Federal and State Policy

Whatever you might have thought of the Administration’s plan to rate colleges, its current plan to provide a new tool to help consumers compare colleges could be a big win for students and families. There is broad bipartisan agreement on the need for better consumer information on college costs and outcomes. In fact, last year the U.S. House of Representatives passed bipartisan legislation requiring the Education Department “to create a consumer-tested College Dashboard that would display key information students need when deciding which school to attend.”

The Administration has not provided much detail about what it is developing other than that it will release this summer an easy-to-use web tool that lets students and families compare colleges based on criteria important to them. So what key information do students and families need to know and what would make the tool most helpful?

Here are some of the things that we and others have publicly recommended for an improved consumer information tool, building off of the current College Scorecard.

Let users compare colleges by degree level, selectivity, and location. Students should be able to filter schools in ways that align with common college selection criteria: which degree I want, what my odds are of getting in, and where the school is located. Additional filters could be considered, but the comparison groups should not be defined by characteristics that bear little resemblance to how a prospective student is likely to consider colleges (e.g., a school’s sector or Carnegie classification). Additionally, national context should always be provided so students will see if there’s a significant gap between the schools they’re looking at and schools overall.

Provide graduation rates for all students and for Pell Grant recipients. Everyone agrees that students and families need to know what share of students graduate. Given the wide gap at some schools between the graduation rates of Pell recipients and non-Pell recipients, it’s important to provide both. Schools are currently required to disclose the graduation rate for Pell recipients, but not all schools comply and those data can be difficult to find. It will be helpful to have both graduation rates side-by-side.

Provide cumulative debt at graduation. Likewise, it’s critical that students and families know what share of a school’s graduates have loans and how much they typically owe. As the table below shows, schools in the same state with similar costs and proportions of low-income students can have very different borrowing rates and average debt levels. 

Source: Calculations by TICAS on data for 2012-13 from the U.S. Department of Education and Peterson's. Cumulative debt data copyright 2014 Peterson's, a Nelnet company.
Note: Figures for “tuition and fees” and “cost of attendance” are for in-district/in-state students at public colleges. Figures for “% low income” reflect the share of 12-month undergraduate enrollment receiving Pell Grants (enrollment as reported by colleges on the Department’s FISAP form).

Currently, the Administration’s College Scorecard shows the median debt of all former students entering repayment, regardless of whether they graduated or dropped out. This makes colleges with high drop-out rates look like a good deal, because students who left the school after borrowing for only a semester or two bring the median debt level down. For instance, the College Scorecards for the University of Phoenix Online (Phoenix) and University of California at Berkeley (Berkeley) show similar median federal debt for borrowers entering repayment ($17,476 at Phoenix vs. $16,436 at Berkeley). However, only 7% of first-time students seeking a bachelor’s degree at Phoenix graduate in six years, compared to 91% at Berkeley. In fact, undergraduates at Phoenix are more than twice as likely to borrow federal loans as students at Berkeley, and they borrow significantly more on average each year.

Instead of providing debt when entering repayment, we recommend using currently available data for average cumulative federal debt at graduation until more comprehensive data are available. Average debt at graduation should be accompanied by the school’s borrowing rate, so students know how common it is for graduates to have any debt.

Flag schools under investigation. TICAS and 47 other organizations recently urged the Department to flag colleges in the comparison tool that are the subject of public federal or state investigations, lawsuits, or settlements. Students deserve to know when a college’s practices are under heightened scrutiny from regulators, just as investors in publicly traded for-profit colleges are required to be notified of such events. No doubt fewer students would have enrolled in schools owned by Corinthian Colleges if they had known of the many open investigations and lawsuits, fewer students would have been harmed, and fewer students would need loan discharges. 

Indicate the default risk. Students should know what share of a school’s students default on their loans. This can be determined by multiplying a school’s cohort default rate (CDR) by its borrowing rate, producing the school’s student default risk indicator (SDRI). By itself, the CDR only tells you the share of federal loan borrowers at a school who default, which may be very different from the share of students who default. For instance, the College Scorecard for Los Angeles Southwest College says it has a 66.6% default rate. However, that default rate is based on just two students defaulting at a school with nearly 11,000 students, so the typical student’s risk of defaulting at this school is actually extremely low.[1] The Department currently has the data to calculate the SDRI for each school and should provide that instead.

