I
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1 have 25 years in the restaurant industry.

2 The Nevada Restaurant Association provides a

3 number of services, mostly importantly the Nevada Pro4 Start, which helps education in partnership with high

5 schools to educate younger people and draw them into

6 our industry, as well as ServSafe certification, which

7 is a certification provided -- recognized by most of

8 the country and most municipalities to protect the food

9 product, to ensure that nobody's getting sick from food

10 borne illnesses.

11 When I was 17 I got my first restaurant job,

12 and it was as a dishwasher. The most complicated piece

13 of machinery in the restaurant was the dishwasher. Five

14 years later when I graduated from college, I worked in

15 a restaurant that wanted to make sure that I told

16 everybody, "We don't have any microwaves." Technology

17 in that five years had changed dramatically. It has

18 changed dramatically since then to now. Las

19 Vegas is the culinary capital of the world.

20 We serve hundreds of thousands of meals every day:

21 breakfast, lunch, dinner, late dinner. We serve

22 gourmet meals for four; we serve banquets for 2,000
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1 where everything goes down at the same time. We can't

2 afford to have anyone dying because of a food borne

3 illness. And we get our food from around the world.

4 The food industry has become very, very complicated,

5 and it requires education.

6 Unfortunately, in Nevada, our higher

7 educational system cannot meet this demand. We have

8 excellent schools. We have UNLV; we have the Community

9 College of Southern Nevada; we have the University of

10 Nevada at Henderson. But they cannot meet the demand

11 our industry has. Arts Institute has stepped in. It

12 graduates hundreds of students every year. They do it

13 very well, and they work in our industry.

14 Unfortunately, they don't always make, in a highly

15 competitive industry, what one would expect from a

16 four-year institution. It's highly competitive. On

17 the other hand, over the years they do reach that

18 goal.

19 We oppose the Gainful Employment issues, but

20 if we're going to use them, the rules should use the

21 higher Bureau of Labor statistics or of actual earnings

22 in debt to income tests. The rule should use a 15-year
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1 repayment schedule. It more accurately reflects the

2 realities of what happens. The rule should be phased

3 in to commence no sooner than 20154. We have hundreds

4 of students currently enrolled in culinary programs

5 across the state. They shouldn't be punished because

6 we decided to change the rules right now. And the rule

7 should excuse graduate programs. I understand the

8 Department of Education is protecting students. We all

9 want to protect our students. But the fact is, is that

10 these rules could impose a great burden, not only on

11 the city of Las Vegas, but on the state of Nevada, on

12 an entire industry that we quite frankly can't afford

13 today. We need those students.

14 Thank you for your time.

15 MR. OCHOA: Next speaker, please.

16 MS. POLLASTRINI: Good morning. My name is

17 Laura Pollastrini. I'm the Government and Public

18 Relations Manager at Northwestern College, which is a

19 family-owned and operated for-profit institution of

20 higher education that serves approximately 2,100

21 students on three campuses in the Chicago-land area in

22 Illinois.
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1 These proposed rules, we believe, will

2 unjustly disenfranchise the non-traditional students,

3 such as the older students who tend to balance jobs and

4 families, many a single parent household, and a greater

5 number of minority students. The Department has seen a

6 problem here and is unfairly throwing all the schools

7 into just one big pot. I'm urging the Department to

8 withdraw its rules and instead specifically address the

9 problems that it sees and where it seems them, instead

10 of victimizing all students in one big pot.

11 Now, the Department has painted all for12 profits with a single brush, which is discriminatory at

13 best, and at worst, it's detrimental to the very

14 students that the Higher Educational Act was intended

15 to benefit the most, which was low income and minority

16 students. So this rule will take away a student's

17 freedom of choice. In essence, the Department will now

18 be dictating to low income and minority students where

19 they can go, what careers they can pursue, or whether

20 to pursue a career college at all.

21 Now, President Obama's goal is to return the

22 United States to the highest proportion of college
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1 grads internationally by 2020. And I believe that

2 rather than helping to meet this goal, the Department

3 is putting up this colossal roadblock to it. If for4 profits are closed or programs are slashed, students

5 such as Northwestern College students have nowhere else

6 to go. Public and community college budgets have been

7 slashed repeatedly over the last few years. Class

8 sizes are growing, and the programs are being

9 eliminated. So fewer and fewer students are being

10 welcomed into these programs, and those that are are

11 being put on waitlists, not only for their classes, but

12 for the programs that they're interested in.

13 Now, some say that those students can just go

14 across the street if a program is closed or a college

15 is closed. But that's not the case, because for-profit

16 schools tend to be neighborhood schools. They're easy

17 to get to for classes, and if a school is closed or a

18 program eliminated, that student might have to take a

19 subway and two buses to find a similar program to give

20 them what they need. But that five-minute original

21 commute now becomes 45 minutes to an hour. It's harder

22 to coordinate their schedules around their children's
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1 schedules, and it's hard to make class on time after a

2 shift at work in the neighborhood. So in essence it's

3 taking away college from those low income and minority

4 populations, because they just won't go.

5 Now, with respect to the proposed rules, I

6 believe the Department has exceeded its statutory

7 authority, because in essence it's attempting to create

8 eligibility rules. However, only the U.S. Congress can

9 do that.

10 Also, the Department has exceeded its

11 statutory authority by proposing to redefine gainful

12 employment, which the Congress on multiple occasions

13 has chosen not to do.

14 Now, the new metric that you are proposing

15 has some flaws in it. And for an example, it is based

16 on factors not under the control of for-profits. Loan

17 repayment information and income data uses Social

18 Security reported earnings to calculate this metric,

19 and that's -- educational institutions are not privy to

20 that data. So without that data, there's no way to

21 determine the need to reassess a program or to seek

22 alterations in order to better comply with it. So
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1 consequently, institutions will only learn that a

2 program has failed the Department's test after it has

3 failed the complicated metrics.

4 Additionally, to remain in compliance,

5 schools and their programs will be judged on graduates'

6 salaries earned the first two years of employment. But

7 a college degree is for a lifetime of earnings, and no

8 one enters into that world making their highest

9 salaries those first few years. Thus, this incomplete

10 and skewed salary data can lead the Department to

11 deeming an institution non-compliant, for per the

12 proposed rules if a single program is out of compliance

13 with the complicated metric, that entire institution

14 can be placed on provisional certification. And that

15 limits the institution's ability to add new or

16 replacement programs and to increase enrollments.

17 Student debt, I agree, it's out of control.

18 But the college students are adults, and they take on

19 debt by choice, as well all do. They can vote; they

20 can go to war; they can sign leases for apartments;

21 they can buy cars. That many choose to take on more

22 than tuition costs and use those funds for
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1 transportation and other living expenses, the amount of

2 debt is their choice. Educational institutions have no

3 control over the amount of the loans taken. We can

4 counsel them, but the ultimate choice as to whether to

5 borrow and at what amount is the student's.

6 So based on all this, I respectfully request

7 the Department to withdraw its Gainful Employment

8 proposed rule until it has reexamined its potential

9 negative ramifications and unintended consequences. The

10 harm that will result if this proposed rule goes into

11 effect will touch the lives of hundreds of thousands of

12 students, graduates, employees, and employers at a time

13 in our history when it will be extremely detrimental.

14 Thank you for your consideration.

15 MR. OCHOA: Next speaker, please.

16 MR. MAZZA: Good morning. My name is Paul

17 Mazza. With me is my wife, Marilyn, a mother of six,

18 grandmother of 15. We live and work in State College,

19 Pennsylvania. We are the founders of South Hill School

20 of Business and Technology. I graduated from the

21 University of Notre Dame in 1952 with a degree in

22 accounting when they knew how to play football. I
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1 graduated from the Harvard Law School in 1955; Mrs.

2 Mazza graduated from Bates College in Maine in 1949,

3 and I've practiced law in State College since 1956.

4 In 1970, we were asked to start a job

5 training school, because young women in the State

6 College area had no alternatives except either to go to

7 Penn State or to become waitresses or retail

8 salesclerks. That did not seem good enough to us.

9 We presented our first classes in January of

10 1971. We decided to make it so tough that those who

11 survived it would be walking advertisements for this

12 little school. Eleven started; seven survived. They

13 did just what we had hoped. We now offer 16 different

14 programs in four different little towns for two-year

15 degree studies. Since 1971, we have graduated 6,200

16 students. The Pennsylvania State University employs 30

17 percent of our graduates historically over the past 40

18 years. Mrs. Mazza was the director of the school for

19 35 years. She ran it as a mother would run a family.

20 She treated every student as if that student were one

21 of her children. She introduced a culture that we

22 don't think we'll ever change.
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1 Secretary Duncan was quoted as saying, These

2 new rules will help ensure that students are getting

3 from schools what they pay for: solid preparation for

4 a good-paying job. Some bad actors are saddling

5 students with debt they cannot afford in exchange for

6 degrees and certificates they cannot use. These

7 schools and their investors benefit from billions of

8 dollars in taxpayer subsidies, and in return, taxpayers

9 have a right to know that they are serving students

10 well.

11 On this coming Saturday I will be 80 years

12 old. And I'm not making small talk when I say, I do

13 not have time to beat around the bush. We have yet to

14 receive our first dollar from any public entity of any

15 kind in any place -- not federal, not state, and not

16 local. We are not the people he's talking about

17 Furthermore, if these regulations work, let's see how

18 they work on two real people. Assume a young man in

19 State College who doesn't want to go to college. He

20 comes to our school. He gets a two-year degree. He is

21 hired by Penn State because he knows how to work. If he

22 borrows a lot of money -- we have a tuition of $13,000
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1 a year -- we have 25 hours a week in the classroom.

2 We're expected to produce 5,800 hours of classroom

3 hours. We produce 1,900. He knows how to work.

4 His good friend next door wants to go to

5 college. He picks Go To College University. He pays

6 $30,000 a year in tuition. He graduates. He is hired

7 by the same Penn State department, as he can't find a

8 job anywhere else, and he doesn't know how to work. He

9 has now four years of $30,000 a year, $120,000 of debt.

10 He has no job except the one he just got. He gets

11 fired from the job because he doesn't know how to do

12 it.

13 And now, Mr. Duncan, I'm saying, How does

14 this gainful employment system work? Who is it for?

15 I'm finished. The red light says I'm

16 finished. I have a lifetime more to say. Thank you.

17 MR. OCHOA: Thank you very much.

18 Next speaker, please.

19 MS. JONES: Good morning. My name is

20 Kimberly Jones, and I am the Associate Vice President

21 for Public Policy at the Council for Opportunity in

22 Education. And I wish to share the comments submitted
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1 by our president, Dr. Arnold Mitchum.

2 On behalf of the board of directors of the

3 Council for Opportunity in Education, I write in

4 response to respect to the recent safeguards issued by

5 the Department of Education on the for-profit sector to

6 protect low income and first generation students and

7 learners with disabilities. As the only higher

8 education organization with a mission to advance and

9 defend the ideal of equal opportunity in postsecondary

10 education, COE commends Secretary Duncan and the U.S.

11 Department of Education for proposing necessary steps

12 to ensure that disadvantaged students are protected

13 from accruing unmanageable debt and a dearth of

14 employment opportunities upon receipt of their

15 certificates or degrees.

16 Career colleges in the for-profit education

17 sector target low income and first generation students

18 to attend their schools, promising flexible hours and a

19 job-friendly curriculum. However, as we have seen time

20 and time again, many students enter these institutions

21 without guidance on financial aid and are subject to

22 the unsavory and unfair recruiting tactics of these
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1 institutions. These students start their higher

2 education dreams with high aspirations, but under false

3 pretenses. Unfortunately, many of them are left with

4 no viable career options and mountains of debt.

5 The data on for-profit institutions and the

6 cost of tuition and default rates is extremely alarming

7 as it relates to low income students. According to a

8 recent study by the College Board, in 2009-2010, the

9 average for-profit institution charged $14,174 in

10 tuition and fees, while the average community college

11 charged only $2,544. In addition, recent data provided

12 by the Department of Education show that 93 of the 100

13 postsecondary institutions with a default rate of 30

14 percent or more in 2006 and 2007 were for-profit

15 institutions, the same institutions targeting

16 disadvantaged students without the knowledge and

17 support systems to make sound decisions.

18 While setting necessary and important

19 safeguards for career colleges in the for-profit sector

20 through measures like Gainful Employment is

21 commendable, that alone cannot solve the problem.

