A Brief History…

Recall- ED enacted two sets of regulations

Part 1: Program Integrity

October 2010

State Approval, Incentive Comp Ban, Misrepresentation, etc

APSCU sued and mostly lost

Part 2: Gainful Employment

June 2011

Used Debt/Income Metrics, program approval, etc.

APSCU sued and mostly won

Why Are We Still Talking

About This?

It’s coming back

APSCU won on a technicality

Court said ED had the power to

Tie eligibility to debt/income metrics

Hold schools retroactively accountable

Collect data to establish eligibility

Approve new programs

ED is appealing

So What’s Next?

It’s true there’s much we don’t know

We don’t know-

When it will be back

How quickly

What standard they will use

How long we’ll have to comply

Etc.

But, There’s Loads We Do

Know

We do know-

The people at ED who created this monster are still

there

They have the power to do this again

They think we should be held responsible for

debt loads

repayment rate and

reported income of our graduates

What Can We Do?

View this as a second (and final) chance!

ED won’t get this wrong again.

Focus efforts on:

Keep student borrowing down

Placement

Income reporting

Loan repayment

Keep Borrowing Down

Educate students

We know they don’t want to listen, but…

Counsel them effectively on borrowing less

Talk about debt load

Encourage payments while in school

Change the culture of your school

Make sure that all your staff knows and understands

the critical nature of this problem

Placement

Traditionally not an issue for us

Work hard to get students placed quickly

Maintain a network of relationships with

salons/employers

On campus interviews, speakers, events, etc.

Income Reporting/Debt Repayment

Change your culture to stress financial responsibility

Make financial counseling part of your curriculum

Place students in locations where they will be

employees