Pretest the tool with consumers: Ultimately, to be effective, this tool must be consumer tested, especially with low-income and first-generation students.

The Administration clearly listened to feedback on its college ratings framework. We hope it considers these recommendations as well so that the new college comparison tool gives students and families the information they need to make more informed decisions and helps encourage colleges to focus more on their affordability and student outcomes.


[1] Based on Los Angeles Southwest College’s FY2011 cohort default rate and its 12-month enrollment in 2011-2012.

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With so many Americans concerned about college costs and student loan debt, there are more and more proposals to improve college affordability and reduce or even eliminate students’ need for loans. Yet most of the proposals are not very detailed at this point, and the details matter.

One critical detail is which costs are covered. To make a real difference for low-income students, any debt-free college plan must take the full cost of going to college into account, including textbooks, transportation, and living costs like food and housing. These non-tuition costs make up the majority of the full cost of attending a public two- or four-year college (61%-79%), yet their importance is too frequently overlooked. Students may only need to pay the tuition bill to enroll in college, but to succeed in school and graduate they need to be able to cover the other costs, too. Students who can’t get to campus or can’t get the required books won’t benefit from their classes. Students who have to work long hours to pay for rent or child care don’t have enough time to study.

Students can use grants like the federal Pell Grant to help pay for either tuition or non-tuition costs. But many lower income students have to take out loans because available grants don’t cover their total costs. In fact, national data show that lower income students (those with incomes at or below the median) who attend public colleges “tuition free” are currently much more likely to borrow than higher income students who pay for some or all of their tuition bill. This underscores why plans to eliminate debt cannot just focus on tuition.

 

This is worth repeating: low-income students who are already attending college “tuition free” are more likely to need loans. To understand why, we have to look at students’ total net costs (cost of attendance after grant aid) as a share of family income.

Data show that the net costs of attending public two-year and four-year colleges account for a much larger share of income for lower income families than for higher income families. As a result, more lower income students have to borrow to get their degree. For instance, as shown below, community college students with family incomes under $30,000 are expected to dedicate 22% of their income toward paying for college. Unsurprisingly, graduates in this income range are more likely to leave school with debt than students from families who can better absorb net college costs. 


This is why ensuring a debt-free college option requires more than covering tuition costs.  It requires providing additional grant aid for lower income students who may already be going to college “tuition free,” and as we have discussed before, it requires a state “maintenance of effort” provision to ensure states hold up their end of the bargain.  

 

Calculations by TICAS on data from the U.S. Department of Education, National Postsecondary Student Aid Study, 2011-12. Median income is based on family incomes for students enrolled in college in 2011-12. Students are classified as attending tuition-free if their tuition net of grant aid is zero, and as paying tuition if their tuition net of grant aid is greater than zero.

U.S. Department of Education calculations of 2012-13 net price for first-time, full time undergraduate recipients of federal Title IV financial aid, from http://nces.ed.gov/pubs2014/2014105.pdf, based on figures reported by colleges to the Department via the Integrated Postsecondary Education Data System. To calculate the shares of income needed to pay the net price, we used the upper bound of the income range (i.e., $30,000 for the $0-30,000 group) when available, and $145,000 for the income range of $110,001 and above which is approximately the median income for students in this group. Graduates’ debt figures from U.S. Department of Education, NPSAS, and include undergraduate students who completed a degree or certificate in 2011-12. Both net price and debt calculations are the most recent available of their kind. 

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Many low-income students who get enough aid to cover their tuition still struggle to pay for other basic college costs, including textbooks, transportation, room and board. These make up most of the cost of college for students at public four-year and community colleges. That’s why free tuition alone won’t solve the college affordability problem. The America’s College Promise Act introduced yesterday recognizes this by adding something with the potential to be far more transformative: a "maintenance of effort" provision aimed at making states hold up their end of the bargain when it comes to college funding.

