The "Gainful Employment" regulation simply does not distinguish between successful and unsuccessful programs. About half of all students who borrow have a debt-to-income ratio above 8 percent, regardless of the type of institution they attend. For financially independent students, every sector averages a debt-to-income ratio greater than 8 percent.

Not surprisingly, it is the independent students who begin school with the lowest income (those in the 25th percentile) who need to borrow the most. These students have an average debt-to-income ratio above 12 percent in every sector. High borrowing rates among private sector institutions are more indicative of the fact that the sector is significantly more likely to serve these students than other schools.

This means that the "Gainful Employment" regulation has a disproportionate impact on low-income students, since it discriminates against students who need to borrow. As programs are penalized for their debt-to-income measures, these students will be forced out because their programs will close or admissions officers will be more stringent about students who may need to borrow.

These students cannot simply enroll elsewhere. Strapped state budgets are leading to curriculum cuts even before a sudden influx of private sector students. For example, course offerings at California community colleges are at a 15-year low as the state looks to limit spending. Therefore, if the regulation is implemented, students will lose access to postsecondary education and the opportunity it brings.


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PSCUs open doors to many of the 9 million unemployed and 90 million undereducated Americans by providing a skills-based education. To remain competitive over the next decade, we must identify between 8 and 23 million new workers with postsecondary skills. PSCUs are a necessary part of that solution, having produced over 800,000 degrees last year alone.