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:
In addition to APSCU’s comments, an expert analysis on the gainful employment regulation was prepared by Northwestern University education and labor economist Dr. Jonathan Guryan and Dr. Matthew Thompson of Charles River Associates. Among their findings, the economists found that the Department built the foundation for the regulation on a flawed analysis by:
“During the regulatory process we witnessed the Department willfully mislead the public and policymakers by creating fake statistics, inaccurately representing the full impact of the regulation, and failing completely to address the loss of access to postsecondary education for 7.5 million students,” said Steve Gunderson, president and CEO of APSCU. “The Department, their allies, and proxies have misrepresented student outcomes, and the proposed regulation will harm both students who stand to benefit the most from postsecondary education with a career focus and employers seeking job-ready employees.”
“The Department has clearly forgotten the central purpose of the Higher Education Act – which is to assist in making available the benefits of postsecondary education to all eligible students,” Gunderson added.
The regulation unfairly targets students attending private sector institutions. While the Department purports to protect students, the regulation eliminates access for 7.5 million students over the next ten years, while doing nothing to protect students at public and private nonprofit institutions who have been identified by the Department’s own data as having unaffordable debt based on the gainful employment metrics. The regulation will disproportionately affect specific student populations, including: