"gainful employment 2012" -ed cramp, duane morris llp
TRANSCRIPT
A Brief History…
Recall- ED enacted two sets of regulations
Part 1: Program Integrity
October 2010
State Approval, Incentive Comp Ban, Misrepresentation, etc
APSCU sued and mostly lost
Part 2: Gainful Employment
June 2011
Used Debt/Income Metrics, program approval, etc.
APSCU sued and mostly won
Why Are We Still Talking
About This?
It’s coming back
APSCU won on a technicality
Court said ED had the power to
Tie eligibility to debt/income metrics
Hold schools retroactively accountable
Collect data to establish eligibility
Approve new programs
ED is appealing
So What’s Next?
It’s true there’s much we don’t know
We don’t know-
When it will be back
How quickly
What standard they will use
How long we’ll have to comply
Etc.
But, There’s Loads We Do
Know
We do know-
The people at ED who created this monster are still
there
They have the power to do this again
They think we should be held responsible for
debt loads
repayment rate and
reported income of our graduates
What Can We Do?
View this as a second (and final) chance!
ED won’t get this wrong again.
Focus efforts on:
Keep student borrowing down
Placement
Income reporting
Loan repayment
Keep Borrowing Down
Educate students
We know they don’t want to listen, but…
Counsel them effectively on borrowing less
Talk about debt load
Encourage payments while in school
Change the culture of your school
Make sure that all your staff knows and understands
the critical nature of this problem
Placement
Traditionally not an issue for us
Work hard to get students placed quickly
Maintain a network of relationships with
salons/employers
On campus interviews, speakers, events, etc.
Income Reporting/Debt Repayment
Change your culture to stress financial responsibility
Make financial counseling part of your curriculum
Place students in locations where they will be
employees