22 Programs like TRIO's Town Search and Education
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1 Opportunity Centers are necessary to ensure that

2 students are making sound decisions regarding higher

3 education. These programs provide financial aid

4 counseling where participants receive information about

5 admissions requirements, scholarships, facts of

6 completion, and various student financial aid programs.

7 On behalf of all low income students and

8 families, COE thanks the Department of Education for

9 taking the necessary steps to prevent fraud and abuse

10 in the for-profit higher education sector and

11 protecting students as they enter in and complete their

12 postsecondary education.

13 We look forward to working with this

14 Administration on means to further promote educational

15 access and achievement for low income and first

16 generation students in TRIO and beyond.

17 With the balance of my time, I just wish to

18 respond to some of the concerns about many of the

19 institutions here in their discussions of low income

20 students and students of color. The Council really

21 encourages the Department to think about low income

22 students and first generation students and students of
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1 color and where they end up and why, and what happens

2 to them once they're there. What we do know is that

3 about 50 percent of students enrolled at for-profits

4 are Pell grant recipients, more than any other type of

5 institution. We know that for-profits serve only six

6 percent of all undergraduates, yet 20 percent of all

7 those receiving Pell grants. And we know that of the

8 top 20 institutions receiving Pell grant funding, 80

9 percent of them are for-profit institutions. So given

10 their low enrollment rate of all undergraduates, it's

11 very alarming that they in fact account for 25 percent

12 for all student financial aid and 44 percent of all

13 federal student loan defaults.

14 We thank you for this opportunity and look

15 forward to working with you.

16 MR. OCHOA: Thank you.

17 MS. HERRON: Thank you for permitting me to

18 share my opposition to the Gainful Employment metric

19 today. My name is Elizabeth Keifer Herron. I'm the

20 Executive Vice President and Compliance Officer for the

21 Postsecondary Education Assistance Corporation. Our

22 company has been serving students and postsecondary
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1 institutions in the areas of admissions, retention,

2 student loan repayment, and indebtedness counseling and

3 following up on loan repayment rights and default

4 prevention initiatives for more than 20 years. We

5 serve hundreds of thousands of students each year and

6 provide services to hundreds of proprietary

7 institutions each year.

8 The Department of Ed has cited abuse in the

9 private school sector has the rationale for publishing

10 this regulation. But the broad-brush approach proposed

11 in the July NPRM will impact hundreds of institutions

12 and thousands of students where absolutely no abuse has

13 been identified. While I appreciate that the

14 Department of Ed is responding to abuses identified in

15 a small number of institutions, this proposed

16 regulation has gone too far. It has gone beyond

17 statutory authority.

18 A better approach may be to enforce existing

19 regulations that the Department of Education already

20 has regarding admissions, information dissemination,

21 disclosure, rather than creating a burdensome and

22 costly regulatory framework.
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1 The metrics proposed are retroactive in

2 nature, taking a snapshot for the repayment and the

3 debt to income ratios, even if we delay the effective

4 date, that are still many years beyond what anyone

5 could have an impact on. The first cohorts of students

6 who will be measured by these regulations were

7 recruited, admitted, trained, certified for student

8 loans, graduated and helped to find jobs before this

9 regulation will even be in effect. The NPRM exceeds

10 statutory authority to define institutions providing

11 gainful employment in a recognized occupation and

12 establishes a complex regulatory framework that will be

13 difficult to establish, maintain, and enforce. The

14 same regulatory framework will cost institutions and

15 taxpayers, via the new tracking and reporting, untold

16 quantities of scarce resources at a time when we should

17 be investing in the nation's educational requirements,

18 rather than combating them.

19 In addition, the regulation seeks to

20 incorporate the Department of Education into the

21 authorization and review process for programs by in

22 essence creating programmatic eligibility, which is
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1 also beyond statutory authority. By creating

2 restrictions and sanctions by program, the Department

3 of Ed is proposing to use the metric to evaluate

4 quality, which it is in no position to do. What this

5 proposed metric will do is evaluate the socioeconomic

6 conditions in particular communities and job markets

7 and unfairly punish those of lower socioeconomic

8 backgrounds and the institutions that serve them at a

9 time when they need our support the most.

10 The student loan programs were conceived and

11 developed to help people pursue their educational

12 objectives, and they come with special repayment rights

13 and responsibilities, deferment and forbearance

14 options, alternate repayment plans. These plans make

15 borrowing more palatable and enable people to pursue

16 their dreams, also making repayment easier. Students

17 are entitled, assuming they meet certain eligibility

18 criteria, to utilize different repayment plans, like

19 income-based repayment, or to avail themselves of

20 deferments or forbearances or consolidations to get

21 them through difficult economic times.

22 The repayment portion of the NPRM punishes
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1 institutions for serving people who exercise their

2 rights. Many students attend our client schools, they

3 have prior debt. They've lost their job and are

4 seeking additional training. They might have a spouse

5 that's lost their job. Even though they may be working

6 and making a reasonable income, family circumstances

7 may necessitate the use of deferments or forbearances

8 or a payment plan that does not chew down principal.

9 Would it be fair to counsel these students against

10 utilizing deferments and forbearances so they default

11 in some other aspect of their life instead of their

12 student loan debt? I think not.

13 It seems that this regulation suggests that

14 institutions must be held accountable for serving any

15 student who is at risk. Institutions are not permitted

16 to alter their admissions practices to refuse entry to

17 individuals based on their socioeconomic status or

18 prior indebtedness, which we know has an impact on

19 their ability to repay and their debt to income ratio.

20 We're not permitted to alter financial planning

21 criteria to refuse to certify student loans if a

22 student is eligible, even if the institution believes
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1 that the student will be incurring too much debt or has

2 prior debt that will make repayment or their debt to

3 income ratio unpalatable.

4 Data: Finally, if this regulation were to go

5 into effect, implementing the repayment rate formula

6 and the debt to income ratio formula will hold

7 institutions accountable for a data set they have no

8 access to; no ability to track, monitor, or review for

9 their progress. It fails to recognize that student aid

10 is portable. Students choose to attend the school or

11 program that best meets their needs. It violates the

12 master calendar, denies process, and exceeds statutory

13 authority.

14 Most importantly, to move forward with this

15 regulation will demonstrate a blatant disregard for the

16 rights of lower income Americans. Who will serve these

17 displaced Americans?

18 Thank you for your time.

19 MR. OCHOA: Please, sir.

20 MR. HARTLE: Good morning. My name is Terry

21 Hartle. I'm Senior Vice President of the American

22 Council on Education. I'm speaking this morning on
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1 behalf of the ACE and the 58 other associations and

2 organizations that signed onto the letter that we

3 submitted in response to these regulations.

4 I'd like to begin by thanking the Department

5 of Education for the exceptional and extraordinary

6 efforts to solicit public comments on the proposed

7 regulations. You are taking a lot of steps that are

8 not required by the Administrative Procedures Act, and

9 I commend you for doing that. I've never seen another

10 agency do anything quite like this, so thank you for

11 that.

12 The second point I would make is that we

13 strongly support efforts to protect students from

14 excessive debt that they cannot pay back. I believe

15 that the repayment rate is a reasonable indicator that

16 we shouldn't be afraid to look at.

17 The third point I would make is that

18 according to IPEDS, there are 53,000 programs that are

19 gainful employment programs that will be covered under

20 the proposed regulation. Forty thousand of these

21 programs -- that's 80 percent -- are at traditional

22 colleges and universities. So traditional colleges and
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1 universities have quite a stake in the proposed

2 regulations.

3 Two substantive points I'd like to make.

4 First is a point that's been discussed before. That's

5 retroactivity. Schools will find out that they have a

6 problem only after it's too late for them to do very

7 much about it because of the implementation schedule

8 you are proposing. Lawyers have a name for a law that

9 retroactively changes the legal consequences taken

10 before its passage. It's called an ex post facto law,

11 and usually it's unconstitutional. Even if not

12 unconstitutional, I think it raises fundamental

13 fairness questions that I would ask the Department of

14 Education to consider. The obvious solution here is to

15 make the test prospective; base it on data going

16 forward as opposed to using retroactive data.

17 Second observation is the very large number

18 of programs that will be covered by this regulation.

19 As I mentioned earlier, according to IPEDS, the

20 regulation will affect roughly 53,000 programs, and

21 it's extremely complex and will require a great deal of

22 data collection by institutions. And it will put a
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1 substantial workload burden on the Department of

2 Education, which will stretch the Department's

3 abilities in several ways unless it gets considerably

4 more staff to take this on.

5 I think there are several ways that the

6 Department could address the broad reach of the

7 regulation that I'd encourage them to consider. First,

8 I think the Department should exempt from gainful

9 employment regulations any program where a degree, a

10 bachelor's or associate's degree, is a prerequisite for

11 participation. Of the 53,000 certificate programs,

12 about 6,000 are post-baccalaureate certificate

13 programs. Post-baccalaureate certificate programs

14 don't rely very heavily on Title IV aid, and most post15 baccalaureate certificate recipients are seeking

16 additional education to expand their education for an

17 occupation they already have.

18 Second observation, or second way to

19 streamline the reach of this would be to impose a five

20 percent test. I think the Department should exempt

21 from the Gainful Employment regulations any institution

22 where less than five percent of the total credentials
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1 awarded come from gainful employment programs. In many

2 schools, if they have that few certificate programs,

3 there's no profit motive that might motivate the

4 expansion of low-cost, high-profit programs without

5 adequate resources.

6 Finally, I would suggest that the Department

7 consider exempting from the Gainful Employment

8 regulation any program where a modest number of

9 students take out federal loans. There are a fair

10 number of certificate programs that do not have a

11 significant amount of borrowing, particularly at

12 community colleges. Community colleges have about 40

13 percent of all total student enrollment in American

14 higher education, but they account for about ten

15 percent of all federal student loans. Indeed, the most

16 recent Department of Education data make clear that

17 only five percent of community college students in

18 certificate programs take out federal loans.

19 I think by targeting the regulation a little

20 bit more specifically, the Department will ease its

21 workload burden and minimize the negative impact on

22 institutions and programs that are not a serious
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1 problem.

2 Again, I thank the Department for the time

3 that they've made available for all of us to express

4 our concerns and suggestions for these regulations.

5 Thank you.

6 MR. OCHOA: Next speaker, please.

7 MS. OLDHAM: Good morning. My name is Cheryl

8 Oldham with the United States Chamber of Commerce, and

9 I want to thank the Department for the opportunity to

10 be here to reiterate the Chamber's opposition to the

11 proposed Gainful Employment regulation.

12 The Chamber is the world's largest business

13 federation, representing the interests of more than

14 three million businesses of all sizes, sectors, and

15 regions, as well as state and local chambers and

16 industry associations. It's overarching mission is to

17 strengthen the competitiveness of the U.S. economy to

18 increase opportunity and prosperity for all Americans.

19 The Chamber recognizes the importance of

20 education, particularly postsecondary education, to

21 that mission. That's why we are opposing the proposed

22 Gainful Employment regulation and submitted our
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1 comments to the Department outlining that position.

2 The Chamber's concerns can be summarized in

3 four areas. The proposal will negatively impact job

4 creation; runs counter to a necessary focus on degree

5 completion; adversely affects minority and low income

6 students; and punishes the innovation in higher

7 education.

8 With regard to job creation, it is our deeply

9 held belief that America's number one priority now

10 ought to be creating the more than 20 million jobs

11 needed over the next ten years to reemploy the

12 unemployed and keep pace with the growing population.

13 Yet this regulation would result in jobs lost and fewer

14 Americans getting the postsecondary education and

15 training they need to secure a job in today's economy.

16 Fostering an environment that promotes job creation

17 should be Job Number One for the federal government,

18 and nothing should be done by any federal agency that

19 could do harm to an already fragile economic situation.

20 Private sector higher education schools are

21 working to help reduce the approximately ten percent

22 unemployment rate Americans have endured for more than
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1 two years. These institutions offer hands-on training

2 and real world experience. For the sector as a whole

3 during 2008, more than 370,000 graduates were placed

4 into jobs needed to drive the economy forward.

