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UNITED STATES OF AMERICA

DEPARTMENT OF EDUCATION

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INTENT TO ESTABLISH

NEGOTIATED RULEMAKING COMMITTEE

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PUBLIC MEETING

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THURSDAY

SEPTEMBER 13, 2018

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The Public Meeting was convened in MET 

Auditorium at the Gateway Technical College, 2320 

Renaissance Boulevard, Sturtevant, Wisconsin at 

9:00 a.m.

PRESENT:

AARON WASHINGTON, Facilitator

MICHAEL BRICKMAN, Facilitator

DR. BRYAN ALBRECHT, President/CEO,

Gateway Technical College
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1 P R O C E E D I N G S

2 (9:00 a.m.)

3 PRESIDENT ALBRECHT: Good morning. I 

4 would like to welcome our guests from the United 

5 States Department of Education, Michael and Aaron, 

6 they will be facilitating today's hearing. They 

7 will have some additional announcements about how 

8 the process works. I just wanted to make sure that 

9 you knew that this is a great opportunity for all 

10 of us in Wisconsin, including Gateway Technical 

11 College to be able host this event, where you can 

12 share your thoughts and ideas on how we can 

13 strengthen education across all sectors in the 

14 United States.

15 And for your safety and comfort of 

16 today's session, this building is a high school 

17 currently from 9:00 until 1:00, so there are high 

18 school students out in the hallway areas, so always 

19 be careful of that. They will be taking their 

20 regular one-hour classroom breaks so there'll be 

21 some energy and activity going on there. At 1:00 

22 p.m. the Governor will be here because we have a 
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1 graduation ceremony with our partnership with the 

2 Department of Corrections. We have a group of 

3 graduates from Ellsworth Correctional Facility. 

4 So, if you're here in the afternoon there will be 

5 a new level of energy that will result from that.

6 Our programs, adult programs, begin 

7 around 2:00 in the afternoon so you'll see a lot 

8 of activity with that as well, and then this evening 

9 we're hosting an event. So, the iMET Center will 

10 have a busy day today. Restrooms are on each end 

11 of the west side of the building so please make 

12 yourself comfortable and there's water and coffee 

13 that we're putting out on the counter if you would 

14 like that as well.

15 So again, welcome on behalf of the 

16 Gateway Technical College. We're very honored and 

17 pleased that you're here and we're happy to host 

18 the U.S. Department of Education hearing. So, 

19 I'll turn it back over to you.

20 MR. BRICKMAN: Thank you, President 

21 Albrecht. I really appreciate the opportunity to 

22 be here. I just want to say thank you to Gateway 
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1 Technical College and the technical college 

2 system. It's really a great opportunity to see the 

3 work that you're doing here and, just on a personal 

4 note, great to be back in Wisconsin, as I'm a native 

5 Wisconsinite.

6 So, I'll just give a few brief remarks 

7 on the plan for the day and some of the topics that 

8 we'll be covering and then I'll turn it over to you 

9 for five minutes each. 

10 I just want to start by saying, on 

11 behalf of Secretary Betsy DeVos, we welcome you. 

12 I'm joined here by Aaron Washington, who's in the 

13 Office of Postsecondary Education. Again, my name 

14 is Mike Brickman. I'm a senior advisor in the 

15 Office of the Under Secretary at the U.S. 

16 Department of Education.

17 This is the third of three public 

18 hearings that we're holding on negotiated 

19 rulemaking to gather input regarding the 

20 regulations that govern programs authorized under 

21 Title IV of the Higher Education Act of 1965. The 

22 first hearing was at our headquarters in 
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1 Washington, DC, and earlier this week we held a 

2 similar hearing in Louisiana.

3 Secretary DeVos has challenged us to 

4 rethink higher education. And for us rethink 

5 means everyone questions everything to ensure 

6 nothing limits students from being prepared for 

7 what comes next. In postsecondary education, we 

8 have focused largely on breaking down barriers to 

9 innovation and reducing regulatory burden, while 

10 protecting students and taxpayers from 

11 unreasonable risk.

12 To that end, we are seeking input 

13 regarding a number of regulatory provisions, 

14 including issues related to recognition of 

15 accreditors, distance learning and 

16 competency-based education, including the 

17 definition of regular and substantive interaction. 

18 Direct assessment and prior learning assessment, 

19 state authorization, the definition of credit 

20 hour, and the rules and responsibilities in 

21 institutions and accrediting agencies in the 

22 teach-out process. 
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1 More specifically, with respect to the 

2 accreditors, the administration is interested in 

3 improving the recognition, the oversight process, 

4 to ensure consistent and equal treatment of all 

5 agencies. In this work, we wish to recognize the 

6 autonomy and the independence of agencies, support 

7 the needs of today's students and honor the 

8 missions of various types of institutions.

9 We'd like to hear from you and your 

10 thoughts about how to simplify the Department's 

11 process for recognition of accrediting agencies, 

12 and how to emphasize the criteria that focus on 

13 educational quality rather than administrative 

14 minutiae. 

15 We're also interested in revising any 

16 accreditation regulations that are ambiguous, 

17 repetitious or unnecessarily burdensome, as well 

18 as reducing duplication of oversight 

19 responsibilities between the Department of 

20 Education, states, and accrediting agencies, and 

21 ensuring the Department is more accountable and 

22 responsive to those it serves.
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1 In addition to the accreditation 

2 regulations, we are exploring some specific 

3 regulatory provisions that are not directly part

4 of the accreditation regulations, but that impact 

5 the work institutions do, and the way that work 

6 might be evaluated by accreditors.

7 These provisions include: the 

8 development of a single-job placement definition 

9 and a single methodology for calculating job 

10 placement rates; the determination of reasonable 

11 program length; the clock hour programs that result 

12 in certification and licensure; the elimination of 

13 barriers to innovation and competition in 

14 postsecondary education or to student completion, 

15 graduation or employment, including barriers 

16 created by unnecessary credential inflation or 

17 other practices that are unfair to students; the 

18 ability for an institution to contract with other 

19 entities to provide percentage of an educational 

20 program, including to promote innovation, and 

21 enable more rapid responses among career and 

22 technical programs to employer and workforce 
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1 needs; and the simplification and clarification of 

2 program requirements to minimize inadvertent grant 

3 to loan conversions for TEACH grant recipients.

4 Additionally, in light of the recent 

5 Supreme Court ruling in Trinity Lutheran, the 

6 Department will review provisions in our 

7 regulations relating to the eligibility of 

8 faith-based entities to participate in Title IV 

9 programs, and the eligibility of students to obtain 

10 certain benefits under those programs.

11 We welcome your perspectives as we work 

12 on updating our regulations in those areas. We 

13 anticipate bringing these issues and any others 

14 that might be added, including at the public's 

15 suggestion, for negotiated rulemaking that will 

16 begin its negotiations in January of 2019.

17 We also plan to create two 

18 subcommittees with one focused on competency-based 

19 education, and the other on the eligibility of 

20 faith-based entities to participate in Title IV 

21 programs. The subcommittee will consist of 

22 experts in those areas who will not make decisions, 
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1 but will report their recommendations back to the 

2 full committee for their deliberation during 

3 public negotiations.

4 In late fall, we'll publish a notice in 

5 the Federal Register seeking nominations for 

6 negotiators and subcommittee members. We hope 

7 that you and your colleagues will consider serving 

8 and nominating at that time. 

9 In order to best use the time of the 

10 committee, prior to the first meeting we plan to 

11 provide draft regulatory language for discussion 

12 by the negotiating committee and the 

13 subcommittees, rather than issue papers, as we have 

14 done in the past.

15 This will enable the committee to 

16 consider concrete proposals before the negotiators 

17 and -- before negotiations begin, so more of the 

18 essential work can happen during the first session. 

19 With respect for the logistics today, 

20 many of you have already signed for a time to speak, 

21 and Aaron will call you up to the microphone 

22 accordingly. We still have some time slots 
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1 available for today, so if you have not signed up 

2 and would like to speak, please see us up at the 

3 table. 

4 Speakers are asked to limit their 

5 remarks to five minutes. If you get to the end of 

6 your five minutes, Aaron will ask you to wrap up. 

7 We ask that you do so within 20 seconds. Please 

8 note that this hearing is being transcribed, and 

9 the transcription will be posted to our website in 

10 the next few weeks.

11 Although the Department is not 

12 preparing a video or audio recording of this 

13 hearing, this is a public hearing, and it's 

14 possible that a member of the public will choose 

15 to record your remarks. 

16 If you have written comments that you 

17 would like to submit here today, you can give them 

18 to me or to Aaron. We are also accepting them via 

19 regulations.gov through this Friday, September 

20 14th, at 11:59 p.m. eastern daylight time. 

21 We have two scheduled breaks today; one 

22 in the morning from 10:30 until 10:40, and one this 
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1 afternoon from 12:00 to 12:15. Those breaks may 

2 be extended if we do not have people scheduled to 

3 speak. In consideration of others, please silence 

4 your cell phones and other devices while you're in 

5 this room. You're welcome, though, to make calls 

6 out in the lobby.

7 When you're called to speak, please 

8 provide your name and affiliation, and we've been 

9 asked that we speak clearly so it can be picked up 

10 by the transcription. We look forward to your 

11 comments. Thank you for your time and sharing your 

12 expertise with us. We look forward to an 

13 interesting and productive day.

14 MR. WASHINGTON: Our first speaker is 

15 Chuck Komp. Please come up to the podium and try 

16 to speak clearly so that your comments may be 

17 accurately accounted for in the transcript.

18 MR. KOMP: Thank you. I'm Charles 

19 Komp, managing director for strategic initiatives 

20 at Nicolet College. I'd like to begin by 

21 expressing my appreciation for your time today, and 

22 for your interest in advancing regulatory and 
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1 accreditation models that encourage responsible 

2 innovations in higher education.

