APC member colleges appreciate the support of our New York Congressional Delegation and the members of the House and Senate Education committees for their commitment to providing students access to higher education. Many of the students attending our member colleges come from under-represented groups, including first-generation and low-income students. Federally supported programs like PELL Grants are an essential lifeline for these students and we appreciate Congress’s long-term commitment to the PELL Grant program.
As the Institutional and Programmatic Eligibility Negotiated Rulemaking process proceeds, misinformation, political agendas, and a lingering national narrative are affecting perceptions and fueling decision-making that is detrimental to proprietary colleges and more importantly to the students they serve.
Many representatives on the negotiating committee are urging a return to the 2014 GE rule and strengthening the 8% debt to earnings metric. However, any analysis of institutional or programmatic debt to earnings data reveals that high student loan debt and low earnings is a problem across all sectors.
Many advocates are saying that the GE regulations should only be applied to for-profit colleges because 98% of the programs that failed the 2014 GE rule were offered at for-profit institutions. However, it’s important to note that the GE regulation did not apply to degree programs at public or non-profit institutions, it only applied to a small number of certificate programs at these schools but the regulation applied to ALL programs at for-profit institutions.
New research by the Texas Public Policy Foundation revealed that if Gainful Employment metrics were applied universally to institutions in all sectors that 89% of the failing programs would be at public and independent non-profit institutions.
In light of this data, APC would recommend the following:
- APC applauds Secretary Cardona’s commitment to treating all sectors of higher education equally and focusing on students. We have long supported accountability and transparency measures but would advocate for any GE metric implemented to be applied universally to all sectors. The Department has authority to do this.
- APC would recommend that any component of the debt to earnings metric be included in the disclosures in section 668.43. This would require all institutions to disclose the same debt to earnings data and create an equal basis for comparison for students deciding what college is the best fit for them.
- APC also applauds the recent release of updated data on the College Scorecard. We noted that the website provides median earnings 10 years after students who received federal aid began at that institution. Using this 10 year data to calculate the debt to earnings ratio would be a good starting point and maintains the correlation between the gainful employment debt to earnings and the recently updated College Scorecard.
Following is a video that APC created in 2015 when the original 2014 Gainful Employment regulation was implemented. Even though this video was created 7 years ago, many of the points made still stand today.