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!!!!:sera", David
From:
Sent:
To:
Cc:
SUbject:
Attachments:
Pauline Abernathy [pabernathy@ticas.org]
Wednesday, April 14, 201010:56 AM
Kanter, Martha; Madzelan, Dan; Gomez, Gabriella; Arsenault, Leigh; Manheimer, Ann;
Shireman, Bob; Dannenberg, Michael; Bergeron, David; Rogers, Margot; Kvaal, James R.;
Plotkin, Hal
Lehr, Susan M.; Debbie Frankie Cochrane; Lauren Asher; Connie Myers
Florida College Presidents ltr in support of Gainful Employment proposal
FL COP Letter to Secretary Duncan re GE.pdf; FL Career Ed OPPAGA Highlights Rpt 10-18
FINAL.docx
Attached is a strong letter from the 28 Florida community and state college presidents urging the
Secretary to move forward with a strong gainful employment definition. The letter was mailed on
Monday and copies are being sent to the FL delegation as well.
For those who may not have seen it before, I have also attached the excellent two-page summary by
Susan Lehr at Florida State College of the recent report by the Florida legislature's policy office
comparing Florida public and for-profit college costs and student outcomes. The report focuses on
five programs and among its conclusions are that the public programs cost both students and
taxpayers less than for-profits, are much more likely to be accredited, and their students have higher
pass rates on licensure and certification tests.
«FL COP Letter to Secretary Duncan re GE.pdf» «FL Career Ed OPPAGA Highlights Rpt 10-18 FINAL.docx»
Pauline Abernathy
Vice President
The Institute for College Access & Success
www.ticas.org and www.projectonstudentdebt.org
We moved! TICAS' main number is now 510.318.7900. My direct line is 510.318.7903.
1
!!!:peron, David
From:
Sent:
To:
Subject:
FYI.
Pauline Abernathy [pabernathy@ticas.org]
Saturday, September 11, 20105:03 PM
Pauline Abernathy
Sunday NYT editorial!
NYT editorial, online Sept 11 for print on September 12, 2010
Let the Students Profit
The Obama administration has proposed tough and much-needed regulations for lucrative for-profit
colleges. Industry is predictably pushing back hard, with legions of high-priced lobbyists and
organized letter-writing campaigns. The administration must hold its ground.
The final rules, due out in November, must be strong enough to rein in businesses that have made an
art of enrolling students who have no chance of graduating and stripping them of state and federal
grants and loans. Besides ending such abuses of students, the regulations are needed to protect
taxpayers, who foot the bill for waste and abuse in the college aid program.
Honest, well-run for-profits play an important role in educating students who may not qualify for
traditional schools. Over the last decade, far too many institutions have been cited for saddling
students with ruinous debt. A recent report from the Government Accountability Office found
fraudulent or deceptive practices at all 15 of the for-profit colleges visited by investigators posing as
prospective students.
Some college officials encouraged applicants to falsify financial aid forms; students were also
pressured into signing enrollment contracts before they were allowed to speak to financial aid
representatives who would clarify costs. The programs offered at the for-profits schools were
substantially more expensive than comparable programs at nearby public colleges. In one example, a
student who inquired about the cost of studying for a massage therapy certificate was told that
$14,000 was a fair price, even though the local community college offered the same courses for
$520.
The new rules would grant the Department of Education stronger authority to stop schools from
making false or misleading statements about financial chargesor the employability of their graduates.
Schools would be barred from paying recruiters based on how many students they brought in. Most
important, the new rules would cut off federal aid to programs that repeatedly saddled students with
debt that is defined as unaffordable under a new formula that takes earnings into account.