3 Nicolet College is a small, public 

4 community college that serves a rural area in 

5 Northern Wisconsin. We're the only institution of 

6 higher education in the region. We serve a large

7 geographic area with a small population. 

8 Residents are primarily working class 

9 and community-minded. Most are employed, but 

10 often in lower skill, low wage occupations. 

11 Relatively few hold college credentials. This, in 

12 turn, constrains economic development, as 

13 employers are unable to fill higher skilled, higher 

14 paying positions.

15 People know that they can improve their 

16 lives through education. But with family, job, 

17 and community commitments, traditional college 

18 simply does not work for many of them. For 

19 example, one of our students is employed full-time 

20 in a maintenance position. He has the opportunity 

21 to advance his career with a welding technical 

22 diploma. 
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1 But his irregular work schedule 

2 frequently conflicts with classes, preventing him 

3 from attending a traditional educational program. 

4 He cannot afford to stop working to attend college. 

5 This is typical of many of the residents in our 

6 district. They're capable of much more. They're 

7 seeking to advance their lot in life. But they're 

8 unable to access the education necessary to achieve 

9 their goals.

10 Nicolet College is transforming its 

11 educational models to better serve working adults. 

12 We are the first college in the Wisconsin technical 

13 college system offering competency-based 

14 education. By focusing on learning, not seat 

15 time, we have developed a flexible learning 

16 environment that fits the lives of busy adult

17 learners.

18 Competencies, the things students need 

19 to know to succeed, are defined hand in hand with 

20 our industry partners. Students progress by 

21 demonstrating what they have learned. The 

22 flexibility of learning on a schedule that works 
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1 around employment demands, and of progressing at 

2 a pace that adjusts to accommodate both life and 

3 learning, has made it possible for the student I 

4 just described to pursue his college degree.

5 He began his studies this summer, and 

6 is well on the track to success. Competency-based 

7 post-secondary education holds an exceptional 

8 potential to meet the critical workforce needs in 

9 predominantly rural regions. Nicolet College 

10 provides one example of the unique ability of 

11 small, creative, locally connected colleges to 

12 realize that potential.

13 While Nicolet College has managed to 

14 navigate regulatory and accountability systems, 

15 innovation is slower and more costly than it needs 

16 to be because these systems are based on the credit 

17 hour, and built for traditional students. 

18 Because students learn at different 

19 rates, measuring learning to demonstrate progress 

20 simply makes sense. Rulemaking that provides for 

21 learning as an alternative measure of progress to 

22 the time-based credit hour system opens a path for 
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1 innovations that will lead to more efficient use 

2 of student and taxpayer funds.

3 However, this freedom for innovation 

4 must be accompanied by protections that assure 

5 quality and value. Sensible regulation to assure 

6 quality is certainly good for students and 

7 taxpayers, but controlling the cost of compliance 

8 is also important. 

9 Public community colleges are held to 

10 a high level of accountability by their local 

11 constituents. District boards and state oversight 

12 assure that we meet needs effectively and that we 

13 use public funding wisely. 

14 Rulemaking that recognizes the unique 

15 mission of the public community college and its 

16 existing local and statewide accountability 

17 systems will help keep costs low for students and 

18 taxpayers, while maintaining quality and value.

19 Regional accreditors are effective in 

20 assuring and advancing the quality of higher

21 education. As membership organizations, they are 

22 committed to continuous quality improvement, to 
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1 clear accountability, and to respecting different 

2 institutional missions and purposes.

3 Regional accreditors serve distinct 

4 and different roles than government regulators. 

5 We believe it is wise to maintain that separation 

6 in order to assure quality and support innovation. 

7 Thoughtful rulemaking holds the potential to 

8 encourage innovation by identifying learning as a 

9 measure of progress and by recognizing the value 

10 of local and state accountability systems and the 

11 regional accreditors in assuring quality and value 

12 for students and taxpayers.

13 Such rulemaking will improve the 

14 ability of public community colleges to provide 

15 high-quality, low-cost education that can 

16 transform lives, foster economic development, and 

17 expand employment opportunities. 

18 Again, thank you for the opportunity 

19 for a small institution from a very rural part of 

20 our country to represent the needs of our 

21 constituents, our students, and our employers. 

22 MR. WASHINGTON: Thank you. Tyson 
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1 Manker.

2 MR. MANKER: Good morning. My name is 

3 Tyson Manker. I am a former infantry Marine and 

4 combat veteran of Iraq, and now Director of 

5 Veterans Engagement with Veterans Education 

6 Success. I appreciate the opportunity to share my 

7 thoughts and concerns with you regarding the 

8 Department's proposed regulatory changes.

9 VES understands the desire to encourage 

10 and improve innovation in higher education, but 

11 takes issue with several of the regulatory 

12 rollbacks that consequently undermine critical 

13 protections for students, while permitting 

14 low-quality education providers to waste taxpayer 

15 dollars.

16 Of these numerous proposed changes, 

17 today I want to focus on the following two issues; 

18 the repeal of the credit hour definition, and 

19 competency-based education. First, the credit 

20 hour requirement was implemented as a way to ensure 

21 bad actor colleges were not misrepresenting the 

22 amount of actual instruction given to students. 
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1 The Department found in 2010, through 

2 its independent Inspector General, that 

3 institutions were inflating the value of their 

4 college courses with minimum to no oversight from 

5 accreditors. The credit hour was a quantitative 

6 way of providing a baseline measurement of 

7 instruction to protect against bad actor schools.

8 We support working with colleges to 

9 best address how to properly measure meaningful 

10 instruction, but outright appeal of the credit hour 

11 would hurt students and increase deceptive 

12 practices by schools. Since we understand the 

13 Department wants to remove the credit hour rule as 

14 currently constructed, we encourage the Department 

15 to work with key stakeholders, like the American 

16 Council of Education and other top tier schools, 

17 to find a quantitative metric that would both 

18 protect students and veterans from predatory 

19 practices.

20 Second, we support competency-based 

21 education and thank the Department for addressing 

22 it. It is an important tool for service members, 
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1 veterans, and military families who relocate 

2 frequently as part of their military service.

3 We encourage the promotion of 

4 competency-based education and recognition of 

5 prior learning credits. Prior learning credits 

6 account for a student's knowledge, and allows those 

7 students to take classes equal with the level of 

8 skill they possess, instead of wasting time, 

9 resources and taxpayer dollars on duplicative and 

10 unnecessary instruction.

11 In addition, we support a standard 

12 definition for competency-based education and 

13 prior learning credits, thereby allowing students 

14 to be fully informed and understand how their prior 

15 training will be applied to the educational 

16 programs they pursue. 

17 In conclusion, the Department must be 

18 a good steward of taxpayer dollars, and therefore, 

19 keep quality standards that protect both students 

20 and taxpayers. This is evidenced by the 

21 Department's own findings by its independent 

22 Inspector General that institutions were inflating 
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1 the value of college courses. These schools, 

2 along with the recent closings of ITT Tech and 

3 Corinthian Colleges amply showed that there are bad 

4 actors attempting to defraud students and the 

5 government. 

6 The outright removal of the credit hour 

7 without an appropriate quantitative replacement 

8 would pave the way for similar bad actors to charge 

9 excessive fees for pointless education and 

10 ultimately hurt those that we represent, service

11 members, veterans, and their families, who use 

12 their hard-earned military education benefits to 

13 go to school and are often the targets of predatory 

14 schools looking to capitalize on those benefits.

15 Similarly, it is important that 

16 competency-based education and prior learning 

17 credits are allowed in a manner that facilitates 

18 veterans, as well as all students, the ability to 

19 utilize their skill and training without 

20 unnecessary delay. It is often the case that 

21 veterans, many who are first generation, and other

22 under-served student population, believe the 
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1 federal government's stamp of approval for the 

2 school to offer Title IV funds means the school is 

3 a high quality school. 

4 Unfortunately, we know all too well 

5 this is not always the case. Unfortunately, 

6 students find out too late that this is not always 

7 the case. 

8 MR. WASHINGTON: Twenty seconds left.

9 MR. MANKER: The Education Department's 

10 mission is to promote student achievement and 

11 quality education. Weakening or removing current 

12 protections would directly contradict that 

13 mission. Thank you very much.

14 MR. WASHINGTON: Thank you. I did 

15 notice that we had several people come in after we 

16 began. If you wouldn't mind coming forward and 

17 signing in at the front table. The sign-in sheet 

18 is here. Our next speaker is Gregory W. Jones.

19 MR. JONES: Thank you. I'm Greg Jones 

20 here today on behalf of the Illinois Attorney 

21 General's office. My office is Illinois' chief 

22 legal officer and primary entity responsible for 
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1 enforcing Illinois' consumer protection statutes. 

2 In that role, my office investigated schools like 

3 Corinthian Colleges, Westwood, and ITT Technical 

4 Institute.

5 Those investigations revealed 

6 accreditors such as ACICS overlooking boiler room 

7 enrollment practices and fraudulent job placement 

8 statistics. Instead of cutting such for-profit 

9 schools off from federal aid, ACICS allowed 

10 students to continue to take out loans. While 

11 ACICS's ultimate fate is currently unclear, we 

12 should use its failures as a cautionary tale to 

13 strengthen accreditor oversight, not weaken it. 

14 Accrediting agencies are the first line 

15 of defense for students and a watchdog for billions 

16 of dollars in student aid provided by the federal 

17 government and taxpayers. Now more than ever, 

18 it's important that the Department ensures that we 

19 have strong, impactful accreditors. The nations 

20 and students simply cannot afford the alternative. 

