Correspondence

  

   
Dear Secretary Duncan:

Given the significant investment of taxpayer resources in postsecondary education, the federal government has an obligation to monitor higher education institutions that participate in federal student aid programs. While we share the goal of promoting accountability and integrity among these institutions, we are deeply concerned about several provisions included in the latest iteration of the gainful employment regulation.

The proposed rule will unduly affect students enrolled at proprietary institutions and non-degree programs at nonprofit institutions, including many community colleges that are critical to our nation’s workforce development. According to the Association of Private Sector Colleges and Universities, the regulation will reduce postsecondary education options for as many as 3.9 million students by 2020 , many of whom are minorities, veterans, or low-income. These nontraditional and low-income students rely on federal student loans and grants to pursue a postsecondary education and need the flexible programs offered by proprietary institutions and community colleges to earn a degree, while also balancing the demands of family and work.

The proposed regulation will also increase the federal reporting burden levied on postsecondary institutions. The gainful employment regulation will require institutions to meet two overly-complicated metrics: a debt-to-earnings measure and a programmatic cohort default rate. Many of the proposed reporting requirements under the gainful employment regulation are redundant to existing requirements, creating additional compliance burdens and paperwork hours that could lead to higher costs for students.

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