From: Plotkin, Hal Sent: Monday, June 02, 2014 5:57 PM To: Finkel, Jessica ce: Géuser Subject: RE: GE Similar to my main confusion which we will discuss Tuesday am - do we have alist of the section headers? | need some type of crib sheet so | know which comments reference which sections of the rule and/or to understand how others doing this task make those determinations without memorizing the entire rule. That is where | am (regrettably) stuck. Talk Tuesday am as planned, Hal Hal Plotkin Sent from my Windows Phone From: Finkel, Jessica Sent: 6/2/2014 4:58 PM To: Plotkin, Hal Ce: GEuser Subject: RE: GE Great, thanks. If you want to follow the general section headers, that will help me place them in the outline when you're done, From: Plotkin, Hal Sent: Monday, June 02, 2014 To: Finkel, Jessica Ce: GEuser Subject: RE: GE 38 PM Got it. | understand that | should proceed to summarize the Shireman comment without regard to where it fits in the overall outline - and that you will integrate it into the large outline after | process it. I'll do my best! More asap, Hal Sent from my Windows Phone From: Finkel, Jessica Sent: 6/2/2014 4:29 PM To: Plotkin, Hal Ce: GEuser Subject: RE: GEThe examples are from actual comments this round, and | just pulled them from one section. | thought it would be easier for you to focus an summarizing and | can add them to the outline when you are done since it's getting pretty unwieldy. | attached a draft version of the outline so you can get a sense of where they might belong. You won't know whether someone already made the comment, but that's ok, Also - [know you're getting used to GE stuff, but just a reminder to always include GEUser on any related email, Thanks! Jessica Sent: Monday, June 02, 2014 To: Finkel, Jessica Subject: RE: GE 216 PM Got it. But here is my question (and please forgive me for being such a newbie)... In your previous email you provided me with a short list of comments that have already been summarized as examples. Are those actual comments from this round? Or just examples from some previous process? I note that all the comments focus on Section 404 - so I can easily see how any comments about that section would be processed (if they repeat a comment made by others note it as indicated but ifit is a new comment note that). But what if the Shireman comment focuses on other Sections? Do you have a more complete list of comments already processed so | can see where I should note comments on topics other than Section 404? Oris that what we are creating? Hang in there with me please, I'l get the hang of this! Hal Hal Plotkin Sent from my Windows Phone From: Finkel, Jessica Sent: 6/2/2014 3:55 PM To: Plotkin, Hal Cc: Higgins, Ashley; Wood, Sandra; GEuser Subject: RE: GE We're aiming to have major comments summarized by Wednesday. Thanks! From: Plotkin, Hal Sent: Monday, June 02, 2014 3:47 PM To: Finkel, Jessica Cc: Higgins, Ashley; Wood, Sandra; GEuser Subject: RE: GE Great, thanks! Let me take a stab at this one, as suggested, and then you can review that work and let me know if | have properly 2processed the Shireman comment. If so, I'll be ready for more. 1'll be able to turn this around tomorrow for your review - and then have lots more free time blocked out for this later in the week and next week. What is our target for completing this task? Many thanks, Hal Hal Plotkin Sent from my Windows Phone From: Finkel, Jessica Sent: 6/2/2014 3:36 PM To: Plotkin, Hal Ce: Higgins, Ashley; Wood, Sandra; GEuser Subje RE: GE Hi Hal, Do you want to take a stab at summarizing CAP/Bob Shireman’s comment? You can find it by searching for “ED-2014-OPE-0039-1955” on www.regulations.gov. Here is an example of what the comment summary outline looks like to give you a sense of the level of detail and how we are marking them. We want to make it easy for the person drafting the preamble to find the relevant comments for their section, so we’ve put the org/commenter name, last 4 digits of the doc ID number, and page in brackets at the end. Section 404 — Calculating D/E Rates {f) Inclusion of Books, Supplies, and Equipment in Cap Likes cap at total tuition and fees, but concerned with additional inclusion of books, supplies, and equipment. Cosmetology programs choose to include the costs of books, kits, and supplies in the cost of the programs ta limit student out of packet costs later. However, inclusion of the kits increases amount that might be borrowed, increasing the amount that must be offset by students’ earning potential early in their professional careers, Suggest excluding these costs if IHE can show there is a reduction in price of equipment through direct purchasing and inclusion of the equipment and supplies from the institution. {AACS - 1455, p22] The Department should not include books, supplies, and equipment (especially supplies and equipment). Many of these are wants and not needs and vary greatly in price. [Marty Mehringer/FAA, 0016, p.2] Should include other debt students incur to cover other legitimate costs of attending college (thresholds too weak) [TICAS - 1935, p13] If someone says the same thing as a point already added to the outline, you would just add their info in brackets at the end of the existing entry:Section 404 — Calculating D/E Rates (I) Exemption for Programs with Low Cost/Low Borrowing or Other Attributes vs. Related Appeal Improve the rule by assuring that the capital and human resources required to administer the rule do not exceed the value it provides to students and taxpayers. For example, exempt schools with overall CDR of 10, whose instruetional expenses exceed 30% of tuition and fees, and/or whose median annual federal borrowing is zero. Would reduce administrative costs and enable ED to focus on poor-performing schools. [UC - 1666] Exempt RVU because it has a strong track record of suecess — high board passage scores, 100% residency placement, services military medical school students, no title LV audit issues, They serve a unique need in Colorado. Debt accrues while students are in residency — unique situation. [RVU - 1954] Go back to 2011 rule and define programs with a median loan debt of zero as automatically passing the debt metrics because they are not placing any debt burden on the majority of their students. More efficient and rational to say that programs showing mitigating circumstances (borrowing rate of 50% or less among title IV completers) should automatically pass both GE metrics. Otherwise, too burdensome and expensive for community colleges. [AACC/AACT - 1700, pl and 4] [NASFAA, 2026, p.2] [California Community Colleges Chancellor's office. 1687, pI][TICAS — 1935, p5] We also have a section to capture the more general comments, so please summarize those too. If this is too much to start with, let me know. We'll probably have some less-intensive ones to assign in the next few days. Thanks in advance for the help! Jessica From: Higgins, Ashley ‘Sent: Monday, June 02, 2014 3:31 PM To: Finkel, Jessica Subject: FW: GE Jess, is there a free major comment for Hal to work on? From: Plotkin, Hal Sent: Monday, June 02, 2014 1:08 PM To: Wood, Sandra Ce: Higgins, Ashley Subject: RE: GE Great, thanks..Ashley, please do let me know what time (if any!) might work for you to get me started on this tomorrow (Tuesday) afternoon, at any time after 1:45PM. Before joining ED five years ago | spent more than 20 years as a writer and editor ~s0 | should be able to do this! But I have never done it before so I really want to make sure | fully understand what is expected and know | am doing it right before I dive into the deep end on my own.IF Tuesday does not work, talso have time Wednesday morning before 11AM or Wednesday afternoon, after 3:45PM. Many thanks, Hal Hal Plotkin From: Wood, Sandra Sent: Monday, June 02, 2014 1:04 PM To: Plotkin, Hal Ce: Higgins, Ashley Subject: RE: GE Hal, Ashley Higgins will be the person you will need to see. | have added Ashley to the email so the two of you can decide on a time to meet on GE assignment{s). Just let me know and I will have the laptop ready for you. Thanks. sandy From: Plotkin, Hal Hi Sandy: Thanks so much for reaching out. ’'m happy to help but as a newbie | do need some additional guidance, as Lynn may have indicated, mostly so I can do at least a few summaries/reviews {whatever you call them!) over at OPE and make sure | have the hang of it. Once | get up to speed, | expect to be able to move forward with less hand-holding and | would hope more quickly. So I'l need the laptop set up for me ~ and someone at OPE to walk me thru the first few examples just to make sure | have “got it.” Any chance we can do this tomorrow (Tuesday) afternoon, sometime between 1:45pm and SPM? Many thanks, Hal Hal Plotkin From: Wood, Sandra Sent: Monday, June 02, 2014 1; To: Plotkin, Hal Subject: GEHi Hal, Lynn mentioned to me that you were interested in working on GE. Let me know when you are available to come over and I can set up a laptop for you. sandyO'Bergh, Jon Greene, Chris Monday, June 02, 2014 11:04 AM Wall, Mary Appel, Jeff; Pedersen, AnnMarie RE: Program review docs removed from the FSA data center Nobody else has asked. | don’t have a concrete timeframe. We are obviously working as quickly as we can and hope to have them re-posted by the end of the month From: Wall, Mary Sent: Monday, June 02, 2014 10:58 AM To: Greene, Chris Ce: Appel, Jeff; Pedersen, AnnMarie Subject: RE: Program review docs removed from the FSA data center Ok, do we have any concrete timeline? Have others asked about these? From: Greene, Chris Sent: Monday, June 02, 2014 10:58 AM To: Wall, Mary Cc: Appel, Jeff; Pedersen, AnnMarie Subject: RE: Program review docs removed from the FSA data center Mary- We ran into a few hiccups during the review. It’s likely another few weeks while we finish review of documents ‘and posting procedures. | understand they want these posted for transparency’s sake but we can’t shortchange the review process, If there are specific reviews they need, let us know and we can provide. Let me know if you have any other questions. chris From: Wall, Mary Sent: Monday, June 02, 2014 10:04 AM To: Greene, Chris Ce: Appel, Jeff Subject: FW: Program review docs removed from the FSA data center Hi Chris —any update on timeline? From: Pauline Abernathy (mailto:pabernathy@ticas.org] Sent: Monday, June 02, 2014 10:02 AM To: Wall, Mary; Appel, Jeff; Studley, Jamie; Ament, Aaron Ce: Joseph Mais; Maura-Dundon ‘Subject: RE: Program review docs removed from the FSA data center, They have not yet been restored. Is there an update on when they will be? Thanks. Pauline From: Pauline Abernathy Sent: Wednesday, May 14, 2014 3:54 PM"Wall, Mary’; Appel, Jeff; Studley, Jamie; Ament, Aaron Ce: Joseph Mais; Maura-Dundon ‘Subject: RE: Program review docs removed from the FSA data center I'm glad to hear that. Thanks for the quick response. Pauline From: Wall, Mary [mailto:Mary.Wall@ed.cov] Sent: Wednesday, May 14, 2014 3:54 PM To: Pauline Abernathy; Appel, Jeff; Studley, Jamie; Ament, Aaron Ce: Joseph Mais; Maura-Dundon ‘Subject: RE: Program review docs removed from the FSA data center Thanks Pauline for the flag. FSA is working on getting them restored shortly. From: Pauline Abernathy [mailto:pabernathy @ticas.ora} Sent: Wednesday, May 14, 2014 3:46 PM To: Appel, Jeff; Studley, Jamie; Wall, Mary; Ament, Aaron Ce: Joseph Mais; Maura-Dundon Subject: Program review docs removed from the FSA data center We are encouraged that ED is now posting final program review documents on ed.gov. However, we noticed that program reviews are no longer listed among the school data available on the FSA data center. Do you know why? If one has the prior link where they had been posted (https://studentaid.ed.gov/about/data- center/school/program-reviews), one finds a note saying “At this time, the FPRD library is unavailable, and will be restored shortly.” We look forward to their being restored shortly and hopefully being joined by school program participation agreements, default management plans and others documents submitted by schools to ED. Pauline Pauline Abernathy Vice President, The Institute for College Access & Suc Direct: 202.223.6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.orgWall, Mary Thursday, May 29, 2014 1:21 PM Joseph Mais; Appel, Jeff RE: TICAS fact sheets on student debt and private education loans Thanks Joseph From: Joseph Mais Sent: 5/29/2014 12:50 PM To: Appel, Jeff; Wall, Mar ‘Subject: TICAS fact sheets on student debt and private education loans I wanted to make sure you saw the most recent fact sheets TICAS has put together. One is current facts and trends in private education loans: http://projectonstudentdebt.org/files/oub/private loan facts trends.pdf The other is a one pager with quick facts about student debt: http://projectonstudentdebt.org/files/pub/Debt Facts and Sources.pdt Joseph Mais Senior policy analyst Director, DC office The institute for college access & success Phone: 202-223-6060 x. 602 imais@ticas. ora www.ticas.orgFrom: Wall, Mary Sent: Sunday, May 25, 2014 4:25 PM To: Appel, Jeff; Sydor, Katherine Subject: FW: CDR concerns FYI ng to find out what this is about and will report back From: Joseph Mais [mailto:imais@ticas.ora] Sent: Thursday, May 22, 2014 6:09 PM To: Wall, Mary Subject: CDR concerns Mary — any chance you have some time tomorrow morning to follow up from our previous discussions about CDRs? Some new developments have given us some reason to be concerned. Please let me know if you have some time to chat tomorrow. Joseph Mais Senior policy analyst Director, DC office ‘The institute for college access & success Phone: 202-223-6060 x. 602 imais@ticas.org www.tieas.orgO'Bergh, Jon Harden, Blake Thursday, May 22, 2014 4:04 PM Pajcic, Helen; Wall, Mary Silver, Joy; Soo, David Subject: RE: Outreach list EOP Attachments: Outreach Assignments.xlsx Here’s an updated version with all the EOP assignments included (I just used “EOP” and will let them decide who calls) They took a lot off our hands, so I made a few other changes over here to make the division of labor more equal. Normally, I'd direct yall to the sharepoint page, but sending in email since Mary is remote, Copying David too so he’s aware, From: Pajcic, Helen Sent: Thursday, May 22, 2014 1:45 PM To: Harden, Blake; Wall, Mary Ce: Silvern, Joy ‘Subject: FW: Outreach list EOP The pigeon has landed, From: Menon, Ajita T. [mallto:Ajita_R_Talwalker@who.eop.gov] Sent: Thursday, May 22, 2014 12:25 PM To: Silvern, Joy; Pajcic, Helen Subject: Outreach list EOPO'Bergh, Jon Pauline Abernathy Thursday, May 15, 2014 9:35 AM Appel, Jeff; Mitchell, Ted; Studley, Jamie; Wall, Mary; Gomez, Gabriella; Muenzer, Melanie; Protopsaltis, Spiros; james_R._kvaal@who.eop gov; rrodriguez@who.eop.gov; Ajita_R Talwalker@who.eop gov; Kelsey Merrick (kmerrick@who.eop gov) sbaker@ovp .eop gov; Lachman, Sherry; Coven, Martha B. (Mertha_B_Coven@omb.eop gov); Aviva Aron-Dine (Aviva RAron-Dine@omb 0p gov); Furman, Jason L; Leibenluft, Jacob; Chopra, Rohit (CFPB); Mahaffie, Lynn; Ament, Aaron; Gast, Sara; Ritsch, Massie; JMatsudaira@cea.eop.goy, educationpolicy@who.eop.go Lexi Saudargas Barrett (abarrett@who.eop gov); PShevlin@who eop.gov; angela peoples@cfpb gov; sarah.bloom.raskin@do.treas.gov; sarah.raskin@do.treas.gov; Kolotos, John; Sheth, Tushar, Nolt, Dorie; McGinnis, Colleen ce: Debbie Cochrane; Joseph Mais; Jennifer Webber Subject: TICAS blog post: 20% of programs with more defaulters than graduates fully pass proposed GE metrics FYI—The new blog post below analyzes data released with the gainful employment NPRM and finds that 20% of programs with more defaulters than graduates would pass the proposed GE standards, Some of these are hhuge programs, and the fact that they fully pass the metrics underscores the need to strengthen them in the final regulation. We will of course include this and other analyses in the detailed comments we formally submit on the NPRM. Pauline Where More Default Than Graduate: Career Education Program Parasites Posted on May 15, 2014 The Obama Administration is moving forward in defining what it means for career education programs to “prepare students for gainful employment in a recognized occupation.” This requirement — which applies to programs at public, nonprofit, and for-profit colleges — has long been in federal law, but, without a rule defining ‘what it means, the Department has been powerless to enforce it. The draft rule would measure career education programs’ outcomes in two ways. First, the debt burdens of program graduates who received federal aid would be compared to their later earnings. Second, students” ability to repay their loans — including both graduates and noncompleters — would be measured through a program- level cohort default rate. Programs where graduates’ earings don’t justify typical levels of debt, and those where borrowers too frequently default on their loans, would lose eligibility for further federal grants and loans unless the programs improve. The data released by the Department in conjunetion with its proposed rule are alarming, They couldn't make a better case for why the rule is desperately needed and must be strengthened to provide meaningful protections for students and taxpayers. To illustrate: Of the 4,420 programs in the dataset with complete data (meaning that both students" debt burdens and default rates are calculated), there are 114 programs where the data show more defaulters than graduates. In other words, students receiving federal aid to attend these programs are more likely to find themselves unable to repay their debt than they are to complete the credential they sought. It’s also important to understand that this very much understates the problem at these programs. That's because, due to the way that debt burden and defaults are measured, these figures represent the defaults from one cohort year (those who 1entered repayment in 2009) compared to ‘wo years’ worth of completers (those who completed in either 2008 or 2009). Here are a few facts about these 114 programs with more defaulters than graduates: © All114 are at for-profit colleges, and most (82) are associate degree (AA) programs. ‘© They include a sizable share of measureable programs in some fields. Seven of the 13 AA programs in ‘securities services administration/management’ have more defaulters than graduates. Six of the 17 ‘accounting technology/technician and bookkeeping’ AA programs have more defaulters than graduates. And the same is ‘rue for all three of the AA programs in ‘criminalistics and criminal science.” ‘+ Almost two dozen of them (23 of the 114) fully pass the proposed rule's modest standards. Of the others, 14 are “in the zone” ~a program limbo for those not good enough to pass and not bad enough to fail outright and 7 fail The fact that 20% of the programs leaving more students in default than with credentials pass the Department's proposed tests clearly shows that the tests aren’t strong enough. And even the 68% of programs that fail outright would remain cligibie for federal funding under the proposed rule unless they failed again. ‘What is also crystal clear from the data is that the stakes for students are high: + Many of the programs are huge: 33 of the 114 programs had more than 1,000 students who entered repayment ina single year, and 6 of them had more than 5,000 borrowers who entered repayment in that year. There are seven programs where the number of defaulters exceeded the number of completers by more than 4,000. All seven are at the University of Phoenix, These are parasitic programs, consuming resources to the detriment of students and taxpayers. Reasonable people may disagree on certain aspects of the Department's proposal, but the need to strengthen the rule so programs like these must shape up should not be one of them. ~ Debbie Cochrane Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 wwwticas.org and www.projectonstudentdebt.org,O'Bergh, Jon Pauline Abernathy Wednesday, May 14, 2014 3:55 PM ‘Wall, Mary; Appel, Jeff; Studley, Jamie; Ament, Aaron Joseph Mais; Maura-Dundon RE: Program review docs removed from the FSA data center V'm glad to hear that. Thanks for the quick response. Pauline From: Wall, Mary [mailto:Mary.Wall@ed.gov} Sent: Wednesday, May 14, 2014 3:54 PM To: Pauline Abernathy; Appel, Jeff; Studley, Jamie; Ament, Aaron Ce: Joseph Mais; Maura-Dundon ‘Subject: RE: Program review docs removed from the FSA data center Thanks Pauline for the flag, FSA is working on getting them restored shortly. From: Pauline Abernathy (mailto:pabernathy@ticas.ora] Sent: Wednesday, May 14, 2014 3:46 PM To: Appel, Jeff; Studley, Jamie; Wall, Mary; Ament, Aaron ct Joseph Mais; Maura-Dundon ‘Subject: Program review docs removed from the FSA data center We are encouraged that ED is now posting final program review documents on ed.gov. However, we noticed that program reviews are no longer listed among the school data available on the FSA data center. Do you know why? If one has the prior link where they had been posted (hitps://studentaid.ed.gow/aboutidata- center/school/program-reviews), one finds a note saying “At this time, the FPRD library is unavailable, and will be restored shortly.” We look forward to their being restored shortly and hopefully being joined by school program partici agreements, default management plans and others documents submitted by schools to ED. Pauline Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.orgO'Bergh, Jon Fro Nolt, Dorie Sent Tuesday, May 06, 2014 9:15 AM To: Appel, Jeff; Ritsch, Massie; Gast, Sara; Schorr, Jonathan; Protopsaltis, Spiros; Greene, Chris Subject: RE: WS) letter to the editor ‘And I added the wrong group of folks to this, so I’m going to move our gainful friends to bee and am adding the correct folks. My apologies! Brain was not firing on all cylinders last night. Dorie Turner Nolt USS. Department of Education Press Secretary Email: Dorie.Nolt@ED.gov P: 202-453-6544 C: 202-465-6540 @EDPressSee From: Appel, Jeff Sent: Monday, May 05, 2014 9:21 PM To: Nolt, Dorie; Ritsch, Massie; Gast, Sara; Sheth, Tushar; McFadden, Elizabeth; Schorr, Jonathan; Protopsaltis, Spiros Subject: RE: WS) letter to the editor Plus Spiros From: Nolt, Dorie Sent: 