APC member colleges have long been avid proponents of leading by example when it comes to student outcomes. As we’ve outlined throughout our previous blog profiles, respected institutions such as the School of Visual Arts, Monroe College, LIM College, Berkeley College, Bryant & Stratton and Utica School of Commerce pride themselves on providing not only a challenging and robust curriculum, but a reliable support network that primes students for future career success.

Indeed, when staking a claim to certain traits or attributes and attempting to establish credibility in any space — education or otherwise — it makes sense to stick by your core values and be the proverbial standard-bearer. That’s why we were surprised to learn that the Department of Education — the driving force behind the stringent Gainful Employment rule, and a vocal advocate for student outcomes — was itself found by a recent Office of Inspector General audit to have insufficient measures in place to prevent said students from defaulting on their loans.

The audit report indicated that, despite its outstanding loan portfolio more than doubling over the last 6 years, the Department had failed to implement a cohesive and organized approach to student debt default prevention. Furthermore, the report states that “without a coordinated plan or strategy, Department management may not be in a position to make strategic, informed decisions about the effectiveness of default prevention initiatives and activities.”

Although the student loan default metric was deleted from the final iteration of the Gainful Employment rule, one thing strikes us: if the Department itself doesn’t have the solutions, or even have workable methods to help students avoid default, then how can anyone have any confidence in its untested Gainful Employment metrics?

The Gainful Employment rule, and the more recently announced college ratings plan, represent a muddled approach to accountability. We suggest the Department revisit its own practices, and reevaluate what really works for students, before it implements this misguided regulation that stands to have a devastating impact.

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