5 We applaud the Administration's emphasis on

6 degree completion and positioning America once again as

7 a global leader in postsecondary attainment. The goal

8 of five million more graduates by 2020 is both

9 aggressive and commendable. However, in order to

10 achieve this goal, even Secretary Duncan has

11 acknowledged the key role the for-profit sector must

12 play. Yet simultaneously, the Department is issuing a

13 rule that runs counter to this goal by targeting the

14 very sector it needs to play a role. By jeopardizing

15 programs and institutions, fewer students, particularly

16 low income and minority students, will have access to

17 postsecondary education.

18 The Administration's completion goal will not

19 be met if these very students are not a part of the

20 equation. These are the students that are most often

21 left behind by some in traditional higher education,

22 but are being served in large numbers by the for-profit
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1 sector, which is providing them an alternative to

2 traditional higher ed when they may otherwise not have

3 access.

4 In direct contrast to the attainment goal,

5 this measure by its nature would disproportionately

6 affect degree programs that take longer to complete.

7 Virtually no colleges, for-profit or nonprofit, can

8 meet the eight percent threshold for bachelor's degree

9 programs included in the rulemaking.

10 The for-profit sector will not and should not

11 replace traditional higher education. However, public

12 and private institutions can provide only a limited

13 number of opportunities. Capacity at public and

14 nonprofit institutions is limited, particularly so in

15 tough economic times, when state and local budgets are

16 tight. And in a global knowledge economy, we as a

17 nation must support those who are providing educational

18 opportunities to those who might otherwise be excluded.

19 We are concerned the Department lacks the

20 data required to sufficiently understand the true

21 impact of this far-reaching regulation, particularly on

22 the minority community. This rule is lethal to
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1 programs that enroll significant numbers of low income

2 students. Low income students, regardless of the type

3 of institution they attend, tend to borrow more money

4 than their more affluent peers. The Chamber is

5 concerned that the institutions may be forced to reject

6 low income students in order to ensure compliance with

7 the proposed rule.

8 Private sector investment in innovation in

9 higher ed is critical to serving more students and

10 tackling the high cost of higher education. For-profit

11 colleges and universities are a proven leader in

12 delivery of instruction and program development that

13 meets the needs of the employer community and students

14 across the country. These institutions serve non15 traditional students with highly convenient delivery

16 that addresses the needs of working students, parents,

17 and first generation college-goers. However, this rule

18 would have a chilling effect on private sector

19 innovation and would result in reduced access and

20 opportunity, fewer choices, and less convenience for

21 students.

22 Finally, while the Chamber will leave the
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1 detailed arguments regarding the approach of this

2 regulation to others, we believe there are very real

3 and significant questions that have been raised about

4 whether there has been an informed and adequate

5 assessment of the overall impact. Getting the bad guys

6 in the sector is certainly a goal that's hard to argue

7 against. However, enough legitimate questions have

8 been raised about the data and analysis that we don't

9 believe the Department can say with certainty that the

10 good guys will not be punished and students, especially

11 those least well served by traditional higher ed, will

12 not be harmed in the process. That is why the U.S.

13 Chamber of Commerce urges the Department to withdraw

14 the proposed regulation at this time.

15 I appreciate your time.

16 MR. OCHOA: Next speaker, please.

17 No more speakers?

18 We will end our session, then, and resume

19 (off mike).

20 MALE: Okay. Thank you, ladies and

21 gentlemen. That concludes this morning's session. We

22 would ask that you come back if you have a black badge,
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1 and if your name is written in black, you can come back

2 at 12:30 and we'll start allowing you back in the room.

3 The next session will start at 1:00. If you have a red

4 badge, that means you're only confirmed for this

5 morning's session, so we ask that you exit the building

6 that way. And we'll see you back here at 1:00 o'clock.

7 Thank you.

8 (First session ends)

9 (Afternoon session begins)

10 MR. OCHOA: Good afternoon. I'm Eduardo

11 Ochoa, Assistant Secretary for Postsecondary Education.

12 And here we have with me also Dan Madzelan from Office

13 of Postsecondary Education and Steve Finley from the

14 Office of General Counsel.

15 The Department has received an unprecedented

16 number of comments on the proposed rule for Gainful

17 Employment, approximately 90,000, from a wide variety

18 of stakeholders. And those stakeholders submitting

19 comments include representatives from for-profit

20 universities and colleges, community colleges,

21 students, higher education associations, members of

22 Congress, financial analysts, economists, and college
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1 and university faculty. As a result, the Department is

2 taking this additional time to consider the comments it

3 received and is hosting today's public hearings to

4 ensure a thoughtful process as we work to finalize the

5 proposed rule.

6 Now, just briefly some ground rules for

7 today. Over the course of two days we expect to hear

8 close to 80 presentations or updated presentations

9 covering a range of interests and ideas. In selecting

10 presenters, the Department worked to ensure that every

11 organization that requested to speak was afforded the

12 opportunity. Each presenter will be afforded five

13 minutes to deliver remarks. We would ask that

14 presenters state their name and their organization at

15 the beginning of their remarks. During this time the

16 Department listening panel reserves the right to ask

17 clarifying questions of a presenter.

18 There will be a timer keeping us on track.

19 When it turns yellow, each presenter will have two

20 minutes remaining. When it turns red, we request that

21 you stop speaking and return to your seat.

22 For those of you who hope to have a record of
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1 this, a full transcription will be posted to the

2 Department's website in the coming weeks.

3 Okay. So we're ready to begin. I think that

4 speakers have been issued numbers. So we will start

5 with our first speaker now.

6 MS. MOREE: Good afternoon. I'm Maggie

7 Moree. I am the Director of Federal Affairs for the

8 Business Council of New York State. We are a business

9 trade organization located in Albany, New York,

10 representing over 3,000 businesses of all sectors and

11 all sizes across the state. Our members include

12 institutions of higher education, public, private, and

13 proprietary; two-year, four-year, and research

14 institutions. And I appreciate the opportunity to

15 present today before you and provide additional

16 perspective on the formal comments that we submitted to

17 the Department.

18 In short, a well-prepared work force gives

19 New Yorkers the opportunity to compete in a global

20 economy. The business of higher education is tied to

21 our state's economic development success. The ability

22 to provide businesses with a skilled work force
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1 enhances the opportunity for business expansion and

2 retention. This is not new, nor is it news to anyone

3 here. It's a maxim our members own, with no

4 distinction between public, private, and proprietary

5 schools.

6 The business of higher education cannot shy

7 away from accountability if it is to be relevant to its

8 students and relevant to the business sectors where its

9 students will apply the skills and knowledge gained.

10 Ramon Vaquez(ph), a 2004 graduate of the Art Institute

11 of New York City, is but one example of putting a face

12 on what this means in New York State. The education

13 and skills he received at the Art Institute put him on

14 a path to gainful employment. That is, he owns his own

15 production company; he provides director and production

16 services to independent films, commercials, music, and

17 corporate videos.

18 The Business Council was disappointed at the

19 rulemaking promulgated by the Department on July 26th,

20 particularly as it defined and proposed to measure

21 gainful employment. As a business trade organization,

22 we value and encourage the use of data to inform public
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1 policy, to assist decision making by consumers, and to

2 measure the effectiveness of the investment of public

3 dollars. While the rulemaking indicates that, quote,

4 "the concept of training leading to gainful employment

5 was intended to ensure that this connection between

6 debt and earnings would not be lost," close quote, the

7 proposed metric does not actually measure gainful

8 employment, but uses debt repayment ability as a proxy

9 for gainful employment.

10 The concept of training leading to gainful

11 employment is not new to much of the work force

12 development system, or perhaps as you know it, the

13 education and training system. Welfare reform in the

14 '90s compelled education and training providers using

15 TANF money to demonstrate that a job at the end of the

16 course of study was there. The Workforce Investment

17 Act compels the training using WIA dollars be directed

18 only to those skills for which jobs are in demand.

19 Both of these federally funded programs

20 measure employment outcomes. They both measure wage

21 gains. And at its most basic level, the public

22 businesses and policy makers understand gainful
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1 employment. I daresay Ramon Vaquez understands it, as

2 well, with the skills that he acquired at the Art

3 Institute.

4 At the heart of our comments, the Business

5 Council would encourage the Department to align its

6 measures with the remainder of the workforce system,

7 rather than creating parallel measures which impose

8 more barriers to the education component of the system

9 and prevent it from fully integrating with the rest of

10 the workforce development system. Public policy and

11 public investments will be much better served by the

12 ability to have a common set of metrics across the

13 education and training portfolio.

14 The Business Council supports accountability.

15 We support transparency. Gainful employment should, in

16 fact, measure employment and not mislead the public by

17 using metrics which are related to debt. And as a

18 broader part of the workforce development system, we

19 would strongly urge you to become a part of, and not

20 stand separate from the rest of that system, and adopt

21 measures which allow all of us to see the results

22 across the publicly funded workforce system.
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1 I would be remiss if I didn't urge the

2 Department to consider what their primary objective is

3 in promulgating these rules. If the goal is to curb

4 fraudulent and marketing practices, then develop the

5 solution to fit the problem. New York State's Board of

6 Regents is the only state board of education in the

7 country having authority over all educational activity

8 at all levels, including private, public, nonprofit,

9 and for-profit institutions. Our system may not be

10 perfect, but it has provided ample oversight and

11 guidance and does not resist in exercising its

12 authority when needed and as appropriate. It has

13 closed proprietary schools; it exercises vigilance on

14 the marketing of programs and services. It is within

15 this well established, highly regulated operational

16 framework that New York's system of education and

17 training thrives. That's the foundation for our

18 opposition to these rules and regulations on gainful

19 employment, and we would ask that you would visit what

20 your primary objective is and target the solution and

21 the metric to that problem.

22 Thank you very much.
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1 MR. WYNNE: Good afternoon. My name is David

2 Wynne, and I'm the Vice President of Stenograph in

3 Elmhurst, Illinois. We're the worldwide leader in the

4 development, manufacture, and distribution of

5 technology solutions for court reporters and closed

6 captioners. We also own two court reporting schools,

7 one in Montgomery, Alabama, and Denver Academy of Court

8 Reporting.

9 In 1995 there were almost 400 schools

10 teaching court reporting. Today there are less than

11 100. Why? The cost to operate an increasingly

12 technology-driven program and extensive -- some might

13 say intrusive -- regulation and compliance issues

14 overwhelmed the majority mom and pop schools run by

15 dedicated educators, but without much business acumen

16 or capital.

17 As a result, there is a national shortage of

18 individuals trained to perform the functions of court

19 reporting critical to the functioning of our American

20 judicial system and CART closed captioning, providing

21 access for the deaf and hard of hearing that is

22 mandated by the Americans with Disabilities Act. We
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1 know. We service these customers every day at

2 Stenograph.

3 Court reporting is a very difficult course of

4 studies, generally leading to an associate degree. It

5 requires a unique combination of English language

6 skills, broad general knowledge, and extensive

7 vocabulary and the ability to master the psychomotor

8 skills necessary to write at 225 words a minute with

9 95-plus percent accuracy, verbatim. Clearly, not

10 everyone can do it. The rewards can be significant

11 when they do. According to the National Court

12 Reporters Association, the national average income of a

13 full-time court reporter is $62,000. Candidly, the

14 public sector has been unwilling or unable to fund the

15 programs necessary to provide this training. It is

16 expensive to offer, and the density of students in any

17 given community is generally not adequate to support a

18 public program. Only about 30 of the 75 accredited

19 programs within NCRA are public, and approximately 80

20 percent of all students going into court reporting

21 programs today are in private, for-profit schools.

22 The demographic of our students is non-
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1 traditional. Many are retraining after layoffs. Our

2 population is 92 percent female; 18 percent minority;

3 72 percent are attending school with children, nearly

4 half of them as single parents; and 83 percent have a

5 current annual income of less than $25,000.

6 With the new rule as proposed, you'll be

7 taking away the dream of a better life and future from

8 our students and thousands of others by denying them

9 access to financial aid which they deserve and need. We

10 ask that you not approve the gainful employment rule as

11 proposed. Instead, enforce the existing rules on

12 default rates mandated by our accrediting bodies -- in

13 our case, ACICS. Why create another unwieldy set of

14 rules and increased bureaucracy?

15 And second, reduce the amount of money that a

16 student can borrow. We spend a lot of time trying to

17 convince students that it is not in their best interest

18 to borrow the maximum provided from their FAFSA

19 calculations.

20 We hear repeatedly that this country needs a

21 more skilled and educated workforce to compete in the

22 world economy. Not all students are traditional and
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1 fit in a traditional four-year institution. Career

2 colleges prepare students, many of whom have not had

3 previous educational success and have other baggage

4 that you and I cannot even imagine.