5/5/2014 8:40 PM To: Ritsch, Massie; Gast, Sara; Sheth, Tushar; GEuser; McFadden, Elizabeth; Appel, Jeff; Schorr, Jonathan Subject: FW: WSJ letter to the editor FYI on an unpublished letter to the editor by TICAS. Dorie Turner Nolt U.S. Department of Education Press Secretary Email: Dorie. Nolt@ED.gov P: 202-453-6544 C: 202-465-6540 @EDPressSec From: Bill Swindell (mailto:BSwindell@ticas.org] Sent: Monday, May 05, 2014 8:39 PM To: Nott, Dorie Subject: FW: WS) letter to the editor Dorie:Here's our unpublished letter to the WSI. Feel free to share with staff. - Bill Today's article (Student-Debt Forgiveness Plans Skyrocket, Raising Fears Over Costs, Higher Tuition, April 22) on federal student loan repayment and forgiveness creates unnecessary confusion and alarm. First, it fils to distinguish income- driven repayment (IDR), which bases monthly payments on a share of the borrower's income, from Public Service Loan Forgiveness (PSLF). Most borrowers in IDR plans won't be eligible for PSLF; you must work full time in the public or nonprofit sector for 10 years — while making qualifying loan payments ~ before you can even apply. ‘The article also cites a cost estimate from a Brookings Institution study that overestimates the cost of Pay As You Earn (the newest IDR plan) in several ways, including presuming nearly universal enrollment and treating anything less than a private lender would charge as a “subsidy,” even though the government doesn’t have the same lending costs or business model. The study's own authors caution, “We do not believe that our estimates represent even rough approximations of the total cost of the income-based repayment programs.” While relying on this flawed estimate to raise alarms about potential costs, the article fails to mention that just last week, the Congressional Budget Office estimated the federal government will make $127 billion in profits from student loans over the next 10 years, even with IDR and PSLF. For a generation, the college costs students and families are expected to cover have risen faster than incomes and grant aid, and state-level cost shifting accelerated during the recent recession. More than 70% of bachelor’s degrees now ‘come with an average of $29,400 in student loans, and IDR is a crucial safeguard for students as loans become more necessary. We and others have proposed ways to make all borrowers eligible for an improved IDR plan that discharges any debt remaining after 20 years while targeting benefits to the neediest. For more information, read our white paper on the issue. Lauren Asher President ‘The Institute for College Access & Success Bill Swindell Communications Director The Institute for College Access & Success 405 14th Street, 11th Floor, Oakland, CA 94612 phone: 510-318-7902 fax: 510-318-7918 email: bswindell@ticas.org wwwticas.ong wuww.projectonstudentdebt.org www. college-insight.org, www. ibrinfo.orgO'Bergh, Jon Fror Nott, Dorie Sent: Monday, May 05, 2014 2:01 PM To: Gast, Sara; GEuser; McFadden, Elizabeth; Sheth, Tushar; Ritsch, Massie; Appel, Jeff; Gomez, Gabriella Subject: FW: Google Alert - "u.s. department of education’ FYI- For-Profit Colleges and the Washington Post © Robert Shireman eco ian ‘© Bxccutive Directo of California Compotes and former Deputy Under Secretary athe US. Department of Education Last month the newspaper that in 1974 launched my teenage interest in journalism as a route to justice and truth got into a tussle with the Department of Education over some data on college graduates’ earnings. That debate was expertly dissected by Ben Miller at the New America Foundation, so it does not need rehashing. Instead, I would like to point out several dubious peripheral claims made by the Post's Glenn Kessler. In shrugging off the Washington Post Company's former ownership of the for-profit Kaplan University, Kessler asserted that with the sale of the Post to Jeff Bezos "there is no longer a potential conflict of interest.” Excuse me, but the Post's ownership of Kaplan was much more than a potential conflict of interest. It was an actual, bona fide conflict. The Post stood to gain financially by dodging oversight of an explosion of predatory practices at for-profit colleges, including Post/Kaplan. Indeed, the CEO of the Washington Post Company actively lobbied to shut down the whole regulatory process (this occurred while I was at the Education Department trying to rein in the abuses). As a newspaper, the Post had an actual confliet, not a potential conflict. Second, Kessler's shorthand description of for-profit colleges was that they "have a different business model than private universities, which generally don't pay taxes, and community colleges, which receive state subsidies.” The business model is indeeddifferent, but not in the ways Kessler implies. As reported by ‘The Huffington Post's Chris Kirkham, the Post/Kaplan recruitment manual included pain and fear sales and students were allegedly subjected to guerrilla i to increase their debt levels to the benefit of the Washington Post Company shareholder: Declaring "state subsidies" as a defining difference is odd since numerous analysts have pointed out that for-profit colleges are up to 90 percent subsidized by grants and loans from the federal government. Owners of for-profit colleges tap directly into the U.S. Treasury to draw down upwards of $30 billion a year. The important difference is not the source of the subsidy, it is the nature of control of the institution: for-profit colleges have investors who demand constantly increasing stock prices, leading executives to mislead and shortchange students and taxpayers.‘The claim that private universities “don't pay taxes" is misleading, too. While they do not pay corporate income taxes, nonprofits are required to commit all of their net revenue to charitable purposes, overseen by trustees without a financial interest. As a result, there is nothing to tax. (Nonprofit colleges are required to pay taxes on unrelated businesses, a category that, yes, should include big-time football and basketball) For-profit colleges would pay no corporate income taxes if they, too, committed their net revenue to charitable purposes, Instead, they choose to capture the income for investors. In other words, for-profit colleges only pay corporate taxes to the extent that they fail to spend their revenue on students. Moreover, nonprofits spend far more of their revenue on salaries that yield payroll and ineome taxes, at tax rates higher than the rate on investors’ capital gains at for-profits, Kessler's assertion about taxes is simplistic and hollow. In covering the issues associated with for-profit colleges, the Washington Post has fallen vietim to the skewed rhetoric of its former corporate sibling, Kaplan. Because of the newspaper's historical commitment to good journalism, especially in light of the its former family ties, the Post owes the public an extra dose of scrutiny of its own assumptions and assertions. Follow Robert Shireman on Twitter: www twitt Dorie Turner Nolt US. Department of Education Press Secretary Email: Dorie.Nolt@ED.gov P: 202-453-6544 C: 202-465-6540 @EDPressSecO'Bergh, Jon From: Studley, Jamie Sent: Wednesday, April 23, 2014 11:26 AM To: Pauline Abernathy Subject: RE: Speaker Update: 6th Annual International Symposium on University Rankings - 25th June 2014, Brussels Ahhot topic to be sure, From: Pauline Abernathy [mailto:pabernathy@ticas.org] Sent: Wednesday, April 23, 2014 11:15 AM To: Studley, Jamie ‘Subject: FW: Speaker Update: 6th Annual International Symposium on University Rankings - 25th June 2014, Brussels Fvil From: Martina Cicakova [mailto:martina.cicakova@publicpolicyexchange.co.uk] ‘Subject: Speaker Update: 6th Annual International Symposium on University Rankings - 25th June 2014, Brussels The 6th Annual International Symposium on University Rankings and Quality Assurance 2014 NH Hotel du Grand Sablon, Brussels Wednesday 25" June 2014 KEY SPEA\ Mr Jordi Curell Director, Lifelong Learning: Higher Education and International Affairs, DG EAC, European Commission Prof. Dr Frank Ziegole Director, Centre for Higher Education: Project Leader, U-Multirank Event Details Website Register to Attend The concept of university rankings is rapidly becoming one of the most important tools used by both students and academic professionals across the world, With the higher education sector widely acknowledged as one of the essential drivers of economic growth, this places an ever greater importance on the systems for assessing and comparing the 1higher education options available Recognising the need for greater clarity, last year the European Commission implemented its key initiatives U-Multirank ‘and U-Map - independent from public authorities and universities, This annual international symposium, now in its sixth year, will assess the challenges that lie ahead in creating and maintaining comprehensive and user-friendly systems for university rankings, Indicators and data collection are key areas which need to be addressed through an integrated and joined-up approach under the guidance of the European Commission, The symposium offers an invaluable opportunity to discuss the dynamics between intemational rankings and rational initiatives developed in various countries, collaborate and communicate strategies and share best practices. For further details, please refer to the enclosed event abstract and programme. Do feel free to circulate this information to relevant colleagues within your organisation, In the meantime, to ensure your university or organisation is represented, please book online or complete and return the registration form at your earliest convenience in order to secure your delegate place(s). Kind regards, Martina Cicakova Public Policy Exchange Tel: +44 (0) 845 606 1535, Fax: +44 (0) 845 606 1539 Ifyou do not wish to receive futher information regarcing PPE events then click here, Publi Poy Exchange Lts Registered in Englana & Wales, Ne 7350384 x80T Registered Office: 253 Grays inn Roza, London,O'Bergh, Jon Fro! Greene, Chris ‘Thursday, April 17, 2014 1:04 PM Wall, Mary Appel, Jeff RE: following up re IBR will do. Sent from my Windows Phone From: Wall, Mary Sent: 4/17/2014 12:45 PM To: Greene, Chris Ce: Appel, Jeff Subject: RE: following up re IBR No worries, and thanks Chris! Could you send along docs or links when they are ready? From: Greene, Chris Sent: 4/17/2014 12:36 PM. To: Wall, Mary Ce: Appel, Jeff Subject: RE: following up re IBR Mary- My apologies for the delay in responding. We do have a process for updating these on a regular basis but the team has been busy working on overhauling the IDR pages in advance of the July 1 changes. That being said, we'll have these fact sheets updated early next week. Chris From: Wall, Mary Sent: Friday, April 11, 2014 4:45 PM To: Greene, Chris Ce: Appel, Jeff Subject: FW: following up re IBR Hey Chris -do you guys have a process for revising these fact sheets at any regular occurrence? If not, could we get the below sheets that Pauline refers to revised? ‘Where I don't think we need to take all of her suggestions, | do want to be sure that IDR fact sheets are up to date and accessible. Maybe we can touch base on this early next week? Thanks! mw From: Pauline Abernathy Sent: 4/10/2014 10:06 PMTo: Gomez, Gabriella; Wall, Mary; Muenzer, Melanie jebbie Cochrane; Joseph Mais Subject: following up re IBR Gaby, Mary and Melanie, thank you again for making the time to meet with us on Monday re CDR issues. We know how packed your schedules are. | wanted to follow up on Mary's question about whether the IBR/PAYE fact sheets in the financial aid toolkit were current. They are not. Neither the IBR nor the PAYE fact sheet has been updated since 2012, which among other things means the monthly payment amounts ate incorrect since they are based on the 2012 poverty thresholds. It is obviously very hard to do IBR outreach without a current fact sheet or brochure from the Dept. (In fact, when the toolkit was launched it did not even have a fact sheet on PAYE in it. We contacted the Dept about that and it was later added.) We have been assured that the Dept is updating these fact sheets but not when, and one of them is now more than 2 years old. Thanks in advance for anything you can do to help with this, Pauline ‘The fact sheets are linked under http: / /financialaidtoolkit.ed.gov/tk/learn/repayment. jsp#repayment-plans and also available under the resources search tool: ‘© IBR (updated March 2012): http:/ /studentaid.ed.gov/sites/ default/files/income-based-repayment.pdf ‘* PAVE (updated Nov 2012): http:/ /studentaid.ed.gov/sites/default/files/pay-as-you-eam, Pauline Abernathy Vice President, The institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 ywwwticas.org and www.projectonstudentdebt.org,O'Bergh, Jon From: Protopsaltis, Spiros Sent: Monday, April 14, 2014 10:25 AM To: Gomez, Gabriella; Muenzer, Melanie; Appel, Jeff; Wall, Mary Subject: RE: Paper Series Funded by Lumina Foundation Explores New Models of Student Financial Success Did not. Had registered to go to their event but was unable to. Thanks for forwarding. | saw the TICAS paper through their press release. Sent from my Windows Phone From: Gomez, Gabriella Sent: 4/14/2014 10:15 AM To: Protopsaltis, Spiros; Muenzer, Melanie; Appel, Jeff; Wall, Mary Subject: FW: Paper Series Funded by Lumina Foundation Explores New Models of Student Financial Success Assume you got these, Sent from my Windows Phone From: Julie Peller Sent: 4/14/2014 10:02 AM To: Gomez, Gabriella ‘Subject: Fwd: Paper Series Funded by Lumina Foundation Explores New Models of Student Financial Success Gaby, | hope you are well! Below are a number of papers on financial aid that we supported and were released today. Talk soon! Julie Julie Peller Director of Federal Policy Lumina Foundation Begin forwarded message: From: Lucia Anderson Weathers Date: April 14, 2014 at 9:48:27 AM EDT To: Julie Peller Ce: Kirsten Cuniffe Subject: FW: Paper Series Funded by Lumina Foundation Explores New Models of Student Financial Success From: Lucia Anderson Weathers Sent: Monday, April 14, 2014 9:30 AM To: Lucia Anderson Weathers Subject: Paper Series Funded by Lumina Foundation Explores New Models of Student Financial SuccessFOR IMMEDIATE RELEASE: Monday, April 14, 2014 PAPER SERIES FUNDED BY LUMINA FOUNDATION EXPLORES NEW MODELS OF STUDENT FINANCIAL SUCCESS - Affordability, State Policy & Passive Repayment Covered by 15 Authors in Papers Released Today - WASHINGTON, DC - Today Lumina Foundation releases a group of 15 expert papers that explore new models of student financial success. These papers are all aimed at addressing one of the biggest barriers to college completion: the amount of money students are required to pay to complete a postsecondary degree or certificate, Considerable research suggests that students are price-sensitive and that financial resources are a necessary tool to help students meet the cost of tuition and fees, as well as transportation, child care, and other indirect expenses, particularly among low-income students. These studies show that the structures currently in place to help students pay these costs are not set up to efficiently provide both access and support completion, The papers, commissioned by the Foundation, are intended to stimulate greater discussion and evaluation around several key topics in student finance, including affordability of higher education, student loan repayment, and federal-state-institutional partnerships. The papers are aimed at addressing solutions that can be implemented at the institutional, state and federal levels. “We believe itis time to fundamentally rethink our national approach to student financing,” said Jamie Merisotis, president & CEO of Lumina Foundation. “Only through substantive redesign can we assure that tuition and financial aid resources are used to support the success of the much larger number of students needed to reach Goal 2025. This launch of the comprehensive policy papers is an early step in that redesign effort.” Last year, Lumina Foundation developed and released a set of design principles to guide the Foundation’s work in this area. The principles were unveiled this past May in a Huffington Post blog authored by Merisotis Using the design principles as a guide, Lumina Foundation invited nationally recognized experts as well {as up-and-coming analysts to author the papers that will be discussed during today’s Ideas Summit at the Newseum in Washington, DC. The papers can be found online at www luminafoundation.org/newsroom/ideas_summit. The titles and authors of the papers are as, follows: ‘* ACollege Considerator: Robert shireman, California Competes, Lande Ajose, California Competes ‘* AStudent Level Analysis of Financial Aid: Richard Rhoda, Tennessee Higher Education Commission, Russ Deaton, Tennessee Higher Education Commission, Davié Wright, Tennessee Higher Education Commission, Doug ‘Mennen, Tennessee Higher Education Commission ‘* Advancing Shared Responsibility as a Model for Contemporary State Grant Aid Programs: arian T. Prescott, WICHE, David A. Longanecker, WICHE * Applying the Lessons of Behavioral Economics to Improve the Federal Student Loan Programs: Six Policy Recommendations: Angela Boatman, Vanderbilt University, Brent Evans, Vanderbilt University, ‘Adela Soli, Harvard University * Can Income-Driven Repayment Policies be Efficient, Effective, and Equitable? nichols Hillman, University of Wisconsin-Madison, Jacob Gross, Unversity of Lousulle. © College Affordability for Low Income Adults: Improving Returns on Investment for Families and Society: earboro Gault, Institute for Women's Policy Research, Lindsey Reichl, Institute for Women’s Policy Research, Meghan Froehner, Institute for Women’s Policy Research, Stephanie Roman, institute for Women’s Policy Research ‘+ College Affordability: What Is It and How Can We Measure It? sandy Boum, George Washington University and The Urban institute Jennifer Ma, The College Board 2* College Costs: Students Can't Afford Not to Know: Brad Hershbein, W.E. Upjoha institute for Employment esearch, Kevin Hollenbeck, W.E, Uplohn Institute for Employment Research © Estimating the Costs and Benefits of Income-Based Student Loan Repayment Systems: Beth Akers, Brookings instution, Matthew Chingos, Brookings Institution © From Income-based Repayment Plans to an Income-based Loan System: Robert G. sheets, George Washington institute for Public Policy, George Washington University, Stephen Crawford, George Washington Institute or Public Policy, George Washington University ‘* Moving the Needle: How Financial Aid Policies Can Help States Meet Student Completion Goals: Andy Carlson, SHEEO, Katie Zaback, SHEEO ‘© Piecing Together the College Affordability Puzzle: Student Characteristics and Patterns of (Un)Affordability: Rashida Welbeck, MORC, John Diamond, MORC, Alexander Mayer, MORC, Lashawn Richburg Hayes, MORC with Melvin Gutierres, MRC & Jessica Gingrich, MORC ‘© Putting Colleges on Notice: Crafting Smarter Strategies to Improve Affordability through Curbing Cost Increases: Alisa Hickin Fryar, University of Oklahoma, Deven Carlson, University of OKahoma ‘© Securing America’s Future with a Universal Two-Year College Option: Sara Goldrck-Rab, Education (Optimists and University of Wisconsin-Modison, Nancy Kendall, Univesity of Wisconsin-Madison «Should All Student Loan Payments Be Income-Driven? Benefits, Trade-offs, and Challenges Lauren Asher, The institute for College Access & Success (TICAS), Diane Cheng, The institute for College Access & Success (TICAS) Jessica Thompson, The Institute for College Access & Success (TICAS) “Our goal in this series is not to prescribe a particular solution or choose one course of action,” said Merisotis. “Rather, we seek to generate innovative ideas for improving the ways in which postsecondary education is paid for in this country and to stimulate further discussion on that vital topic.” Each paper reflects the views and recommendations of its authors, not those of Lumina Foundation. Lumina’s Strategy Director, Zakiya Smith, oversees the Foundation’s work in student financial support and will head up the paper launch event at the Newseum today. ane ‘About Lumina Foundation: Lumina Foundation is an independent, private foundation committed to increasing the proportion of Americans with high-quality degrees, certificates and other credentials to 60 percent by 2025, Lumina’s outcomes-based approach focuses on helping to design and build an accessible, responsive and accountable higher education system while fostering a national sense of urgency for action to achieve Goal 2025. For more information, log on to: www.luminafoundation.ong Media contact: Lucia Anderson Weathers 30'S. Meridian S., Suite 700 Incianspolis, IN. 46 omice: (317) 951-5316 je: (317) S17~ This email has been nned by the Symantec Email Security. cloud service.For more information please visit http://www.symanteccloud.comfergh, Jon Sent: To: Subject: Bob Shireman and Lande Ajose on behalf of Bob Shireman and Lande Ajose Monday, April 14, 2014 10:23 AM Plotkin, Hal The College Affordability Puzzle The College Affordability Puzzle You'd think it would be pretty easy to develop a college affordability calculator. Start with the value — benefits minus costs over time — and then plug in financial aid and loans, and voila, an answer pops up telling a high school senior what to do. But what if the cheaper college is also the least likely to support the student to graduation? That was just one of the complicating factors we at California Competes grappled with as we tried to develop a working calculator. Realizing that numbers and formulas can’t produce the one right answer, we created a tool we call the College “Considerator” because it aims to prompt thinking about important aspet of the college-going decision. © The Considerator tells users how likely they are to graduate and how long it will take based on a combination of their own self-described backgrounds and plans (such as working, or going part time) and the colleges’ graduation rates. It grabs actual price and financial aid estimates from college web sites to produce a debt