The for-profit sector is claiming that such abuses are rare and says that these rules would hurt the
poor and minority students who are disproportionately enrolled in f o r ~ p r o f i t schools. In fact, the rules
would go a long way toward preventing those students from being preyed upon and saddled with debt·
that follows them for the rest of their lives.
http://www.nytimes.com/2010/09/12/opinion/12sui12.html
. 1
Pauline Abernathy
Vice President
The Institute for College Access & Success
www.ticas.org and www.projectonstudentdebt.org
TICAS: 510.318.7900 Direct: 510.318.7903
2
!.!!ieron, David
From:
Sent:
To:
Cc:
Subject:
Attachments:
Pauline Abernathy [pabernathy@ticas.org}
Thursday, September 09,20107:36 PM
Kvaal, James; Arsenault, Leigh; Hamilton, Justin; Madzelan, Dan; Bergeron, David; Smith,
Zakiya; Gomez, Gabriella
Lauren Asher; Debbie Frankie Cochrane
TICAS and student comments on GE NPRM
July 26 NPRM Comments FINAL.pdf
FYI, the submitted comments of TICAS, U.S. PIRG, USSA, and Campus Progress Action are
attached. Our comments cite Sandy Baum's excellent post on gainful employment yesterday in the
Chronicle (http://chronicle.com/blogPost/Gai nfuI-Employment/26770/)
1
.!!!.!:Sera", David
From:
Sent:
To:
Subject:
Pauline Abernathy[pabernathy@ticas.org]
Tuesday, September 07,20108:32 AM
Bergeron, David
RE: Today's NYT article
Thanks David. I know you're looking for real feedback and we1re working on our detailed public
comments (as I'm sure are many schools). But as you know, after some of the for-profit schools
spent so much money generating comments, one can be sure they'll be trumpeting how many
comments were negative. 1'mglad thatthe Dept is also receiving comments that indicate that
thousands of Americans su·pport strong regulation of career education programs, including specific
suggestions for how to strenghten the NPRM.
Thanks again. Pauline
From: Bergeron, David [mailto:David.Bergeron@ed.gov]
Sent: Tuesday, September 07, 2010 8:21 AM
To: Pauline Abernathy .
Subject: RE: Today's NYT article
Sorry about not getting back to you sooner. I spoke with the NYT on Tuesday, August 31. At that point, weld received
26,000 comments. I don't know what the breakdown was at that time - for or against -but that is irrelevant as the
number has grown significantly. Again, still don't have counts for and against because that is not the point of the public
comment process which is about getting suggestions for changes to the proposed rule. Astroturf doesn't help in that
regard.
David
From: Pauline Abernathy [mailto:pabemathy@ticas,org]
Sent: Saturday, September 04,20106:59 PM
To: Bergeron, David
Subject: Today's NYT article
Hi David,
I was wondering if you could say about what share of the more than 26,000 public comments
received so far support the reg and/or making it stronger! Credo alone has submitted more than
20,000 in support of strengthening the regs. Hope you're getting some well-deserved time off this
weekend! Pauline
Pauline Abernathy
Vice President
The Institute for College Access & Success
..;.
www.ticas.org and www.projectonstudentdebt.org
TICAS: 510.318.7900 Direct: 510.318.7903
1
~ e r o n J David
From:
Sent:
To:
Subject:
Attachments:
Pauline Abernathy [pabemathy@ticas.org]
Saturday, September 04, 201 a 3:43 PM
Pauline Abernathy
LULAC endorses Gainful Employment regulation
LULAC National.Gainful EmploymentLetter.9.1 a.pdf
FYI--Attached is LULAC's letter endorsing the proposed gainful employment regulation and urging the
Administration "to take the necessary steps to protect students from the predatory practices of many
for-profit institutions of higher education." . .
1
!.2.!lIeron. David·
From:
Sent:
To:
Cc:
Subject:
Pauline Abernathy [pabemathy@ticas.org]
Thursday, September 02, 20105:36 PM
Kvaal, James; Gomez, Gabriella; Arsenault, Leigh; Smith, Zakiya; Madzelan, Dan; Bergeron,
David; Hamilton, Justin
Connie Myers
FW: Education, Finance: Dear Colleague: Strengthen Protections for Students of For-Profrt
Higher Education
FYI Below is aDear Colleague from Gwen Moore asking members to sign a letter in support of strengthening the GE
reg.