21 First, the Department should ensure 

22 that accreditors examine relevant criteria for 
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1 exposing institutional fraud. We note with alarm 

2 recent efforts to reduce oversight criteria, 

3 specifically the PROSPER Act, no longer requiring 

4 accreditors to consider such items as recruiting 

5 and admissions practices, areas most ripe for 

6 institutional misrepresentations, or records of 

7 students complaints.

8 As consumer protection enforcement 

9 entities, we know how valuable consumer complaints 

10 can be to identifying such fraud. Our offices 

11 regularly rely on such complaints to initiate and 

12 inform investigations into institutions. The 

13 Department should require close review of such 

14 criteria.

15 The Department should also create 

16 additional specific criteria which accreditors 

17 much consider when accrediting schools. For 

18 instance, the Department has recently indicated 

19 that it intends to rescind entirely the gainful 

20 employment regulations.

21 While we strongly disagree with the 

22 Department's actions in rescinding this 
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1 regulation, we call on the Department to require 

2 accreditors to determine and consider those same 

3 debt-to-earnings ratios of overseen programs, or 

4 at a minimum, examine the average debt load of 

5 students, as well as median earnings. 

6 Examining such statistics would reveal 

7 whether or not students will be able to pay off 

8 their loans. By examining these rates, the 

9 accreditors can hold institutions accountable for 

10 forcing students to take on massive amounts of debt 

11 while failing to give them the tools necessary to 

12 earn enough to repay their loans by revoking those 

13 predatory schools' recognition.

14 Second, we encourage the Department to 

15 take a hard look at job placement rates. Our 

16 experience with predatory for-profits make clear 

17 just how vital accurate job placement rates are to 

18 students and how easily they are manipulated by 

19 predatory schools. 

20 For instance, investigations by my 

21 office revealed job placement rate inflation at 

22 both Corinthian and Westwood. These schools 
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1 counted students as placed when they attended 

2 one-day job fairs or obtained minimum wage 

3 employment outside their fields of study.

4 The Department found similar 

5 systematic misrepresentations of job rates at 

6 certain Corinthian colleges between 2010 and 2014. 

7 ACICS, the accreditor for both Corinthian and 

8 Westwood, failed to verify job placement 

9 statistics, even after findings of fabricated job 

10 placement rates were being made public.

11 Given the importance of these numbers, 

12 the Department must take steps to ensure that 

13 accreditors are actively policing the job 

14 placement rates at accredited institutions. We 

15 encourage the Department to adopt a definition of 

16 job placement similar to that adopted by 39 states 

17 in settlements with EDMC, and to clearly identify 

18 the methodology for determining that rate whenever 

19 it's used.

20 The settlement provides that, 

21 generally speaking, an individual is deemed 

22 employed if they are working in a related field to 
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1 their field of study, the position is permanent, 

2 the position is paid, the position requires a 

3 minimum of 20 work hours per week, and the 

4 individual has been in the position for 30 days.

5 Such a definition would ensure that job 

6 placement rates accurately apprise students of 

7 their potential to be employed in a real job in 

8 their field of study upon graduation. 

9 Third, and finally, we encourage the 

10 Department to require accreditor oversight and 

11 approval of third parties providing instruction at 

12 accredited institutions. The Dream Center, 

13 EDMC's successor, recently attempted to have an 

14 unaccredited third party for-profit entity, 

15 allegedly owned in part by the CEO, teach computer 

16 coding classes for the school.

17 Had the Dream Center not abandoned the 

18 plan, students would potentially have been unable 

19 to transfer credits earned in courses taught by 

20 that third party. 

21 MR. WASHINGTON: Twenty seconds left.

22 MR. JONES: Some accreditors have 
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1 issued guidelines for such shared services 

2 agreements such as the Higher Learning Commission. 

3 To ensure uniformity across accreditors and ensure 

4 students are not receiving unaccredited 

5 instruction, the Department should require such

6 third-party accreditation, and such oversight 

7 should ensure that the third party is providing 

8 services at fair market value and there are no 

9 conflicts of interest between the third party and 

10 the educational institution. 

11 We encourage the Department to consider 

12 the items outlined here today. Thank you very much 

13 for your time.

14 MR. WASHINGTON: Thank you. Analiese 

15 Eicher.

16 MS. EICHER: Good morning. My name is 

17 Analiese Eicher, and I'm the program director at 

18 One Wisconsin Now. We're located in Madison, 

19 Wisconsin. Since Secretary DeVos took office, she 

20 has made every effort to reverse course on higher 

21 education rules meant to protect students and 

22 borrowers. 
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1 Rules respecting state sovereignty and 

2 oversight of distance education have been delayed. 

3 Student loan forgiveness for students defrauded by 

4 their institutions have been ignored and weakened. 

5 And the gainful employment rules protecting 

6 students who graduate from certain programs have 

7 been gutted.

8 The DeVos Department of Education has 

9 indicated that it intends to weaken additional 

10 rules that are vital to the prosperity of students, 

11 their families, and getting the most out of our 

12 taxpayer dollars. DeVos wants to charge students 

13 more, while providing less, by inflating the value 

14 of college courses. 

15 DeVos wants to weaken protections and 

16 requirements for students who are attending 

17 college online by removing a requirement that 

18 professors engage and interact with their students 

19 on a regular basis. DeVos wants to weaken 

20 accreditation standards across institutes of 

21 higher education. And finally, DeVos wants to 

22 limit the oversight role and function of states in 
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1 higher education.

2 Higher education and job training are 

3 a necessity in our changing economy, yet the 

4 actions of the DeVos Education Department to repeal 

5 and modify regulations jeopardize higher 

6 education, our economy, and our people. We need 

7 to strengthen, not weaken, federal and state 

8 oversight of higher education systems.

9 Fewer protections for students and 

10 spending tax dollars on irresponsible institutions 

11 has historically shown to serve students and 

12 taxpayers poorly. Rolling back state oversight 

13 removes states' ability to oversee programs and 

14 protect their citizens. The Department should 

15 allow states to do their job to protect their 

16 constituents and regulate entities within their 

17 borders by keeping this established role.

18 Online college education is growing and 

19 is meant to provide flexible learning experiences 

20 for those who want or need it, while not sacrificing 

21 the quality of the education they are receiving. 

22 By lessening the requirement for online programs 
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1 to provide regular and substantive interaction, 

2 the DeVos Department of Education will take online 

3 education back to a time when institutions ignored 

4 student needs and outsourced instruction to call 

5 centers and non-experts.

6 Accreditation is, and should be, the 

7 stamp of approval and key indicator that guarantees 

8 quality for students and borrowers. Already weak 

9 accreditation laws allow schools to operate and 

10 leave students with worthless or no degrees and 

11 student loans. 

12 And we know that these schools tend to 

13 target and prey on people of color, military 

14 veterans and their families, and low income 

15 individuals. States play an important role in the 

16 oversight of higher education institutions and 

17 affiliation organizations and actors that operate 

18 within their borders.

19 They need strong encouragement from the 

20 federal government, not regulatory rollbacks that 

21 would allow them to not do their job. We've 

22 already seen the dangers of that here in Wisconsin. 
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1 As part of his 2017 budget, Governor Walker 

2 succeeded in eliminating the Educational Approval 

3 Board. The EAB was created in 1944 to oversee 

4 institutions like for-profit colleges and to 

5 protect consumers.

6 The functions of this formerly 

7 independent agency were transferred to the 

8 Department of Safety and Professional Services, 

9 and experienced staff, including the executive 

10 director position, were either eliminated or not 

11 retained and were, instead, replaced by staff with 

12 no experience with the industry.

13 Eliminating and lessening state 

14 oversight can and will have a drastic and negative 

15 impact on borrowers, their families, and 

16 taxpayers. The actions by DeVos and Walker put 

17 Wisconsin students and Wisconsin student loan 

18 borrowers at a unique disadvantage compared to 

19 their peers across the country. 

20 Students and borrowers are not asking 

21 for much. They are asking to be treated fairly in 

22 a system that does not treat them fairly. 
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1 Unfortunately, the DeVos Department of Education 

2 and the Walker administration are moving to make 

3 the problems worse, not better. Thank you.

4 MR. WASHINGTON: Thank you. 

5 Stephanie Sklba.

6 MS. SKLBA: Good morning and welcome, 

7 again, to Gateway Technical College. I'm 

8 Stephanie Sklba. I'm the vice president of 

9 community and government relations here at Gateway 

10 Technical College. I want to thank you for the 

11 opportunity to talk to you today about the 

12 important issue of transcripted and dual credit. 

13 Dual credit offers students to begin 

14 their college education and career while still in 

15 high school, providing a student a chance to earn 

16 college early, saving them time and money and 

17 providing them a clear pathway early in life to 

18 their career. How many of us wish that we would 

19 have figured out earlier in life which direction 

20 we wanted to take? This gives these students that 

21 ability.

22 Many students in Gateway's district do 
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1 engage in transcripted credit. In the 2017-18 

2 academic year, 6,233 students took a total of 

3 14,781 credits, saving them $2.6 million in tuition 

4 costs. These courses were taught by 112 

5 transcripted teachers, high school teachers who 

6 have earned at least a Bachelor's degree and are 

7 certified to teach specific career and technical 

8 education courses.

9 Those 112 teachers teach 70 career and 

10 technical education courses. At this point, we 

11 are unable to offer general studies courses in the 

12 high schools because of a requirement that teachers 

13 hold a Master's degree in the content area that they 

14 will teach in, or a Master's degree with 18 credit 

15 hours in the content area.

16 For instance, to teach math a teacher 

17 must have earned a Master's degree in math or a 

18 Master's degree in another program plus 18 credit 

19 hours of Master's degree level math courses. High 

20 school teachers interested in teaching general 

21 studies classes do not have these certifications.