hazardindicator reflecting the amount of loans the user would need to take out compared to pre led post-college earnin * We pioneer the concept of a “break-even age" — how old the graduate would be when the cumulative benefits of coll surpass the costs. (This was the result of our effort to avoid requiring any mind-numbing discussion of net present value). * Probably the most unusual aspect of the Considerator is our effort to include the lif enrichment value of college. Trying to account for self- fulfillment, fun, and friendships may seem strange, but excluding them ‘would cheapen college by ignoring its possibly most important elements, We prompt ets to ponder the life-enrichment value of college through a survey that asks about their reasons for going to college. (You c: ty the alumni version of the survey here). The complications we faced in building the Considerator are chronicled in a new publication, A College Considerator: Factors to weigh in contemplating college affordability. The report includes instructions for trying out the too! yourself, but remember: we produced it as a thought exercise so itis stil in a developmental stage, where it may remain. Read the report, A College Considerator: Factors to weigh in contemplating college affordability Visit us online at www. rniacompetes.org us on Facebook Follow us on Twitter Find us on F ae Copyright © 2014 Califomia Competes, All ights POUL Ia Rien ction eer atO'Bergh, Jon From: Pauline Abernathy Sent: Monday, April 14, 2014 9:47 AM To: Pauline Abernathy Subject: TICAS Details Unintended Consequences, Trade-offs, and Challenges of Making All Student Loan Payments Income-Driven Attachments: TICAS IDR White Paper NRPOF college access: success FOR IMMEDIATE RELEASE: April 14, 2014 CONTACTS: Shannon Gallegos Gretchen Wright Bill Swindell 510/318-7915 202/371-1999 510/318-7902 Should All Student Loan Payments Be Income-Driven? TICAS Details Unintended Consequences, Trade-offs, and Challenges (Oakland, CA) - Ina new white paper issued today, The Institute for College Access & Success (TICAS) finds that while income-driven repayment is a crucial option for student loan borrowers, making it mandatory could have a range of unintended consequences. Federal student loan borrowers can currently choose from multiple repayment plans, including several that base monthly payments on a share of the borrower's income and provide a light at the end of the tunnel by discharging any remaining debt after 20 or 25 years of payments, TICAS developed the policy framework and led the advocacy campaign for income-Based Repayment, the most widely available of these income-driven repayment (IDR) plans. Some researchers and policymakers have proposed making IDR the only way to repay student loans, or automatically enrolling borrowers in IDR but letting them opt out. Such proposals also typically call for employers to withhold income-driven Joan payments from borrowers’ paychecks. In Should All Student Loan Payments Be Income-Driven? Trade-offs and Challenges, TICAS analyzes the potential effects of requiring IDR for all federal loans as well as relying on paycheck withholding for loan payments, with particular attention to the implications for low-income students and families. TICAS also examines the relevance and evolution of mandatory IDR systems in Australia and the United Kingdom, and the paper includes specific recommendations to streamline and improve student loan repayment options in the United States. “Income-driven repayment is a crucial option for federal student loan borrowers. It can help keep monthly payments manageable and prevent default, but it’s not the best choice for everyone,” said TICAS president and paper co-author Lauren Asher. “If income-driven repayment were mandatory, some borrowers would end up carrying debt for many more years and paying more over the life of their loans. This could make them less likely to buy a home, start a family, save for retirement, or launch a small business.” Among the report's key findings:IDR plans can help make monthly payments manageable, and more widespread use could thus reduce, but not eliminate, student loan defaults. IDR can increase the amount of time that borrowers have outstanding debt, which could reduce access to other forms of credit and borrowers’ willingness to make other financial commitments. ‘* Some borrowers end up paying more over the life of their loans under IDR than in a traditional repayment plan, even after adjusting for inflation. ‘* Lessons from other countries’ mandatory IDR systems are not necessarily applicable to the U.S. For example, the Australian and U.K. systems were introduced to generate new revenue for public higher education systems that had not been charging tuition, In the U.S., tuition already accounts for nearly half of public college revenue. ‘* Without significant reforms to current college accountability systems, mandatory IDR could inadvertently create a safe haven for schools that fail to serve students well. * Mandatory IDR could reduce pressures on government and colleges to make higher education more affordable, leading to even higher tuition and less need-based grant aid. Research shows that reducing upfront costs is the most effective way to increase college access and success. + Paycheck withholding could simplify or complicate student loan repayment depending on the borrower's circumstances. It poses particular risks to those who have to work multiple part-time jobs, are self-employed, don’t have enough savings to cover unexpected costs in a given month, or have an employer with limited ‘administrative capacity. The paper also identifies specific areas where more data and research are needed to assess how specific proposals for mandatory or automatic IDR and paycheck withholding would affect process burdens and costs for the neediest students, Policy recommendations in the paper include: streamlining current IDR plans into one improved plan that better targets benefits to the borrowers who need help the most; making it easier for all borrowers to update their financial information in IDR; not treating debt discharged through IDR as taxable income; automatically enrolling severely delinquent borrowers in IDR; and improving the timing, content, and effectiveness of loan counseling. “Our student loan repayment system is clearly ripe for improvement: there should be one, well-designed income-driven plan and more help for borrowers to choose the plan that’s right for them, keep up with their payments, and avoid default,” said Asher. “Stil, repayment reform won't solve the problems of rising college costs and student debt, Mandatory income-driven repayment could make college even less affordable by reducing pressure on states and colleges to contain the costs they're passing on to students and families.” Should Ail Student Loan Payments Be Income-Driven? Trade-offs and Challenges, by Lauren Asher, Diane Cheng, and Jessica Thompson, Is one of a series of reports funded by Lumina Foundation and released at a summit in Washington, D.C. today. The views expressed in the paper are solely those of TICAS. wee ‘An independent, nonprofit organization, The institute for College Access & Success (TICAS} works to make higher education more available and ‘affordable for people of al backgrounds, TICAS’ Project on Student Debt works to increase public understanding of rising student debt and the implications for our families, economy, and society. Folow us on Twitter.Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.orgO'Bergh, Jon From: Studley, Jamie Sent: ‘Tuesday, April 08, 2014 9:27 PM To: Debbie Cochrane Subject: RE: Sorry I missed you, too Ok! Sent from my Windows Phone From: Debbie Cochrane Sent: 4/8/2014 6:57 PM To: Studley, Jamie ‘Subject: Re: Sorry | missed you, too ‘Two metro stops away On Apr 8, 2014, at 6:40 PM, "Studley, Jamie" wrote: Great. Let’s meet at Oyamel, right at that corner. From: Debbie Cochrane [mailto:DCochrane@ticas.ora] Sent: Tuesday, April 08, 2014 6:38 PM To: Studley, Jamie Ce: Joseph Mais Subject: Re: Sorry I missed you, too | think Joseph may be out but I'd love to meet up for a drink. See you there in 20. On Apr 8, 2014, at 6:34 PM, "Studley, Jamie" wrote: Just got out of a mtng myself. | could be at Penn Quarter (7th and D NW) in about 20, ‘min, would you like to have a drink then /there? if that’s not feasible I certainly understand From: Debbie Cochrane [mailto:DCochrane@ticas.ora] Sent: Tuesday, April 08, 2014 5:42 PM To: Studley, Jamie Ce: Joseph Mais ‘Subject: Re: Sorry I missed you, too Hi Jamie - Joseph and | just got out of a meeting and wanted to check in. Let us know if you're available to meet up and, if so, where! We are free until 7:30 or so. (On Apr 7, 2014, at 9:39 PM, "Studley, Jamie" wrote: Do you want yo check in tomorrow and see how our days go? | cd probably do something in that window (maybe near my home in Penn Quarter, across the mall on 7th).Sent from my Windows Phone From: Debbie Cochrane Sent: 4/7/2014 To: Studley, Jamie Cc: Pauline Abernathy; Joseph Mais Subject: Re: Sorry | missed you, too Very understandable! Pauline went back to Philly already but | (and maybe Joseph) could meet up between 6-7:30 if you're free. Just let us know. (On Apr 7, 2014, at 5:58 PM, "Studley, Jamie" wrote: | was overly optimistic about getting out of a meeting with 60 student govt leaders from the Big 10. Hope you're having a good visit and not getting too wet. If by chance you're still here tomorrow nigh Jamienne 5. Studley ‘Acting Under Secretary Us Department of Education 400 Maryland Avenue, SW Washington, DC 20202 202-453-5666O'Bergh, Jon Studley, Jamie Tuesday, April 08, 2014 7:08 PM. Debbie Cochrane{(bl6) Subject: Im at oyamel at 7th and D NW Pls reply to Gmail, other phone running low Sent from my Windows Phone From: Debbie Cochrane Sent: 4/8/2014 6:38 PM To: Studley, Jemie Ce: Joseph Mais Subject: Re: Sorry | missed you, too | think Joseph may be out but I'd love to meet up fora drink. See you there in 20. On Apr 8, 2014, at 6:34 PM, "Studley, Jamie" wrote: Just got out of a mtng myself. I could be at Penn Quarter (7th and D NW) in about 20 min, would you like to have a drink then /there? If that’s not feasible | certainly understand From: Debbie Cochrane [mailto:DCochrane@tticas.org] Sent: Tuesday, April 08, 2014 5:42 PM To: Studley, Jamie Ce: Joseph Mais Subject: Re: Sorry I missed you, too Hi Jamie - Joseph and | just got out of a meeting and wanted to check i to meet up and, ifso, where! We are free until 7:30 or so. Let us know if you're available On Apr 7, 2014, at 9:39 PM, "Studley, Jamie" wrote: Do you want yo check in tomorrow and see how our days go? | cd probably do something in that window (maybe near my home in Penn Quarter, across the mall on 7th) Sent from my Windows Phone From: Debbie Cochrane Sent: 4/7/2014 7:33 PM To: Studley, Jamie Cc: Pauline Abernathy; Joseph Mais Subject: Re: Sorry | missed you, too Very understandable! Pauline went back to Philly already but | (and maybe Joseph) could meet up between 6-7:30 if you're free. Just let us know. On Apr 7, 2014, at 5:58 PM, "Studley, Jamie" wrote: 1was overly optimistic about getting out of a meeting with 60 student govt leaders from the Big 10. Hope you're having a good visit and not ‘getting too wet. if by chance you're still here tomorrow night...? Jamienne S. Studley Acting Under Secretary US Department of Education 400 Maryland Avenue, SW Washington, DC 20202 202-453-5666O'Bergh, Jon Fror Sent: To: Subject: Bob Shireman and Lande Ajose on behalf of Bob Shireman and Lande Ajose Tuesday, April 08, 2014 1:55 PM Plotkin, Hal Webinar: Where are California's next 40,000 community college seats most needed? Webinar Where are California's next 40,000 community college seats most needed? REMINDER Ifyou haven't already registered, please join us tomorrow at 10:30AM PDT for a webinar and report release examining strategies for growing California's community college enrollment, building on the analysis we released in November of last year. ‘Welll be looking at where community college growth is most needed and how “unmet need” should be defined, identified, and addressed, while ensuring equity and a focus on serving the neediest students When: Tomorrow - Wednesday, April 9 from 10:30AM - 11:30AM Space is limited - only 10 seats left. Reserve your Webinar seat now at: hiipsv//www3.got ccom/register/958560038 Questions: Contact Remmert at rdekker@californiacompetes.org Visit us online at www.californiacompetes.oraLike us on Facebook Gace and Twiter right © 2014 Califomia Competes, Alligh poe EP ayeu nara Hunt House, Suite 100 BaiseO'Bergh, Jon Fitzpatrick, Kelly Thursday, April 03, 2014 11:43 AM Henderson, Josh Subject: RE: following up re meeting Monday or Tuesday with you and Gaby Thanks Josh From: Henderson, Josh Sent: Thursday, April 03, 2014 11:32 AM Tos Fitzpatrick, Kelly Subject: RE: following up re meeting Monday or Tuesday with you and Gaby Yup, that works From: Fitzpatrick, Kelly Sent: Thursday, April 03, 2014 11:26 AM To: Henderson, Josh ‘Subject: FW: following up re meeting Monday or Tuesday with you and Gaby Hey Josh — just wanted to verify that this time works for Jeff. See message below re: meeting with TICAS on COR, From: Joseph Mais (mailto:jmais@ticas.ora] Sent: Thursday, April 03, 2014 11:12 AM To: Fitzpatrick, Kelly ‘Subject: RE: following up re meeting Monday or Tuesday with you and Gaby Got it- Monday 3-4pm should work fine. Thanks. Joseph From: Fitzpatrick, Kelly [mailto:Kelly.Fitzpatrick@ed.gov] Sent: Thursday, April 03, 2014 10:41 AM To: Joseph Mais Subject: RE: following up re meeting Monday or Tuesday with you and Gaby HiJoseph, Unfortunately, it looks like a conflict may have just arisen on Tuesday. How does Monday look for you all? Thanks, kelly From: Joseph Mais {mailto:\mais@ticas.ora] Sent: Thursday, April 03, 2014 8:53 AM To: Fitzpatrick, Kelly Subject: RE: following up re meeting Monday or Tuesday with you and Gaby Kelly - can we confirm Tuesday 3-4pm.Thanks for all your help, Joseph Joseph Mais Senior policy analyst Director, DC office ‘The institute for college access & success 202-223-6060 x 602 imais@TICAS.ora. aww TICAS.org “Fitzpatrick, Kelly" wrote: Great — how does Monday 3:00 ~ 4:00 or Tuesday 3:00 ~ 4:00 work for you? Thanks, kelly From: Joseph Mais [mailto:jmais@ticas.org] Sent: Wednesday, April 02, 2014 4:07 PM To: Fitzpatrick, Kelly ‘Subject: RE: following up re meeting Monday or Tuesday with you and Gaby Thank you Kelly ~ an hour would be preferable if possible Joseph Joseph Mais Senior policy analyst Director, DC office The institute for college access & success Phone: 202-223-6060 x. 602 imais@ticas.ora From: Fitzpatrick, Kelly [mailto:Kelly.Fitzpatrick@ed.gov] Sent: Wednesday, April 02, 2014 3:04 PM To: Joseph Mais Subject: RE: following up re meeting Monday or Tuesday with you and Gaby HiJoseph, I’m looking at the schedule right now — could you tell me exactly how much time you all are looking for? 30 min or an hour? Thanks, kellyFrom: Muenzer, Melanie Sent: Wednesday, April 02, 2014 3:01 PM To: Pauline Abernathy Cet Joseph Mais; Fitzpatrick, Kelly ‘Subject: RE: following up re meeting Monday or Tuesday with you and Gaby Thanks Pauline, Adding Kelly who is Gaby’s scheduler and can work with Joseph to find a time for us to all meet on Monday or Tuesday. From: Pauline Abernathy [mailto:pabernathy@ticas.org] ‘Sent: Wednesday, April 02, 2014 2:49 PM To: Muenzer, Melanie Cc: Joseph Mais Subject: following up re meeting Monday or Tuesday with you and Gaby Good speaking with you. I've cc’d Joseph Mais, our DC office director, per our conversation. Below is an excerpt from our public memo on CDR manipulation in which ITT said that improper servicing appeals would lower their CDR by up to 8 percentage points. “In January 2012, ITT Educational Services (ITT) told investors that it expected its average draft FY2009 three-year CDR to be between 3426-3626--well above the 30% threshold. However, ITT also told investors that it was appealing all of its draft CDRs and estimated dramatic reductions in all of their rates as a result. For instance, in the case of its FY09 two-year CDR, executives said excluding loans they considered to have been “improperly serviced” decreased the rate from 22% to as low as 14%."! In April 2012, ITT executives told investors that it had “won all of the appeals we’ve heard back on, and we're just waiting to hear back on the remainder of them.” 1 pre 42011 earings cll, January 26,2012, Available a ip:scekingsgha con/atile/322420-Atdusationalseviesineseniscsss-gt-20 els: ines clarnsi. " TrrQ1 2012 caring el, April 26,2012. Availabe at pzisekingalha con/atle/$3299 -it-educatonal sevies-cev-discuses1-20]2-esls-camings= sala Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223,6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.orgrrr 2011 caring cll, January 26,2012, Available at hip:/seckingalpha comlansle!322420sit-educstons-scrvces-ine-seo-sisousses-g420 Leas camingecall-ancrint 21 ryr.Q1 2012 earings cll, April 26,2012. Available ot pecking convatice'S3299-it-duciona-serviees-teo diseases salsranssti. sesuls-emings=O'Bergh, Jon Fro Bob Shireman and Lande Ajose on behalf of Bob Shireman and Lande Ajose Wednesday, April 02, 2014 4:44 PM Plotkin, Hal ‘Webinar: Revamping California's community college funding strategy Webinar: Where are California's next 40,000 community college seats most needed? REMINDER: Please join us next week Wednesday, April 9, at 10:30AM for a webinar and report release that examines strategies for growing California's community college enrollment, building on the analysis we released in November of last yeer. Welll be looking at where community college growth is most needed and how “unmet need” should be defined, identified, and addressed, while ensuring equity and a focus on serving the neediest students. When: Wednesday, April 9 from 10:30AM - 11:30AM. a=] Space is limited. Reserve your Webinar seat now at: hups:/Avww3.gotomeeting.com/register/95856003: Questions: Contact Remmert at rdekker@californiacompetes.org, Visit us online at yww.californiacompetes.org, Like us on Facebook Follow us on Twitterieee ee a c , Allrights Coen Pee aca igi) Cre rca rr nen freer Geni ory Yate tare xtermO'Bergh, Jon Perrotti, Carmine Wesinesday, April 02, 2014 2.05 PM carrie wofford@veteranseducationsuccess.org; Henderson, Josh Carrie Wofford [confirmation] your form has been received Dear Carrie ~ ‘Thank you for submitting this scheduling request to the Office of the Under Secretary. ur staff will review your proposal and follow up with you shortly. We look forward to being in touch soon. Best, Carmine Perrotti Confidential Assistant Office of the Under Secretary U.S. Department of Education Email: carmine.perrotti@ed.gov Desk: 202-401-0264 From: carrie.wofford@veteranseducationsuccess.org [mailto:carrie.wofford @veteranseducationsuccess.org] Sent: Wednesday, April 02, 2014 11:59 AM To: Perrotti, Carmine; Henderson, Josh Ce: Carrie Wofford Subject: RE: Meeting Request PS we are flexible on date. If those 2 weeks (April 14-25) are when Jamie, Jeff and Jim are traveling, we can do the next week. Or the previous week. We're pretty flexible. THank .- Original Message Subject: Meeting Request From: carrie.wofford@veteranseducationsuccess.org, Date: 4/1/14 3:43 pm To: "Perrotti, Carmine" , Josh. Henderson@ed.gov Ce: "Carrie Wofford" Carmine and Josh - thank you both so much for reaching out about scheduling this meeting. The organizations are very eager for this meeting. Attached is the meeting request. Did I complete it all correctly? Thank you! Original Message Subject: [action requested] Your meeting request of Acting Under Secretary Jamienne Studley From: "Perrotti, Carmine” 1Date: 3/27/14 7:24 am ‘To: "carrie, wofford@veteranseducationsuccess.org" Ce: "Carrie Wofford" Dear Carrie ~ Thank you for contacting the Office of the Under Secretary, In order to submit a formal scheduling request, please complete the attached form and return it to me by email Please keep in mind that if you are requesting a meeting with less than two weeks notice, your request will be difficult to accommodate. IF you have any questions, feel free to contact me. Best, Carmine Perrott Confidential Assistant Office of the Under Secretary USS, Department of Education Email: carmine.perrotti@ed.gov Desk: 202-401-0264 From: carrie,wofford@veteranseducationsuccess.ora [mailto:carrie wofford@veteranseducationsuccess.ora) Sent: Thursday, March 27, 2014 8:12 AM Studley, Jamie Ce: Protopsaltis, Spiros; Carrie Wofford; Perrotti, Carmine; Appel, Jeff ‘Subject: RE: Meeting request‘Thank you! Original Message Subject: RE: Meeting request From: "Studley, Jamie" Date: 3/26/14 7:08 pm To: "carrie. wofford @veteranseducationsuecess.org" Ce: "Protopsaltis, Spiros" , "Carrie Wofford" , "Perrotti, Carmine" , "Appel, Jeff" Obviously a very important topic! I'm looping in my scheduler to follow up about who and when. Thanks for reaching out. Sent from my Windows Phone From: carrie. wofford @veteranseducationsuccess.org Sent: 3/26/2014 4:52 PM To: Studley, Jamie Ce: Protopsaltis, Spiros; Carrie Wofford; Perrotti, Carmine Subj : Meeting request Hello. A coalition of organizations would like time to brainstorm with you and whoever else at ED could help talk about things ED could do right now to help stop deception and fraud against students by predatory for-profit colleges. We have some brainstorms for ED. None of it relates to Gainful Employment, We're happy to wall that off entirely. Could we please book a time? I'm looping Spiros only b/e we worked together on Senate HELP and he knows the issues too. And Carmine who I hope can help book this. The groups who might attend, depending on schedule, include: Ed Trust, TICAS, Young Invincibles, NACAC, Vets Ed Success, Military Officers Assoc of America, Iraq & Afghanistan Vets of America, Student Vets of America, California Competes, AASCU, New America Foundation, US PIRG, AFT, National Consumer Law Center, Leadership Conference on Civil & Human Rights, Center for Responsible Lending, Mississippi Center for Justice, and Lumina Foundation.