States are critical players in keeping college affordable, but they have also been complicit in the rise of tuition and student loan debt by letting higher education get squeezed out of state budgets. The decline in per-student state funding for higher education has been well documented, as has the resulting impact on public college costs. Without federal intervention, higher education funding is likely to keep getting squeezed out, to the detriment of students, families and our economy. The legislation introduced yesterday includes such an intervention: it requires states to keep their funding levels up, in addition to eliminating tuition at community colleges, if they want to access new federal dollars. That’s why the state maintenance of effort requirement in the legislation is so important.

States can adopt proposals labeled “free college” that do little or nothing to make college more affordable for low- and moderate-income students. That’s what happened in Tennessee: it created a “last-dollar scholarship” that only helps students who don’t get enough from other grants to cover tuition. Oregon is poised to do something similar with $10 million, although some students will receive up to $1,000 for non-tuition expenses. Significantly, Oregon also increased need-based grant aid for low-income students by $27 million, which is critical because only one in five poor students who apply receives this state grant aid due to lack of funding.

We want states to invest in college affordability and debt-free college options, not in programs that may sound good but don’t make college more affordable for low- and moderate-income students. If we’re serious about increasing affordability and reducing debt, we need to help low-income students cover more of their costs. The America’s College Promise Act would free up community college students’ federal Pell Grants to cover non-tuition expenses by requiring states to waive tuition. This helps low-income students cover non-tuition expenses; using Pell Grants to declare tuition “free” for low-income students does not. After all, Pell Grant recipients, most of whom have family incomes under $40,000, are currently more than twice as likely to have to borrow and they graduate with more debt.    

Making college affordable requires state investment in higher education.  We commend the bill’s sponsors for tackling state disinvestment in public colleges—the primary driver of rising college costs and student debt in America. 

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Yesterday, Corinthian Colleges abruptly closed its remaining 30 campuses in California, Arizona, Hawaii, New York, and Oregon, where 16,000 students were enrolled. While nothing can give these students back the time they spent at Corinthian, they deserve a fresh start.

The good news is that the Higher Education Act (HEA) provides for the discharge of students’ federal loans if a school closes before students finish their programs. In fact, the HEA says “the Secretary shall discharge” students’ loans, and the Education Department’s regulations specify that the Secretary will mail each borrower a discharge application and an explanation of the qualifications and procedures for obtaining a discharge.

The bad news is that the HEA does nothing similar to restore students’ eligibility for Pell Grants, which needy students can receive for no more than six academic years. Because the law doesn’t reset the clock on a student’s eligibility for Pell Grants when a school shuts down, low-income students may not be eligible for enough aid to complete a program anywhere else.

For example, the students enrolled in the pharmacy technician certificate program at Corinthian’s Everest College in West Los Angeles – which cost more than $11,000, and had a 25% job placement rate and a 35% student loan default rate – will be able to get their federal loans discharged, but they won’t get their Pell Grant eligibility restored to what it was before they enrolled at Everest. As a result, they may not have enough Pell Grant eligibility left to complete the much lower cost pharmacy tech program at the nearby community college. 

For the more than 12,000 Pell Grant recipients estimated to be enrolled at the Corinthian campuses that suddenly closed yesterday, this is an oversight needing swift correction.

How did Pell Grants get left out of the closed-school provisions? Prior to 2008, students could receive Pell Grants for as long as they were making satisfactory academic progress towards a degree or certificate. So if a school closed before a student could finish, the student didn’t need to worry about their Pell Grant eligibility running out. 

However, in 2008 Congress limited future Pell Grant eligibility to nine years.  Then, in 2011 Congress lowered this lifetime limit to six years and applied the new limit immediately and retroactively to all students, including those just a semester away from completing their degrees.

Unfortunately, Congress didn’t amend the HEA to restore students’ eligibility for Pell Grants when a school closes before they can finish. This was likely an oversight, not a conscious policy decision. As a result, the lowest income students at Corinthian campuses may not have enough Pell Grant eligibility left to complete a program at another school. 

It’s time to fix this harmful omission. In the last Congress, Representative Janice Hahn introduced the Protecting Students from Failing Institutions Act (HR 4860) to restore Pell Grant eligibility for students at campuses that close. We recommend going a step further: Pell Grant eligibility should be restored for any student who has their federal student loans discharged, either because their school closed or because of school fraud. Current and former Corinthian students deserve a true fresh start and the chance to get a meaningful degree or certificate at another school.  