22 We certainly would like to be able to 
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1 provide the same benefits of CTE courses to 

2 students through offering them general studies 

3 courses. Those benefits of starting their 

4 education and career early, saving money, and 

5 helping them to decide their post-high school path 

6 early. 

7 For students who may feel daunted at the 

8 prospect of college or being in a large pit class, 

9 being able to take college courses at the high 

10 school level can be a confidence booster, too. A 

11 confidence booster that would propel them on to 

12 college or some post-secondary training. 

13 The pool of high school teachers 

14 willing to teach general education courses is 

15 there. A recent poll done by staff at Gateway 

16 showed that 191 teachers in Gateway's tri-county 

17 district said they were interested in teaching dual 

18 credit general studies courses, but do not have the 

19 Master's degree requirement.

20 Again, our goal is to be able to provide 

21 the education-changing benefits of dual credit to 

22 students who want to take those courses through 
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1 teachers who would be qualified to do so. Thank 

2 you for your time.

3 MR. WASHINGTON: Thank you. Our next 

4 speaker is Laura Kite. 

5 MS. KITE: Good morning. My name is 

6 Laura Kite. I'm the assistant dean for student 

7 services for the University of Wisconsin-Extension 

8 Continuing Education, Outreach and E-Learning. 

9 I'm here today to represent UW system president, 

10 Ray Cross.

11 The UW system is one of the largest 

12 systems of public higher education in the country, 

13 serving more than 170,000 students each year, and 

14 employing approximately 39,000 faculty and staff 

15 statewide. 

16 The UW system is made up of 13 four-year 

17 universities, including two doctoral campuses at 

18 UW Madison and UW Milwaukee, and 13 two-year branch 

19 campuses affiliated with seven of the four-year 

20 institutions.

21 The UW system contributes $24 billion 

22 to Wisconsin's economy each year, with a 23 to 1 
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1 economic return on investment. And it is a major 

2 source of research and innovation, with more than 

3 $1 billion of sponsored research activity each 

4 year. 

5 On behalf of the UW system, we are 

6 honored you chose our state as a location for only 

7 one of three public hearings across the country. 

8 I also want to thank our partner, Gateway Technical 

9 College, for hosting this hearing.

10 We support the Department's effort to 

11 modernize existing higher education regulations to 

12 promote greater access for students to high 

13 quality, innovative programs. We're pleased to 

14 have this opportunity to discuss specific 

15 regulations we believe need to be updated to 

16 achieve this goal.

17 We believe to be successful, we must be 

18 innovators. To be innovators, we need our 

19 partners, like the U.S. Department of Education, 

20 to remove rules and regulatory barriers to 

21 innovation. In that spirit, the UW system 

22 supports the Department's inclusion of direct 
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1 assessment, competency-based education, or CBE, 

2 and the proposed agenda for negotiated rulemaking 

3 and committing a separate subcommittee to focus on 

4 this critical issue.

5 Similarly, we support the related 

6 proposed agenda items, including rethinking the 

7 definition of the credit hour and regular and 

8 substantive interaction as they pertain to 

9 expanding opportunities for direct assessment 

10 competency-based education. And finally, 

11 examining ways to provide more flexibility to 

12 accreditors to support direct assessment CBE.

13 Our experience in CBE provides us 

14 firsthand knowledge of why addressing these 

15 specific regulations is critical to the goal of 

16 providing students greater access to high quality, 

17 innovative programs. In 2014 the UW system began 

18 enrolling students in the nation's first public 

19 system of higher education's direct assessment CBE 

20 program, which we call the UW Flexible Options.

21 At the time it was created, an estimated 

22 700,000 to 1 million residents, or about one in five 
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1 working age adults in Wisconsin, had some college 

2 credit but no degree. Wisconsin is also 

3 experiencing a workforce shortage, which is why the 

4 UW system and our partners at the technical 

5 colleges and private universities set a 

6 post-secondary attainment goal of 60 percent by 

7 2027 to meet workforce demands. 

8 To achieve this goal, we built programs 

9 like the UW Flexible Option to specifically provide 

10 access to adults and other returning students who 

11 want a quality degree, but their full-time lives 

12 make it difficult for them to through the 

13 traditional educational system. 

14 Since the Flexible Option's inception 

15 just a few years ago, I'm proud to say the program 

16 offers nine degrees and certificates, serving 

17 almost 1,800 students, with about 300 having 

18 already graduated. The UW Flexible Option is 

19 transforming the delivery of higher education. 

20 Students progress to their degree by mastering 

21 competencies rather than accumulating credit 

22 hours.
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1 With CBE, self-motivated and 

2 self-directed students receive a high quality 

3 education at their own pace at a fraction of the 

4 cost it takes to pursue a traditional on-campus or 

5 traditional online program. 

6 For example, registered nurses who take 

7 the UW flex bachelor of science in nursing program 

8 are completing their degree at their own pace and 

9 often in less than the standard two years of 

10 traditional program. UW flex's BSN outcomes are 

11 exactly the same as that in face-to-face BSN 

12 program and, in fact, the faculty are the exact same 

13 college of nursing faculty from UW Milwaukee. 

14 One area in need of reform to expand the 

15 delivery of CBE learning is the issue or regular 

16 and substantive interaction with an instructor, as 

17 it is currently defined. The current definition 

18 was rightly developed with the goal of safeguarding 

19 taxpayers and students from unscrupulous 

20 providers. 

21 But the current definition also leaves 

22 out modern instructional roles and uses of adaptive 
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1 inter-instructional technologies. Institutions 

2 offering well designed and proactively engaging 

3 CBE programs --

4 MR. WASHINGTON: Twenty seconds left.

5 MS. SKLBA: -- must adhere to current 

6 narrow definition of regular and substantive 

7 interaction or risk having their direct assessment 

8 programs labeled as correspondent study. 

9 We suggest the Department change the 

10 regulation to focus it more directly on regular and 

11 substantive interactions that directly impact 

12 student learning outcomes, while continuing to 

13 protect taxpayers and students against fraud. 

14 Thank you for your time.

15 MR. WASHINGTON: Thank you. Monique 

16 Currie.

17 MS. CURRIE: Good morning. My name is 

18 Monique Currie. I'm a policy analyst with 

19 Wisconsin Technical College system board. The 

20 13-member system board provides guidance and 

21 oversight to the 16 colleges that make up 

22 Wisconsin's technical college system. 
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1 We are Wisconsin's largest higher 

2 education system, educating over 300 students 

3 annually in over 400 degree programs. Programs 

4 range from high quality certificates to one and 

5 two-year technical diplomas to Associate degrees 

6 in fields from advanced manufacturing to 

7 healthcare to IT. 

8 Our colleges are the skill talent 

9 pipeline for Wisconsin. Ninety-four percent of 

10 graduates surveyed are employed six months after 

11 graduation. And 98% of employers surveyed tell us 

12 our colleges are important to the success of their 

13 businesses. 

14 I'd like to start out by conveying tech 

15 college system President Morna Foy's regrets that 

16 she wasn't able to be here today. She's asked that 

17 I express her thanks to Michael Brickman and Aaron 

18 Washington of the Department of Education for their 

19 efforts in bringing this public hearing to 

20 Wisconsin and, especially, to the campus of one of 

21 our technical colleges. We appreciate your work 

22 to broaden the dialog and hear from those of us 
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1 outside the beltway.

2 As the Department plans its 2019 

3 rulemaking agenda, we would ask you to consider the

4 following issues, many of which relate directly to 

5 newer paradigms for delivering higher ed. First, 

6 the federal rules which define the term regular and 

7 substantive interaction were derived many years 

8 ago, prior to today's technology, and should be 

9 updated.

10 Further, the definition should be 

11 expanded to include other meaningful types of 

12 interactions, such as those provided by mentors. 

13 Both changes are critical for students in rural 

14 communities where traditional in-class 

15 educational opportunities are limited or may be 

16 located a great distance, as well as the many 

17 students who work full-time while attending school 

18 and whose demanding schedules leave little time for 

19 8:00 to 5:00, Monday through Friday classroom 

20 instruction.

21 Second, the public and individual 

22 disclosure requirements found in the distance 
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1 education regulations are unrealistic and 

2 burdensome for our colleges. They should be 

3 eliminated or, at the very least, severely 

4 minimized. 

5 Third, we also ask the Department of 

6 Education to reconsider the credit hour standard, 

7 and provide flexibility on this issue. Current 

8 Department rules over rely on the credit hour as 

9 the basis of awarding academic credit. Again, 

10 it's difficult to apply this standard to new and 

11 growing paradigms of educational delivery, 

12 including online competency-based and prior 

13 learning assessment models.

14 Lastly, as you heard from my colleague 

15 from Gateway Technical college, while we do support 

16 the current regional accreditation system, we 

17 would ask you to reconsider the negative impact 

18 that the higher learning commission's new 

19 requirement that high school teachers who teach 

20 dual enrollment courses must have a Master's degree 

21 or 18 graduate credits in the subject areas they 

22 teach.
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1 What do we mean by dual enrollment? 

2 Dual enrollment, and specifically, this case 

3 transcripted credit, allows high school students 

4 to earn college credit by attending courses at 

5 their local area high school as taught by their 

6 local high school teachers, who are teaching our 

7 college level curriculum.

8 Dual enrollment allows high school 

9 students to reduce the time it takes to earn a 

10 post-secondary degree or credential and, overall, 

11 reduce the cost of higher education. Many high 

12 school teachers do not have advanced degrees beyond 

13 a bachelor's in the subject areas they teach, and 

14 will have to refrain from teaching dual enrollment 

15 classes with this new requirement.

16 The education requirements from the 

17 higher learning commission will reduce the 

18 availability of qualified teachers, as mentioned 

19 by Stephanie Sklba, and therefore limit the 

20 opportunities of high school students to earn 

21 college credit not only in Wisconsin, but in many 

22 other states. 
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1 Our technical colleges will work hard 

2 to ensure that high school faculty teach our 

3 college level courses with the same content and 

4 rigor as those taught by the faculty on our 

5 campuses. No advanced degree can guarantee that. 