From: e-Dear Colleague
Sent: Thursday, September 02,20105:04 PM
To: E-DEARCOLL_IS5UES_A-F_0000@ls2.house.gov
Subject: Education, Finance: Dear Colleague: Strengthen Protections for Students of For-Profit Higher Education
Strengthen Protections for Students of For-Profit
Higher Education
From: The Honorable Gwen Moore
Sent By: steffany.stern@mail.house.2QY
Date: 9/2/2010
Protect Students and Families inYour District from Harmful Practices by For-Profit Schools
Dear Colleague,
On July 23, the U.S. Department of Education released its long-awaited proposed regulations defining "gainful
employment." Career education programs are required to "prepare students for gainful employment in a recognized
occupation" in order to receive federal student aid. But without clear, enforceable definitions and rules, many of these
for-profit programs have gone unchecked for a long time-and too often have failed to provide students with solid
preparation for aJob, while burdening students with large debts they are unable to repay. We must do more to ensure
that programs and schools meet reasonable standards for eligibility, if they are going to continue to reap our taxpayer
dollars.
The publiC has until September 9
th
to comment on these regulations. Please join me in support of the regulations, and
encouragetheDepartment to strengthen, not weaken, these guidelines. To sign the letter below, please Steffany Stern
(Steffany.stern@mail.house.gov) in my office.
Sincerely,
/s
Gwen Moore
1
Member of Congress
U.S. Department of Education
Attn: Jessica Finkel
1900 KStreet, NW, Room 8031
Washington, DC 20006-8502
Re: Docket ID ED-2010-0PE-0012 defininggainful employment
Dear Secretary Duncan:
We write to comment on the proposed gainful employment regulation published in the July 26, 2010 Federal Register.
Now more than ever, Americans need access to quality, affordable career education programs, and taxpayers should not
be forced to subsidize programs that routinely saddle students will debts they cannot repay and degrees and certificates
they cannot use.
Federal law requires all career education programs that receive federal student aid to "prepare students for gainful
employment in a recognized occupation." Covered programs include most for-profit programs and all public and non-
profit programs of less than two years. As a result of aggressive advertising and recruiting, students of color
disproportionately attend for-profit school programs, accounting for at least half of all students enrolled, making them
particularly vulnerable.
We commend the Education Department for proposing a long overdue definition of gainful employment. To better
protect students and taxpayers, we encourage you to strengthen the draft regulation by making four changes:
Students and Taxpayers Need Protection Beginning Next Year. While the proposed regulations would take effect in
July 2011, they would not even begin to protect students or taxpayers until July 2012-two years from now-and would
not be fully effective until July 2013. Students and taxpayers should not have to wait so long for some protection from
exploitation.
The Rule Needs Higher Standards. The proposed rule would let programs continue to grow and profit from federal
student aid even when more than half of theirformer students with loans can't afford to pay down their principal.
Career education programs eligible for federal grants and loans should be held to a higher standard.
Programs Must Improve to Remain Eligible for FederalAid. Programs with high student borrowing rates, low loan
repayment rates, and high student debt burdens should have to improve to keep receiving fed.eral student aid dollars.
to-slJ-bsidize low performanc-eand highprofits, andcertairiiynot indefrnltelY. -
Families with Children Need Equal Protection. Half of all undergraduates at for-profit colleges have dependent
children, and more than one in four have at least two children. If the final rule includes a threshold based on
"discretionary income," it should reflect the real debt burden on low- and middle-income families with children.
Thank you for considering our views and for your commitment to increasing access to quality, affordable higher
education for all Americans.
2
Visit the e-Dear Colleague Service to manage your subscription to the available Issue and Party list(s).