5 In closing, I would like to share two success

6 stories. Tasha returned to school as a married

7 African-American parent. She loved her program, and in

8 her internship, provided CART and captioning services

9 to students at the University of Alabama, Birmingham,

10 and Troy State College. She liked it so much that over

11 the last six years, she has developed a business and

12 has contracts with virtually every public institution

13 of higher education Alabama to provide access for

14 students and faculty members who are deaf or hard of

15 hearing And she employs seven people.

16 Janie is a graduate and single parent. She

17 was encouraged by her mother to continue her education,

18 even though her family had no resources to help. She

19 did it the hard way, going to school at night. But she

20 was determined. Even an unanticipated pregnancy did

21 not stop her. She was attending class within a week of

22 the birth of her son. By the time she crossed the
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1 stage to receive her diploma, she'd already accepted a

2 position as an official court reporter in South Dakota.

3 Tasha and Janie and hundreds more like them

4 are not numbers. They are people like you and me who

5 want more for themselves and their families. Please do

6 not stifle their dreams of a better future. The rule

7 as proposed hurts more good schools and has more

8 unintended consequences than you can imagine. Please

9 don't lump all career colleges with a few bad actors.

10 Thank you.

11 MR. OCHOA: Thank you.

12 Next speaker, please.

13 MS. FLANAGAN: Good afternoon. My name is

14 Sarah Flanagan. I'm Vice President of Government

15 Relations at the National Association of Independent

16 Colleges and Universities. NAICU has more than 950

17 colleges in its membership and more than 70 additional

18 independent college associations. We represent private

19 nonprofit colleges that are either regionally or

20 nationally accredited. In total, our sector educates

21 about 20 percent of the nation's students, but awards

22 about 30 percent of all degrees.
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1 First I'd like to address a common

2 misunderstanding about these regulations. These

3 regulations impact all certificate programs at all

4 schools, regardless of whether a student attends a

5 public, nonprofit, or for-profit institution. Indeed,

6 ACE estimates that 40,000 of the 53,000 credentialed

7 programs that will be affected by these regulations are

8 in the public and nonprofit sectors.

9 At its core, NAICU understands the Department

10 of Education's efforts under the gainful employment

11 regulations are designed to address the issue of

12 negative amortization in the student loan program.

13 Currently, schools with excessive default rates are not

14 allowed to access Title IV funds. But as the federal

15 government has become more generous in extending

16 repayment terms to borrowers, they've created a large

17 group of students who are not technically in default,

18 but are unable to even make a dollar down payment on

19 their principal.

20 The proposal before us essentially tries to

21 capture these students through a second repayment

22 screen. We are deeply appreciative of the generous
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1 terms and conditions Congress and the Administration

2 have extended to student borrowers. We have a shared

3 responsibility to taxpayers and to the students we

4 serve to make sure that those benefits are not gamed.

5 However, we also recognize that complex

6 regulations not only add to the increased cost of

7 college which will be ultimately passed on to students,

8 but can also add a significant burden to the Department

9 of Education and reduce administrative effectiveness.

10 With that in mind, I'm going to suggest

11 several ways in which the Department might target the

12 regulations to make them more efficient and effective.

13 Our recommendations are based on the clear, well

14 established distinction in the Higher Education Act

15 that student aid may be used for two different

16 purposes: general education and degree programs, and

17 job training through credential programs.

18 Student loan repayment options recognize that

19 while degree attainment leads to higher earnings,

20 commonly quoted figures of over a million dollars over

21 a lifetime, it may take several years for the

22 investment in a degree program to pay off. Indeed, a
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1 recent study published in USA Today cites age 33 as the

2 average point at which the investment in traditional

3 college degree pays for itself.

4 But this same principle does not necessarily

5 apply to job training programs that are not premised on

6 degree acquisition, and so do not yield the same

7 lifetime bump in earnings. Student loan limits and

8 borrowed benefits are largely constructed around

9 traditional pathways to four-year degree. So how do we

10 deal with these credential programs?

11 We have three basic proposals to target.

12 First, remove credential programs that assume a degree

13 is a prerequisite, no matter whether that's an

14 associate's, bachelor's, master's, or doctoral. These

15 students are really degree students, and they are going

16 to have the lifetime earnings that reflect in the

17 degree programs.

18 For related reasons, exempt credential

19 programs, too, that students receive as part of a

20 degree track. Students may receive credentials often

21 automatically on the pathway to degrees, an example of

22 a stackable credential. But these students are for all
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1 intents and purposes in degree programs.

2 Our third proposal tries to address the

3 Department's concern that some students may not be able

4 to repay loans because the schools they attended did

5 not have adequate resources to prepare students for the

6 modern day workplace. We recommend that the Department

7 exempt institutions in which no more than five percent

8 of the total credentials awarded are in gainful

9 employment programs that are not tied to degrees or met

10 one of the two previously proposed tests. An analysis

11 of a sample set of about 50 of our member schools that

12 offer these type of credential programs illustrate that

13 programs at these schools are generally tied to, grew

14 out of, and benefit from the infrastructure of the

15 school's overall focus on degrees. As an illustration,

16 we looked at a well known university that awards about

17 300 certificates a year that are at least one year, but

18 not more than two years. Nearly all of these

19 credentials were for clinical medical laboratory

20 technicians. This made sense, because the institution

21 runs a well-known, household name research hospital and

22 medical school and nursing program. Such credential
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1 programs benefits hugely from these comprehensive

2 campus resources, including equipment, facilities, and

3 faculty.

4 Finally, I would like to mention that we were

5 conservative in selecting the five percent figure.

6 Since Title IV data is not available to us at the

7 programmatic level, we would highly encourage the

8 Department to look at this type of a model and see if

9 it applies at ten percent or what the right percentage

10 would be.

11 Thank you very much for allowing me to speak

12 today on behalf of our schools and students.

13 MR. OCHOA: Thank you very much.

14 Next speaker, please.

15 MR. MITCHELL: Good morning. Or good

16 afternoon, gentlemen. My name's Paul Mitchell. I'm

17 the Chief Executive Officer of Ross Education, the

18 parent company of Ross Medical Education Centers. Thank

19 you for the opportunity to speak with you today

20 regarding what is now simply known as GE.

21 My entire 30-plus-year career has been

22 devoted to postsecondary education, both in the public
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1 and the private sector. By way of background, Ross

2 provides allied health training in 19 campuses,

3 generally in smaller communities -- communities like

4 Flint, Saginaw, Muskegon, Michigan, Niles, and Toledo,

5 Ohio. Contrary to the image of our sector that many

6 hold, we operate small campuses, with the largest

7 having enrollment of about 210 students. Unemployment

8 rates in most of our communities hover in the teens.

9 Allied health careers are among only a handful of

10 growth occupations in Michigan, Ohio, and Indiana.

11 In many of our communities, Ross is the only

12 or primary training provider in these expanding allied

13 health fields. Michigan, where 14 of our campuses are

14 located, has experienced a 21.3 percent drop in median

15 household income since 2000, compared to a 6.6 percent

16 drop nationwide. In just one year, 2008-2009, Michigan

17 experienced a 6.5 percent drop in median household

18 income, essentially the national average over the

19 previous ten years.

20 Our enrollment is about 96 percent female.

21 Interestingly, the average age is 26 years old -- not

22 the young, naive, relatively recent high school grad,
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1 again, depicted by many.

2 Minority students comprise 34 percent of

3 enrollment at our Roosevelt Park campus, for example,

4 and not surprisingly, given our economy, 63 percent of

5 our students were full Pell eligible -- the most

6 disadvantaged in our population.

7 It is against this backdrop of economic

8 dislocation and financial challenges that the GE

9 regulations need to be considered. They can't be

10 considered in a vacuum. I strongly believe the

11 regulations as proposed -- not surprisingly to you, I

12 don't think -- are counterproductive, but have

13 significant consequences for our communities and

14 segments of the public that the regulation seeks to

15 protect.

16 The repayment rate standard and calculation

17 methodology certainly does not provide consumers

18 accurate and complete information to assess educational

19 opportunities. How can a repayment rate of 35 percent

20 be an appropriate minimum for private for-profit

21 institutions when many community colleges in the same

22 communities we work have repayment rates below 30
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1 percent, and some are below 20 percent?

2 Studies conducted by respected analysts have

3 revealed that the repayment rate is more closely tied

4 to the socioeconomic status of the borrower than any

5 other single factor. Simply put, enrolling a higher

6 percentage of economically disadvantaged students means

7 a lower repayment rate.

8 Further, we contend the more economically

9 depressed the community, the more the repayment rate

10 will be adversely impacted. The proposed debt to

11 income ratio standard disproportionately impacts

12 programs with a heavily female enrollment. GAO data

13 shows females are more likely to leave the workforce;

14 work part-time; and leave for family needs. Further,

15 due to the economic situation in Michigan and Ohio, our

16 campuses would be disproportionately impacted under

17 those proposed rules.

18 Further, Ross cannot require that every

19 graduate seeks or accepts employment, work full time,

20 or remain in the labor force. The debt to income

21 standard penalizes institutions for every student that

22 fails to seek employment or likes to work part-time or
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1 leaves the labor force as a result of family needs,

2 childbirth, or various other things that come up in

3 families.

4 The question then is, put very clearly:

5 Should Ross close its campuses in many of our

6 communities, who will fill the educational void for

7 these still-growing allied health careers? How will

8 employers' needs for training personnel be met? How

9 will our students be served? As I said earlier, we are

10 in many communities the only provider, and the other

11 provider may well be another proprietary institution.

12 Our local community colleges now provide most of the

13 programs we run.

14 Critical changes to GE need to be adopted to

15 avoid extensive economic damage and dislocation.

16 First, utilizing 40 percent of the BLS wage

17 for an occupation as the appropriate standard for debt

18 to income to level the playing field for programs

19 heavily serving females and to adjust for factors

20 beyond institutional control.

21 A three-year phase-in period to avoid the

22 retroactivity which I'm sure many people have spoken
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1 about and will.

2 Eliminating either graduates receiving Pell

3 grants in the repayment rate calculation or modifying

4 the definitions to exclude students exercising their

5 borrower's rights to deference or forbearance from the

6 calculation entirely.

7 Modifying the debt to income ratio standard

8 to ten percent of 13.8 percent, which I believe Mark

9 Antowich(ph) has also recommended, and inclusion of an

10 adjustment in the repayment rate and debt to income

11 standard that recognizes the unique challenges our

12 community is facing in protracted economic --

13 unemployment challenges and economic dislocations. In

14 fact, a number of federal regulations do that now,

15 where there are adjustments to various standards

16 because of economic issues.

17 Lastly, modifications of this nature I

18 believe are significant without.... Lacking -- I'm

19 sorry -- modifications of this nature, I believe

20 significant adverse incomes and unforeseen economic

21 dislocations will occur in our communities. Frankly,

22 things we cannot afford.
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1 Since I have one -- ten seconds, I have one

2 other observation. After 30 years in this field, I

3 found it entertaining how when dealing with

4 regulations, people can argue the regulations are good

5 for everybody else but them.

6 Thank you. Any questions?

7 Thank you, gentlemen.

8 MR. OCHOA: Thank you.

9 Next speaker, please.

10 MR. ANDERSON: Good afternoon. I'm Duncan

11 Anderson and CEO of Education Affiliates.

12 On behalf of the 22,000 students we serve, I

13 have six recommendations on how to make the gainful

14 rule -- employment rule more workable and fair for all.

15 The majority of my students are female and/or

16 minority and have family incomes of less than $40,000.

17 Seventy-nine percent of our graduates go into the

18 healthcare field, into scarce areas such as nursing,

19 dental hygienists, medical -- you name it.

20 Point number one: To ensure transparency and

21 avoid discrimination, earnings data should be measured

22 by medium BLS statistics, not an average of actual
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1 earnings data from the Social Security Administration

2 or IRS. The flaws with this are the Department's

3 proposed using data in a manner that provides no

4 transparency for decision makers. The model has not

5 been tested and is not using live data. Institutions

6 lack the underlying data, and as a result, we'll have

7 very limited ability to plan and adjust their

8 performance appropriately in advance in order to

9 remediate their programs.