6 Thank you for the opportunity to share our 

7 concerns. Addressing these issues will give our 

8 colleges the flexibility they need to serve our 

9 students and meet our state's growing workforce 

10 needs.

11 MR. WASHINGTON: Thank you. Monique 

12 Currie was our last speaker before our scheduled 

13 break at 10:30. Is Dr. Barbara Gellman-Danley, 

14 okay, you can come up.

15 DR. GELLMAN-DANLEY: Good morning. 

16 I'm Barbara Gellman-Danley, president of the 

17 Higher Learning Commission and chair of the Council 

18 of Regional Accrediting Commissions. Thank you 

19 for this opportunity. C-RAC already submitted a 

20 separate letter, so today I have a singular issue 

21 on which I want to focus; innovation.

22 I believe you'll be excited about the 
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1 work at our agency to promote innovation and find 

2 ways to build an accreditation system responsive 

3 to the dynamic changes in higher education. In 

4 2016, the Higher Learning Commission launched its 

5 strategic plan entitled beyond the horizon, aptly 

6 named to be forward looking and visionary.

7 With generous support from the Lumina 

8 Foundation, initiatives were established to 

9 support two parts of the plan, innovation and 

10 student success. In light of the plan, I want to 

11 tell you about that works and the critically 

12 important need to introduce flexibility and vision 

13 into negotiated rulemaking discussions.

14 Our project participants are in the 

15 process of presenting us unprecedented ideas for 

16 high education. And without a shift in the 

17 regulations, some will likely never see the light 

18 of day. Why does this matter? Accreditors are 

19 strong influencers and opinion leaders in higher 

20 education, and we want to remove the anchors that 

21 keep new ideas and innovation tethered to the 

22 shores of the past.
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1 For one initiative, HLC established a 

2 think tank of nationally recognized leaders; we 

3 call it the partners for transformation. It 

4 includes leaders such as Michael Crow, president 

5 of Arizona State University, a national leader in 

6 higher education innovation or, as he calls 

7 himself, a knowledge enterprise architect.

8 We also have representation from 

9 alternative providers and several types of 

10 colleges and universities, as well as Arthur Levine 

11 from the Woodrow Wilson Foundation who often 

12 reminds us that we are operating with a very old 

13 model from an agrarian society in higher education, 

14 despite living in a technological world.

15 In addition to the partners, we are 

16 receiving incredible recommendations from an 

17 innovation zone initiative and two on student 

18 success, all made up of some of the greatest 

19 thinkers in this country. What are they telling 

20 us? Keep regional accreditation, but make it 

21 stronger. Remove the shackles of old regulations 

22 that we are responsible for enforcing, even if we 
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1 know they have little to do with our main mission, 

2 quality assurance.

3 Re-examine the credit hour. Allow us 

4 to try experimental pilot programs without going 

5 through arduous approvals at the federal and state 

6 level, while also protecting our consumers. Let 

7 us move forward in new ways to serve these students, 

8 while also assuring that if something fails treat 

9 that as a learning experience without fear of 

10 punishment from either the accreditors, the 

11 Department of Education or the Office of the 

12 Inspector General.

13 Do not sit on the sidelines as other 

14 groups are formed to look at quality assurance and 

15 add complexity. Clarify opaque definitions and 

16 processes, such as regular and substantive faculty 

17 interaction. Pilot regional accreditation 

18 innovation projects that include alternative 

19 providers, new forms of credentialing and 

20 recognition of differences among institutions.

21 Our goal is singular; allow regional 

22 accreditors to be positioned to assure that this 
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1 country strengthens its already remarkable fleet 

2 of institutions that serve our learners of all ages 

3 and backgrounds. 

4 My ask today is simple. As negotiated 

5 rulemaking proceeds, involve us in the 

6 discussions. Do not place too much in one group; 

7 create appropriate sub-groups such as innovation. 

8 Be courageous. Create an environment where 

9 innovation can take place for the sake of our 

10 students and the future economic and intellectual 

11 growth in this country and globally.

12 See beyond the horizon, looking forward 

13 to new ways we can increase educational attainment. 

14 I encourage policymakers to listen to us, 

15 accreditors, as experienced educators and leaders 

16 who are committed to creating the most functional 

17 regional accrediting system for the 21st century.

18 And I implore you to take the 

19 recommendations of our HLC innovators into 

20 consideration, and we will be glad to share them 

21 at the appropriate time. Let's use this 

22 opportunity to work as two parts of the triad; the 
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1 states, the Federal Government and regional 

2 accreditors. 

3 The Higher Learning Commission has a 

4 long and proud history of working very closely with 

5 the state. We invite the Federal Government to 

6 join us. Focus on the stakeholders that matter, the 

7 students. Step off the shore where we are held by 

8 the sands of the past, and move forward. We can 

9 be the lighthouses in that journey. Thank you.

10 MR. WASHINGTON: Thank you. I'm going 

11 to keep moving forward. Just in case we have any 

12 additional speakers in the afternoon that aren't 

13 currently here that would like to be known. Jon 

14 Shelton. Dr. David Forstein, Nicholas Kent, 

15 Michael Rosen, Nicholas Fleisher, Greta Neubauer, 

16 Jeffrey Sommers, and Luz Sosa.

17 Okay, it looks like we have no 

18 additional speakers until 11:00 a.m. If anybody 

19 is here who hasn't spoken that wishes to speak, can 

20 come step forward to the podium now. And, if not, 

21 we will wait until our next speak arrives to 

22 continue the hearing.
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1 (Slight pause.)

2 MR. WASHINGTON: So, we decided to go 

3 ahead and take an official break until 11:00 a.m.

4 (Off the record.) 

5 MR. WASHINGTON: Our first speaker is 

6 Jon Shelton.

7 MR. SHELTON: Hello there, and thank

8 you for holding these hearings. My name is Jon 

9 Shelton, and I am associate professor at the 

10 University of Wisconsin Green Bay. My institution 

11 is not an elite institution. Most of my students 

12 come from working class families, and many of them 

13 are first generation college students. 

14 They see public higher education as a 

15 promise, and they trust us to make sure that their 

16 institution serves their interest by giving them 

17 instruction from experts. They trust us to give 

18 them instruction that is affordable and will help 

19 them find their place as citizens and workers in 

20 the modern world. Though it isn't perfect, my 

21 university does an excellent job of giving them 

22 affordable, high quality instruction. 
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1 But there are other institutions out 

2 there, as we've learned in recent years, especially 

3 for-profit institutions; not always, but that's 

4 often the case, that don't have similarly situated 

5 students' best interests at heart. 

6 And this new rulemaking process the 

7 Department of Education is considering could very 

8 well make it easier for these kinds of institutions 

9 to prey on them. The United States, going back to 

10 the 19th and well over the course of the 20th 

11 century, has been a pioneer in facilitating high 

12 quality, and then later in the 20th century, 

13 affordable higher education.

14 We know that quality post-secondary 

15 public education helps development good 

16 citizenship and gives students the capability to 

17 think critically and creatively. American 

18 graduates of higher education, because of these 

19 virtues of the education system, have done much of 

20 the work that has made the American economy a world 

21 powerhouse.

22 It's no wonder that so many Americans, 
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1 especially young people, seek higher education. 

2 Unfortunately, without safeguards, predatory 

3 institutions like ITT Tech and Corinthian Colleges 

4 exploit their thirst for higher education. 

5 The Education Department already, I 

6 understand, has reinstated the accrediting council 

7 for independent colleges and schools, which was 

8 responsible some several years ago for allowing 

9 for-profits to misrepresent the kind of education 

10 these students were getting, while raking in 

11 federal dollars that students were supposed to pay 

12 back.

13 When students take out loans at an 

14 institution that does not provide them a worthwhile 

15 education, they suffer twice. First from the 

16 waste of time and effort and what economists call 

17 the opportunity cost. And second, from the fact 

18 that they're now stuck with loans that they can 

19 virtually never discharge. 

20 Not being able to pay it back can ruin 

21 their lives. And ultimately federal tax dollars 

22 go to enrich private corporations. We should be 
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1 skeptical of any new rulemaking by an education 

2 department that moved to allow the ACICS to once 

3 again monitor for-profit colleges. 

4 Higher education may not be perfect in 

5 the United States. More students need more access 

6 to high quality universities and technical 

7 colleges. We have to make it more accessible too, 

8 particularly, to minorities who have been 

9 historically excluded. There needs to be much 

10 more public investment to reduce the cost for all 

11 our young people, and older people, who are 

12 engaging in lifelong learning.

13 And we need to move toward guaranteeing 

14 debt-free college education for everybody. That 

15 needs to be one of our long-term goals in this 

16 country. Compromising what has made higher 

17 education in the U.S. the envy of the world, 

18 however, including as I understand it, these are 

19 things that this rulemaking process could do, 

20 reducing access to expert instruction and 

21 subcontracting out instruction to unaccredited 

22 bodies; these are both things that I think this 
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1 process could do, from what I understand. 

2 It's certainly not the way to make 

3 higher education more accessible. We need to 

4 enhance Americans access to affordable, high 

5 quality, post-secondary education. That means 

6 strengthening safeguards for students, not 

7 weakening critical safeguards that would, once 

8 again, open the door to let predatory for-profit 

9 colleges exploit working Americans' thirst for 

10 higher education. Thank you.

11 MR. WASHINGTON: Thank you. Dr. David 

12 Forstein. Nicholas Kent. Well, what I'm doing 

13 right now is, we do not have another speak signed 

14 up to speak until 11:30. So, if you are signed up 

15 after noon and you wish to speak now, you can step 

16 forward to the podium. 