‘Thanks so much for making time for us. Preferably an hour and a half to have a real discussion. Thank you! Carrie Wofford - Original Message ~ Subject: do you have time to meet with a group of us? From: carrie.wofford@veteranseducationsuccess.org, Date: 1/30/14 5:57 pm To: jamie.studley@ed.gov Hello Jamie. [hope you are enjoying ED and it isn't like drinking from a firehose, Could you and your team make time, please, to meet with vets groups, consumer groups, education groups, and civil rights groups to talk about a range of issues regarding deceptions and abuses of students by predatory for- profit colleges (but not Gainful Employment, if you aren't allowed to)? We have some brainstorms for ED. Thank you, All the best, Carrie WoffordO'Bergh, Jon Studley, Jamie Tuesday, April 01, 2014 10:03 PM Perrotti, Carmine RE: Meeting request What a coincidence Sent from my Windows Phone From: Perrotti, Carmine Sent: 4/1/2014 7:22 PM To: Studley, Jamie Subject: RE: Meeting request Carrie jus submitted a meeting request form at 6:43 tonight. Sent from my Windows Phone From: Studley, Jamie Sent: 4/1/2014 7:21 PM To: Perrotti, Carmine Subject: FW: Meeting request This is in the works, right? I'd like to add Lauren Thompson to the invitation list, From: carrie.wofford@veteranseducationsuccess.org [mailto:carrie.wofford@veteranseducationsuccess.org] Sent: Wednesday, March 26, 2014 4:52 PM To: Studley, Jamie Ce: Protopsaltis, Spiros; Carrie Wofford; Perrotti, Carmine Subject: Meeting request Hello. A coalition of organizations would like time fo brainstorm with you and whoever else at ED could help talk about things ED could do right now to help stop deception and fraud against students by predatory for- profit colleges. We have some brainstorms for ED. None of it relates to Gainful Employment. We're happy to wall that off entirely. Could we please book a time? I'm looping Spiros only b/e we worked together on Senate HELP and he knows the issues too. And Carmine ‘who T hope can help book this. ‘The groups who might attend, depending on schedule, include: Ed Trust, TICAS, Young Invincibles, NACAC, Vets Ed Success, Military Officers Assoc of America, Iraq & Afghanistan Vets of America, Student Vets of ‘America, California Competes, AASCU, New America Foundation, US PIRG, AFT, National Consumer Law Center, Leadership Conference on Civil & Human Rights, Center for Responsible Lending, Mississippi Center for Justice, and Lumina Foundation, ‘Thanks so much for making time for us. Preferably an hour and a half to have a real discussion. Thank you!Carrie Wofford - Original Message Subject: do you have time to meet with a group of us? From: carrie. wofford@veteranseducationsuccess.org Date: 1/30/14 5:57 pm To: jamie.studley@ed.gov Hello Jamie. I hope you are enjoying ED and it isnt like drinking from a firehose. Could you and your team make time, please, to meet with vets groups, consumer groups, education ‘groups, and civil rights groups to talk about a range of issues regarding deceptions and abuses of students by predatory for-profit colleges (but not Gainfuul Employment, if you aren't allowed to)? We have some brainstorms for ED. Thank you. All the best, Carrie WoffordO'Bergh, Jon From: news=ticas.org@mail salsalabs.net on behalf of The Institute for College Access & Success Sent: Thursday, March 27, 2014 2:07 PM To: Soo, David Subject: ‘Administration's Gainful Employment Proposal Must Be Strengthened; Our Take on the President's Budget; Other News Administration's Gainful Employment Proposal Must _ [j'!!#inis trues sons ste Be Strengthened ae The President's FY15 Budget Fully Funds Pell Grants, Improves Income-Driven Repaym: ind Expands Access to the Targeted Education Tax Credit TICAS Testifies at Two Cal Grant Hearings Community College Groups Honor TICAS' Debbie Cochrane Administration's Gainful Employment Proposal Must Be Strengthened The Education Department this month released its proposed "gainful employment" regulation. While we commend the Administration for issuing a proposed rule, it needs to be strengthened to adequately protect students and taxpayers and prompt schools to quickly improve or end weak programs that consistently leave students with debts they can't pay. The rule enforces a federal law requiring career education programs that receive federal student aid - at public, nonprofit, and for-profit colleges - to prepare students for gainful employment in a recognized occupation. Read our statement on the proposed rule The President's FY15 Budget Fully Funds Pell Grants, Improves Income-Driven payment, and Expands Acces the 1Mos Targeted Educatio President Obama released his fiscal year 2015 budget earlier this month, and we welcomed the steps it takes to make college more affordable for millions of Americans. It does this by investing in Pell Grants, making the American Opportunity Tax Credit permanent and expanding access to it, improving income-driven federal student loan repayment plans, and preventing the taxation of Pell Grants and debts forgiven for borrowers in income-driven repayment plans. The budget funds the scheduled $100 increase in the maximum Pell Grant to $5,830 in 2015-16, helping nearly nine million students attend and complete college. Still, even with the increase, the maximum Pell Grant is expected to cover the smallest share of the cost of attending a four-year public college since the program was started. The budget also improves income-driven repayment, making more borrowers eligible to cap their monthly payments at 10 percent of their discretionary income and have any debt remaining after 20 years discharged without taxation. As we have recommended, the proposal also makes permanent the American Opportunity Tax Credit (AOTC), which research suggests is the most likely of the current tax benefits to increase college access and success, and enables more Pell recipients to benefit from the tax credit. Read our press release on the budget proposal This month, TICAS research director Debbie Cochrane was invited to testify about Cal Grants before both the California Assembly and Senate budget subcommittees. She shared new TICAS findings on college affordability at different income levels and recommended ways to strengthen Cal Grants for the state's neediest students. The recommendations, supported by a diverse coalition of student, civil rights, business, and college access organizations, include: increasing the Cal Grant B ‘Access Award, which helps the lowest income 2recipients pay for college costs beyond tuition; providing Cal Grants to more nontraditional students; and allowing Cal Grant B students to receive tuition and fee support during their freshman year. Students and representatives of several coalition members, including California Competes, CALPIRG, the California State Student Association, the Earned Assets Resource Network, and the Los Angeles Area Chamber of Commerce, echoed these priorities. Debbie noted these reforms "are affordable and within reach if the legislature chooses to make college affordability a priority.” Read Debbie's testimony View the supplemental one-pager The Association of Community College Trustees and the American Association of Community Colleges recognized TICAS research director Debbie Cochrane's "exceptional contributions at the federal level in promoting national public policies and goals of community colleges and their students" with their 2014 Government Relations Award. Scott Lay, CEO of the Community College League of California, presented Debbie with the award. home contact us terms of use click to unsubscribeO'Bergh, Jon Debbie Cochrane ‘Thursday, March 27, 2014 5:08 PM Studley, Jamie RE: Pell provision Hi Jamie, at long last I'm getting back to this. I've sent Spiros a note but is there anyone else you'd suggest | follow up with about the administration Pell SAP provision, too? Many thanks, and | hope you're welll Debbie From: Studley, Jamie [maitoJamie,Studley@ed.gov] ‘Sent: Wednesday, March 05, 2014 7:54 AM ‘To: Pauline Abernathy Cc: Debbie Cochrane ‘Subject: RE: Pell provision Of course, And you can always try Spiros Sent from my Windows Phone From: Pauline Abernathy Sent: 3/5/2014 9:44 AM. To: Studley, Jamie Cc: Debbie Cochrane Subject: RE: Pell provision Jamie, we would very much appreciate it if you can connect Debbie with someone who knows the provision better. Debbie is in Sacramento until Friday but can circle back with you on Friday to get connected to the right person, Thanks! From: Studley, Jamie {mailto:Jamie.Studley@ed.gov} Sent: Tuesday, March 04, 2014 6:36 PM To: Pauline Abernathy Subject: RE: TICAS: President's FY15 Budget Fully Funds Pell Grants and Improves Income-Driven Repayment It relates to what Jeff Appel described as “reflecting consumption of education services at the student level.” Specifically, students moving from first to second year would be required to have grades for at least half their classes, a proportion that rises as they move through school. If you want more Imk and I'll find someone who knows the specific provision better. From: Pauline Abernathy [mailto:pabernathy @ticas.org} Sent: Tuesday, March 04, 2014 5:16 PM To: Studley, Jamie Subject: RE: TICAS: President's FY15 Budget Fully Funds Pell Grants and Improves Income-Driven Repaymentcan’t imagine why! © Separately, can you tell me what this reference in the budget is to? “The Administration will also strengthen academic progress requirements in the Pell Grant program to encourage students to complete their studies on time.”O'Bergh, Jon From: Glickman, Jane Sent: Thursday, March 27, 2014 1:41 PM To: Henderson, Josh; Wall, Mary Subject: RE: errors and omissions in Politico article on IBR taxation Yes, we can correct that too, but Lauren says the year it was enacted, which reporter says was 2009, is. wrong. Do you know the correct date for that? From: Henderson, Josh Sent: Thursday, March 27, 2014 1:36 PM To: Glickman, Jane; Wall, Mary ‘Subject: RE: errors and omissions in Politico article on IBR taxation From FSA; You must be a new borrower on or after Oct. 1, 2007, and must have received a disbursement of a Direct Loan on or after Oct. 41,2011. The graduation year, which she refers to in the article, has nothing to do with it. Let me know if that helps. From: Glickman, Jane Sent: Thursday, March 27, 2014 1:29 PM To: Henderson, Josh; Wall, Mary Subject: RE: errors and omissions in Politico article on IBR taxation Our press release came out in December 2012, but it's not clearly stated when the effective date was ~ http://www.ed.gov/news/press-releases/education-department-launches-pay-you-earn-student-loan- Fepayment-plan jenderson, Josh Sent: Thursday, March 27, 2014 1:25 PM To: Glickman, Jane; Wall, Mary Subject: RE: errors and omissions in Politico article on TBR taxation Lauren is right. Under PAYE and 1BR you are not dropped from the program if your income increases, and payment is capped at what you would pay under a standard 10 year repayment plan. Borrowers are required to recertify their income each year in order to remain in |BR, but they are not dropped from the program based on income. Mary, do you know the effective date on PAYE? I'm confused where the 2014 date is coming from From: Glickman, Jane Sent: Thursday, March 27, 2014 1:14 PM To: Wall, Mary; Henderson, Josh Subject: FW: errors and omissions in Politico article on IBR taxationMary and Josh — if you could provide the accurate answers for her clear errors, marked in blue below, | will do my best to get changed She is correcting the spelling on Jeff's name. but she’s rejected a lot of what Treasury and I have pointed out. Thanks very much! Jane From: Lauren Asher Sent: 3/26/2014 12:24 PM To: Gast, Sara; Appel, Jeff Ce: Pauline Abernathy; Studley, Jamie; Protopsaltis, Spiros Subject: errors and omissions in Politico article on IBR taxation V'm writing to encourage you to respond to the errors and omissions in this article and to (if you haven't already). The piece makes it sound like IBR is a disaster for borrowers and taxpayers, easily gamed, and leads to tuition increases, and the corrections will be most effective coming from the Department. The text is pasted below with key issues and errors highlighted. © Errors: Jeff Appel’s name is misspelled; the year in which 2014 IBR was enacted is wrong; and it says You can get “dropped” from IBR if your income rises. © Omissions: Doesn’t mention that that the President proposed fixing the married filing separately issue or targeting benefits; doesn’t mention until very late in the article that POTUS has proposed fixing the tax issue or HR 2492; and doesn’t mention the very low budget score of eliminating taxation or that most will repay in classic IBR. POLITICO Student loan debt deal comes with tax catch BY: kets sre March 26, 2014 05:05 AM EDT Millions of taxpayers struggling with student loan debt are being pitched what may seem like a dream come true this tax season: lower monthly payments and a chance to see a chunk of their debt disappear. But there's a catch: the potential for a huge tax bill down the road. The new push from the departments of Treasury and Education uses tax time to promote the opportunity for a borrower to have his or her entire debt repaid after 20 or 25 years. The agencies are partnering with TurboTax, the tax software used by more than 18 million Americans, to advertise the deal. It's part of an administration wide effort to make college more affordable, but consumer advocates worry that the tax-time pairing fails to fully disclose that the debt forgiveness counts as income and will likely lead to a bill from the Internal Revenue Service. Some even liken it to the too-good-to-be-true mortgages that played a role in the collapse of the housing market “Itis saving them some short-term pain in exchange for a longer-term tax payment,” said Scott Fleming, an education expert at the American Action Forum think tank. “It is like a 2balloon payment on a mortgage.” Officials from the departments of Education and Treasury said the public information effort gives consumers the tools to make better decisions about their financial future and that even with a big tax bill, on net, they'll be paying less. “The bottom line would be that a consumer would be better off having debt forgiven,” said Jeff Attel, deputy undersecretary of education. “Their tax liability is always going to be less than the amount of debt that is going to be forgiven.” It also means helping people who are struggling to keep up with steep monthly payments avoid default “There's a lot of research and analysis of what is going on in the minds of tax filers,” said Melissa Koide, deputy assistant treasury secretary and head of the office of consumer policy, “We are thinking about our money; we are thinking about our finances. For a lot of people, that means thinking about making payments on outstanding debt.” Another criticism of the program is that because there are limits on the amount of repayment, it encourages never-ending tuition hikes. And the tax bill is based on the original loan amount. One example, calculated by the New America Foundation, shows a veterinarian graduating with $190,000 in debt, eventually paying off just $131,000 of that and winding up with a whopping $60,000 tax bill at the end of it all. “Renting money has a cost,” said Jason Delisle, an education policy expert at New America. “If you're renting it from the federal government, it still has a cost.” Anew element of the program this year involves the marketing effort by TurboTax, sold by Intuit. The software identifies tax filers now using credits and deductions for higher education to target information to them about the income-dependent program. These filers will see information about loan repayment options and a link to the Department of Education website in a section of the program called “My Money Tools.” They are provided with a link to a calculator that uses tax information, including their adjusted gross income, marital status and household size to determine eligibility for income-based and other income-dependent repayment programs. The options allow qualified borrowers to lock in monthly payments that are determined by how much they make, not how much they owe. The rollout is being promoted in conjunction with new income-based repayment levels that will be phased in this year. Anyone with a federal direct loan issued before this year can apply to pay 15 percent of. his or her discretionary income for 25 years. If the loan isn’t paid off, the rest of the debt is 3forgiven. Those graduating after 2014 will have the option of applying to an even more generous program Congress passed in 2009 that would set payments at 10 percent of discretionary income for 20 years. After that, the loan is forgiven What they won't see is an estimate of how those payments might change in the future or what happens if they stay in the program long enough for a portion of their debt to be forgiven. Itis dificult to predict the future income for any given borrower, whose employment and earnings could change drastically over a 20- or 25-year window. But observers of the program say the long-term costs of enrolling in a repayment program that could last more than two decades are poorly disclosed and the tax implications are far from clear. The section of the studentaid.ed.gov website that explains the details of each payment option mentions only that borrowers may be subject to income tax on any forgiven debt. That language is ambiguous, critics say, considering that the forgiven debt is considered taxable income under current law and that it would take an act of Congress to change that President Barack Obama has proposed excluding alll forgiven federal student loan debt from income tax in his recent budgets. Administration officials said they hope that Congress will take up Obama's recommendations. But the matter has not been formally debated since 2009, when a bipartisan bill died in the House Ways and Means Committee. That leaves Intuit as the middle man in the process. It provides the portal for taxpayers. The Department of Education takes the reins from there. "We are committed to supporting the consumers, but we believe that the public policy drivers need to come from the administration,” said David Williams, the chief tax officer at Intuit But that role may make TurboTax the bearer of bad news decades from now on if the student loan forgiveness is converted into a tax bill. And most people are not struck with fear when they hear from the Department of Education; hearing from the tax man is a different story. “If you owe money to the Department of Education, the worst they can do is garnish a ‘small share of your wages, but the IRS can do much more horrible things to you,” Delisle said. “The Department of Education can't put a lien on your home, but the IRS can.” Another concern is that some borrowers may end up with monthly payments so low that they can't keep pace with the interest on their loans. That kind of shortfall can add up over 4months and years, particularly for people with lots of debt. These borrowers could wind up like the veterinarian who owes $60,000 in taxes. The sum would most likely still be a discount from the cost of paying off the entire debt, but the payment could come as a major shock. It could also mean ballooning debt for people who earn enough, or marry into a significantly higher household income, and are dropped from the program. “A very likely scenario would be if you have a higher-than-average debt amount and an average income after college, you might find that a 10 percent cap on payment doesn't quite keep up with the interest amount,” said Fleming, of the American Action Forum. Delisle said borrowers who have the time, means and education to navigate all of their filing options could easily find ways to legally game the filing process and come out ahead. For example, married people with high debt could choose the martied-filing-separately status to make sure their loan payments are based on their individual incomes, rather than that of their entire families. But those without sophisticated tax advice may be in for an unpleasant surprise at the end of the repayment period. More savvy borrowers can also whittle away at their individual adjusted gross income by investing in tax-preferred savings and health care programs at work. Every dollar diverted from take-home pay is a dollar diverted from the income-based repayment equation. “There's a huge incentive to hide income,” he said. “There are some downsides to filing separately, like paying slightly higher taxes, but there’s no way that’s going to wash with the amount of loan forgiveness they will get.” Lauren Asher, President ‘The Institute for College Access & Success 405 14th Street, 11th Floor, Oakland, CA 94612 phone: 510-318-7900, x304 fax: 510-318-7918 email: jasher@ticas.org www ticas.org wiwi.projectonstudentdebtorg www.college-insightorg wwwwwibrinfoorgO'Bergh, Jon Fror Lauren Asher Sent: Thursday, March 13, 2014 9:36 PM To: Appel, Jeff Subject: FAFSA timing problem See p. 30 for a description of the FAFSA timing problems and our proposed solutions: http://www.ticas.orp/files/pub/TICAS RADD White Paper.pdf Lauren Asher, President ‘The Institute for College Access & Success 405 14th Street, 11th Floor, Oakland, CA 94612 phone: 510-318-7900, x304 fax: 510-318-7918 email: lasher@ticasorg a www.projectonstudentdebtorg yeww.college-insightorg www.ibrinfoorgO'Bergh, Jon — Ochinko, Walter (HSGAQ) Tuesday, March 11, 2014 4:48 PM Stanek, Taylor Subject: FW: examples of misleading on-time completion rate disclosures Attachments: OnTimeCompletionRateExamples.Decemberl2 2012.docx Taylor, is documentation of the outreach from Senate HELP and TICAS to ED over the past several years. My questions are (1) whether ED looked into Harris School of Business's was complying with the gainful employment reporting requirements, (2) what actions ED took to bring Harris into compliance, and (3) whether Harris is currently in compliance. Thanks, Walter From: Pauline Abernathy [mailto:pabernathy@ticas.org] Sent: Tuesday, March 11, 2014 1:52 PM To: Ochinko, Walter (HSGAC); Masiuk, Libby (HELP Committee) Ce: Jennifer Webber; Joseph Mais Subject: FW: examples of misleading on-time completion