10 Institutions will have no ability to

11 challenge or appeal Department data. Actual earnings

12 data is discriminatory. Actual earnings data penalizes

13 schools whose graduates are self-employed, choose to

14 work part- time, choose to leave the workforce

15 voluntarily for pregnancy, illness, or other family

16 issues.

17 These programs which serve a higher

18 percentage of women, such as my schools, will be

19 significantly more likely to be eliminated than those

20 serving lower percentages of women when actual earnings

21 data is used. Actual earnings data will cause the

22 metrics to vary significantly from year to year in
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1 programs with a small number of students, and such

2 fluctuations have nothing to do with the quality of the

3 programs.

4 The use of a medium BLS statistic will

5 provide much-needed transparency and the ability for

6 institutions in advance to calculate their programs'

7 performance and remediate and fix them in a timely

8 manner. The medium BLS statistic is fair, agnostic,

9 and non-discriminatory. Loan repayment takes place on

10 an average of over 15 years. As economists have

11 written, the value of education lasts a lifetime, not

12 three years.

13 Number two: Any loan in compliance with

14 terms of its debt agreement, including income-based

15 repayment loans, consolidation loans, interest-only

16 loans, and extended repayment loans should be counted

17 in both the numerator and the denominator of the

18 repayment rate calculation. The Legislature has made a

19 policy decision to allow and even promote loan

20 consolidation's income-continent repayment plans.

21 These programs often result in a borrower being in good

22 standing with both the Department and its lenders while
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1 not reducing principal, and therefore penalizing the

2 institution that has no control over the issuance of

3 this.

4 The Department's repayment rate calculation

5 is inconsistent when the policy decision is made by the

6 Legislature. The proposed regulation includes only

7 borrowers making payments to reduce their principal

8 balance. As a result, the borrowers who use programs

9 enacted by the Legislature will not be included in the

10 repayment rate calculation, despite they are not in

11 default.

12 The institutions should not be penalized

13 because the Legislature has determined as a matter of

14 policy that it is appropriate to offer flexible payment

15 plans to those consumers that have taken loans and are

16 availing themselves of their legal rights. We should

17 exclude all borrowers on deferment or forbearance from

18 both the numerator and the denominator. This is not

19 something that the educational institutions have any

20 control over. Your servicers are making these

21 decisions. You need to train your servicers. Every

22 day they are putting people into forbearance right now.
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1 My students last week are calling up trying to make

2 payments. They're told, "Don't worry. We're putting

3 you in forbearance."

4 Debt should be defined to include only that

5 portion specific to tuition, which would exclude prior

6 debt and debt incurred for living expenses.

7 Institutions are required by federal regulation to

8 allow students to draw the maximum loan amount for

9 which they are eligible, irrespective of relative

10 tuition level. Institutions cannot discriminate

11 against students whom they believe might have

12 difficulty repaying that loan amount by insisting they

13 borrow a lesser amount. If the institutions are

14 required to offer the maximum loan amount to students,

15 how can they simultaneously be held accountable for

16 excessive borrowing by the students, over which they

17 have no control?

18 The loan repayment metric as a percentage of

19 actual earnings should start at ten percent. The eight

20 percent was based on a mortgage-related debt which the

21 author Sandy Baum has stated clearly does not apply.

22 President Obama's speech clearly called out for ten
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1 percent, so I think you're thinking about it.

2 Thresholds were arbitrary and were based on proxy data,

3 not actual income data.

4 I would ask that you would eliminate the

5 retroactive nature of the tests by waiting to implement

6 until July 1, 2015. Institutions need a one-year

7 period to put these policies and procedures in place,

8 hopefully with transparency to calculate where they

9 stand and remediate them, and then start the three-year

10 clock as you've suggested. Fairness dictates the data

11 should only be used after the preparation period. As

12 the Department has recognized, three years of data is

13 necessary to evaluate. We should have time to prepare

14 and not be measured retroactively.

15 I want to thank you very much for the chance

16 to comment. I ask for you to have objectivity. What's

17 at stake, again, are 22,000 students who have no other

18 alternative for education. They're trying to better

19 themselves in life. And we're measuring this and

20 enacting this rule in the worst economic period over

21 the last four years in the modern history of this

22 country.
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1 So it should not come as a surprise they're

2 having a problem in meeting some of these payment

3 results. It doesn't mean they're going to default,

4 because legally they haven't defaulted. But the way

5 you're measuring this, you're counting them as a

6 default.

7 Thank you.

8 MR. OCHOA: Thank you.

9 Next speaker, please.

10 MS. CARTY(ph): Thank you for the opportunity

11 to speak today. I'm Karen Ann Carty. I've been an

12 educator my entire professional life, first as a

13 teacher and then as a higher administrator. I've been

14 25 years in higher education, 15 of those years at a

15 small Catholic liberal arts college and ten of those

16 years at the current college I'm with, Monroe College.

17 Today I represent the Association of Proprietary

18 Colleges in New York. We are 27 accredited degree19 granting institutions of higher education serving over

20 50,000 students on 41 campuses throughout our state.

21 These are institutions like the School of Visual Arts,

22 Berkeley College, Plaza College, the Laboratory
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1 Institute of Merchandising, the College of Westchester,

2 and my own institution, Monroe. We offer high quality

3 programs and fine student outcomes. We have a history

4 of serving students who desire a clear path to career

5 opportunities and a track record of providing a wide

6 range of industries skilled, educated employees.

7 First, about proprietary education in New

8 York State. Like every other degree-granting college

9 and university in New York, irrespective of sector, APC

10 colleges are regulated by the New York State Board of

11 Regents, which means all of our programs undergo

12 rigorous review and must be approved prior to enrolling

13 students. Like my colleagues at other APC colleges, I

14 have always slept well at night knowing I work for an

15 institution with a worthwhile mission and an

16 extraordinary history. Each day we are challenged

17 professionally, held highly accountable, encouraged to

18 make reasoned decisions, and expected to act in the

19 best interests of the students we serve. Anyone who

20 visits an APC college or meets my colleagues invariably

21 walks away with a fresh and positive perspective on

22 proprietary education.
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1 Second, we support the broad aims intended by

2 the Department of Education. At APC we agree that we

3 should prepare students for employment, and we agree

4 that measures should be taken to eliminate unethical

5 practices; curb unruly and irresponsible growth; limit

6 excessive borrowing; and curtail anything that would

7 thwart the long-term success of our students and

8 graduates. However, the harsh economic realities of

9 the past several years have had an impact on every

10 industry and people from every walk of life. Likewise,

11 the economy has had an impact on our recent graduates.

12 They, and thousands of others across the country, have

13 entered a difficult and competitive employment

14 environment through no fault of their own or the

15 institutions where they chose to pursue their studies.

16 Next, the Gainful Employment regulation as

17 proposed will not help realize the intended outcomes.

18 As noted in our written response, the regulation

19 presents great difficulties for institutions because

20 the metrics on which we will be judged have been

21 changed mid-stream, and the penalties, which are harsh,

22 will apply retroactively. We will be judged on data
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1 that we cannot examine, verify, or remediate.

2 One noteworthy example of just how difficult

3 and unfair the regulation is, is we have identified

4 multiple instances where students' principal loan

5 balances are incorrectly recorded in NSLDS due to

6 complications related to having multiple service

7 providers. This means that a student may have an

8 outstanding balance of $15,000 and it is recorded as

9 $30,000. Such flawed data will have an impact on both

10 the loan repayment rate and the debt to earnings ratio.

11 The loan repayment rate formula, in particular,

12 presents its own set of problems. It judges

13 institutions on repayment of loan principal immediately

14 following graduation for cohorts of students who

15 entered the most strained employment market in memory.

16 And the formula seriously penalizes institutions whose

17 graduates had deferred their loans or entered into

18 income-contingent and interest-only repayment plans,

19 which were previously perfectly acceptable ways for

20 recent graduates to manage their debt while seeking

21 employment or getting established in the job market.

22 The debt to earnings and loan repayment rate metrics
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1 are purported to identify programs that are of little

2 or no value and where students have taken on more debt

3 than they are able to pay back. But many researchers

4 and other thoughtful commentators, including Mark

5 Antowich(ph), have provided compelling evidence that

6 the repayment rate in its current formulation punishes

7 institutions on the income level of their students and

8 not on the quality of the programs and the career

9 preparation they receive.

10 In closing, we have committed to working

11 together to realize the outcomes we all desire. If you

12 ask most middle class parents whose children graduate

13 this year if they believe their investment will pay off

14 in the first year out, they will tell you that they do

15 not expect an immediate return on their investment. In

16 fact, they will probably tell you that their graduate

17 is moving back in and looking for a job.

18 This regulation as it is proposed gives

19 neither our institutions nor our graduates the time or

20 opportunity to respond appropriately to this dramatic

21 and sudden shift in how the proprietary sector is

22 viewed by the Department of Education. All the
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1 (inaudible) students who own their degrees, do get

2 established in their careers, and pay down their loan

3 debts. This does not happen overnight, and

4 particularly for students from economically

5 disadvantaged backgrounds. We have faith that the

6 Department will craft a regulation that leads to real

7 improved outcomes and is not simply punitive. We know

8 there are ways to apply a level of accountability that

9 will encourage colleges and universities of every

10 stripe to realize their missions and serve all students

11 well, regardless of their backgrounds or their personal

12 circumstances. This version of Gainful Employment,

13 unfortunately, is not the way.

14 We look forward to working with the

15 Department to assure that our graduates find meaningful

16 employment and have debt levels that they can manage.

17 Thank you very much.

18 MR. OCHOA: Thank you.

19 Next speaker, please.

20 DR. SHANNON: Good afternoon. My name is Dr.

21 Stephen Shannon. I'm the President of the American

22 Association of Colleges of Osteopathic Medicine, which
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1 I'll refer to as AACOM. And I'm pleased to present on

2 our recently submitted comments to the Department on

3 Gainful Employment.

4 AACOM represents the administrators, faculty,

5 and students of the nation's 26 colleges of osteopathic

6 medicine and four branch campuses that offer the Doctor

7 of Osteopathic Medicine degree. Today more than 18,000

8 students are enrolled in osteopathic medical schools.

9 More than 20 percent of U.S. medical students are

10 training to be osteopathic physicians.

11 AACOM commends the Secretary for proposing

12 rules that are designed to promote the principles of

13 the Title IV student financial aid programs and for

14 understanding the importance of accountability. We

15 recognize that appropriate oversight is a fundamental

16 function of the Department to ensure that federal

17 funding is being appropriately allocated, and we thank

18 the Department for its leadership on this important

19 matter.

20 During a time when our nation faces a

21 critical and growing shortage of physicians,

22 particularly in the area of primary care, AACOM asks
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1 the Department to take into consideration the factors

2 that are unique to medical education. Medical students

3 follow a common sequence of coursework, clinical

4 training, internship, residency, and national board

5 exams regardless of whether they attend a public,

6 nonprofit, or for-profit medical school. Typically,

7 students spend their first and second year of medical

8 school in classrooms and laboratories and their third

9 and fourth years on clinical rotations. Each

10 osteopathic medical student must pass three separate

11 national exams in order to graduate. However, upon

12 graduation, medical students cannot begin practice.

13 They must undergo an additional three to seven years of

14 graduate medical education, depending on their

15 specialty, and then take additional national board and

16 certifying exams. During internship and residency,

17 students earn a stipend. However, that income is

18 generally not sufficient to provide financial resources

19 to begin significant payment of educational loans, and

20 it certainly is not indicative of the future practicing

21 physician salary.

22 We hope that the Department recognizes the
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1 special educational process that is unique to medical

2 education and gains understanding of the negative

3 impact this proposed rule could have if applied to U.S.

4 medical schools.

5 While AACOM has concerns with the potential

6 impact of the proposed regulation on all U.S. medical

7 schools, we understand that the proposed regulation

8 would affect only for-profit medical schools. One

9 AACOM member institution that would be affected is

10 Rocky Vista University College of Osteopathic Medicine,

11 which filed comments on August 26th with the

12 Department. AACOM supports those comments and would

13 like to draw your attention to them as illustrative of

14 the problems that regulation would pose for all U.S.

15 medical schools. AACOM has serious concerns

16 that if these regulations were applied to nonprofits as

17 well as for-profit U.S. medical schools, essentially

18 all schools would be deemed ineligible for Title IV

19 student financial aid programs. Therefore, as the

20 implementation process of these regulations continues,

21 AACOM asks the Department to exempt all U.S. graduate

22 terminal degree medical education programs from these
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1 regulations.