17 Of course, we will honor if you wanted 

18 to wait and not speak until the time that you were 

19 assigned. So, if we don't have anybody signed up 

20 that, if we do have people in attendance that are 

21 signed up for after noon and don't wish to speak 

22 until their assigned time, we will wait until 11:30 
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1 when our next speaker is scheduled to speak.

2 (Off the record.) 

3 MR. WASHINGTON: Our first speaker is 

4 David Forstein.

5 DR. FORSTEIN: Good morning. My name 

6 is Dr. David Forstein, and I am dean of the Touro 

7 College of Osteopathic Medicine in New York City. 

8 I also serve as the vice chair of the American 

9 Osteopathic Association's commission on 

10 osteopathic college accreditation, known as the 

11 COCA.

12 This year, the Secretary of Education 

13 renewed the COCA's recognition as the only 

14 accrediting agency of institutions and programs 

15 that award the Doctor of Osteopathic Medicine or 

16 DO degree. Thank you for the opportunity to 

17 present comments on behalf of the COCA. 

18 We commend the Department of Education 

19 for initiating a new negotiated rulemaking process 

20 to address some of the shortcomings of the current 

21 gainful employment regulations, particularly as 

22 they are applied to graduate and professional 
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1 schools. 

2 As the Department begins to consider 

3 its changes to the regulations, we ask that you 

4 consider the value of graduate level professional 

5 programs, such as osteopathic medical education, 

6 to the nation. And we further ask that any 

7 revisions of gainful employment rules be done to 

8 enhance and increase opportunities to provide such 

9 education.

10 Please allow me to tell you a little 

11 about the COCA. This summer, the Secretary again 

12 recognized the COCA to accredit institutions and 

13 programs that lead to the DO degree. The COCA has 

14 enjoyed this recognition since 1952 without 

15 interruption. 

16 Accordingly, the COCA serves the public 

17 by establishing, maintaining and applying 

18 accreditation standards and procedures to ensure 

19 the academic quality and continuous quality 

20 improvement delivered by the colleges of 

21 osteopathic medicine, reflecting the evolving 

22 practice of osteopathic medicine.
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1 The scope of COCA's authority and 

2 competent accreditation for both non-profit and 

3 for-profit colleges of osteopathic medicine, and 

4 the COCA is the only accrediting agency to accredit 

5 osteopathic medical schools in the United States.

6 Currently, there are 34 accredited 

7 osteopathic medical schools operating on 51 

8 campuses. Between now and 2020, the COCA expects 

9 to have a nearly 25 percent increase of campuses, 

10 consisting of non-profit and for-profit new 

11 schools, new branch campuses and new additional 

12 locations.

13 Graduates of accredited COMs earn a 

14 degree of doctor of osteopathic medicine. In the 

15 United States, physicians licensed to practice are 

16 either DOs or MDs. DOs practice in every medical 

17 specialty, applying a patient-centered, whole body 

18 philosophy to treat their patients.

19 DOs are also one of the fastest growing 

20 segments of healthcare professionals in the United 

21 States. Currently, there are more than 105,000 

22 DOs, some 15 percent of all U.S. physicians in 
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1 active medical practice. And one out of every four 

2 medical students is in an osteopathic medical 

3 school.

4 With the anticipated growth of 

5 osteopathic medical schools, the gap between 

6 osteopathic medical students and allopathic or MD 

7 medical students will get narrower in just a few 

8 short years. With this narrowing gap, the 

9 correspond gap between the number of DOs and MDs 

10 in the United States will decrease. 

11 While DOs practice in all medical 

12 specialties, more than 60 percent of all DOs 

13 specialize in primary care. That includes family 

14 medicine, general internal medicine, emergency 

15 medicine and pediatrics. Osteopathic medical 

16 schools and training programs also provide care to 

17 rural patient populations for whom gaps in access 

18 to care are more pronounced.

19 The COCA is pleased to support 

20 educational opportunities for future physicians in 

21 these geographical areas and in the most needed 

22 specialties, and to support workforce development 
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1 to address healthcare provider shortages. 

2 As the COCA accredits both non-profit 

3 and for-profit medical schools, whether a medical 

4 school is a non-profit or for-profit institution, 

5 the COCA imposes the same accreditation standards. 

6 The current rigor of the gainful employment 

7 regulations requires more accountability by these 

8 medical schools, and will result in improved 

9 student outcomes, such as residency placement, 

10 higher licensing exam rates, and other measures of 

11 success for a medical school that includes lower 

12 loan default rates upon graduation.

13 Such outcomes will provide prospective 

14 students with the necessary information to 

15 determine which institution would provide the best 

16 investment in their future education. In addition 

17 to any undergraduate debt, osteopathic medical 

18 school graduates can typically expect to graduate 

19 with more than $200,000 in student loan debt with 

20 large monthly loan payments immediately following 

21 graduation, when they are still in training in at 

22 least three-year residency programs required for 
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1 state medical licenses, and potentially an 

2 additional one to three-year fellowship, depending 

3 on specialty.

4 However, as soon as they complete this 

5 training, their income will increase 

6 exponentially. This increase in income is in 

7 stark contrast to other careers which may not 

8 incorporate extensive post-graduate training.

9 MR. WASHINGTON: Twenty seconds left.

10 DR. FORSTEIN: We appreciate the 

11 Department's intent to rescind gainful employment 

12 regulations. However, we suggest the Department 

13 carefully consider the unique nature of certain 

14 programs, such as medical schools, and develop 

15 appropriate metrics for each category of programs. 

16 Finally, medical schools are in short 

17 supply in many geographic areas in the United 

18 States, particularly in rural parts of the country. 

19 The Department should consider the impact of 

20 rescission on the gainful employment regulations 

21 could have on the success on medical school 

22 graduates who wish to pursue medical careers in 
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1 areas where physician shortage exists.

2 We urge the Department to reconsider 

3 rescinding the gainful --

4 MR. WASHINGTON: You're now over time.

5 DR. FORSTEIN: Time's up?

6 MR. WASHINGTON: Yes.

7 DR. FORSTEIN: Thank you.

8 MR. WASHINGTON: Thank you. So, I'm 

9 going to go slightly out of order. Nicholas 

10 Fleisher.

11 MR. FLEISHER: Thank you. My name is 

12 Nicholas Fleisher. I live in Milwaukee, 

13 Wisconsin. I'm an associate professor of 

14 linguistics at the University of Wisconsin, 

15 Milwaukee, and I'm also here today in my capacity 

16 as president of the Wisconsin State Conference of 

17 the American Association of University Professors, 

18 the AAUP.

19 AAUP Wisconsin joins faculty and 

20 student groups around Wisconsin and across the 

21 country in condemning rulemaking changes that 

22 would degrade the quality of American higher 
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1 education. Under its current leadership, the 

2 Department of Education has worked actively to 

3 loosen constraints on for-profit operators and 

4 rollback protections meant to ensure quality and 

5 value for students.

6 The current round of negotiated 

7 rulemaking is designed to further this erosion of 

8 standards. We object. One of the changes the 

9 Department of Education seeks is to water down the 

10 definition of regular and substantive interaction 

11 in higher education. This change of the 

12 piece with ongoing efforts to denigrate 

13 de-professionalize teachers at all levels in 

14 American education.

15 These efforts fly in the face of the 

16 basic truth; teaching and learning go together. 

17 Any innovation that decouples a student's learning 

18 experience from extensive contact with experienced 

19 teachers will harm the quality of that student's 

20 education. We call the Department's attention to 

21 this basic truth about the domain over which it 

22 exercises regulatory authority.
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1 The AAUP advocates for faculty rights 

2 and responsibilities in American higher education. 

3 It does so in the interest of maintaining the high 

4 education quality that can only come from a strong, 

5 independent, professional teaching workforce. 

6 This redounds to the benefit of students, and it 

7 has made the United State the undisputed world 

8 leader in higher education.

9 The Department of Education now seeks 

10 to dismantle the regulatory framework that has 

11 allowed higher education to flourish in this 

12 country. We call on the Department of Education 

13 to abandon this destructive path and, instead, to 

14 embrace its true mission; to promote and safeguard 

15 educational quality at all levels. Thank you.

16 MR. WASHINGTON: Thank you. Michael 

17 Rosen.

18 MR. ROSEN: My name is Michael Rosen. 

19 I recently retired from Milwaukee Area Technical 

20 College, where I taught economics for 29 years. 

21 MATC is one of the largest two-year colleges in the 

22 nation, with more than 40,000 students. The 
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1 majority of students are of color and economically 

2 disadvantaged. 

3 I'm appearing before you today to urge 

4 you to restore the gainful employment rule that 

5 ensures that students who attend college with noble 

6 academic and employment aspirations are not left 

7 unemployed or underemployed with huge debts they 

8 have no possibility of paying back.

9 I became an advocate for gainful 

10 employment based on my own experience and that of 

11 dozens of former for-profit college students I have 

12 met and worked with. I first became acquainted 

13 with for-profit colleges when Everest College, 

14 affiliated with Corinthian, opened in Milwaukee. 

15 Less than two years after it opened, it closed. 

16 As it had in other cities, Everest 

17 enticed low-income students with the promise they 

18 would find gainful employment after they completed 

19 their studies, encouraged and sometimes coerced 

20 them to take out huge loans to pay tuition for 

21 programs that cost four times what they would have 

22 paid for the same courses at Milwaukee Area 
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1 Technical College, and had many more students drop 

2 out than graduate.

3 An article in the Milwaukee Journal 

4 Sentinel documented this. More than half of the 

5 1,585 students who enrolled when the school opened 

6 in 2010 dropped out. Everest only placed 95 

7 students, less than six percent of the enrolled. 