rate disclosures Here is the December 2012 email to ED, with WH and HELP cc’d, with the 2011 email below it. Both cited Harris by name. The 2011 email was sent following a meeting with HELP, ED and WH to discuss concerns with GE disclosures. From: Pauline Abernathy Sent: Wednesday, December 12, 2012 6:31 PM To: 'David.Bergeron@ed.gov'; ‘ata. talwalker@ed. gov; 'steve.finley@ed.gov’; 'Gabriella.gomez@ed.gov'; Yuan, Georgia "Stein, Beth (HELP Committee); 'Wotford, Carrie (HELP Committee)’; Deanne Loonin; 'Protopsaltis, Spiros (HELP Committee)’; Persis Yu; Rich Williams; ‘angela. peoples@cfpb.gov'; Debbie Cochrane; 'Protopsaltis, Spiros (HELP Committee)’; Libby Masiuk (Libby Masiuk@help.senate.gov); ‘Otero, Mildred (HELP Committee)’; ‘Rohit.Chopra@cfpb.gov'; Margaret Reiter; Julie Miceli (julie.miceli@ed.gov); 'rodriguez@who.eop.gov'; Lexi Saudargas Barrett (abarrett@who.eop.aov); Joseph Mais; ‘Connie Myers’; Lauren Asher Subject: RE: examples of misleading on-time completion rate disclosures A year ago, following a meeting with you and Chairman Harkin’s staff, we sent you examples of misleading or otherwise problematic “on-time completion” rate gainful employment program disclosures (see email below). In light of the Department’s November 23, 2012 guidance to colleges on GE program disclosures, we took another look at whether and how colleges are complying with the current GE disclosure regulations and guidance. The attached document provides current examples of disclosures that: ‘© Misrepresent the on-time completion rates as graduation rates, do not specify the “normal time” to complete the program, and do not post the disclosures directly on the program web site (Lincoln, Everest) '* Do not specify the “normal time” to complete the program and do not post the disclosures directly on the program web site (ATI, Ashford)© Are highly misleading (Strayer which considers 4.5 years on-time completion of a certificate program) © Are not posted anywhere on the school’s web site (Harris School of Business) We continue to have the concerns expressed in the October 2011 coalition letter to Secretary Duncan that these on-time completion rate disclosures can be highly misleading and unintentionally lead students to enroll in programs with abysmal graduation rates. We hope that the final GE disclosure template will address these concerns and ensure that the disclosures are prominently displayed, meaningful, and easily understood by consumers. Please do not hesitate to contact us with any questions. Thank you. Pauline Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.org, From: Pauline Abernathy Sent: Tuesday, November 15, 2011 8:09 PM To: David.Beraeron@ed.goy; ajita.talwalker@ed,gov; Zakiya w_smith@who.cop.goy; steve.finley@ed.gov; Gabriella. gomez@ed gov; Protopsaltis, Spiros (HELP Committee); Little, Bethany (HELP Committee) Cc: Stein, Beth (HELP Committee); Wofford, Carrie (HELP Committee); Deanne Loonin; Persis Yu; Libby Masiuk; Josh Murphy; Margaret Reiter; Rich Willams; Getachew Kassa; angela.peoples@cfpb.gov; Debbie Frankle Cochrane Subject: examples of misleading on-time completion rate disclosures ‘Thank you for last week's meeting regarding the an-time completion rate disclosures for career education programs. At the meeting, we were asked to provide examples of schools that are misrepresenting their on-time completion rates and/or using them in ways likely to mislead those consumers who are able to find them Attached are examples of schools that © misrepresent their on-time completion rates (Lincoln, University of Phoenix); © inflate their rates by using unreasonable time frames for completion, e.g., 4.5 years to complete a certificate program (Strayer); © donot clearly explain the rates and thereby give a misleading impression of what they mean (Ashford, ATI, Everest, DeVry}; and © do not appear to disclose an on-time completion rate as required (Harris School of Business). ‘The list is by no means exhaustive but is illustrative of some of the problems we have seen and which we hope the Department will act quickly to address. | apologize if! inadvertently left anyone who attended the meeting off this email Pauline Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: §10.318.7900jergh, Jon. From: Debbie Cochrane Sent: Monday, March 10, 2014 4:50 PM To: Appel, Jeff; Wall, Mary ce: Pauline Abemathy; Joseph Mais Subject: PCC opts out of offering federal student loans FYI, we learned Friday that another North Carolina community college, Central Piedmont, has opted out of the federal loan program. Based on the two articles we've seen about the decision, the school is aware that it is not at risk yet cites the potential risk for why its pulling out of the program. From http://www_biziournals.com/charlotte/news/2014/03/07/cpcc-opts-out-of federal-student-loan-program.htm! “CCC and Catawba Valley Community College are the only institutions in the Charlotte region still participating in the program. Less than half of the state’s 58 community colleges are participating, “Most of the community colleges in North Carolina have reached the same conclusion as CPC; the federal direct loan program puts students and institutions at great risk,” says Jeff Lowrance, CPC public information officer and assistant to the CPC President Tony Zeiss.” From: http://www.acitymetro.com/news/articles/no more direct federal loans for_cpce_students105853422.cfm: “Lowrance described the move as precautionary and said the school had no indication that its students were approaching a critical default level.” CPCC has put a notice on its website announcing the decision to stop offering federal loans but has otherwise not updated the content. Currently, the ‘orivate or alternative loans’ section references federal loans being a “better” form of aid than private loans, including stating that “We strongly encourage families to fully utilize all federal aid programs before turning to this source of funds.” We will monitor this page to see how it changes once federal loans are no longer available to students, and keep you posted. Best, Debbie Debbie Cochrane Research Director The Institute for College Access & Success 405 Lath Street, Suite 1100 Oakland, California 94612 office: (510) 318-7900 // fax: (510) 318-7918 dcochrane@ticas.or www.ticas.org www.projectonstudentdebt.org wwww.college insight.orgO'Bergh, Jon Studley, Jamie Wednesday, March 05, 2014 10:54 AM Pauline Abernathy Debbie Cochrane RE: Pell provision Of course. And you can always try Spiros Sent from my Windows Phone From: Pauline Abernathy Sent: 3/5/2014 9:44 AM To: Studley, Jamie Ce: Debbie Cochrane Subject: RE: Pell provision Jamie, we would very much appreciate it if you can connect Debbie with someone who knows the provision better. Debbie is in Sacramento until Friday but can circle back with you on Friday to get connected to the right person. Thanks! From: Studley, Jamie [mailto:Jamie, Studley@ed.cov] Sent: Tuesday, March 04, 2014 6:36 PM To: Pauline Abernathy ‘Subject: RE: TICAS: President's FY15 Budget Fully Funds Pell Grants and Improves Income-Driven Repayment It relates to what Jeff Appel described as “reflecting consumption of education services at the student level.” Specifically, students moving from first to second year would be required to have grades for at least half their classes, a proportion that rises'as they move through school. If you want more Imk and I'l find someone who knows the specific provision better, From: Pauline Abernathy [mailto:pabernathy@ticas.or] Sent: Tuesday, March 04, 2014 5:16 PM To: Studley, Jamie Subject: RE: TICAS: President's FY15 Budget Fully Funds Pell Grants and Improves Income-Driven Repayment | can’t imagine why! © Separately, can you tell me what this reference in the budget is to? “The ‘Administration will also strengthen academic progress requirements in the Pell Grant program to encourage students to complete their studies on time.”O'Bergh, Jon From: Studley, Jamie Sent: Friday, February 28, 2014 2:16 PM To: Kinsley, Kody Subject: RE: Models --TICAS Great. Here's one of the RFI submissions that has a well-articulated approach: http://wwweticas.org/files/pub/TICAS Comments on Ratings.pdf ~~Original Message From: Kinsley, Kody [mailto:Kody H_Kinsley@who.eop.gov) Sent: Friday, February 28, 2014 1:22 PM To: Studley, Jamie Subject: Models HiJamie, I'm happy to put together a table of sorts that examines the various rating/accountability models and what inputs and ‘output variables and approaches they consider. | actually have quite a bit of this from states systems, and state funding systems, but may not have some of the novel things you mentioned in the meeting, Could you send me the list you mentioned and any resources you may have about them? Otherwise Ill google my way to finding thern. Kody Howard Kinsley Domestic Policy Council 202-856-3428 (office) 202-503-5578 (mobile)Pauline Abemathy Thursday, February 27, 2014 8:18 PM Appel, Jeff; Debbie Cochrane; Wall, Mary Joseph Mais RE: TICAS PRI worksheet and question about PRI thresholds We have been urging the Dept to issue a DCL like this for more than four years! Thank you two for making it happen! From: Appel, Jeff {mailto:Jeff.Appel@ed.cov] Sent: Thursday, February 27, 2014 8:11 PM To: Debbie Cochrane; Wall, Mary Ce: Pauline Abernathy; Joseph Mais Subject: RE: TICAS PRI worksheet and question about PRI thresholds Thanks for the note! Appreciate it! Sent from my Windows Phone From: Debbie Cochrane Sent: 2/27/2014 8:04 PM To: Wall, Mary : Appel, Jeff; Pauline Abernathy; Joseph Mais ‘Subject: Re: TICAS PRI worksheet and question about PRI thresholds Jeff and Mary, the DCL is great. We appreciate how many important bases it covers - not just clarifying the PRI threshold but also the encouragement for colleges maintaining loan access and the comparison of federal and private loans. We think it has enormous potential to keep colleges from pulling out of the loan program unnecessarily (and you can be sure we willbe touting it in our work with colleges on the issue!) We of course still would love to see the PRI appeal process modified so that colleges could file appeals in any year in which their CDR is above sanction thresholds (and not just when they're on the verge of losing Title IV eligibility), but this is a big step and we are very grateful. Thank you. Debbie ‘On Feb 27, 2014, at 2:16 PM, "Wall, Mary" wrote: We aim to please. :) From: Debbie Cochrane Sent: 2/27/2014 5:15 PM. To: Wall, Mary; Appel, Jeff Ce: Pauline Abernathy; Joseph Mais Subject: RE: TICAS PRI worksheet and question about PRI thresholds Wow, what timing! Look forward to seeing it!From: Wall, Mary [mailto:Mary,Wall@ed.gov] Sent: Thursday, February 27, 2014 2:15 PM To: Debbie Cochrane; Appel, Jeff Ce: Pauline Abernathy; Joseph Mais Subject: RE: TICAS PRI worksheet and question about PRI thresholds Thanks Debbie, We have clarified this issue in the letter on cdr, which should be posted to ifap ‘momentarily, Let me know if you don't see it or if you have ather comments or concerns. From: Debbie Cochrane Sent: 2/27/2014 5:12 PM To: Appel, Jeff; Wall, Macy Ce: Pauline Abernathy; Joseph Mais ‘Subject: TICAS PRI worksheet and question about PRI thresholds HiJeff and Mary, I wanted to let you know that we have updated our PRI worksheet for the FY 2011 three-year CDRs, available here: http://www.projectonstudentdebt.org/files/pub//TICAS PRI Worksheet _2014.xlsx Please note that we specify in our worksheet that the allowable PRI for sanctions based on a single year’s CDR is 0.0832, which, per new rules that go into effect July 1, 2014, we believe to be the PRI most applicable for the FY 2011 cohort (because even ifthe rules are not final at the point of challenges, they will be applicable for appeals). However, this is not the PRI listed in the CDR resource guide distributed to colleges along with the draft rates last week. Can you please confirm which PRI will be applicable for this cohort and beyond? Also, in case you were not aware, AACC last week sent a letter to their member colleges about CDR sanctions and the PRI appeal. The letter included the specific single-year-sanction PRI threshold of 0.06015, which is the threshold listed in the Department’s materials. If we are correct in thinking that the relevant PRI for this cohort is instead 0.0832, this of course underscores the urgency of sending a clear and accurate letter detailing CDR appeal options out to colleges as soon as possible. Best, Debbie Debbie Cochrane Research Director The Institute for College Access & Success 405 14th Street, Suite 1100 Oakland, California 94612 office: (510) 318-7900 // fax: (510) 318- 7918, dcochrane@ticas.org wunw.ticas.org www. projectonstudentdebt.org www. college-insight.orgO'Bergh, Jon From: Debbie Cochrane Sent: Friday, February 21, 2014 4:40 PM To: Wall, Mary; Appel, Jeff Ce: Pauline Abernathy; Joseph Mais, Subject: RE: Opportunity to spread the word about PRI, CDRs, and putting federal loans first Thank you, Mary! We look forward to hearing more when you have more to share. Debbie From: Wall, Mary [mailto:Mary.Wall@ed.gov} Sent: Friday, February 21, 2014 1:39 PM To: Debbie Cochrane; Appel, Jeff Ce: Pauline Abemathy; Joseph Mais Subject: RE: Opportunity to spread the word about PRI, CDRs, and putting federal loans first ‘Thanks Debbie. As you know, we ate working on this communication now, and we are trying to get this out as soon as possible. As soon as I can share it (which we're hopeful is very soon), we will do so. Thanks, MW From: Debbie Cochrane [mailto:DCochrane@tticas.ora] Sent: Friday, February 21, 2014 3:16 PM To: Wall, Mary; Appel, Jeff Ce: Pauline Abernathy; Joseph Mais ‘Subject: Opportunity to spread the word about PRI, CDRs, and putting federal loans first Jeff and Mary, I wanted to share with you that | had a recent conversation with Brice Harris, Chancellor of the California Community Colleges, about the extent to which his colleges were pulling out of the federal loan program unnecessarily. He is very interested in doing what he can to spread the word about the importance of federal loan access and how the participation rate index appeal can help colleges with high CDRs but low borrowing rates. As part of his monthly ‘communication with college CEOs across the state, Dr. Harris offered to include any information we could provide about how the PRI appeal works and who can benefit. Since colleges just this week received their draft CDRs, time is of the essence. We would very much like to make the most of this opportunity by having him share information that comes straight from the Department. Pauline and | spoke with you last week about how helpful clear communication from the Department about the PRI (beyond simply the CDR resource guide) would be, and having Dr. Harris include it in his, regular communications with college leadership would help ensure that the information gets to many colleges that need it Please let me know if there is anything we can do to be of assistance. Best, DebbieDebbie Cochrane Research Director ‘The Institute for College Access & Success 405 14th Street, Suite 1100 Oakland, California 94612 office: (510) 318-7900 // fax: (510) 318-7918 dcochrane@ticas.org wwww.ticas.org wwww.projectonstudentdebt.org wwnw.college -insight.org‘wall, Mary Friday, February 14, 2014 10:28 AM Pauline Abernathy; Appel, Jeff Debbie Cochrane RE: promised items re CDRs and community colleges Thanks for flagging again, Pauline. From: Pauline Abernathy [mailto:pabernathy@ticas.org] Sent: Friday, February 14, 2014 10:27 AM To: Wall, Mary; Appel, Jeff Ce: Debbie Cochrane ‘Subject: RE: promised items re CDRs and community colleges Since the govt was closed yesterday I'm resending what I sent yesterday. Pauline From: Pauline Abernathy Sent: Thursday, February 13, 2014 12:57 PM To: ‘Mary.Wall@ed.gov'; "Jeff.Appel@ed.gov' Ce: Debbie Cochrane ‘Subject: promised items re CDRs and community colleges Jeff and Mary: ‘Thank you so much for meeting with Debbie and me this week on CDR issues. Below are examples of: © Community colleges that said they pulled out of the federal loan program to prevent being sanctioned—even though they were clearly protected by their PRI (Yuba and Hartnell in CA) © Community colleges that report being told by ED staff that they should pull out of the loan program and/or can’t count on the PRI appeal when they clearly qualified (Antelope Valley College and Hartnell in CA) * Community colleges promoting private loans and not offering federal loans (College of the Desert, Yuba, Southeastern Community College in NC, Virginia Highlands Community College in VA) ‘* Media coverage of this issue in which TICAS is cited (there are many more) You can see why it is so critical that the Department provide additional written guidance to colleges and reassure colleges after a single year’s CDR that would be eligible for a PRI appeal that they are not in jeopardy of being sanctioned. Please let us know what the Department plans to do to encourage community colleges to participate in the loan program and to discourage them from pulling out unnecessarily. As we mentioned, we also believe the Department needs to provide updated guidance on preferred lender lists and ensure colleges are complying with the law. I suspect the CFPB would be glad to work with the Department on this. Please let us know if there is any additional information we can provide. Pauline FYI—Our PRI worksheet is posted here: http://projectonstudentdebt.org/files/pub/TICAS PRI Worksheet 2013.x!s 1Examples of community colleges that said they pulled out of the federal loan program to prevent being sanctioned—even though they were clearly protected by their PRI: © Yuba College: (from http://yc.yccd.edu/student/financial-aid-types.aspx#loans) :ffective in the fall of 2013, the Yuba Community College District including Yuba College and Woodland Community College, will suspend the Federal Student Loan Program. The U.S. Department of Education's policy would be to revoke a college's ability to participate in any Federal Financial Aid program, including Pell Grants, FSEOG and Federal Work Study, because of excessive default rates. The decision by the College and its Board of Trustees to suspend the Federal Student Loan Program was ‘made in an effort to protect the availability of future Federal Financial Aid. The Board of Trustees has formed a Committee to assess its decision through data analysis for future years. “The Board's action to suspend Federal Student Loans will protect all Federal student aid, including Pell Grant, meaning that eligible students will still be able to receive all Federal Grants as well as State Cal Grants.” From Sacramento Bee article: “[Yuba Community College District] Chancellor Douglas B. Houston said the district unsuccessfully combed U.S. Department of Education regulations in search of assurances that the district could successfully appeal. He said the risk was too great not to act.” Yuba’s undergraduate borrowing rate: 4% (from college navigator) ‘* Hartnell Community College: (from http://www.hartnell.edu/financial_aid/): "Beginning Summer Term 2012 Hartnell Community College will no longer participate in the Federal Direct Student Loan Program. Hartnell will continue to make a variety of federal, state, and private grants, scholarships, and work programs available to students. "Hartnell's student loan default rate has risen drastically in the last two years. This is the result of some Hartnell students not repaying their student loans. The Department of Education has determined that schools with high default rates may not be allowed to participate in other financial aid programs, like Pell Grant. In order to protect Hartnell's ability to provide other financial aid to students, Hartnell has made the decision to no longer offer Direct Student Loans.” Less than 1% of Hartnell undergraduates take out federal loans Examples of community colleges that report being told by ED staff that they should pull out of the loan program and/or can’t count on the PRI appeal (Antelope Valley College and Hartnell in CA) © Hartnell Community College: According to its trustee meeting minutes, it pulled out at the urging of a U.S. Department of Education representative and on the belief that it was at risk of sanctions despite less than 1% of its undergraduates taking out federal loans: "Mary Dominguez, Interim Vice President, Student Affairs, reported on the Financial Aid Technical Visit conducted by the Department of Education (DOE) on April 16-19, 2012. Mr. Raul Galvan, DOE representative, met with various individuals across the campus and looked at the processes used to determine student financial 2assistance, Ms, Dominguez reported that he indicated that 86% of Hartnell students receive some sort of federal financial assistance. Thus the overall percentage is likely higher because some students receive only the Board of Governors (BOG) fee waiver and that percentage is not included in the 86%. Ms. Dominguez stated that the Mr. Galvan strongly recommended that the college no longer authorize student loans because the college has a high loan default rate (28.9%) and could jeopardize the entire Title 1V financial aid program. One of the reasons that the rate is so high is because fewer than forty students have loans, thus even one or two defaults will exceed the percentage allowed. (Appendix 8) The Board asked several questions about financial aid, student loans, impact to students, and importance of communicating to students that loans are no longer available, The Board thanked Ms, Dominguez for her report." ‘© Antelope Valley College in CA: In the course of creating a default management plan, Antelope Valley College was told by the ED regional office that the college cannot count on having its PRI appeal granted as “you never know’ whether it will be approved. Examples of community colleges promoting private loans: ‘+ From College of the Desert’s website: “Due to College of the Desert no longer participating in the Federal Direct Loan Program beginning with the 2013-2014 school year, some students and families will need access to other resources to cover their educational expenses. Private loans are one option....” The site goes on to provide links for Sallie Mae, Wells Fargo, and Discover. College the of Desert’s undergraduate borrowing rate: 4% (from college navigator) © Anarticle about Yuba College: “After the Yuba Community College District elected to suspend its participation in a federal student loan program this year, district officials are hoping student-loan provider SLM Corp. — Sally Mae — can fill the financial aid gap. (sic)” * Anatticle about Southeastern Community College in NC: “Glenn Hanson, Director of Financial Aid, said in an email to students that the decision came because of the school's increasing student loan default rate. The school's participation in the program will stop at the end of summer school this year, so that federal loans won't be offered for fall 2013 or after. Hanson noted that students can still take out non-federal private student loans, utilize the school's payment plan and see if they apply for scholarships....David Hardin, a public information officer at Cape Fear Community College, says they are also considering whether or not they should continue offering federal loans, because their default rate has also increased. Currently, 17 percent of their federal loans are in default” © Many other community colleges in NC are pulling out: http://views.ticas.org/wp- content/uploads/2014/01/No-student-loans-at-SCC-but-college-still-concerned.pdf Haywood Community College in CA: (from http://www.haywood.edu/student loans) “The Financial Aid Office at Haywood Community College (HCC) works with many sources of alternative or private loans to help provide additional funding to students at the college. HCC does not endorse the use of any particular alternative loan program, but rather encourages students to thoroughly review the programs available and to select the program that best meets their personal needs, «,,,. Haywood Community College (HCC) does not have a preferred lender list and does not engage in any of the practices that have come to light at very few institutions across the country. HCC has no representatives from student loan organizations on campus or appearing to represent HCC in any way. Neither do HCC staff members receive any funding or incentives whatsoever from lenders providing student loans. 