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While the President’s proposed budget fully funds the scheduled increases in the maximum Pell Grant and continues to tie it to inflation after 2017, the FY16 House and Senate budget proposals freeze the maximum Pell Grant for 10 years. As recently as the mid 1980s, the maximum Pell Grant covered more than half of the average annual cost of attending a four-year public college. Freezing the maximum grant for the next 10 years would reduce the share of covered costs from an already record low of 29 percent in 2015-16 to just 20 percent by 2025-26, making college even less affordable.

Sources: Calculations by TICAS on data from the College Board, 2014,Trends in College Pricing 2014, Table 2, http://bit.ly/1F9qoJv; and U.S. Department of Education data on the maximum Pell Grant. The maximum Pell Grant for 2015-16 was announced in the Department of Education’s Pell Grant Payment and Disbursement Schedules,http://ifap.ed.gov/dpcletters/GEN1502.html. College costs are defined here as average total in-state tuition, fees, and room and board costs at public four-year colleges. Projected college costs for future years were estimated by using the average annual increase in costs over the most recent five years.

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Last year’s House Budget Resolution proposed charging students with financial need interest on their subsidized loans while they are still in school and using that money to reduce the deficit. In other words, the House Budget proposed increasing student debt to reduce government debt. Unfortunately, many expect that next week’s House and Senate Budget Resolutions will propose this change again, despite growing public concern about rising student debt and broad consensus on the importance of higher education and postsecondary training to the US economy.

Currently, undergraduates with financial need are eligible for subsidized Stafford loans, which do not accrue interest while students are enrolled at least half time or during the first six months after students leave school (the “grace period”). Eliminating this in-school and grace period subsidy (i.e., charging interest during these periods) would increase the cost of college by thousands of dollars for undergraduate students with financial need.

The charts below illustrate how much more a student would have to pay if the in-school and grace period interest subsidy were eliminated, assuming the student starts school in 2015-16, borrows the maximum subsidized student loan amount ($23,000), and graduates in five years.

Using current CBO interest rate projections, eliminating the in-school and grace period interest subsidy on subsidized Stafford loans would cause this student to enter repayment with $3,750 in additional debt due to accrued interest charges. As a result, she would end up repaying $4,900 (16%) more over 10 years and $6,900 (16%) more if she repaid over 25 years.

The added costs to students will be even higher when interest rates in the economy rise from their current levels, which are still historically low. If the undergraduate Stafford loan interest rate hits the statutory cap of 8.25%, eliminating the in-school and grace period interest subsidy on subsidized Stafford loans would cause this student to enter repayment with $5,700 in additional debt due to accrued interest charges. As a result, she would end up repaying $8,350 (25%) more over 10 years and $13,450 (25%) more if she repaid over 25 years.

At a time when higher education has never been more important or more difficult to afford, we should not be trying to balance the budget on the backs of students. We need to be doing more, not less, to keep college within reach for all Americans.

Note: More than four in five (82%) undergraduates with subsidized loans also have unsubsidized loans. If this student borrowed unsubsidized loans in addition to her subsidized loans and entered repayment with more than $30,000 in debt, she would qualify for a 25-year repayment plan

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Update: Details of the White House plan are becoming available and make clear it differs significantly from the Tennessee Promise and other “free community college” plans. In particular, the White House proposal is not a “last-dollar” scholarship. Instead, it provides additional federal funding to states that make key reforms, including not charging tuition or fees at community colleges. It is aimed squarely at stopping state disinvestment in public colleges, which is crucial to making college more affordable. Also, unlike the Tennessee Promise, low-income students could benefit. These are clear improvements on the plans discussed in our blog posted earlier today. Still, making tuition free for all students regardless of their income is a missed opportunity to focus resources on the students who need aid the most. Consider California community colleges, with the lowest tuition in the nation and waivers for low-income students. The result? Federal student aid application rates, even among low-income students, have been notoriously low, and part-time enrollment rates sky-high. "Free tuition" is not a panacea.