2 While AACOM agrees with the Department's

3 statement that programs offered by the for-profit

4 sector must lead to measurable outcomes, AACOM

5 maintains that the best way to measure the outcome for

6 graduate medical programs is through other means, such

7 as the graduation rates of schools matriculates, their

8 students' pass rates on national board exams, or

9 employment, income, or loan repayment metrics after the

10 completion of specialty training and entry into

11 practice. Income alone repayment after graduation --

12 during graduate medical education is not appropriate.

13 Thank you for the opportunity to offer these

14 public comments. AACOM looks forward to working

15 closely with the Department to ensure the responsible

16 and productive utilization of Title IV student

17 financial aid programs by U.S. medical schools and

18 their students.

19 Thank you.

20 MR. OCHOA: Thank you.

21 Next speaker, please.

22 MS. HAUGH: Good afternoon. I would like to
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1 thank the U.S. Department of Education for inviting me

2 here today to speak. I'm here representing Herzing

3 University as one of their students in their MBA

4 program. I'm here to tell my story.

5 My name is Tommie Jo Haugh. I'm that girl

6 that grew up in rural Wisconsin on a dairy farm with

7 only 42 in my graduating class. I'm sure several of

8 you can probably relate to that.

9 I'm the first college graduate in my family.

10 My parents have a high school education. And when I

11 graduated from high school, they couldn't guide me in

12 the direction that I needed to go for college. My

13 friends were doing it; I knew it was probably the right

14 thing to do for my future. But I had no stability at

15 home and no money to do it with.

16 I did attend college for three years after

17 high school, and in my last year of college -- I was on

18 the University of Wisconsin program -- I couldn't

19 afford to live any more and go to school. So I joined

20 the workforce and started working full time. At the

21 age of 27 my current employer now wanted me to go back

22 to school to gain an education that would benefit my
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1 future with the help -- they would help me financially,

2 and I would be silly not to take advantage of that

3 opportunity. My challenge was finding a program that

4 was conducive to my work schedule at that time. I

5 travel all over the country, and when I do travel, I

6 travel Thursday to Monday. I couldn't attend a

7 traditional campus like University of Wisconsin

8 Madison. I did look into their programs, and it's

9 Monday through Friday. It's daytime. It would have

10 interfered with my work schedule and my travel, and I

11 wouldn't have been able to work full time, afford to

12 put a roof over my head, food on the table, pay my

13 bills, plus go to school.

14 I did some research and found Herzing

15 University, that offered a class schedule that was

16 conducive with my work schedule. I could go to school

17 online if I wanted to. I could go to school at

18 nighttime. I could still work full time, and it worked

19 out perfect.

20 Here I am four years later in their MBA

21 program, getting ready to graduate on December 21st

22 with my MBA in healthcare. And I'm not counting down
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1 days or anything. But just letting you know that

2 without career education, I would not be where I am

3 today. And after I graduate, I feel like the sky is

4 the limit. I can go anywhere.

5 And I would like the U.S. Department of

6 Education to take into consideration what career

7 education can do for so many more after me. By taking

8 my funding from private sector schools and programs, we

9 eliminate others from achieving their hopes and dreams.

10 Please don't take that away from them.

11 Thank you very much.

12 MR. OCHOA: Thank you.

13 Next speaker, please.

14 MR. LARUE: Gentlemen, my name is Dave Larue.

15 I'm the campus president of the Akron Institute of

16 Herzing University.

17 My comments today deal with the Gainful

18 Employment rule currently being considered by the U.S.

19 Department of Education. Career schools are essential

20 to the educational process in the United States. Not

21 all students are suited to traditional educational

22 methods or educational offerings. Many of today's
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1 students are better suited to career-oriented programs

2 not always offered by public or private nonprofit

3 institutions.

4 I've been in private for-profit education in

5 1979 as an instructor, an education supervisor,

6 director of education, and now as campus president.

7 Through these years I've measured my success by my

8 students' success. My students have worked for major

9 manufacturers and healthcare providers. They've helped

10 in the design of items from ladders to automated

11 control systems that can monitor and control heating

12 and ventilating systems in buildings around the world.

13 They've provided billing services nationwide and work

14 in major hospitals, including the Cleveland Clinic.

15 I, too, am a product of career-focused

16 education. In 1976 I graduated from ITT Technical

17 Institute in Youngstown, Ohio, with a degree in

18 drafting. I attended there because I'd attended the

19 Ohio State University with a Navy ROTC scholarship, and

20 having graduated from a small, rural community high

21 school, I was a very small fish in a very large pond.

22 The instruction process was foreign to me. It was also
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1 at a time where the university was experimenting with

2 educational methods that had many faults.

3 Upon graduating from ITT, I received an

4 employment offer for a contractor at the Johnson Space

5 Center in Houston, Texas. My job was to coordinate the

6 construction of the simulators for the space shuttle

7 between the technicians building them, most of which

8 were DeVry Institute graduates, and the engineers that

9 were designing the process. The engineers did not

10 always have a clear comprehension of what the actual

11 simulator looked like.

12 With my educational experience at a career13 focused school, I was able to assist in the completion

14 of the shuttle procedure simulator ahead of schedule

15 and under budget -- terms very seldom used in

16 government work. As a result of the accomplishments on

17 the simulator projects I worked on, I was selected to

18 be the first pilot of the motion-based simulator after

19 being man-rated after it was rebuilt after the approach

20 and landing tests. The approach and landing tests were

21 where they flew the shuttle on the 747 to see if it was

22 going to fly, it would drop like a rock. The motion-
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1 based simulator was one that simulated actual movement

2 instead of just being a platform.

3 Once we had restructured it, no one could

4 ride it during the assembly. Once it was man-rated,

5 which means somebody could ride in it, I was sitting in

6 the right-hand seat. A NASA monitor was sitting in the

7 left-hand seat.

8 Career-focused education build the workers

9 who build the items that make the world what it is

10 today. With automation and integration, engineers can

11 do more with less. But there is still the need for the

12 grunt work and the nuts and bolts of today's business.

13 Career-focused education provides these people. Do not

14 hinder their ability to do their job.

15 Since I have been in the position I have been

16 in, I continued my education, and I now have a degree

17 in management. But it was the foundation that was laid

18 with the career-focused school that I have been able to

19 allow others to succeed.

20 And two last items that have developed since

21 the time that I presented my original comments. The

22 Ohio State University earlier this week released a
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1 statement that the majority of their students were now

2 completing their assigned program in six years. And

3 they think that's a great accomplishment, because it

4 used to be much longer. Well, six years is 150 percent

5 of the intended program. One of the ways they are able

6 to accomplish that is they are now restricting entry

7 into the university. They are allowing less people to

8 attend because they want a higher completion rate --

9 something that proprietary schools have been measured

10 on for a very long time, but traditionals have not been

11 measured on but are being looked more closely at.

12 So I would ask that as the Department

13 develops the final rule that will be submitted, I would

14 ask that fair and equal treatment be given to

15 proprietary schools, as well as all educational

16 programs, for the success of our students, not the

17 providers of the education.

18 Thank you very much.

19 MR. OCHOA: Thank you.

20 Next speaker, please.

21 MR. FRANKEL: Good afternoon. My name is

22 Jonathan Frankel. I'm from the law firm of Steese,
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1 Evans & Frankel, and I'm representing Alta Colleges. I

2 want to thank you for the opportunity to speak today.

3 Other speakers today have talked about the

4 policy problems with the Department's proposed rule,

5 and in particular how at the very time when more

6 working adults than ever need job skills training, the

7 rules would cripple the very schools that, as we just

8 heard two speakers ago, have proven themselves to be

9 the most flexible and the most able to meet the needs

10 and schedules of working adults.

11 Alta's comments in this proceeding focused on

12 a different issue, but it is one that the Department

13 must address. And that is that the rule that's being

14 proposed would not survive judicial review. It should

15 come as no surprise that, given the enormous impact

16 that the rule would have on the ability of proprietary

17 and vocational institutions to continue operating, that

18 those schools will feel they have no choice but to

19 challenge the rule in court. And looking at the law

20 and looking at the rule as it's proposed now, the

21 Department stands to lose that challenge.

22 The statutory foundation for the rule is weak
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1 to the point of non-existent. The Department is

2 proposing to take an innocuous two-word phrase that

3 appears in the description of the programs offered by a

4 proprietary institution, that those programs train

5 students for gainful employment, and use these two

6 words to supplant pages and pages of explicit statutory

7 mandates and detailed instructions from Congress. Where

8 Congress has wanted the Department to regulate with

9 respect to student loan burdens and loan repayment

10 rates, it has created detailed rules and spelled out

11 the Department's authority explicitly and carefully.

12 Lengthy sections of the Higher Education Act spell out

13 default standards and the consequences for schools that

14 fail to meet those standards. Congress also went into

15 great detail in the Higher Education Act creating

16 different mechanisms and payment plans for students to

17 manage their loan repayments.

18 By contrast, the Department is proposing to

19 find an even broader authority to regulate student loan

20 practices, and effectively tuition prices, and find

21 this hiding in the definition of a proprietary

22 institution in the two words, "gainful employment." On
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1 its face, though, that phrase is simply talking about

2 the purpose and content of the programs that such an

3 institution offers. It means that to count, a program

4 must directly train students for a specific occupation,

5 as opposed to being a general education program that

6 may only indirectly make a student more employable.

7 This is how the Department has read the statutory

8 language for decades, and Alta's comments lay out this

9 precedent.

10 There is nothing in this language that makes

11 any reference to tuition prices or to student loan

12 burdens. And that's why you find the same statutory

13 language, the same phrase, "gainful employment," in

14 numerous tax, labor, and other statutes that have

15 nothing to do with student loans. It makes no sense to

16 suggest that Congress would have gone through all the

17 trouble of spelling out the cohort default rules and

18 detailing multiple options for helping students manage

19 their loan repayments, only to turn around and give the

20 Department implied authority to undo those rules and

21 those mechanisms and adopt different ones simply by

22 hiding two words in a definitional provision somewhere
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1 else in the statute. I think the clearest example of

2 the conflict is something we've heard from several

3 speakers today -- the fact that the repayment rate

4 calculation actually ends up penalizing institutions

5 when students take advantage of the Congressionally

6 approved alternative payment programs. A review in

7 court looking at this would not accept this reading of

8 the Higher Education Act as reasonable.

9 I know that the Department believes that the

10 current Higher Education Act provisions do not go far

11 enough, but the solution is to go to Congress and ask

12 for the regulatory authority that the Department seeks.

13 That would be a solution that would stand up in court.

14 Instead, the Department is risking a court decision

15 that would not only strike down the Gainful Employment

16 rule, but also constrain the Department's authority to

17 interpret the Higher Education Act going forward. In

18 other words, the Department could well be left with

19 less regulatory authority than it had before.

20 I strongly urge the Department and legal

21 counsel to review the comments filed by Alta Colleges

22 in this proceeding. Everybody in the field shares the
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1 Department's interest in crafting rules that are

2 sustainable, predictable, and that have a solid legal

3 foundation. But the current proposal risks a strong

4 legal challenge and may end up harming the Department's

5 efforts in the long run.

6 Thank you very much.

7 MR. OCHOA: Thank you.

8 Next speaker, please.

9 MR. DUMARESQ: Good afternoon. My name is

10 Richard Dumaresq. I'm the Executive Director of the

11 Pennsylvania Association of Private School

12 Administrators. Our association represents 320 -- more

13 than 320 for-profit career schools, colleges, and

14 universities in the Commonwealth of Pennsylvania.

15 I want to focus my testimony and expand on

16 one aspect of my original comments on gainful

17 employment, and that is student over-borrowing. We are

18 aware that one of the major goals of the Gainful

19 Employment regulation is the reduction of student loan

20 debt. Institutions are concerned, however, that the

21 gainful employment strategy focuses primarily at the

22 back end of the equation -- after students have
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1 incurred the debt. Very little attention is given to

2 approaches to curb debt at the front end.

3 Currently, student debt counseling is the

4 only acceptable strategy. Yet what schools have found

5 is that over-borrowing is a big part of the loan debt

6 problem, especially among unsophisticated borrowers,

7 and it is increasing, despite aggressive counseling.