3Itis HCC’s policy to process alternative loans from any lender the student selects. HCC students have a choice in the selection of lenders. This policy is consistent with federal regulations. For assistance in selecting an alternative or private student loan lender, visit either of the following websites:” It then lists and describes: http://www. studeritloanlistings.com/ and www. finaid.org/loans/privatestudentloans.phiml + Virginia Highlands Community College in VA: hnipz/ivww vhoe eduindex asp page~433 “Virginia Highlands Community College participates in the Alternative Student Loan Program, Alternative loans, also called private loans, are offered by lending institutions as an additional source of funds for higher education. These funds are not part of the federal government loan programs; VHCC does not participate in the Stafford or Plus student loan programs. An alternative loan is a good option only after all other financial aid sources have been exhausted.” “To determine the best lender for your needs, consider the annual percentage rate (APR), co-signer requirements, loan fees, loan limits, repayment period, income to debt ratio, and grace period offered. For more information concerning these loans, please contact the lender. VCC does not suggest a specific lender for your loan application process nor do we endorse one lender over the other. After the lender approves your loan, the Financial Aid Office is contacted to certify that you have completed a FAFSA, enrolled in 6 or more credits and are in a program of study at VIICC. ted below are only a few lenders that VHCC students have chosen to use in the past. Please choose a lender that best meets your individual needs and borrow only what you need. Remember, the lenders listed are only for your convenience; you may choose any lender that offers educational loans. * Sallie Mae Smart Option Student Loan * Sallie Mae Smart Option Student Loan for Regions Bank Customers” [Only Sallie Mae loans are listed!) which TICAS is cited: Examples of media coverage of this issu More Calif. community colleges stop offering federal loans http://californiawatch.org/dailyreport/more-calif-community-colleges-stop-offering-federal-loans- 17721 Yuba Community College District suspends federal student loan program http://www.sacbee.com/2013/07/15/5566610/yuba-community-college-district. htm! Federal loans not available for LTCC students htto://Awww.laketahoenews.net/2013/07/federal-loans-not-available-for-ltcc-students; Community College Students Denied Federal Loans: Report htto://www.huffingtonpost.com/2011/04/29/community-college-student_n_855523.html CCC&TI will no longer accept fed loans (NC) http://www2.wataugademocrat.com/News/story/CCCTI-will-no-longer-accept-fed-loans-id-011202 Presentation at CA community college student financial aid association on this issue 4HTTP://WWW. CCCSEAAA.ORG/DOCS/CONFERENCES/2011/PRESENTATIONS/D3_MAKINGLOANSWORK BESTPRACTICES.PDF Pauline Abernathy Vice President, The institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.org,O'Bergh, Jon SL From: Diane Cheng Sent: Wednesday, February 12, 2014 5:46 PM To: Gast, Sara Ce: Wall, Mary: Appel, Jeff; Lauren Asher Subject: RE: Moneywatch story appeats to have new enrollment figures for IBR/PAYE/ICR Hi Sara, Thanks for your clarification about the 2.5 million figure. We'd love to see updated data on enrollment in the income: driven plans, including both DL and FFEL borrowers, so we appreciate your keeping us in the loop. ~Diane Diane Cheng Research Analyst The Institute for College Access & Success 405 14th St., Suite 1100 Oakland, CA'94612 dchengaticas.org www. ticas.org From: Gast, Sara [maito:Sara.Gast@ed.cov] Sent: Tuesday, February 11, 2014 5:34 PM To: Lauren Asher Ce: Diane Cheng; Wall, Mary; Appel, Jeff ‘Subject: RE: Moneywatch story appears to have new enrollment figures for IBR/PAYE/ICR Hi Lauren —so sorry on the delay. Mary and Jeff may be able to dig and help better than I, What the 2.5 million is referencing is the White House fact sheet from the August announcement, so | imagine that number has ticked up some since then ~ and | believe it captures all income-driven options now, not just IBR As you know, we had been working through some pieces over here to make sure we had an accurate sense of who is in an income-driven plan. We haven't been releasing any new numbers publically, but if we're able to do so, we'll keep you in the loop. Thanks for all your patience on this! Sara From: Lauren Asher (mailto:lAsher@ticas.ora) Sent: Tuesday, February 11, 2014 1:09 PM To: Gast, Sara Ce: Diane Cheng Subject: Moneywatch story appears to have new enrollment figures for IBR/PAYE/ICR sara, Just touching base to see if you've got new enrollment figures for the income-driven repayment plans. Lynn O'Shaughnessy's new Moneywatch story at http://www.cbsnews.com/news/are-student-debt-relief-services-worth-the-money/ says 2.5 million are enrolled, but ‘we haven't seen anything public since figures as of 12/31/13 which were just for Direct Loan borrowers and counted 1.9 million, Are there now 600 million FFEL borrowers enrolled in 1BR? Thanks for any insights you can provide. 1Lauren Lauren Asher, President ‘The Institute for College Access & Success 405 14th Street, 11th Floor, Oakland, CA 94612 phone: 510-318-7900, x304 fax: 510-318-7918 email iasher@ticas.orgO'Bergh, Jon Henderson, Josh Friday, February 07, 2014 4:06 PM Debbie Cochrane Wall, Mary RE: Time to discuss CCs, loans, and CDRs 2/11 oe 2/12? You will be meeting with myself and Mary, as well as Deputy Under Secretary Jeff Appel. See you next week! From: Debbie Cochrane {mailto:Cochranes@ticas.ora} ‘Sent: Friday, February 07, 2014 4:05 PM To: Henderson, Josh Gc: Wall, Mary ‘Subject: RE: Time to discuss CCs, loans, and CDRs 2/11 oe 2/12? Wonderful — thank you, Josh, Can you tell us who will be joining from ED? Best, Debbie From: Henderson, Josh [mailto:Josh,Henderson@ed.gov] Sent: Friday, February 07, 2014 1:04 PM To: Debbie Cochrane Ce: Wall, Mary Subject: RE: Time to discuss CCs, loans, and CDRs 2/11 0¢ 2/12? Hi Debbie, Yes, we're on for Tuesday, February 11" at 1pm at the LBJ building at 400 Maryland Ave. SW. You can arrive at either the C St. or Maryland Ave. entrance. When you arrive you'll need a government ID to enter, and you can use my name asa point of contact. Looking forward to meeting next week, Best, Josh From: Debbie Cochrane (mailto:DCochrane@ticas.or4] Sent: Friday, February 07, 2014 1:51 PM To: Henderson, Josh Ce: Wall, Mary ‘Subject: RE: Time to discuss CCs, loans, and CDRs 2/11 oe 2/12? Hi Mary and Josh, Just confirming that we are on for Tuesday at 1pm (at 400 Maryland, | presume?). It will be me and Pauline Abernathy in attendance for TICAS. Thank you, DebbieFrom: Debbie Cochrane Sent: Wednesday, February 05, 2014 4:15 PM To: ‘Henderson, Josh’ Ce: Wall, Mary ‘Subject: RE: Time to discuss CCs, loans, and CDRs 2/11 o€ 2/12? ’'m sorry for the delay! Tuesday at 1-2pm would be great. Thank you. From: Henderson, Josh {mailto:Josh.Henderson@ed.gov] Sent: Tuesday, February 04, 2014 2:44 PM To: Debbie Cochrane Ce: Wall, Mary Subject: RE: Time to discuss CCs, loans, and CDRs 2/11 o¢ 2/12? Hi Debbie, Unfortunately, Jeff now has a conflict on 2/11. Would you have availability at any of the times below? Tues. Feb. 11": Ipm-2pm Wed. Feb, 12" 11am-4pm From: Debbie Cochrane [mallto:DCochrane@ticas.ora] Sent: Friday, January 31, 2014 5:05 PM. To: Wall, Mary Ce: Henderson, Josh Subject: RE: Time to discuss CCs, loans, and CDRs 2/11 oe 2/12? 3pm on 2/11 sounds great - I will figure out who else can join from TICAS and let you know that Friday before, too. Best, Debbie From: Wall, Mary (Mary.Wall@ed.gov] Sent: Friday, January 31, 2014 2:00 PM To? Debbie Cochrane Ce: Henderson, Josh Subject: RE: Time to discuss CCs, loans, and CDRs 2/11 oe 2/12? Thanks, Debbie — yes, that would be great. I'm currently pretty open both of those days: 2/11, and cirele back the Pri before to confirm? an we maybe aim for 3pm on Adding Josh here, in ease he or others want to join as well Thanks, MW From: Debbie Cochrane [mailto:DCochraneticas.ora] riday, January 31, 2014 12:26 AM fll, Mary Subject: Time to discuss CCs, loans, and CDRs 2/11 08 2/12? Hi Mary,Do you have time to meet on February 11 oF 12 to discuss community colleges’ loans and CDRs? | will be in town from California and would appreciate the opportunity to meet and discuss how we best ensure that community colleges make loans available while staying within allowable default rate limits. Best, Debbie Debbie Cochrane Research Director ‘The Institute for College Access & Success 405 14th Street, Suite 1100 Oakland, California 94612 office: (510) 318-7900 // fax: (510) 318-7918 dcochrane@ticas.org www.ticas.org www.projectonstudentdebt.org www.college-insight.orgO'Bergh, Jon From: Studley, Jamie Sent: Wednesday, February 05, 2014 12:35 PM Te Pauline Abernathy Ce : Jessica Thompson; Connie Myers Subjes RE: TICAS recommendations for college ratings Thank you very much for developing comments on the proposal. We're pleased to be getting so many constructive contributions, From: Pauline Abernathy (mailto:pabernathyticas.ora] Sent: Wednesday, February 05, 2014 12:13 PM To: Pauline Abernathy Ce: Jessica Thompson; Connie Myers ‘Subject: TICAS recommendations for college ratings FYL-TICAS submitted the attached comments on Friday on the development of the proposed college ratings system. Our recommendations include: + Focus first on designing a system for consumers only rather than attempting to design one system that meets the needs of both consumers and policymakers. ‘* Apply the ratings system to institutions that primarily grant bachelor’s degrees before expanding it to. other types of institutions. © Rate colleges separately on several key dimensions, including affordability, success, and student support, rather than providing just one overall rating for each college. + Recognize institutions that serve a disproportionate number of low-income students well without adjusting results by institutional or student characteristics + Allow users to select comparisons groups but always provide national context so it is clear if there is a large gap between the selected group and colleges nationally. You can also read the comments here. Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.org,O'Bergh, Jon Pauline Abernathy Sent: Tuesday, February 04, 2014 9:36 AM To: Douglas J_Kramer@who.eop.gov; Duncan, Ame; cmunoz@who.eop.gov; gsperiing@who.eop.gov; Syivia_M. Burwell@omb.eop.gov; Jason_L_ Furman@cea.eop.gov ce: james R._kvaal@who.eop.gov; Coven, Martha B,; Studley, Jamie; Lachman, Sherry: bauguste@who.eop gov; sbaker@ovp.eop.gov; Appel, Jeff; Danielle _C_Gray@who.eop.gov Subject: Letter to the President signed by more than 50 organizations urging a stronger gainful ‘employment regulation Attachments: Coalition letter to President in support of GE sent Feb 4 2014.pdf On behalf of the coalition, attached and below is a letter to President Obama urging the Administration to promptly issue a strong and effective proposed gainful employment regulation so it can be finalized by November 1, 2014, and go into effect by July 1, 2015. The letter is signed by more than 50 organizations that work on behalf of students, college access, consumers, veterans, servicemembers, and civil rights. The letter states that, at a minimum, the regulation should include the following five elements: 1. Arepayment rate or another metric to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding, 2. Ameaningful approval process to weed out programs that will not prepare students for gainful employment in the specified occupations before they harm students. 3. Borrower relief that is fair and provides a greater incentive to improve weak programs. 4. Meaningful debt-to-earnings standards. 5. Protection for schools offering low-cost programs in which most students do not borrow. Coalition members are also submitting requests for meetings with the Administration to discuss our views and answer any questions, consistent with Executive Order 12866. We thank the Obama Administration for its efforts to protect students and taxpayers from fraud and abuse in career education programs. The coalition stands ready to assist you in strengthening protections for taxpayers and students, including veterans and servicemembers who risked their lives to defend our country. Thank you. February 4, 2014 ‘The Honorable Barack Obama President of the United States 1600 Pennsylvania Avenue Washington, DC 20500 Dear Mr. President: Our organizations—which work on behalf of students and college access, veterans, consumers, and civil rights—were heartened by your remarks last August when you so effectively summed up the problems in the for-profit college industry:[T]here have been some schools that are notorious for getting students in, getting a bunch of grant money, having those students take out a lot of loans, making big profits, but having really Tow graduation rates, Students aren’t getting what they need to be prepared for a particular field, They get out of these for-profit schools loaded down with enormous debt. They can’t find ajob, They default, The taxpayer ends up holding the bag. Their eredit is ruined, and the for- profit institution is making out like a bandit. ‘That’s a problem. Your administration now has an opportunity to better protect taxpayers and students, including our nation's velerans, service members and their families, from predatory career education programs. ‘The Education Department is developing draft regulations to enforce the statutory requirement that all career education programs that receive federal funding, whether at for-profit, public or nonprofit colleges, “prepare students for gainful employment ina recognized occupation.” The negotiated rulemaking panel convened last year by the Department to develop the draft regulations was unable to reach consensus. Even after the Department made multiple changes requested by the for-profit college industry representatives that dramatically weakened the draft regulation, the for-profit college industry representatives objected to it. ‘The changes would have made the regulation so weak on predatory colleges and so hard on low-cost, high-performing colleges that not a single negotiator voiced support for the Department's last proposal, ‘We urge the Administration to issue promptly a stronger, more effective proposed regulation so that the urgently needed rules can be finalized by November 1, 2014, and go into effect by July 1, 2015. Ata minimum, we believe the regulation should include the following five elements: 1. A repayment rate or another metric to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding. A low completion rate is one of the ways that programs can fail to prepare students for gainful employment, particularly when they leave school with substantial debt. But programs where 99% of the students drop out with heavy debt that they are unable to pay down could still pass the Department’s most recent proposal. A program-level cohort default rate (pCDR) was the only metric in that proposal to assess the outcomes of students who do not complete a program. However, a PCDR alone is not sufficient for at least two reasons. First, the well-documented manipulation of cohort default rates by some for-profit college corporations undermines their meaning. Second, default is an extreme situation, measuring whether borrowers have failed to make any required payments in at least 270 days and does not measure whether students are able to pay down their loans. ‘To be clear, we believe that a strong repayment rate or other metric addressing programs with high borrowing and high dropout rates should be a separate requirement that gainful employment programs must pass, in addition to the other tes in order to retain eligibility. 2. A meaningful approval process to weed out programs that will not prepare students for gainful employment in the specified occupations before they harm students. Programs that lack the programmatic accreditation or other attributes needed for graduates to be hired in the field should not be eligible to receive taxpayer funds, yet the Department’s most recent proposal would allow funding to continue to flow to these programs. For example, federal funding should not be available for dental assisting and other medical programs whose graduates are ineligible for the licensing exam required to work in that field. Subsidizing such programs misleads students, who trust the federal government to fund only ‘worthwhile programs and is clearly inconsistent with the statutory requirement that all career education programs receiving federal funding “prepare students for gainful employment in a recognized occupation.” 3. Borrower relief that is fair and provides a greater incentive to improve weak programs. The Department proposed partial relief—at no cost to taxpayers—for some students who enroll in programs that the Department ultimately determines systematically and consistently fail to prepare students for gainful employment in the specified occupations. We believe students should not be responsible for any loans theyreceived to attend such programs: Providing full relief to all such students is not only fair, it also provides a more effective incentive for schools to improve their programs so they never have to provide such relief. 4, Meaningful debt-to-earnings standards. The debt-to-earnings standards in the Department's last proposal ‘were so weak that literally thousands of programs with median and mean debt levels that exceed their graduates’ entire discretionary incomes would not fail the standards. This is clearly too low a standard. Students and taxpayers deserve better. 