May 27, 2014
Hon. Arne Duncan, Secretary
U.S. Department of Education
c/o Ashley Higgins
1990 K Street NW, Room 8037
Washington, DC 20006
RE: Program Integrity – Gainful Employment [Docket ID: ED-2014-OPE-0039; RIN: 1840-AD15]
Submitted via email: firstname.lastname@example.org
Dear Secretary Duncan:
Consumers Union, the policy and advocacy arm of Consumer Reports®, appreciates the opportunity to comment regarding the Department’s Notice of Proposed Rulemaking to define “gainful employment” standards for career colleges receiving Title IV funds. We appreciate the Department’s efforts to revise its definition of gainful employment and protect students from poor-quality career college programs that do little more than put them into debt.
However, we believe that the rule must be significantly strengthened to ensure that students and taxpayers are protected high-cost, poor-quality career programs that undercut the benefits of pursuing higher education in America. Specifically, we urge the Department to: (1) close a number of loopholes that will enable colleges to game the standards; (2) protect low-cost programs that are not putting most of their students in debt; (3) limit enrollment at schools that need to improve their standards; and (4) provide monetary relief to students who have been harmed by low-performing career college programs.
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