Many are predicting that President Obama tomorrow will endorse Tennessee’s "free community college" plan. While the Tennessee Promise is well intentioned and more students than anticipated applied for it, many higher education experts have rightly criticized it and other "free community college" plans.

One of the major problems with the Tennessee plan (and others) is that the "promise" isn't actually much of a promise at all. That’s because the "free" moniker only relates to tuition charges – charges which comprise just one-fifth of the actual costs of going to community college. The other costs of college, including textbooks, transportation, and living expenses, are far more substantial – and far more likely to prove a barrier to student success. Yet they’re left out of the deal.

Further, the Tennessee plan (and others like it) is a "last-dollar" scholarship, meaning that it only helps students who don’t get enough from other grants to cover tuition. This is a critically important point because, given the relatively low income of community college students and the relatively low tuition charges at community colleges, it means that the students with the greatest need for financial aid will rarely benefit. Conversely, those with the least need are the most certain to benefit.

Free tuition plans are giant missed opportunities because they put resources where they are less needed when the need is so great in other areas. As shown in the table below, students in the lower income categories need far more financial support to bring college within reach. The vast majority of them (92% for the lowest income group) have "unmet need" even after accounting for available grants and what they can afford out-of-pocket. That’s true of just 9% of students in the highest income category: 91% of those students can already afford not just tuition, but their entire cost of attendance. Surely higher income students would appreciate additional resources, but do they need them? Not according to federal needs analysis, and the vast majority of these higher income students already enroll in college and are the most likely to graduate.

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In addition to providing resources where they are not needed or needed less, these free-tuition plans are also ticking time-bombs. They signal that tuition is all that matters and flat-out ignore the other costs of attendance that determine whether students can get to campus, whether they’re focused on the material or how to pay for their next meal while in class, and whether they have a place to sleep at night.

Currently, many community college students get help paying for these other costs in addition to tuition. As shown above, the lowest income students’ average grant aid exceeds the amount of the tuition they’re charged by quite a bit: their total grant aid comes to about three times (328%) their tuition charge. On average, students with incomes below the median get grants that cover full tuition, with some resources left to help pay non-tuition costs, including fees, books, transportation, food and housing; students with incomes above the median get grants that cover, on average, about one-third of tuition.

If we prioritize covering tuition costs, treating the other costs of attendance as less important, how long until the grants for lower income students – grants which currently exceed tuition – are cut? This isn't a fantastical possibility. Limiting certain students’ Pell eligibility to tuition costs was an idea included in a federal appropriations bill not too long ago.

If resources were unlimited, there would be more merit to free tuition arguments. But resources are in fact so limited that the vast majority of low-income students – the students for whom financial aid will make the difference – aren't getting what they need. Free tuition proposals are politically popular, but regressive and inefficient. They are a lot like higher education tax benefits, where there is broad and bipartisan agreement that much better targeting is needed.

Free tuition proposals don’t just fail to move us forward: they’re a step in the wrong direction. We should absolutely do more to encourage students to pursue higher education and make them aware of financial aid, but this is not the way to do it.

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The final gainful employment rule released last week eliminated a key accountability measure for career education programs. As a result, many programs that would have failed the draft rule will now pass the final rule.  While some have argued that this change was made to benefit public institutions, it’s clear that for-profit colleges – and the University of Phoenix in particular – were the biggest winners.

The draft rule released in March measured career education program outcomes in two ways. First, the debt burdens of program graduates who received federal aid would be compared to their later earnings. Second, students’ ability to repay their loans – including both graduates and noncompleters – would be measured through a program-level cohort default rate, or pCDR. But the final rule uses only one measure: the debt to earnings ratio of program graduates, or DTE.

There are 682 programs that failed the draft rule’s pCDR test but pass the final rule (including those exempted because they have very few graduates). The vast majority of these programs - 89% - are at for-profit colleges, and for-profit college programs account for 97% of the now-passing programs’ defaulters. University of Phoenix programs alone account for 43% of the defaulters at programs that pass the final rule because the pCDR was eliminated.

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In May, we wrote about the 114 career education programs from which more students default than graduate (it’s actually even worse than that since they have more defaulters in one year than graduates over two years). With Corinthian Colleges now preparing to sell or close all of its campuses, it is worth noting that Corinthian runs 25 of the 114 programs with more defaulters than graduates.

These programs are shockingly bad. Everest College Phoenix Associates’ programs in Securities Services Administration and Management, and in Business, Management and Marketing both had more than three times as many defaulters as graduates. Everest University in Tampa has an Associate’s degree program in Computer and Information Sciences that also has three times as many defaulters as graduates.

An effective gainful employment regulation would help protect students and taxpayers from schools like Corinthian. By enforcing the law requiring career education programs to prepare students for gainful employment in a recognized occupation, a strong rule would hold programs to clear outcome standards and measure their performance against those standards regularly. It would force the worst performing programs to improve or lose eligibility for funding before burying countless students with debts that may haunt them for the rest of their lives.

We and more than 50 other organizations submitted written comments urging the Education Department to improve its draft gainful employment rule to better protect students and taxpayers, including by requiring schools to provide financial relief for students in programs that lose eligibility, limiting enrollment in poorly performing programs until they improve, and closing loopholes and raising standards. If a rule with the changes we called for had already been in effect, Corinthian would long ago have had to rapidly improve or close programs in a way that better protected students and taxpayers.

The final gainful employment rule will be too late to protect Corinthian students, but it is not too late to protect the millions of students enrolling in other schools’ career education programs and the taxpayers who subsidize them.

Click here for a sortable list of the 114 programs with more defaulters in one year than graduate over two years. To read the New York Times editorial on our May blog post, click here.

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As the Department of Education works on a final rule to stop federal funding for career education programs that over-promise and under-deliver, it needs to close loopholes to prevent unscrupulous colleges from gaming the system.

Under the draft regulation, career education programs would be judged by two different tests: how the debt of their graduates compares to later earnings, and how many of the programs’ borrowers default on their loans.  Programs that consistently exceed allowable thresholds of debt-to-earnings or rates of default would lose eligibility for federal aid.  While many in the for-profit college industry complain that the tests are too stringent, the data show the exact opposite and that the rule needs to be strengthened.

Exhibit A for a tougher rule is the fact that 20 percent of the 114 parasitic career education programs – those where more students default than graduate – would pass the proposed tests. And exhibit B would appear to be Education America Inc.’s Remington College, a formerly for-profit chain that began operating as a nonprofit in 2011.

Data released by the Department in conjunction with the rulemaking show three large certificate programs that have a collective repayment rate of 12 percent – meaning only 12 percent of borrowers are paying down their debt. The three are large medical/clinical assistant certificate programs at what appear to be Remington’s Texas, Ohio and Alabama campuses. (Some of the data files released by the Department do not include college names so only the Department can confirm which college’s programs these are.  However, looking across multiple data files, including a file with college names, strongly suggests these three low-repayment programs are the Remington programs.)

To make matters worse, these three programs would not fail under the Department’s draft regulation– the one that industry complains about being too strict.  Despite the extremely low repayment rate, the aggregate cohort default rate for the three Remington programs is only 14 percent, far below the threshold of 30 percent. Such a low rate of borrower default from programs where hardly any borrowers are paying down their loans suggests the college may be manipulating their default rates by putting former students in forbearance during the window when default rates are being measured – regardless of whether it is in the borrowers’ best interest to do so. In fact, a Remington College executive said as much in 2009, noting that “we’ve known all along what [the Department] finally figured out,” that borrowers receiving forbearance and deferment were later defaulting on their loans once it stopped tracking defaults after two years. The Department then changed its default monitoring to a broader three-year metric. “They [the Department] decided we were getting off too easy,” the Remington executive noted. (Note that colleges can and do manipulate three-year default rates, but it takes more work to do so than for two-year rates.)

Programs where most students borrow and the vast majority of borrowers cannot repay their loans should not keep enrolling students receiving federal aid. The Department could close this loophole in the gainful employment rule by instituting a repayment rate in addition to the other tests. It must also prohibit unscrupulous schools from manipulating their program default rates or their repayments rates by making small payments on behalf of former students.

Read more about these issues and recommendations in our comments on the Department’s draft gainful employment rule. -Debbie Cochrane

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