8 Schools constantly report stories of students

9 asking for all the financial aid they are entitled to;

10 paying their tuition, and then walking away with

11 thousands of dollars which ends up paying for a newer

12 car, Christmas presents, plastic surgery, bail money,

13 or big parties, which the school usually ends up

14 hearing about. These cash stipends can be, in one

15 case, as high as $24,000. The student needed $7,000

16 and ended up borrowing $31,000.

17 Despite the best efforts of schools to curb

18 over-borrowing, the Department insists that schools

19 must disclose to students all the loan money they are

20 entitled to. Yet how can schools be responsible for

21 repayment when the Department encourages irresponsible

22 over-borrowing?
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1 Over-borrowing is defined in three ways by

2 our schools. A student transfers or moves from school

3 to school and they continue to mount debt, which goes

4 into deferment while they are attending another college

5 or school. Or number two, commuter students living at

6 home borrow available funds in excess of direct school

7 costs -- tuition, fees, and books -- without regard to

8 debt consequences. While these dollars make sense for

9 traditional college students living on campus, they are

10 not appropriate for commuter students living at home.

11 Number three: Students also over-borrow when

12 they receive an unexpected increase in grant money:

13 Pell, OVR, state grant, public assistance, or WIA

14 funding. As a result, more grant money is received

15 than students originally planned. And when the school

16 counsels and encourages them to return the excess loan

17 money, the students almost always decline the request

18 and keep the extra loan amount.

19 The following are some actual examples of

20 student over-borrowing. The first is a small

21 cosmetology school in central Pennsylvania. In 2007,

22 '08, and '09, the school had a zero percent tuition
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1 increase; .6 percent of an enrollment increase. Yet

2 over-borrowing increased from four to 41 students, a

3 925% increase. Over-borrowing loan amounts increased

4 from $2,000 to $68,000 by 2009.

5 Three business school campuses in

6 northwestern

7 Pennsylvania: In 2007, '08, and '09, the

8 schools averaged a 3.8 percent total tuition increase,

9 with a 43 percent enrollment increase because of a new

10 campus. But 152 percent increase in over-borrowing,

11 from $234,000 to $590,000 in two years.

12 Finally, one business school campus in

13 central Pennsylvania. Between 2007 and 2009, again,

14 the school averaged a 1.7 percent tuition increase each

15 year and no increase in enrollment or borrowers. Yet

16 over- borrowing increased by 104 percent, from 36 to 74

17 students; and over-borrowing dollars tripled, from

18 $100,000 in 2007 to $363,000 in 2009.

19 The three-year trend appears clear. While

20 there were minor tuition increases, no change in

21 student demographics, stable or moderate enrollment

22 increases due to some new campuses, only over-
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1 borrowing, as was defined earlier, increased

2 exponentially.

3 We would hope that the Department and/or

4 Congress would provide additional methods beyond

5 counseling for limiting student over-borrowing. We

6 have a number of suggestions. But I'll close by

7 saying, if the Department is going to address the back

8 end of the loan debt problem through gainful employment

9 -- and our school community has provided many reasons

10 why the Department shouldn't -- at the very least,

11 address the front end as well by curbing over-borrowing

12 and considering other front end approaches which we

13 will be glad to discuss with you.

14 Thank you very much.

15 MR. OCHOA: Thank you.

16 Next speaker, please.

17 MR. HEFFNER: These are actually computer

18 glasses -- stop the strobing.

19 Gentlemen, this is a formal statement on

20 behalf of the Gainful Employment rule. For the record,

21 my name is Van Heffner. I am President and CEO of the

22 Nevada Hotel and Lodging Association, the NH&LA.
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1 The NH&LA is a unifying voice of Nevada's

2 multibillion dollar hospitality industry, serving

3 Nevada since 1979. This trade association represents

4 more than 300 hotel casinos statewide, with

5 approximately 150,000 rooms and over 200,000 employees.

6 Nevada's hospitality industry is heavily

7 dependent on a knowledgeable and well-trained

8 workforce. Southern Nevada's tourism and hospitality

9 industry has been well served by graduates of the

10 institutions that will be harmed by these proposed

11 rules. These institutions have provided students the

12 education that has given them the essential skills and

13 talents that have supported Nevada's economy.

14 Private sector postsecondary schools like the

15 Art Institute of Las Vegas provide career training for

16 the jobs they need to succeed in today's economy. This

17 institution provides a broad range of education options

18 that provide a skilled workforce to the hospitality

19 industry in Nevada.

20 In Las Vegas, the entertainment capital of

21 the world, the Art Institute of Las Vegas and the

22 Culinary Institute of Las Vegas have graduated over
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1 1,000 students in the past eight years. Many employers

2 are eager to express the important role the Art

3 Institute plays for their business. Victoria Lee, a

4 creative manager of MGM Resorts International

5 Advertising, Inc., has said that MGM Resorts

6 International Advertising has been very pleased with

7 the caliber of talent graduating from the Art Institute

8 of Las Vegas. They have hired many Art Institute

9 graduates, because they come well prepared with

10 excellent skills and great enthusiasm to thrive in a

11 fast-paced environment. Lee believes the graduates are

12 bright, creative, and talented and that they are a

13 tremendous asset to the MGM Resorts International

14 advertising team. Nevada has the dubious distinction

15 of having the highest unemployment rate in the nation

16 of over 14 percent, to the Bureau of Labor Statistics

17 ranking. And the U.S. Department of Education's

18 proposed rule would prevent hundreds of Nevadas, as

19 well as future students, from acquiring the job skills

20 they need to work in and support our critically --

21 tourism industry to help reduce this troubling

22 statistic.
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1 The proposed rule is discriminatory. Our

2 industry is particularly concerned about the bias this

3 proposed rule holds against students who must borrow

4 money to attend college. The Gainful Employment rule

5 proposed by the Department of Education would render

6 many of these career-oriented degree programs

7 ineligible for Title IV financial aid if students fail

8 to meet a debt service to income ratio test.

9 This rule is arbitrary and unfair to those

10 who want to pursue careers with lower starting

11 salaries, in the culinary arts, for example.

12 Essentially, these students would be ineligible to

13 qualify for the same federal funding as classmates who

14 opt for careers that may initially pay better starting

15 salaries. Because this rule discriminates against

16 those who must borrow to attend college, access to

17 postsecondary education may move out of reach for many

18 low income and minority students. This is

19 unacceptable, and I believe the Department of Education

20 has overstepped its statutory authority with this

21 ruling and should rescind it. Matters of education

22 policy should be administered by Congress on the advice
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1 or counsel of the Education Department.

2 Thank you for the opportunity to address you

3 on this important issue to the industry that I

4 represent.

5 Thank you.

6 MR. OCHOA: Thank you.

7 Do we have any additional speakers?

8 Okay. Then there's no more for the rest of

9 the afternoon?

10 All right. Well, this concludes our session.

11 I thank you very much for your comments.

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 My commission expires: June 20, 2015

20

21

22
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$

$100,000 141:18

$120,000 69:9

$13,000 20:22

68:22

$14,174 71:9

$15,000 120:8

$19,319 58:7

$2,000 141:4

$2,544 71:11

$234,000 141:11

$24,000 139:15

$25,000 98:5

$28,000 58:4

$30,000 69:6,9

120:9

$31,000 139:16

$33,000 50:20

$363,000 141:18

$40,000 111:16

$5,000 21:3 23:21

$590,000 141:11

$6 55:5

$60,000 23:19

$62,000 97:13

$68,000 141:4

$7,000 139:15

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08 140:22 141:7

09 140:22 141:7

1

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1,000 144:1

1,900 69:3

1.2 6:11

1.7 141:14

1:00 89:3,6

10 5:7

100 71:12 96:11

104 141:16

11.2 7:16

12 9:10 20:13

12,000 57:21

12:30 89:2

125 6:16

13.8 110:8

14 106:13 144:16

14,000 9:13

15 8:1 25:7 66:18

113:10 117:14

150 133:4

150,000 143:5

152 141:10

15-year 60:22

16 67:13

17 52:2 59:11

18 98:2

18,000 36:16 123:7

1886 5:12

19 13:8 106:2

1949 67:2

1952 66:21

1955 67:1

1956 67:3

1965 55:13

1970 67:4

1971 67:10,15

1976 130:16

1979 130:5 143:3

1992 25:18

1995 96:9

1st 23:20

2

2,000 59:22

2,100 61:20

2,800 36:17

20 21:17 43:16

73:6,8 74:4

84:10 100:21

108:1 123:9

147:19

200 5:13

200,000 54:13

143:5

2000 106:15

2002 58:12

2004 92:10

2006 71:14

2007 58:13 71:14

140:21

141:7,13,18

2008 85:3

2008-2009 106:16

2009 141:4,13,18

2009-2010 71:8

2010 1:8

2012 15:10

52:14,17

2014 22:13

2015 116:6 147:19

20154 61:3

2020 63:1 85:8

20202 1:16

21.3 106:14

210 106:7

21st 128:21

22,000 111:12

116:17

225 97:8

23 22:6 25:7

25 54:22 59:1 69:1

73:11 117:14

25th 58:5

26 52:4 106:21

123:5

26th 92:19 125:11

27 117:18 127:21

29 17:16

3

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3,000 56:16 91:10

3.8 141:8

30 47:6 67:16

71:13 97:18

100:22 107:22

111:2

300 5:13 104:17

143:4

30-plus-year
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105:21

32 18:18

320 138:12,13

33 103:1

34 107:2

35 67:19 107:19

350,000 10:1

36 141:16

37 52:5

370,000 85:3

4

4 1:8

40 52:2 67:17

82:12 109:16

40,000 101:6

400 1:15 96:9

41 10:1 117:20

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42 127:7

43 141:9

44 73:12

45 63:21

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478 10:1

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5,800 69:2

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50,000 117:20

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53,000 79:18 80:20

81:11 101:6

58 79:1

6

6 141:1

6,000 81:12

6,200 67:15

6.5 106:17

6.6 106:15

63 107:4

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70 5:22 38:11 52:1

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72 98:3

74 141:16

747 131:21

75 97:18

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80 3:1 9:14 11:1

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90,000 2:12 89:17

9010 29:14,20 30:1

32:11,13

90s 93:14

92 98:2

925% 141:3

93 71:12

950 100:16

95-plus 97:9

96 106:20

9th 37:9 40:11

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AACOM

123:1,4,11,22

125:5,9,12,15,21

126:2,4,14

abandoning 22:11

abilities 81:3

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17:9 18:6 35:15

48:6 65:15 77:19

78:8 91:21 93:8

94:12 97:7

112:7,10 113:5

132:14 134:16

able 3:2 13:10

24:1,6 52:8

53:11 55:14,21

104:3 121:3

128:11 131:13

132:18 133:5

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abuses 74:14

academic 6:1 38:6

Academy 96:7

accelerated 32:18

accept 137:7

acceptable 120:19

139:4

accepted 100:1

accepts 108:19

access 16:13,14,20

17:1,2,6 21:13

44:7,16 45:20

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85:16 86:3 87:19

96:21 98:9 99:13

101:14 145:16

accomplish 133:6

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133:3

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131:16

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33:5 71:7 79:18

80:19 97:11

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38:21 39:6 50:13

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115:15 118:17

accounting 66:22

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18:21,22 97:18

100:20 117:18

accrediting 98:12

accruing 70:13

accuracy 17:9

97:9

accurate 25:4

38:18 107:18

accurately 23:18

43:17 61:1

ACE 79:1 101:6

achieve 20:16
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35:15 54:11

85:10

achievement 72:15

achieving 129:9

ACICS 98:13

acknowledged

85:11

acquired 94:2

acquiring 144:19

acquisition 103:6

across 6:4 12:6

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57:15 61:5 63:14

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32:17 37:10 42:4

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102:14 118:18

135:12,15

137:8,10,17

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action 37:16

147:9,13

activity 95:7

actors 68:4 100:9

actual 12:12

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60:21 111:22

112:11,12,20,21

115:19 116:3

131:10 132:1

140:19

actually 93:7

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134:13 142:7,11

146:2

addresses 87:16

addressing 51:9

adequate 82:5

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34:14 46:20

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adjust 22:9 109:19

112:7

adjusting 29:18

adjustment 44:11

110:10

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33:21 44:13,19

110:15

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30:17 39:16

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52:15 79:8 102:9

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117:13

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33:2 36:16,17

123:4 138:12

admissions 72:5

74:1,20 77:16

admitted 75:7

adopt 94:20

136:21

adopted 6:20

14:17 15:9 30:10

109:14

adults 65:18

134:6,10

advance 18:8

41:14 70:8 112:8

113:6

advantage 2:5

27:19 128:2

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84:5 108:10

advertisements

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advice 145:22

advocacy 40:22

49:20

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Affairs 91:7

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35:2 80:20 86:6

125:8

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125:9

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Affiliates 111:11

affluent 87:4

afford 55:21 60:2

61:12 68:5

110:22 127:19

128:11

affordability 41:8

45:20

afforded 35:12

39:3 90:11,12

afraid 79:16

African-American

99:7

afternoon 89:9,10

91:6 96:1 100:13

105:16 111:10

122:20 126:22

133:21 138:9

146:9

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77:9 88:7 107:7

115:11 145:3,15
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age 54:22 103:1

