WASHINGTON, D.C. | August 2, 2010 -
Dear Secretary Duncan:
Thank you for this opportunity to comment on the proposed program integrity regulations included in the Notice of Proposed Rulemaking published in the Federal Register on June 18, 2010.
We share your goal of strengthening accountability and integrity among the institutions that participate in the federal student aid programs and agree a number of the issues included inthe package warrant additional clarification through updated regulations. ...
We are deeply concerned by a second regulation that would define "gainful employment" through a confusing and complex set of metrics. This new regulation will harm students, particularly those non-traditional students who are returning to school to update their skills or who may be unable to pursue an education at a traditional four-year institution.
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