8 By comparison, according to the 

9 Wisconsin technical college annual graduate 

10 follow-up report, 88 percent of graduates from the 

11 technical colleges were employed within six months 

12 of graduation. And 71 percent were employed 

13 directly in their field.

14 One of the Everest College students was 

15 Michelle Reise whose testimony I supplied to this 

16 Department five years ago at a hearing in 

17 Minneapolis. Her experience is like many others 

18 who have been lured into attending for-profit 

19 colleges by the promise of an accelerated academic 

20 program that will lead to immediate and gainful 

21 employment.

22 She wrote I graduated with a 4.0 GPA and 
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1 was an Everest ambassador. My credentials speak 

2 for themselves. I have only had three interviews 

3 for offices in my field, all of which I found on 

4 my own, with no help from Everest. 

5 They promised me, based on their 

6 advertising, a better life, and that they would 

7 place me in my desired field of study. Everest was 

8 not the start of a better life, but more of a 

9 beginning of a long, still unfinished nightmare, 

10 leaving me with a large amount of debt, $15,000, 

11 and no new start. 

12 Karen Kilpatrick, an Everest grad wrote 

13 everything they promised me was a lie. I could 

14 talk all day about how my decision to go to this 

15 career college ruined my life. But, 

16 unfortunately, I don't have enough time in my day 

17 because I am working two jobs as a housekeeper and 

18 personal aide, and have two children to take care 

19 of.

20 My intentions were to give my children 

21 a better future by bettering myself through 

22 education. Everest ripped that dream away from 
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1 me, and is the reason I am struggling today with 

2 $12,000 in debt.

3 Or listen to Antonia Fuentes. I 

4 enrolled in the criminal justice program at 

5 Sanford-Brown. My recruiter embellished on the 

6 career outlook, promised a brighter future with a 

7 favorable career from a salary level of $40,000 

8 annually to success stories plastered on the walls. 

9 It was all an advertisement to recruit 

10 vulnerable students to enroll in their bogus 

11 programs. The credits I earned were 

12 non-transferrable to any four-year program. I 

13 found myself stuck with close to $30,000 in debt 

14 that I may never be able to pay back. It has been 

15 almost four years since I graduated, and I am 

16 without a job in the field of study. 

17 These are a sample of the testimonies 

18 I submitted five years ago. But all of them 

19 indicate that students, many of whom had no 

20 experience with higher education, were lured into 

21 enrolling in for-profit colleges by aggressive 

22 recruiting and marketing techniques, the promise 
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1 of accelerated classes and effective job placement 

2 services.

3 Yet, they wind up with their dreams 

4 destroyed, credits that do not transfer, huge debts 

5 they cannot possible pay back, and no gainful 

6 employment. The United States Senate study of 

7 for-profit and proprietary colleges came to the 

8 very same conclusion. 

9 The reason there are so many 

10 dissatisfied students, so many lawsuits by 32 state 

11 attorney generals investigating for-profits, and 

12 even why the Trump --

13 MR. WASHINGTON: Twenty seconds left.

14 MR. ROSEN: -- administration reached 

15 a $25 million settlement is that this is a business 

16 model, not and education model. I urge you to 

17 restore the gainful employment rule. 

18 In my testimony, which I guess I can't 

19 give because I've used up my time, but I will 

20 provide in written form, I have addressed many of 

21 the rule changes, including accreditation, 

22 including the relationship between faculty and 
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1 students, and many of the other rules changes that 

2 you are discussing. 

3 So, I'd like to submit this if it's 

4 possible, and I appreciate you taking the time to 

5 come through Wisconsin. Welcome, by the way, to 

6 Sturtevant and southeastern Wisconsin, and thank 

7 you very much. Should I give this to you?

8 MR. WASHINGTON: Yes, if you can give 

9 me a copy. 

10 MR. ROSEN: I only have one copy.

11 MR. WASHINGTON: If you want to submit 

12 it electronically, you can, as well.

13 MR. ROSEN: Who would I submit that to?

14 MR. WASHINGTON: So, individuals can 

15 submit commits electronically to the Department of 

16 Education by tomorrow at 11:59 p.m. You would go 

17 to www.regulations.gov. You type in 

18 ED-2018-OPE-0076 and you can submit comments. For 

19 anybody who needs that information, you can come 

20 forward and I will write it down for you.

21 MR. ROSEN: I would appreciate that.

22 MR. WASHINGTON: Okay, thank you. You 
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1 can take a seat now. I'll bring it to you.

2 MR. ROSEN: Okay, thank you.

3 MR. WASHINGTON: We do have several 

4 other speakers signed up for the afternoon. If 

5 anybody is here, after 12:00 p.m. If anybody's 

6 here that's assigned to speak after 12:00 p.m., and 

7 wishes to come to the podium now, you may approach. 

8 If you do not choose to, we will begin at 12:15. 

9 (Off the record.) 

10 MR. WASHINGTON: Nicholas Kent.

11 MR. KENT: Good afternoon. My name is 

12 Nicholas Kent, Senior Vice President of policy and 

13 research at Career Education Colleges and 

14 Universities. On behalf of CECU and its members, 

15 I want to extend my appreciation to the Department 

16 for holding these important public hearings. 

17 We applaud the Department for proposing 

18 a comprehensive list of regulatory issues to be 

19 considered as part of the negotiations. These 

20 topics include, but are not limited to the core 

21 functions of accreditation, state authorization, 

22 developing a single definition for reporting and 
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1 measuring job placement, and the concept of the 

2 term credit hour.

3 I will briefly address each of these 

4 topics, but to start I'd like to provide feedback 

5 on the upcoming negotiated rulemaking process. 

6 Due to the indisputable need to develop new or 

7 revised regulations in each of the proposed topic 

8 areas, we fully endorse the Department designating 

9 one rulemaking committee with responsibility to 

10 address the list of issues listed in the July 31 

11 Federal Register Notice.

12 However, due to the variety and 

13 complexity of the proposed topics, we recommend the 

14 Department consider convening additional 

15 subcommittees, beyond the two already planned, to 

16 help inform the rulemaking committee's work. 

17 We believe that this committee 

18 arrangement, i.e., one rulemaking committee and 

19 several subcommittees, along with the Department's 

20 plan to provide draft regulatory language for 

21 discussion prior to the first meeting of the 

22 committee will lead to a more meaningful debate of 
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1 the issues with a higher likelihood the rulemaking 

2 committee will reach consensus. 

3 The current version of the Higher 

4 Education Act was last fully reauthorized in 2008, 

5 and so much has changed in the last decade, 

6 including student demographics, program offering 

7 and delivery models. Thus, we applaud the 

8 Department for recognizing the need to update 

9 regulations that prevent access to quality 

10 programs, stifle innovation and impede on 

11 institutional and academic freedoms.

12 To begin, we must acknowledge the 

13 current regulatory triad is broken. Under this 

14 checks and balances system, each of three important 

15 actors should play a distinct role in protecting 

16 students and taxpayers. 

17 For example, the Federal Government 

18 historically attended to issues related to 

19 financial capacity. State government 

20 concentrated on consumer protection. And 

21 accreditors focused on academic quality and 

22 improvement. Unfortunately, in recent years, the 
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1 lines of responsibility between these three actors 

2 have become increasingly blurred beyond the notion 

3 of shared responsibility.

4 We advocate for a framework where there 

5 are discrete roles and responsibilities for each 

6 actor of the triad. One critique we often hear of 

7 the current accreditation system is that it 

8 restricts innovation, limits colleges' abilities 

9 to try new organizational and delivery models, and 

10 is costly.

11 For example, the proprietary sector has 

12 been handcuffed by both the demands for new 

13 programs and inability to get necessary approvals 

14 from accreditors or the Department in a timely 

15 fashion. We must find ways for accreditors and the 

16 Department to provide low-risk institutions 

17 approvals more expeditiously. 

18 Also, any change to the Secretary's 

19 recognition criteria must reduce challenges of 

20 students transferring college credits. In 

21 today's higher education environment, students' 

22 pursuit of post-secondary education often includes 
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1 transferring from one school to another. 

2 However recent studies, including one 

3 published in 2017 by the GAO, suggest the cost that 

4 students and taxpayers incurred through the lack 

5 of academic credit transfer is significant.

6 In addition to improve the core 

7 functions of accreditation, the process by which 

8 accreditors are recognized must also be changed. 

9 Notable, no sector has been more impacted by the 

10 recent politicization of the NACIQI than the 

11 proprietary sector. 

12 We recognize there are limits to the 

13 changes the Department can make to NACIQI in this 

14 area during the rulemaking process, but there are 

15 steps the Department can and must take to ensure 

16 future fairness for all accreditors and 

17 institutions.

18 First, NACIQI just recognize its role 

19 as advisory, providing impartial advice to the 

20 Secretary. Second, the format of NACIQI meetings 

21 must be overhauled. And finally, we recommend 

22 creating common definitions for all performance 
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1 indicators used by committees to review agency 

2 effectiveness.

3 Every student, family and policymaker 

4 deserves to know the expected outcomes of programs, 

5 and the ability to compare these data to similarly 

6 situated programs at other institutions. 

7 However, this can only be achieved through 

8 consistently defined outcome indicators across all 

9 sectors. 

10 The first step is developing easy to 

11 understand federal definitions and methodologies 

12 for indicators students and families believe are 

13 most important in defining academic quality, 

14 including placement. We must also recognize 

15 technology innovation in our educational and 

16 student services delivery models. Yet, we also 

17 must recognize the cost of burdensome regulations.

18 Accordingly, the concept that 

19 institutions offering online programs be required, 

20 for FSA eligibility purposes, to obtain 

21 authorization from each state in which the 

22 institution enrolls is a waste of institutional 
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1 resources and better directed towards student 

2 learning. 