This e-mail and any attachments are confidential and are intended solely for the named addressee(s). If you are not a named addressee, you should not copy,
alter, post, forward, distribute or disseminate the contents of the e-mail or attachments. Any views or opinions expressed are solely those of the individual and do
not necessarily represent those of the American Federation of Teachers (AFT).
3
!!!lJeron, David
From:
Sent:
To:
Cc:
SUbject:
Attachments:
Pauline Abernathy [pabemathy@ticas.org]
Tuesday, August 17, 2010 1:16 PM
Kvaal, James; Hamilton, Justin; Arsenault, Leigh; Gomez,Gabriella; Bergeron, David;
Madzelan, Dan; Kolotos, John; Smith, lakiya
Lauren Asher; Connie Myers; Jennifer Webber; Angela Peoples; Lindsay McCluskey;
Getachew Kassa; chris.lindstrom@pirg.org; Nicole Allen
Q&A on Gainful Employment
QA on GE Aug 16 FINAL w logos.docx
FYI. Attached are public Q&A on the Gainful Employment NPRM. It is being widely distributed to Hill
staff, stakeholders and the press to address some common questions. As always, questions or
comments are welcome to the extent they are permissable. Pauline
«QAon GE Aug 16 FINAL w logos.docx»
Pauline Abernathy
Vice President
The Institute for College Access &Success
www.ticas.org and www.projectonstudentdebt.org
TICAS: 510.318.7900 Direct: 510.318.7903
1
.2!!lIeron, David
From:
Sent:
To:
Subject:
Attachments:
Pauline Abernathy [pabernathy@ticas.org]
Friday, August 13,201010:05 AM
Bergeron, David
Are Default Rates Determined Solely By Student Demographics?
Default Fact Sheet_June2010.doc
FYI. Attached is the one pager I mentioned. Doesn't tell you anything you don't already know-it just
puts it on one page with citations. Pauline
«Default Fact SheeCJune201 a.doc»
Pauline Abernathy
Vice President
The Institute for College Access &Success
www.ticas.org andwww.projectonstudentdebt.org
TICAS: 510.318.7900 Direct: 510.318.7903
1
!!!lJeron, David
From:
Sent:
To:
Cc:
Subject:
Attachments:
Pauline Abernathy [pabemathy@ticas.org]
Wednesday, April 14, 2010 10:56 AM
Kanter, Martha; Madzelan, Dan; Gomez, Gabriella; Arsenault, Leigh; Manheimer, Ann;
Shireman, Bob; Dannenberg, Michael; Bergeron, David; Rogers, Margot; Kvaal, James R.;
Plotkin, Hal
. Lehr, Susan M.; Debbie FrankIe Cochrane; Lauren Asher; Connie Myers
Florida College Presidents Itr in support of Gainful Employment proposal
FL COP Letter to Secretary Duncan re GE.pdf, FL Career Ed OPPAGA Highlights Rpt 10-18
FINAL.docx

Attached is a strong letter from the 28 Florida community and state college presidents urging the
Secretary to move forward with a strong gainful employment definition. The letter was mailed on
Monday and copies are being sent to the FL delegation as well.
For those who may not have seen it before, I have also attached the excellent two-page summary by
Susan Lehr at Florida State College of the recent report by the Florida legislature's policy office
comparing Florida public and for-profit college costs and student outcomes. The report focuses on
five programs and among its conclusions are that the public programs cost both students and
taxpayers less than for-profits, are much more likely to be accredited, and their students have higher
pass rates on licensure and certification tests.
«FL COP Letter to Secretary Duncan re GE.pdf» «FL Career Ed OPPAGA Highlights Rpt 10-18 FINAL.docx»
Pauline Abernathy
Vice President
The Institute for College Access & Success
www.ticas.org and www.projectonstudentdebt.org
We moved! TICAS' main number is now 510.318.7900. My direct line is 510.318.7903.
1

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