Washington, D.C., May 27, 2014 - At the conclusion of the U.S. Department of Education’s public comment period on the proposed gainful employment regulation, the Association of Private Sector Colleges and Universities (APSCU) submitted comments to the Department detailing the regulation’s serious flaws, which include the following:
The full Guryan/Thompson paper, as well as a summary of the analysis, is available online.
The regulation is flawed, arbitrary, and biased. The Department does not have the authority to regulate student outcomes in this manner. The Department fails to analyze adequately the regulation’s impact on underserved students and in-demand programs. The regulation is backwards looking and does not evaluate all programs at all institutions. The regulation uses a one-size-fits-all approach, instead of taking into consideration the level of academic preparation and the socio-demographic characteristics of entering students.