3 We believe reciprocity agreements are

4 just one appropriate mechanism for states to 

5 address balancing quality and consumer protection. 

6 No sector of higher education is more engaged in 

7 experiential learning ours, and the use of the 

8 over-limiting definition of a credit hour doesn't 

9 fit today's students or today's programs. And 

10 dare I say, it is the imposition of a new 

11 construction on seat time.

12 As a result, we propose repealing the 

13 federal definition of a credit hour, and 

14 re-empowering accreditors with the core academic 

15 responsibility of measuring students' work. This 

16 administration's call for comments and the 

17 ambitious rulemaking agenda proposed reflects the 

18 urgent need for us to modernize the delivery of 

19 today's post-secondary education system.

20 We stand ready as a sector, to provide 

21 the Department with further input and 

22 recommendations as it proceeds with this important 
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1 work. Thank you. 

2 MR. WASHINGTON: Thank you. Is 

3 Jeffrey Sommers here? Okay, Luz Sosa.

4 MS. SOSA: Hello everyone. My name is 

5 Luz Sosa. I'm an instructor of economics at 

6 Milwaukee Area Technical College. I am one of the 

7 44 million Americans struggling with student loan 

8 debt. When I graduated from college in 2010, I had 

9 graduated with $67,000 in debt. Today, after 

10 paying for eight years, I owe $84,000.

11 When I got my loans, I got them at zero 

12 to two percent and over time, because of Congress's 

13 actions in increasing interest rates and selling 

14 our debt to private entities, my interest rates 

15 went up to 8.8 percent, which makes it almost 

16 impossible to pay off my debt with a $60,000 salary. 

17 Like I said, my story is not unique 

18 because I'm one of 44 million Americans who are 

19 struggling today with student loan debt, and seven 

20 million people have already defaulted. 

21 So, this takes me to the point of why 

22 we're here today. The deregulation of the college 
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1 system and higher education is going to bring new 

2 problems for students who are graduating from 

3 for-profit universities. Because according to 

4 the Institute for College Access and Success, the 

5 average for-profit college graduate finishes 

6 schools with $49,000 of student loan debt compared 

7 to only $25,000 for the average public college 

8 graduate.

9 Additionally, the percentage of 

10 students with debt also increases substantially 

11 when comparing for-profit and the public school 

12 students. Eighty-eight percent of for-profit 

13 graduates carry loans where only 66 percent of 

14 their public school counterparts do the same. 

15 Studies also indicate that for-profit students 

16 account for nearly half of all student loan 

17 defaults in the nation. 

18 Also, the Brookings report examined two 

19 cohorts of students, one that entered college in 

20 1996, and one that entered in 2004. The study 

21 found that for-profit borrowers default at twice 

22 the rate of public two-year borrowers. But since 
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1 for-profit students are more likely borrower, they 

2 default at four times the rate of public two-year 

3 students, as a whole.

4 So, the default rate is rising. In the 

5 1996 cohort, 23 out of every 100 for-profit 

6 students defaulted within 12 years of starting 

7 college. For the 2004 cohort, the number jumped 

8 to 43 students out of every 100. And this point 

9 is too often the higher prices for-profits charge 

10 aren't correlated with better educational 

11 outcomes.

12 Many students don't learn as much as 

13 they had anticipated and they don't complete their 

14 degrees at all making it more difficult to pay back 

15 the loans. The root of the problem is that the 

16 for-profit sector continues to benefit from public 

17 financing despite its relatively poor results, 

18 prompting a severe lack of accountability.

19 Why does the for-profit sector generate 

20 these terrible outcomes? That is very simple. 

21 Because the terrible outcomes are very profitable 

22 and there are no adverse consequences against these 
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1 for-profit colleges that take advantage of both the 

2 students and the taxpayers. And yet, continue to 

3 be in good standing to victimize people.

4 These people are usually more likely to 

5 be first generation Americans, low-income students 

6 who might struggle to pay back loans regardless of 

7 the type of institution they attend. The research 

8 suggests that for-profit students still see worse 

9 outcomes than their peers at public or non-profit 

10 private schools. 

11 Even their backgrounds are corrected 

12 for. One study found that the certificate seeking 

13 students at for-profit schools are less likely to 

14 be employed after graduation than their 

15 counterparts at any other type of school, and that 

16 their earnings are, on average, lower; results that 

17 held true for seven of the 10 top fields of study.

18 We need to advocate for our students, 

19 and make sure that the changes that occur are for 

20 their well-being. We must advocate for the 

21 enforcement and expansions of what is currently 

22 known as gainful employment rules, which require 
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1 students of for-profit programs to meet a certain 

2 debt to earnings ratio to qualify for student aid. 

3 Deregulation is what brought us the 

4 great recession in 2008, and I hope that we have 

5 learned from our mistakes. We must learn that when 

6 we leave the consumers at the mercy of 

7 corporations, they will only take advantage of them 

8 for the sake of profit.

9 MR. WASHINGTON: Time.

10 MS. SOSA: We must continue to regulate 

11 this industry and make sure --

12 MR. WASHINGTON: Your time has 

13 expired.

14 MS. SOSA: Oh, I'm sorry. Just one 

15 sentence. And we keep increasing the quality of 

16 higher education by protecting students and 

17 taxpayers from these for-profit loan predators. 

18 Thank you.

19 MR. WASHINGTON: Thank you. Greta 

20 Neubauer? Jeffrey Sommers? Okay, we will break 

21 until the last two speakers arrive.

22 (Off the record.) 
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1 MR. WASHINGTON: Greta Neubauer.

2 MS. NEUBAUER: Thank you. My name is 

3 Greta Neubauer and I'm a state representative from 

4 Racine, Wisconsin. I am also a millennial, and 

5 it's that experience that I'm going to speak to 

6 today. I grew up believing that this country stood 

7 for opportunity. 

8 Between the Statue of Liberty on my 

9 history textbook and what I learned in my classes, 

10 I believed that with an understanding of our past, 

11 our successes and our failures, we were moving 

12 forward, and in my lifetime we would see more and 

13 more people achieve the American dream.

14 I remember feeling a great sense of 

15 possibility as I applied to colleges. I could 

16 afford to dream big because my choice was not 

17 dependent on financial aid. But many of my 

18 friends, and most of my peers, are not so lucky, 

19 and their decision was determined by the financial 

20 aid packages they were offered. They depended on 

21 that aid, scholarship and loans, in addition to 

22 their summer jobs and work study.
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1 We were told that student debt is good 

2 debt, and that this mortgage on our future would 

3 lead to a better life. But as America's collective 

4 debt burden approaches $1.5 trillion, it is clear 

5 that this system has gone terribly wrong. 

6 Burdened by student debt, my generation 

7 is making drastically different life decisions 

8 than our parents and grandparents. Our career 

9 paths are dictated by where we can make the most 

10 money or pay our loans off most quickly. Or delay 

11 marriage, children and buying homes as we pay 

12 hundreds or thousands of dollars each month. 

13 Student debt is defining my generation's lives, 

14 from how we spend our time, to where we live, to 

15 what our families look like. 

16 When my parents went to college, many 

17 people could earn their tuition through summer and 

18 campus jobs. But the minimum wage has not kept 

19 pace with inflation, and tuition has increase at 

20 seven percent per year for decades. 

21 The same generation that graduated with 

22 little to no debt told us to make up the difference 
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1 with ever increasing student loans, saddling my 

2 generation with debt many will carry for the rest 

3 of their lives. 

4 They have allowed predatory lenders and 

5 for-profit colleges to ravage our community, 

6 particularly, poor people and people of color. I 

7 asked members of my community to share their 

8 experiences in higher education with me, and heard 

9 from a number of them.

10 I heard from a single mom who teaches 

11 at a technical college and works to improve 

12 people's lives in our community. She has multiple 

13 student loans, and has struggled to navigate the 

14 difficult repayment system. She was tricked by a 

15 predatory lender and lost an additional $1,000 as 

16 a result.

17 I spoke with a teacher who spent 10 

18 years working towards his degree in secondary 

19 education as a non-traditional student. After 27 

20 years of teaching, he's already paid back double 

21 his original loan amount. But due to high interest 

22 rates, he still faces hundreds of thousands of 
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1 dollars in student debt.

2 If people are pursuing higher education 

3 to build a better life and better contribute to 

4 their community, we have an obligation to make that 

5 education accessible. How can families 

6 participate in this economy when we mortgage our 

7 lives with student loan debt?

8 Instead of living up to the values that 

9 I mentioned at the beginning, Betsy DeVos has drawn 

10 back from the Obama administration's progress. 

11 Under her watch, the Department of Education is 

12 deregulating predatory for-profit institutions 

13 and lenders. And she regularly threatens to 

14 discontinue loan forgiveness programs for students 

15 cheated by predatory and fraudulent institutions 

16 and for those who work in public service.

17 Her policies support high dollar 

18 corporate interests over people, effectively 

19 auctioning off our chance at the American dream. 

20 While I speak as a millennial, we're not the only 

21 people who are suffering or will suffer under the 

22 burden of student debt. As I mentioned, those who 
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1 are going back to school are struggling with the 

2 same system.

3 We are not asking for a handout. We're 

4 not asking to take the easy way. We're asking for 

5 the same opportunity our parents' generation had 

6 at a quality education. We're willing to work 

7 hard, but we need a fair shot, and that won't be 

8 possible if our own Department of Education's 

9 policies are stacked against us from the start. 

10 Thank you.

11 MR. WASHINGTON: Thank you. Jeffrey 

12 Sommers? 

13 (Off the record.) 

14 MR. WASHINGTON: It is now 1:00 

15 o'clock. That concludes our public hearing. 

16 Thank you for coming. Have a nice day. 

17 (Whereupon, at 1:00 p.m., the 

18 above-mentioned public hearing was concluded.)

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