5. Protection for schools offering low-cost programs in which most students do not borrow. The final 2011 gainful employment regulation automatically passed all low-cost programs where the majority of graduates do not borrow. The federal district court reviewing the regulations upheld this provision, which recognized that such programs do not consistently leave students with unaffordable debts. The new draft regulation should also. In contrast, the Department’s last proposal would unintentionally jeopardize funding for many of these low-cost programs because the metrics would consider only students receiving Title IV funding, which in many cases are a small, unrepresentative share of the program’s students. These proposals would ineentivize more schools to leave the Federal student loan program, lead to the voluntary or involuntary closure of effective, low-cost programs, and is at odds with related statutory precedent which acknowledges the importance of the share of students borrowing in applying default rate sanctions, We believe these five elements are essential, but there are other areas in which thoughtful proposals were submitted by negotiators that merit further consideration. Several of the negotiated rulemaking panel working groups and individual negotiators developed detailed proposals to strengthen the regulation in important ways while reducing its burden on high-performing, low-cost colleges. For example, the Department’s proposals do nothing to inerease the accuracy or comparability of the job placement rates that schools advertise to students. As the commissioner of the National Center for Education Statistics told the negotiated rulemaking panel in September, the exclusion of deceased students is just about the only thing that the many current definitions of job placement have in common. In light of this lack of comparability and the increasing evidence of widespread manipulation and inflation of job placement rates in the for-profit college industry, the proposals, by the working group on job placement are timely, thoughtful, and practical. We applaud the Members of Congress who recently sent a letter to Secretary Duncan urging the Administration to move decisively towards issuing a final regulation. We thank you for your leadership in seeking to improve higher education and career opportunities for all Americans. We and our members and supporters stand with you and look forward to the prompt issuance a strengthened gainful employment rule and other urgently needed Steps to enforce current laws to better protect students, taxpayers, and our nation’s economy. Sincerely, AFL-CIO The American Association of State Colleges and Universities (AASCU) ‘American Association of University Professors (AAUP) ‘American Association of University Women (AAUW) ‘American Federation of Teachers (AFT) ‘Americans for Financial Reform Association of the United States Navy (AUSN) Center for Law and Social Policy Center for Public Interest Law Center for Responsible Lending Children’s Advocacy Institute Consumer Action Consumers Union Consumer Federation of CaliforniaCouncil for Opportunity in Education Crittenton Women’s Union East Bay Community Law Center Generation Progress Initiative to Protect Student Veterans ‘The Education Trust The Institute for College Access & Success Institute for Higher Education Policy (IHEP) Iraq and Afghanistan Veterans of America AVA) ‘The Leadership Conference on Civil and Human Rights League of United Latin American Citizens MALDEF Mississippi Center for Justice [National Association for Black Veterans, Inc. (NABVETS) National Association for College Admission Counseling National Consumer Law Center (on behalf of its low-income clients) ‘National Consumers League National Education Association ‘The National Guard Association of the United States (NGAUS) National Women Veterans Association of America ‘New Economy Project (formerly NEDAP) NYPIRG Paralyzed Veterans of America Public Advocates Inc. Public Higher Education Network of Massachusetts (PHENOM) Public Citizen Rebuild the Dream Service Employees Intemational Union Student Veterans of America United States Student Association USS. PIRG Veteran Student Loan Relief Fund Veterans Education Success Veterans for Common Sense Vetlobs VetsFirst, a program of United Spinal Association Vietnam Veterans of America Young Invincibles ce: Hon. Ame Dunean, Sectetary of Education Hon, Cecilia Mutioz, Director, White House Domestic Policy Council Hon, Gene Sperling, Director, White House National Economic Council Hon. Sylvia Mathews Burwell, Director, Office of Management and Budget Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.orgFebruary 4, 2014 ‘The Honorable Barack Obama President of the United States 1600 Pennsylvania Avenue Washington, DC 20500 Dear Mr, President: Our organizations—which work on behalf of students and college access, veterans, consumers, and civil rights—were heartened by your remarks last August when you so effectively summed up the problems in the for-profit college industry: [T)here have been some schools that are notorious for getting students in, getting a bunch of grant money, having those students take out a lot of loans, making big profits, but having really low graduation rates. Students aren’t getting what they need to be prepared for a particular field. They get out of these for-profit schools loaded down with enormous debt. They can’t find a job. They default. The taxpayer ends up holding the bag. Their credit is ruined, and the for-profit institution is making out like a bandit, That’s a problem. ‘Your administration now has an opportunity to better protect taxpayers and students, including our nation’s veterans, service members and their families, from predatory career education programs. The Education Department is developing draft regulations to enforce the statutory requirement that all career education programs that receive federal funding, whether at for-profit, public or nonprofit colleges, “prepare students for gainful employment in a recognized occupation.” ‘The negotiated rulemaking panel convened last year by the Department to develop the draft regulations was unable to reach consensus. Even after the Department made multiple changes requested by the for-profit college industry representatives that dramatically weakened the draft regulation, the for-profit college industry representatives objected to it. ‘The changes would have made the regulation so weak on predatory colleges and so hard on low-cost, high-performing colleges that not a single negotiator voiced support for the Department's last proposal, We urge the Administration to issue promptly a stronger, more effective proposed regulation so that the urgently needed rules can be finalized by November 1, 2014, and go into effect by July 1, 2015. Ata minimum, we believe the regulation should include the following five elements: 1. A repayment rate or another metric to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding. A low completion rate is one of the ways that programs can fail to prepare students for gainful employment, particularly when they leave school substantial debt. But programs where 99% of the students drop out with heavy debt that they are unable to pay down could still pass the Department's most recent proposal. A program-level cohort default rate (pCDR) was the only metric in that proposal to assess the outcomes of students who do not complete a program. However, a pCDR alone is not sufficient for at least two reasons. First, the well-documented manipulation of cohort default rates by some for-profit college corporations undermines their meaning. Second, default is an extreme situation, measuring whetherborrowers have failed to make any required payments in at least 270 days and does not measure whether students are able to pay down their loans. To be clear, we believe that a strong repayment rate or other metric addressing programs with high borrowing and high dropout rates should be a separate requirement that gainful employment programs must pass, in addition to the other tests, in order to retain eligibility. 2. A meaningful approval process to weed out programs that will not prepare students for gainful employment in the specified occupations before they harm students. Programs that lack the programmatic accreditation or other attributes needed for graduates to be hired in the field should not be eligible to receive taxpayer funds, yet the Department's most recent proposal would allow funding to continue to flow to these programs. For example, federal funding should not be available for dental assisting and other medical programs whose graduates are ineligible for the licensing exam requited to work in that field. Subsidizing such programs misleads students, who trust the federal government to fund only worthwhile programs and is clearly inconsistent with the statutory requirement that all career education progeams receiving federal funding “prepare students for gainful employment in a recognized occupation. 3. Borrower relief that is fair and provides a greater incentive to improve weak programs. The Department proposed partial relief at no cost to taxpayers—for some students who enroll in programs that the Department ultimately determines systematically and consistently fail to prepare students for gainful employment in the specified occupations. We believe students should not be responsible for any loans they received to attend such programs. Providing full relief to all such students is not only fair, it also provides a more effective incentive for schools to improve their programs so they never have to provide such relief. 4, Meaningful debt-to-earnings standards. The debt-to-carnings standards in the Department's last proposal were so weak that literally thousands of programs with median and mean debt levels that exceed their graduates’ entire discretionary incomes would not fail the standards. This is clearly too low a standard. Students and taxpayers deserve better. which most students do not borrow. The 5. Protection for schools offering low-cost programs final 2011 gainful employment regulation automatically passed all low-cost programs where the majority of graduates do not borrow. ‘The federal district court reviewing the regulations upheld this provision, which recognized that such programs do not consistently leave students with unaffordable debts. The new draft regulation should also, In contrast, the Department's last proposal would unintentionally jeopardize funding for many of these low-cost programs because the metries would consider only students receiving Title IV funding, which in many cases are a small, unrepresentative share of the program’s students. These proposals would incentivize more schools to leave the Federal student loan program, lead to the voluntary or involuntary closure of effective, low-cost programs, and is at odds with related statutory precedent which acknowledges the importance of the share of students borrowing We believe these five elements are essential, but there are other areas in which thoughtful proposals were submitted by negotiators that merit further consideration, Several of the negotiated rulemaking, panel working groups and individual negotiators developed detailed proposals to strengthen the regulation in important ways while reducing its burden on high-performing, low-cost colleges. Forexample, the Department’s proposals do nothing to increase the accuracy or comparability of the job placement rates that schools advertise to students. As the commissioner of the National Center for Education Statistics told the negotiated rulemaking panel in September, the exclusion of deceased students is just about the only thing that the many current definitions of job placement have in common. In light of this lack of comparability and the increasing evidence of widespread manipulation and inflation of job placement rates in the for-profit college industry, the proposals by the working group on Job placement are timely, thoughtful, and practical We applaud the Members of Congress who recently sent a letter to Secretary Duncan urging the Administration to move decisively towards issuing @ final regulation. We thank you for your leadership in seeking to improve higher education and career opportunities for all Americans. We and our ‘members and supporters stand with you and look forward to the prompt issuance a strengthened gainful employment rule and other urgently needed steps to enforce current laws to better protect students, taxpayers, and our nation’s economy, Sine ely, AFL-CIO ‘The American Association of State Colleges and Universities (AASCU) American Association of University Professors (AAUP) American Association of University Women (AAUW) American Federation of Teachers (AFT) ‘Americans for Financial Reform Association of the United States Navy (AUSN) Center for Law and Social Policy Center for Public Interest Law Center for Responsible Lending Children’s Advocacy Institute Consumer Action Consumers Union Consumer Federation of California Couneil for Opportunity in Education Crittenton Women’s Union East Bay Community Law Center Generation Progress Initiative to Protect Student Veterans ‘The Education Trust The Institute for College Access & Success Institute for Higher Education Policy (IHEP) Iraq and Afghanistan Veterans of America (AVA) ‘The Leadership Conference on Civil and Human Rights Mississippi Center for Justice National Association for Black Veterans, Inc. (NABVETS) National Association for College Admission Counseling National Consumer Law Center (on behalf of its low-income clients) National Consumers League National Education Association The National Guard Association of the United States (NGAUS) National Women Veterans Association of America New Economy Project formerly NEDAP) NYPIRG Paralyzed Veterans of America Public Advocates In Public Higher Educ: (PHENOM) Publie Citizen Rebuild the Dream Service Employees International Union Student Veterans of America United States Student Association US. PIRG Veteran Student Loan Relief Fund Veterans Education Success ‘Veterans for Common Sense VetJobs VetsFirst, a program of United Spinal Association n Network of MassachusettsLeague of United Latin American Citizens Vietnam Veterans of America MALDEF ‘Young Invineibles ce: Hon, Arne Duncan, Secretary of Education Hon. Cecilia Mufioz, Director, White House Domestic Policy Council Hon, Gene Sperling, Director, White House National Economic Council Hon, Sylvia Mathews Burwell, Director, Office of Management and BudgetJamienne Studley Saturday, February 01, 2014 1231 AM Studley, Jamie; Appel, Jeff; Henderson, Josh Federal College Ratings: Three Modest Steps by Robert Shireman | College Guide | The Washington Monthly http://www.washingtonmonthly.com/college guide/blog/federal college ratings three.php Josh, include in our ratings files pls. I'll circulate Sent from my iPhone Please excuse typosBergh, Jon From: Studley, Jamie Sent: Monday, January 27, 2014 8:02 PM To: Pauline Abernathy Subject: RE: House briefing on gainful employment next Tuesday at Llam Thanks. From: Pauline Abernathy [mailto:pabemnathy@tticas.org} Sent: Monday, January 27, 2014 8:01 PM. To: Gomez, Gabriella; Protopsatis, Spitos; Appel, Jeff; Wall, Mary; Studley, Jamie Ce: Lynn-Jennings Subject: House briefing on gainful employment next Tuesday at 11am FYE From: e-Dear Colleague Reply-To: e-Dear Colleague Date: Monday, January 27, 2014 at 1:48 PM To: "E-DEARCOLL ISSUES A-F_0000@Is2,house.gov" Subject: ConsumerAffairs, Education: Dear Colleague: Briefing on the Need for Gainful Employment Regulations Briefing on the Need for Gainful Employment Regulations From: The Honorable Mark Takano Sent By: Julia.Steinberger@mail.house.gov Date: 1/27/2014 Career Education Programs Should Lead to Careers: Why we need Gainful Employment Regulations 11am, Tuesday, February 4th 340 Cannon Please join us for a briefing on ensuring that career education programs adequately prepare students for their chosen careers. We must address the fact that far too many of our students graduate from these programs - especially those at for-profit colleges - with unmanageable debt and worthless degrees.Specifically, the briefing will discuss the state of career education programs, the history and current status of gainful employment regulations, and the impact these programs have on certain populations, including veterans, minorities, and low-income individuals. Opening Remark: Congressman Mark Takano (CA-41) Moderator: Craig Smith, Director of Higher Education, American Federation of Teachers Panelists: Ben Miiller, Senior Policy Analyst, Education Policy Program, New America Foundation ‘Tom Tarantino, Chief Policy Officer, iraq and Afghanistan Veterans of America Luis Torres, Director of Education Policy, League of United Latin American Citizens To RSVP or for more information, you may contact Julia Steinberger with Congressman Takano at Julia Steinberger @mail.house.gov or 202-225-2305. We look forward to seeing you and your staff. Sincerely, MARK TAKANO. Member of Congress Visit the e-Dear Colleague Service to manage your subscription to the available Issue and Party lists).O'Bergh, Jon Fro Gast, Sara Sent Friday, January 24, 2014 5:43 PM To: Spector, Stephen; Wall, Mary; Appel, Jeff; Henderson, Josh Ce: Gomez, Robert Subject: RE: student loan/tax prep pilot -- one factual issue in the press release and thanks everyone! sorry to create unnecessary chaos for this project two days in a row. From: Gast, Sara Sent: Friday, January 24, 2014 5:42 PM To: Spector, Stephen; Wall, Mary; Appel, Jeff; Henderson, Josh Ce: Gomez, Robert Subject: RE: student loan/tax prep pilot ~- one factual issue in the press release woohoo! the west coast will be happy. From: Spector, Stephen Sent: Friday, January 24, 2014 4:53 PM To: Gast, Sara; Wall, Mary; Appel, Jeff; Henderson, Josh Gomez, Robert Subject: RE: student loan/tax prep pilot — one factual issue in the press release We should be good https://www.ed.gov/news/press-releases/us-departments-education-and-treasury-announce-collaboration-intuit-inc- Beginning in 2009, federal student loan borrowers who are not in default have been able to enroll in an expanded suite of income-driven repayment plans that cap their monthly payments at a percentage of their current discretionary income. The plans also extend the repayment timeframe to 20 or 25 years, and provide for forgiveness of the remaining student loan debt at the end of the repayment period, From: Spector, Stephen Sent: Friday, January 24, 2014 4:43 PM ast, Sara; Wall, Mary; Appel, Jeff; Henderson, Josh Ce: Gomez, Robert ‘Subject: RE: student loan/tax prep pilot -- one factual issue in the press release Yup, will let this chain know when the online version is finally ready for primetime. From: Gast, Sara riday, January 24, 2014 4:41 PM spector, Stephen; Wall, Mary; Appel, Jeff; Henderson, Josh Ce: Gomez, Robert ‘Subject: RE: student loan/tax prep pilot -- one factual Issue in the press release nooeaee worries. Could you ping them again to flag the change? 1From: Spector, Stephen Sent: Friday, January 24, 2014 4:40 PM To? Gast, Sara; Wall, Mary; Appel, Jeff; Henderson, Josh Ce: Gomez, Robert Subject: RE: student loan/tax prep pilot one factual issue in the press release This is the update that | sent the web team. I should have noticed that it wasn’t accurately updated online. My fault. ONS From: Gast, Sara Sent: Friday, January 24, 2014 4:33 PM. To: Spector, Stephen; Wall, Mary; Appel, Jeff; Henderson, Josh Ce: Gomez, Robert Subject: RE: student loan/tax prep pilot ~ one factual issue in the press release (OxSy From: Gast, Sara Sent: Friday, January 24, 2014 4:17 PM To: Spector, Stephen; Wall, Mary; Appel, Jeff; Henderson, Josh Ce: Gomez, Robert Subject: RE: student loan/tax prep pilot -- one factual issue in the press release Gracias — | just passed the word along to TICAS. | haven't seen a blog or release from them today, but I'm not necessarily expecting one. Actually, if they haven’t already asked you guys for this, | bet they'll want to see the report out from the IDR email outreach last fall (so you may want to keep your little summary handy, Josh) From: Spector, Stephen Sent: Friday, January 24, 2014 2:49 PM : Wall, Mary; Appel, Jeff; Gast, Sara; Henderson, Josh Ce: Gomez, Robert Subject: RE: student loany/tax prep pilot ~- one factual issue in the press release Updatedhitps://www.ed.gov/news/press-releases/us-departments-educatio! raise-aw From: Spector, Stephen Sent: Friday, January 24, 2014 1:30 PM To: Wall, Mary; Appel, Jeff; Gast, Sara; Henderson, Josh Ce: Gomez, Robert Subject: RE: student loan/tax prep pilot ~ one factual issue in the press release Thanks for these flags. I've asked the web team to make the chariges. From: Wall, Mary Sent: Friday, January 24, 2014 1:24 PM To: Spector, Stephen; Appel, Jeff; Gast, Sara; Henderson, Josh Ce: Gomez, Robert Subject: RE: student loan/tax prep pilot -- one factual issue in the press release I think that’s fine. Sounds a little better to me to say “for borrowers who are not in default matter of taste. From: Spector, Stephen Sent: Friday, January 24, 2014 1:19 PM To: Appel, Jeff; Wall, Mary; Gast, Sara; Henderson, Josh Ce: Gomez, Robert ‘Subject: RE: student loan/tax prep pilot -- one factual issue in the press release ‘Would it make sense ifit read like this: treasury-announce-collaboration-intuit-inc- but that is probably just a (ens From: Appel, Jeff Sent: Friday, January 24, 2014 1:08 PM To: Wall, Maty; Gast, Sara; Henderson, Josh; Spector, Stephen Gomez, Robert Subject: RE: student loan/tax prep pilot ~ one factual issue in the press release (ersy From: Wall, Mary Sent: Friday, January 24, 2014 12:51 PM ast, Sara; Henderson, Josh; Appel, Jeff; Spector, Stephen Ce: Gomez, Robert Subject: RE: student loan/tax prep pilot ~- one factual issue in the press release 3Shoot, sorry should have caught that. It’s come up in the past ake sense to fix on website by simply the default thing, My personal reaction is that it’s not worth reissuing the press release, but does n striking that highlighted clause. Though we could, I don’t think we need to From: Gast, Sara Sent: Friday, January 24, 2014 12:49 PM To: Henderson, Josh; Appel, Jeff; Wall, Mary; Spector, Stephen Ce: Gomez, Robert Subject: FW: student loan/tax prep pilot -- one factual issue in the press release Go From: Bill Swindell [mailto:BSwindell@tticas.org] Sent: Friday, January 24, 2014 12:09 PM To: Gast, Sara; Gomez, Robert Subject: student loan/tax prep pilot -- one factual issue in the press release Sara and Rober It’s very exciting to see these new outreach efforts on income-driven repayment plans that you announced today with the Treasury Department. Just one factual issue on the press release: on page 2, paragraph 4, it says that the payment cap only applies if payments are made on time. That’s not actually the case. The loans must not be in default, but that is different (it takes at least 270 days of nonpayment to default). Is it possible to fix the release? Let me know if you have any questions. ‘Thanks, Bill Swindell Communications Director The Institute for College Access & Success 405 14th Street, 11th Floor, Oakland, CA 94612 phone: 510-318-7902 fax: 510-318-7918 email: bswindell@ticas.org www.tieas.org www.projectonstudentdebt.org www.college-insight.org www. ibrinfo.org,O'Bergh, Jon Fro Studley, Jamie Sent: Wednesday, January 15, 2014 9:03 AM Te Mitsui, Mark; Perrotti, Carmine Subject: RE: Expected attendee list Carmine will help with that, pls Sent from my Windows Phone From: Mitsui, Mark Sent: 1/15/2014 8: To: Studley, Jamie Subject: RE: Expected attendee list 9AM ‘Thanks. Any logistical info, Waves, location etc.? Sent from my Windows Phone From: Studley, Jamie Sent: 1/15/2014 8:36 AM To: Shelton, Jim; Gomez, Gabriella; Vadehra, Emma; Dann-Messier, Brenda; Appel, Jeff; Muenzer, Melanie; Mitsui, Mark; Wall, Mary; Soo, David; Whitman, David; Borders, Tia; Pollack, Joshua ‘Subject: FW: Expected attendee list Sent from my Windows Phone From: Leibenluft, Jacob Sent: 1/15/2014 4:22 AM To: Doyle, Matthew; Studley, Jamie Subject: Re: Expected attendee list We just wanted to re-share an updated list. From: Doyle, Matthew Sent: Wednesday, January 15, 2014 04:21 AM To: Studley, Jamie (Jamie. Studley@ed.gov) Cc: Leibenluft, Jacob Subject: Expected attendee list Full