106:21 127:21

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73:11

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98:15

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140:18

amounts 141:3

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108:2

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142:3

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111:10,11

Angela 40:22

50:10

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announced 58:11

annual 5:13 98:5

Anthem 22:17

25:7

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anticipate 57:13

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Antowich(ph

110:9 121:5

anybody 12:15

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119:6 129:1

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129:4

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APC 118:9,13,20

119:2

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44:21 105:9
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apply 6:3 15:9

21:6 37:12

38:14,16 44:17

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115:21 119:22

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138:16

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78:10 87:3 124:5

127:16 128:6

133:8 145:4,16

attended 104:4

130:18

attendees 35:4

attending 20:4

37:21 47:19 48:5

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125:13 139:1

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29:9

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authority 15:6

16:3,6 18:3

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75:10 76:1 78:13

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136:20

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75:21

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automatically

103:21

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132:10

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availability 55:18

available 3:20 9:3

18:13 28:20,21

32:21 83:3 105:6

140:6

availing 114:16
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Avenue 1:15

average 13:7 22:2

37:13,15,20 58:2

71:9,10 97:12

103:2 106:18,21

111:22 113:10

averaged 141:8,14

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111:21

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Await 31:22

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baccalaureate

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122:5,11

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68:4 88:5 100:9

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baggage 99:3

bail 139:12

balance 2:5 46:16

62:3 72:17 114:8

120:8

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balances 120:5

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26:16 30:8 52:22

64:15 66:6 77:17

102:13 115:20

116:2 132:1

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111:12 142:20

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63:1 64:6 79:14

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110:8,18,19

115:11 121:13

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137:9 144:11

benchmark 5:14

benefit 62:15 68:7

104:14 127:22

benefiting 53:14

benefits 38:19

53:14 102:4

103:8 105:1

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78:11 98:17

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116:18 130:1

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72:16 74:16 75:4

76:1 109:20

142:4

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Bill 30:16

billing 130:13

billion 55:5

billions 68:7

bills 128:13

Birmingham

26:16 99:9

birth 99:22

bit 82:20

black 88:22 89:1

blatant 78:15

BLS 21:21 28:19

109:16 111:22

113:4,8

Blue 10:10

board 9:12 12:6

22:19 50:18 70:2

71:8 95:5,6

118:10 124:4,15

126:8

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bodies 98:12

bolts 132:12

bonuses 52:9

books 140:7

bore 16:4

borne 59:10 60:2

borrow 28:9,14

66:5 87:3

98:16,18 115:13

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borrowed 103:8

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108:4 113:21

borrowers

37:13,14,15,18,1

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101:16 102:2

114:7,8,17 139:6

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51:7 76:15 82:11

115:16 119:6

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142:1

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branch 123:6

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breakfast 59:21

brief 14:7

briefly 90:6

bright 144:12

bring 16:18

broad 9:14 42:9

45:21 81:6 97:6

119:1 143:17

broad-brush

74:10

broader 20:12

22:14 94:18

135:19

broadly 44:5

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brought 56:13

brush 62:12

budget 131:15

budgets 63:6

86:15

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132:8,9

building 9:11 10:2

89:5 131:7

buildings 130:12

built 3:12

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burden 13:5 22:4

43:18 61:10 81:1

82:21 102:8

burdening 31:13

burdens 135:9

136:12

burdensome 18:2

74:21

Bureau 58:1,5

60:21 144:16

bureaucracy

98:14

buses 63:19

bush 68:13

business 5:11 9:15

12:10 54:7 58:10

66:20 83:12

91:8,20

92:1,6,8,18,21

94:4,14 96:15

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141:5,12 144:3

businesses 9:10

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91:10,22 93:22

buy 65:21

C

calculate 64:18

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calculated 29:3

calculation 23:5

27:22 35:12 43:6

107:16 110:3,6

113:18 114:4,10

137:4

calculations 40:10

98:19

calendar 78:12

caliber 144:7

campus 41:1,3,5

42:8,13 45:3

105:2 107:3

128:7 129:15

130:6 140:9

141:10,12

campuses 9:14

10:1 11:2 50:1

61:21 106:2,6,13

108:16 109:5

117:20 123:6

141:5,22

Candidly 97:13

cap 53:11

capacity 9:12

22:10 86:13

capital 59:19

96:16 143:20

captioners 96:6

captioning 96:20

99:8

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101:21

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care 123:22

career 4:6 9:12

20:14 22:6 45:8

55:22 56:12,18

62:20 70:16

71:4,19 99:1

100:9 105:21

118:4 121:8

129:2,6,19

131:12 138:13

143:15

career-focused

130:15

132:8,13,18

career-oriented

19:15 130:1

145:6

careers 10:8 41:14

45:12 54:10

62:19 106:9

109:7 122:2

145:10,14

careful 37:3 39:13

carefully 2:21

135:11

caring 35:7

Carolina 54:2,6

56:8 58:13
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Carolina's 57:14

carry 24:20

cars 65:21

CART 96:20 99:8

Carty 117:11

CARTY(ph

117:10

case 13:22 63:15

98:13 139:15

cases 52:6

cash 139:14

casinos 143:4

catch 12:4

categories 57:15

category 24:12

Catholic 117:15

cause 112:21

cease 8:13

Center 41:4 131:5

Centers 72:1

105:18

central 140:21

141:13

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54:2 111:11

142:21

certain 8:17 12:7

15:12 30:6 55:10

76:17

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12:14 19:22 88:6

107:17 124:20

certainty 41:16

88:9

certificate 31:5

38:9

81:11,12,13,15

82:2,10,18 101:3

147:1

certificates 9:16

34:18 68:6 70:15

104:17

certification 35:10

59:6,7 65:14

certified 75:7

certify 77:21 147:3

certifying 33:8

124:16

chain 6:9,16 7:20

chains 6:12 8:10

Chairman 22:19

challenge 17:9

36:21 39:2

112:11 128:3

134:19,21 138:4

challenged 118:16

challenges 27:18

107:8 110:11,13

Chamber

83:8,12,19

87:4,22 88:13

chambers 83:15

Chamber's 83:10

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29:19 80:9

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Charleston

57:9,11 58:8,9

chef 57:3

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Chicago-land

61:21

Chief 22:19,20

26:14 105:17

childbirth 109:2

children 67:21

98:3 121:12

children's 63:22

chilling 87:18

choice 18:14 31:11

48:3 56:12 62:17

65:19 66:2,4

134:18

choices 19:3 87:20

choose 22:2 28:15

31:8 39:22 41:15

47:14,16 65:21

78:10 112:13,14

choosing 34:13

chose 119:15

chosen 64:13

Christmas 139:12

circumstances

77:6 122:12

citations 16:4

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cited 74:8

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cities 8:11 25:22

city 58:9 61:11

92:11

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clarifying 3:15

90:17

class 35:6 63:7

64:1 99:21

121:12 127:7

128:15

classes 63:11,17

67:9

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classroom 69:1,2

classrooms 124:8

clear 16:5 17:16

23:22 82:16

102:13 118:4

131:10 141:19

clearest 137:1

clearly 8:18 97:9

109:4 115:21,22

Cleveland 130:14

client 77:2

Cliff 10:10

climate 41:7

Clinic 130:14

clinical 104:19

124:3,9

clock 116:10

close 25:9,11,12
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90:8 93:6 109:5

142:6

closed

63:4,14,15,17

95:13 96:5,20

closely 108:3

126:15 133:11

closing 44:17 99:5

121:10

closure 7:10 25:6

coalition 9:19

42:9,12 45:22

46:6

co-chairman 9:19

COE 70:10 72:8

cohort 23:3

38:12,13,15,20,2

2 39:6 40:4

52:3,4 136:17

cohorts 75:5

120:14

colleague 23:5

colleagues 4:19

26:5 118:13,20

collection 31:17

80:22

college 4:18 6:2,8

9:13 12:16

20:2,5 21:3

27:21 28:6,8

30:20 33:1 34:13

35:4,20 41:8

44:7 46:1 50:1,3

58:16 59:14 60:9

61:18 62:20,22

63:5,6,14 64:3

65:7,18 66:18

67:2,3,6 68:19

69:5 71:8,10

82:17 89:22

99:10 100:18

102:7 103:3

117:15,16,22

118:1,8,20

125:10

127:9,12,16,17

140:4,9 145:4,16

college-goers

87:17

colleges 18:21

20:2,6,15 22:5

27:3 28:11,13,22

30:11 36:17

50:20 51:6 57:9

70:16 71:19

79:22 82:12 86:7

87:11 89:20 99:2

100:9,17,19

107:21 109:12

118:10,13 122:9

123:5 138:13

college's 21:6

Colleges 100:16

117:18 122:22

134:1 137:21

color 72:20 73:1

colossal 63:3

Columbia 147:17

combating 75:18

combination 97:5

combined 6:10

comes 68:20

coming 3:20 43:1

68:11 91:2

command 10:21

commence 61:3

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commendable

71:21 85:9

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123:11

comment 14:8,11

16:16 40:11,16

116:16

commentators

121:4

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commenting 46:21

comments 2:12

3:13 4:12 5:1,8

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22:14,18 26:19

33:16 37:8 40:18

42:13,15 44:2,5

46:7,8 51:11

69:22 79:6 84:1

89:16,19 90:2

91:16 94:4 123:2

125:11,12

126:14 129:17

132:21 134:11

136:8 137:21

138:16 146:11

Commerce 83:8

88:13

commercials

92:16

commission

147:19

committed 121:10

common 24:18

94:12 101:1

124:3

commonly 102:20

Commonwealth

138:14

communities 8:14

76:6 106:3,8,11

107:13,22

109:6,10 110:21

community

5:11,16 6:21

7:5,17 14:17

20:12 21:3,6

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58:10 60:8 63:6

71:10 82:12,17

86:22 87:13

89:20 97:17

107:21 108:9

109:12 110:12

130:20 142:9

community-based

6:4

commute 63:21

commuter

140:5,10

companies 9:11

company 73:22

92:15 105:18

comparable 20:20

comparably 21:17

compared 31:18

106:15

compelled 93:14

compelling 121:5

compels 93:17

compete 91:19

98:21

competitive

60:15,16 119:13

competitiveness

83:17

competitors 25:14
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complete 17:2

24:21 47:14

55:14 72:11 86:6

107:18

completed

15:17,19 16:11

completeness

17:10

completers 51:8

completing 133:2

completion

38:4,7,10 40:3

51:18 72:6 84:5

85:6,18 126:10

131:13 133:8

complex 14:19

75:12 80:21

102:5

compliance 15:8

16:18,21 26:15

29:20 35:11

65:4,12 73:20

87:6 96:13

113:13

complicated 59:12

60:4 65:3,13

complications

120:6

comply 22:9 29:1

32:8 64:22

complying 11:20

23:7

component 5:19

94:8

components 11:11

comprehension

131:10

comprehensive

105:1

comprise 6:7

107:2

comprised 6:9 8:9

compromise 48:15

computer 24:4

25:3 142:17

conceived 76:10

concept 93:4,10

concepts 36:21

concern 19:15

104:3

concerned 24:8

44:15 86:19 87:5

138:20 145:2

concerns 19:10

51:10 53:9 72:18

83:4 84:2

125:5,15

concludes 88:21

146:10

conclusion 18:9

35:17 42:6 44:4

conditions 76:6

102:1

conducive

128:4,16

conduct 16:9

conducted 34:1

108:2

conference 24:10

confirmed 89:4

conflict 137:2

confronted 19:20

Congress 27:11

31:22 32:3,14

33:10,14 64:8,12

89:22 102:1

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69:19 78:20,22

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noteworthy 120:2

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