expected list in two categories ‘College and University Presidents Invitee ‘Amherst Biddy Martin ‘Augustana College Steven C. Bahls Barnard Debora L. Spar 1Berkeley Nicholas Dirks Bowdoin Barry Mills Davidson Carol Quillen Drake Univer David Maxwell Franklin& Marshall College Daniel Porterfield ‘Georgetown University President John J. DeGioia Hamilton Joan Hinde Stewart Harvey Mudd College ‘Maria Klawe Hobart William & Smith Colleges Mark D. Gearan Kenyon College Sean M, Decatur Oberlin College Marvin Kristov ‘Skidmore Philip A. Glotzbach ‘Smith College Kathleen McCartney. ‘Stony Brook Stanley, Samuel L. Tulane ‘Scott Cowen UC Irvine, UC San Diego, UC Santa Barbara Janet Napolitano (president of the University of California system); University of North Carolina, Chapel Hill Carol Folt, University of Puget Sound Ronald Thomas University of Virginia Teresa Sullivan University of Wisconsin Becky Blank Vassar Catharine Hill ‘Washington and Jefferson College Tori Haring-Smith ‘Washington Univesity in St. Louis Mark Wrighton’ ‘West Virginia Higher Education Policy Commission _| Paul Hill Whittier College ‘Sharon D. Herzberger Yale Peter Salovey UC San Diego Pradeep Khosla, Chancellor Claremont McKenna Hiram E. Chodosh ‘Mount Holyoke College Lynn Pasquerella Pitzer College Laura Skandera Trombley Bates Clayton Spencer Spelman College Beverly Daniel Tatum, Ph.0. Georgia Institutute of Technology (Georgia Tech) Bud Peterson lowa State University Steven Leath University System of Maryland Brit Kirwan’ University of Minnesota, Twin Cities ic Kaler Wesleyan University Michael S. Roth ‘Oregon Tech Chris Maples Pomona David W. Oxtoby University of Colorado, Boulder Philip DiStefano University of Missouri Mike Middleton, Deputy Chancellor Middlebury Ronald Liebowitz Princeton. Chris Eisgruber 2Bryn Mawr College kim Cassidy University of Vermont E. Thomas Sullivan Georgia state Mark Becker Florida international Mark Rosenberg Walden Jonathan Kaplan University of Pennsylvania ‘Amy Gutmann Brown University Christina Paxson. University of Tennessee, Knoxville Jimmy Cheek North Carolina - NC State University ‘Woodson, William Randolph Howard University Dr. Wayne Frederick Goucher College ‘Sanford J. Ungar, University of Arkansas Dr. G. David Gearhart University of New Hampshire ‘Mark W. Huddleston University of Nebraska James Milliken Northeastern University Joseph Aoun, President University of California, Merced Chancellor Leland SUNY Nancy Zimpher Cheyney State University Dr. Michelle Howard-Vital Morgan State University Dr. David Wilson University of Texas at Austin Bill Powers Scripps College Lori Bettison-Varga Morehouse John Wilson’ El Paso Community College William Serratta Zane State Community College Paul Brown, Tacoma Community College Pamela Transue Community College of Denver Cliff Richardson ‘Community College of Baltimore County Sandra Kurtiniti Lake Washington Institute of Technology ‘Amy Morrison Goings Patrick Henry Community College ‘Angeline Godwin Bunker Hill Community College Pam Eddinger Northern Virgina Community College Robert Templin Montgomery County Community College Karen Stout Kingsborough Community College Stuart Suss ‘Cuyahoga Commuity College ‘Alex Johnson Valencia College Sandy Shugart Harper College Ken Ender Louisiana State University F. King Alexander Navajo Technical University Elmer Guy, Organizations and individuals invitee Kresge Foundation Bill Moses, Program Director-Education Lumina Foundation Jamie P. Merisotis, President and CEO.Bloomberg Foundation Jon Schnur (america achieves); Jessica Levin (alternate) Citi Pam Flaherty, President and CEO Traveler's Foundation ‘Marlene lbsen, President and Chief Executive Officer Belk Foundation (regional - NC) Kristy Teskey Irvine Foundation (CA) ‘Anne Stanton, Program Director; Joyce Foundation Ellen Alberding, President Aspen Institute ‘Walter Isaacson MacArthur Foundation Connie Yowell Posse Foundation?? Jeff Ubben’ Thave a Dream Foundation Eugena Oh 100kin10 Talia Milgrom-Elcott Harvard Bridget Terry Long. Harvard Christopher Avery UVA Ben Castleman Stanford Eric Bettinger Bob Shireman PG&E Tony Earley; Melissa Lavinson (alternate) Bob Kerrey AT&T ‘Samantha Lasky City of San Antonio Mayor Julian Castro Delaware Governor Markell NCAC Nicole Hurd Posse Foundation Deborah Bial College Spring Garrett Neiman College Possible Jim McCorkell College Board David Coleman College Track David Silver NCAN Cook College Summit 38 Schramm Khan Academy. Sal khan Blue Engine Nick Ehrmann iMentor, Mike O'Brien Ac ‘Scott Montgomery NACAC Joyce Smith Gear Up. Norma McCormick MDRC Gordon Berlin American Federation of Teachers Randi Weingarten Walmart Bill Simon ‘Mutual of America Foundation ‘Thomas Gilliam Samberg Family Foundation ‘Art Samberg. Innovate+Educate Jamai Blivin Carnegie Corp Michelle Cahill 4John and Laura Overdeck Family Foundation John Overdeck John and Laura Overdeck Family Foundation Laura Overdeck Tortora Silcox Family Foundation Mark Silleox Tortora Silcox Family Foundation Leslie Silcox Paul Tough NCAN Carrie Warick Chegs Dan Rosensweig ACE Molly Corbett Broad ‘ACC Dr. Walter Bumphus ‘ARSC Dr. Muriel Howard APLU Peter McPherson NAICU David L. Warren ‘AAU Hunter R, Rawlings Wi West Virginia Gear Up ‘Adam Green United Negro College Fund (UNCF) Cheryl Smith, SVP Public Policy & Government Affairs LEDA John C. Roberts; Beth Bregers Martha Kanter ‘The National Education Foundation Bob Craves Helmsley Charitable Trust Ryan Kelsey OneGoal Jeffrey William Nelson Kaplan For Profit College Don Graham Belk Foundation (regional — NC) Mary Claudia Pilon Belk Foundation (regional — NC) Kate Belk Morris NAFEO Leslie Baskreville Lawrence Harris Department of Education Jamie Studley Department of Education Jeff Appel New York Public Library Tony Marx Achivieving the Dream Bill Trucheart Complete College America Stan Jones Jobs for the Future Marlene Seltzer UT-Austin Dr Byron McClenney New Mathways Project Uri Treisman, Education Commission of the States Matt Gianneschi, PhD Carnegie Foundation for the Advancement of Teaching (Quantway/Statway) ‘Tony Byrk Carnegie Foundation for the Advancement of Teaching (Quantway/Statway) Karon Klipple, PhD. Starfish David Yaskin TRIO Maureen Hoyler Kansas Board of Regents Blake Flanders Illinois Community College Board Karen Anderson 5Colorado Community College System Nancy McCallin Connecticut Board of Regents Gregory Gray State of Illinois Julie Smith State of Indiana Mike Pence- R Kentucky Council on Postsecondary Education Bob King State of Massachusetts Deval Patrick- D Massachusetts Department of Higher Education Richard Freeland ‘Montana University System Clay Christian Virginia Community College System Glenn DuBois ‘Texas Association of Community Colleges Rey Garcia California Community Colleges Brice W. Harris California State System Tim White University of Hawaii System David Lassner University of Wisconsin System ‘Mark Nook: Wyoming Community College Commission James Rose Brenda Dann-Messier Lawrence HarrisO'Bergh, Jon From: Studley, Jamie Sent: Tuesday, January 14, 2014 4:32 PM To: Pauline Abernathy Subject RE: two quick college ratings questions It’s the only NCES sponsored public technical symposium on ratings that has been scheduled so far. But we are by no means done. You are right that this might one of the most open, we'll have a mix of formats and I'm sure you'd want some of them to be smaller and not so much in the limelight. Pints well taken. ‘And yes, | thought they were looking for some pre Jan 22, but later in the month is just fine, To be continued From: Pauline Abernathy {mailto:pabernathy@tticas.org] Sent: Tuesday, January 14, 2014 3:57 PM To: Studley, Jamie Subject: RE: two quick college ratings questions, Thanks Jamie. | thought at one point you thought there was some value in submitting comments earlier in January but itis certainly better for us to submit them at the end of the month after the symposium. As you know, there are technical experts who do not work for colleges or organizations that represent colleges or depend on them for funding, It is unfortunate that such experts are not better represented at the symposium, but I take your point that it is not the only place to weigh in (although | believe it is the only public forum on ratings in DC!). Thanks again for the quick reply. Pauline From: Studley, Jamie [mailto:Jamie,Studley@er,gov] Sent: Tuesday, January 14, 2014 3:49 PM To: Pauline Abernathy ‘Subject: RE: two quick college ratings questions Here's how we've been explaining this to folks (lifted from a colleague’s email) This conversation on Jan 22 — which is NCES sponsored — is designed to be almost exclusively technical, and the presenters were invited based on their expertise in performance measurement, data/data systems, and ratings systems. (I think people are thinking that the symposium is the only way they can weigh in on the ratings, so it would be good to remind people that there will be continued conversation as the Department's proposal develops.) Vil add that we will be sure to have a mix of voices, advocates etc as we go forward, and will have other combinations of people throughout. We share your interest in a full range of perspectives, As for timing, | don’t think it makes a difference whether you submit feedback before or after the symposium, since the Department will primarily be in listen mode anyway In fact if you want to go to it and use that to inform your comments that should be fine. From: Pauline Abernathy [mailto:pabernathy@ticas.org Sent: Tuesday, January 14, 2014 11:41 AM To: Studley, Jamie Subject: two quick college ratings questionsJamie, Happy New Year! | just left you a voice mail message with more detail but the gist of my two questions ar it sufficient if we submit our comments by Jan 31 or is there some info that it would be helpful for us to submit before the symposium? Also, we were surprised to see so few experts with a clear consumer/student perspective invited to present at the symposium. What was the thinking in inviting so many people who look at these issues from an institutional perspective? We fear it will create a false impression of consensus on some of issues because they are coming at it from an institutional perspective. Can you give me a quick call when you get a chance, or respond by email if that is easier. Thanks. Pauline Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 wwwticas.org and www.projectonstudentdebt.org,QO'Bergh, Jon From: Immerman, Suzanne Sent: Tuesday, January 14, 2014 1:03 PM To: Soo, David Subject: RE: Summit -- attendance and commitments list to date, Thank you! From: Soo, David Sent: Tuesday, January 14, 2014 11:50 AM Tor Immerman, Suzanne Subject: FW: Summit Suzanne, below is the list of presidents | know about on Thursday. As far as I know, none will be here on Wednesday. attendance and commitments list to date, ‘Organization Invitee ‘Amherst, Biddy Martin Augustana College Steven C. Bahls: Barnard Debora L. Spar Berkeley Nicholas Dirks Bowdoin Barry Mills Camegie Mellon Subra Suresh Davidson’ Carol Quillen Drake University David Maxwell Franklin& Marshall College Daniel Porterfield Georgetown University President John J. DeGioia Hamilton Joan Hinde Stewart Harvey Mudd College Maria Klawe Hobart William & Smith Colleges Mark D. Gearan Kenyon College ‘Sean M. Decatur Oberlin College Marvin Krislov Skidmore Philip A. Glotzbach Smith College Kathleen McCartney Stony Brook Stanley, Samuel L. Tulane Scott Cowen. University of Chicago Robert Zimmer University of North Carolina, Chapel Hill Carol Folt University of Puget Sound Ronald Thomas. University of Virginia Teresa Sullivan, University of Wisconsin Becky Blank Vassar Catharine Hill Washington and Jefferson College Tori Haring-Smith Washington Univesity in St. Louis ‘Mark Wrighton 1West Virginia University Paul Hill Whittier College ‘Sharon D. Herzberger Yale Peter Salovey UC San Diego Pradeep Khosla, Chancellor Claremont Mckenna Hiram E. Chodosh_ Mount Holyoke College Lynn Pasquerella Pitzer College Laura Skandera Trombley Bates Clayton Spencer Spelman College Beverly Daniel Tatum, Ph.D. Georgia Institutute of Technology (Georgia Tech) Bud Peterson lowa State University Steven Leath University of Maryland Brit Kirwan University of Minnesota, Twin Cities Eric Kaler Wesleyan University Michael S. Roth ‘Oregon Tech Chris Maples: Pomona David W. Oxtoby University of Colorado, Boulder Philip DiStefano University of Missouri Mike Middleton, Deputy Chancellor Kresge Foundation Bill Moses, Program Director-Education Lumina Foundation Jamie P. Merisotis, President and CEO Bloomberg Foundation Jon Schnur (america achieves) Helmsley Charitable Trust John Ettinger, CEO Citi Pam Flaherty, President and CEO Traveler's Foundation Marlene Ibsen, President and Chief Executive Officer Joyce Foundation Ellen Alberding, President. Aspen Institute Walter Isaacson ‘MacArthur Foundation Connie Yowell Posse Foundation? Jeff Ubben Ihave a Dream Foundation. Eugena Oh 100kin10 Talia Milgrom-Elcott Harvard Bridget Terry Long. Harvard Christopher Avery. Uva Ben Castleman Stanford Eric Bettinger Bob Shireman City of San Antonio Mayor Julian Castro NCAC Nicole Hurd Posse Foundation Deborah Bial College Spring Garrett Neiman College Possible dim MeCorkell College Board David Coleman College Track David Silver CAN kim Cook 2College Summit JB Schramm Khan Academy sal Khan Blue Engine Nick Ehrmann iMentor Mike O'Brien ACT Scott Montgomery MDRC Gordon Berlin Princeton Chris Eisgruber Innovate+Educate Jamai Blivin Carnegie Corp Michelle Cahill John and Laura Overdeck Family Foundation John Overdeck John and Laura Overdeck Family Foundation Laura Overdeck Bryn Mawr College kim Cassidy Tortora Silcox Family Foundation Mark Silcox. Tortora Silcox Family Foundation Leslie Silcox University of Vermont E, Thomas Sullivan Georgia state Mark Becker NCAN Carrie Warick Florida international Mark Rosenberg, University of Pennsylvania ‘Amy Gutmann Brown University Christina Paxson. University of Tennessee, Knoxville Jimmy Cheek. Chegg. Dan Rosensweig ACE ‘Molly Corbett Broad ‘AACE Dr. Walter Bumphus AASCU Edward M. Elmendorf APLU, Peter McPherson NNAICU David L. Warren AAU Hunter R. Rawlings ll North Carolina - NC State University ‘Weodson, William Randolph Howard University Dr. Wayne Frederick Goucher College Sanford J. Ungar, University of Nebraska James Milliken Northeastern University Joseph Aoun, President University of California, Merced Chancellor Leland) SUNY Nancy Zimpher Morgan State University Dr. David Wilson. Gear Up. ‘Adam Green University of Texas at Austin Bill Powers Morehouse John Wilson’ Achivieving the Dream Bill Trueheart Complete College America Stan Jones Jobs for the Future Marlene Seltzer ‘American Association of Community Colleges Walter Bumphus 3UT-Austin Dr Byron McClenney Uri Treisman Education Commission of the States Matt Gianneschi, PhO. Camegie Foundation for the Advancement of Teaching (Quantway/Statway) Tony Byrk. Carnegie Foundation for the Advancement of Teaching (Quantway/Statway) Karon klipple, PhD Starfish David Yaskin Kansas Board of Regents Blake Flanders ilinois Community College Board Karen Anderson Connecticut Board of Regents Gregory Gray State of Georgia Nathan Deal: R State of ilinois Pat Quinn- D State of tlinois Julie Smith State of indiana Mike Pence- R Kentucky Council on Postsecondary Education Bob King State of Maryland Martin O'Malley-D State of Massachusetts Deval Patrick: D ‘Montana University System Clay Christian Virginia Community College System Glenn DuBois ‘Texas Association of Community Colleges Rey Garcia California Community Colleges Brice W. Harris El Paso Community College William Serratta ‘Tacoma Community College Pamela Transue ‘Community College of Baltimore County Sandra Kurtinitis Lake Washington Institute of Technology ‘Amy Morrison Goings Patrick Henry Community College Angeline Godwin Bunker Hill Community College Pam Eddinger Miami Dade Community College Lenore Rodicio Northern Virgina Community College Robert Templin ‘Montgomery County Community College Karen Stout Kingsborough Community College Stuart Suss. Cuyahoga Commuity College ‘Alex Johnson Harper College Ken Ender Louisiana State University F. King Alexander Lelbentuft, Jacob Sent: Friday, January 10, 2014 12:18 AM To: ‘Studley, Jamie’; Menon, Ajita T.; Doyle, Matthew ‘Subject: RE: Summit -- report draft, commitments list to date, agenda? ‘Adding Matt, so he can send the latest RSVP list (and context) as well as our latest rough draft commitment lst. We should be able to send a report draft tomorrow. Thanks for your patience on all ofthis, 4From: Studley, Jamie [mailto:Jamie,Studley@ed.gov] Sent: Thursday, January 09, 2014 8:04 AM To: Leibenluft, Jacob; Menon, Ajita T. Subject: RE: Summit — report draft, commitments list to date, agenda? Thanks. That's a great idea Sent from my Windows Phone From: Leibenluft, Jacob Sent: 1/9/2014 12:19 AM To: Studley, Jemie; Menon, Ajita T. Subject: RE: Summit ~ report draft, commitments list to date, agenda? | should add that Gene asked Jim personally about possibly moderating a panel, and I believe Jim is trying to make that work. Studley, Jamie {mailto:Jamie.Studley@ed.gov} Sent: Wednesday, January 08, 2014 8:04 PM, To: Menon, Ajita T.; Leibenluft, Jacob Subject: RE: Summit — report draft, commitments list to date, agenda? That's great to know! Really appreciate it. \ will let those folks and their schedulers know about these invitations. Thanks! You also know that as an advocate and messenger I'm, going to get back to you to suggest a couple of others should there be space or someone can’t be there the whole time, but let me check with my team on that From: Menon, Ajta T. (maito:Ajita R Talwalker@who.cop.gov] Sent: Wednesday, January 08, 2014 7:53 PM To: Studley, Jamie; Leibenluft, Jacob Subject: RE: Summit ~ report draft, commitments lst to date, agenda? Hi Jamie, We should have most of these things (participant list, commitment summary, draft session agenda and report) to share tomorrow a.m On the scheduling front, in addition to AD’s time on Wednesday evening and Thursday afternoon, we were hoping to have You, Gaby, and Jim for the most of the day on Thursday, and the evening before. More to come...and many thanks, Ajita From: Studley, Jamie [mailto:Jamie, Studley@ed.gov] Sent: Wednesday, January 08, 2014 11:41 AM To: Leibenluft, Jacob; Menon, Ajita T. Subject: Summit ~ report draft, commitments list to date, agenda? We'd really like to see as soon as you can the full participant list so far (we got it without the ones in the remediation bucket) and what kinds of commitments are being made, even if not final or complete. Overview from your comms folks??Anything you can tell us about who should be holding time to be at any of your sessions would be helpful of course ‘And we'll want to turn the report around fast for you once we get it. Any estimate? | know you're crunching on many fronts, thanks for any new pieces you can get to us. Thank you!!! Jamienne S. Studley Acting Under Secretary US Department of Education 400 Maryland Avenue, SW ‘Washington, DC 20202O'Bergh, Jon Fror Sanders, James Sent: Friday, January 03, 2014 4:15 PM Te Culatta, Richard; Givens, Garren ce: Soo, David Subject: Re: ACTION REQUIRED: Tomorrow's Company Outreach Please add your notes from your calls to this document: https://docs.google.com/spreadsheet/ccc?key-OApokqnZedY3idFiFaW piNGONVTIIZE ShWXhYNnd3SncBusp=drive_webtgid=0 On 1/2/14, 8:38 PM, "Sanders, James" wrote: >I ust pulled a P2PU name from the list. Sounds like Phillip would be >better. 'm not familiar with the P2PU team. > >On 1/2/14, 8:17 PM, "Culatta, Richard” wrote: >>Any reason not to reach out to Phillip at P2PU? > >>. >>From: Sanders, James >Sent: Thursday, January 02, 2014 7:07 PM >oTo: Givens, Garren; Culatta, Richard; Soo, David >>Subject: ACTION REQUIRED: Tomorrow's Company Outreach >>Team, > >>Here are the companies | need you to reach out to tomorrow and vet as >to whether or not they should have a table or a speaking slot at the >>Datapalooza. > >>Here isa link to the rubric that we're using to look at the >>companieschttps://docs.google.com/document/d/1RaKMPVI88mdj7nLD6pHK9s55, >oxde >>d >i_Z_rRsLcLEzdaU/edit?usp=sharing> (Thanks Garren!) > >>My list is a little longer because | have standing relationships with >>some of the people and it's an easier task. Feel free to look at the >>Datapalooza master polistchttps://docs google. com/spreadsheet/ccc?key=OAsBXCIhkrPMudDOSaWat >oaiZ >on >>emMtWkhMTmptQIRIZHc&usp=drive_webiigid=0>, or the company >olistchttps://docs.google.com/spreadsheet/ccc?key=OAoENACdmabvHdExpM1dk >>UIF >>u >>U3laSKNYSF9zb3V2ZFERUSp= ve_webiigid=0> to bite off a few more if 1>>you'e feeling ambitious. >>Remember, under promise, over deliver. >olames > >oRichard >eVanessa Gennarelli vanessa@p2pu.org >>P2PU >>Brent Grinna_ brent@evertrue.com Evertrue >>Anne Dwayne anne@zinch.com Zinch >>*Plus the two companies you mentioned on our call tonight >>Garren > >>Arial Diez >>ariel@boundlesslearning.comemailto:ariel@boundlesslearning.com> Boundless >>Bobby Touran bobby@applykit.com ApplyKit >>Jim Mcintyre / Christina Mcintyre >>im@BecomeAlum.comemailto:jim@BecomeAlum.com> >>Christina@becomealum.comemailto:Christina@becomealum.com> > >>Become/lum.com>2&u >os >>geALhdy29uBQ3ZQrTWsnfedrraQNkHRBadjw> >>Bob Giannino-Racine bob@uaspire.org uAspire >> > >>David > >>Brad Hunt bhunt@simpletuition.com >>Simple Tuition >>Alexdra Bernadotte >>abernadotte@beyond12.org Beyond 12 >eCurt Allen curt.allen@agilix.com >>Agilix >elessica L. Thompson _jthompson@ticas.org >STICAS ttp://BecomeAlum.comB&usd= >>lames >>David Yaskin >>dyaskin@starfishsolutions.comemallto:dyaskin@starfishsolutions.com> >oStarfish Retention Solutions>Cecilia Retelle cecilia@goranku.com Ranku >»Christina Allen callen@linkedin.com Linkedin >>Aaron Michael aaron@pathsource.com >>PathSource >>William Houghteling >>will@minervaproject.com Minerva >>Project Arthi Krishnaswami >>arthi.krishnaswami@gmail.com >>Rye Catcher >» Brian Duffy >>brian.duffy@carneylabs.com Carney >>labs >>Christopher Sheppard >>csheppard@parchment.comemailto:csheppard@parchment,com> Parchment >eAllen Kim — akim@findthebest.com >oFind the Best >