From: Miller, Tony </O=USDOED/OU=USDOED/CN=RECIPIENTS/CN=TONY.

MILLER>
. - ~
To: Mi.l.ler, Tony "
Shireman, Bob
Yuan, Georgia
McFadden, Elizabeth
KvaaL James
Date: 6/24/2010 11:50:36 AM
Subject: OMB Call on Gainful Employment
When: Friday, June 25, 201012:30 PM-1:00 PM (GMT-05:00) Eastern Time (US & Canada).
Where: Tony's Office -or- Dial: 866-731-1731, code: 9028762#
Note: The GMT offset above does not reflect daylight saving time adjustments.
I
From: Miller, Tony <IO=USDOED/OU=USDOED/CN=RECIPlENTS/CN=TONYMILLER>
To: Miller, Tony
Yuan, Georgia
Shireman, Bob
Bergeron, David
Madzelan, Dan
McFadden, Elizabeth
Date: 5/1 1120104:49:04 PM
Subject: OMB/ED GE Conference Call
When: Monday, May 17,20103:00 PM-4:00 PM (GMT-05:00) Eastern Time (US & Canada).
Where: Gather in Tony's Office
Note: The GMT offset above does not reflect daylight saving time adjustments.
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,
From: Miller, Tony </O=USDOED/OU=USDOED/CN=RECIPIENTS/CN=TONY.MILLER>
To: Miller, Tony
Yuan, GeQrgia
Shireman. Bob
Madzelan, Dan
Bergeron, Dayid
McFadden, Elizabeth
Date: 5/11/2010 9:12:06 AM
Subject: Prep for OMB Call
When: Tuesday, May 11,2010 10:45 AM-II :00 AM (GMT-05:00) Eastern Time (US & Canada).
Where: Tony's Office -or- Dial: 866-731-1731, code: 9028762#
Note: The GMT offset above does not reflect daylight saving time adjustments.
From: Miller, Tony </O=USDOED/OU=USDOED/CN=RECIPIENTS/CN=TONY.MILLER>
To: Miller, Tony
Shireman, Bob
Date: 5/17/2010 3:24:08 PM
Subject: GE Update: Bob & Tony
When: Occurs every Friday effective 6/4/2010 from 12:30 PM to 1:00 PM (GMT-05:00) Eastern Time (US &
Canada).
Where: Tony's Office
Note: The GMT offset above does not reflect daylight saving time adjustments.
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From: Miller, Tony
To: Miller, Tony
Shireman, Bob
cc.
Date: 5/17/20103:24:08 PM
Subject: GE Update: Bob & Tony
When: Occurs every Friday effective 6/4/2010 from 12:30 PM to 1:00 PM (GMT-05:00) Eastern Time (US &
Canada).
Where: Tony's Office
Note: The GMT offset above does not reflect daylight saving time adjustments.
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From: Miller, Tony </O=USDOED/OU=USDOED/CN=RECIPIENTS/CN=TONY.MILLER>
To: Milter, Tony
Shireman, Bob
cc:
Date: 5/17/2010 3:24:08 PM
Subject: GE Update: Bob & Tony
When: Occurs every Friday effective 6/4/2010 from 12:30 PM to 1:00 PM (GMT-05:00) Eastern Time (US &
Canada).
Where: Tony's Office
Note: The GMT offset above does not reflect daylight saving time adjustments.
From: Miller, Tony </O-USDOED/OU=USDOED/CN=RECIPIENTS/CN=TONY.MILLER>
To: Miller, TQny
Kanter, Martha
Shireman, Bob
Kvaal, James
Yuan, Georgi!!
Date: 6/2412010 8:43:18 AM
Subject: GE Meeting
(b )(S)
-----Original Message-----
From: Yuan, Georgia
Sent: Thursday, June 24, 2010 7:39 AM
To: Miller, Tony; Kanter, Martha; Shireman, Bob; Kvaal, James; Ferguson, Keith
Subject: Re: Info Request
(b)(S)
----- Original Message -----
From: Miller, Tony
To: Kanter, Martha; Shireman, Bob; Kvaal, James; Yuan, Georgia; Ferguson, Keith
Sent: Thu Jun 2406:32:012010
Subject: Re: Info Request
j(b)(S)
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Sent using BlackBerry
----- Original Message -----
From: Kanter, Martha
To: Miller, Tony; Shireman, Bob; Kvaal, James; Yuan, Georgia; Ferguson, Keith
Sent: Wed Jun 2322:20:152010
Subject: RE: Info Request
(b)(5)
ivrartna
From: Miller, Tony
Sent: Wednesday, June 23, 201010:08 PM
To: Shireman, Bob; Kvaal, James
Cc: Kanter, Martha
Subject: Info Request
(b)( 5)
From: Miller, Tony </O=USDOED/OU=USDOED/CN=RECIPIENTS/CN=TONY.MILLER>
To: Miller, Tony
Shireman, Bob
Date: 5/19/2010 8:08:38 AM
Subject: GE & Talent Search
When: Wednesday, May 19,20101:00 PM-l:30 PM (GMT-05:00) Eastern Time (US & Canada).
Where: Tony's Office
Note: The GMT offset above does not reflect daylight saving time adjustments.
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From: Miller, Tony </O=USDOED/OU=USDOED/CN=RECIPIENTS/CN=TONY.MILLER>
To: S£hmjdt, Greg
RQQinson-Kimble. Stephanie
Date: 5/3/2010 9:17:22 PM
Subject: ?FW: GE Data Working Group
When: Tuesday, May 04, 2010 8:30 AM-IO:OO AM (GMT-05:00) Eastern Time (US & Canada).
Where: Tony's Office
Note: The GMT offset above does not reflect daylight saving time adjustments.
(b)( 5)
-----Original Appointment-----
From: Fine, Stephanie
Sent: Monday, May 03, 2010 12:46 PM
To: Miller, Tony; Shireman, Bob; Bergeron, David; Madzelan, Dan; Finley, Steve; Dannenberg, Michael; Yuan,
Georgia; Weko, Tom; Miller, Elise; Graham, William; Fine, Stephanie
. Subject: GE Data Working Group
When: Tuesday, May 04, 2010 8:30 AM-IO:00 AM (GMT-05:00) Eastern Time (US & Canada).
Where: Tony's Office
When: Tuesday, May 04, 20108:30 AM-IO:00 AM (GMT-05:00) Eastern Time (US & Canada).
Where: Tony's Office
Note: The GMT offset above does not reflect daylight saving time adjustments.
Pollack,Joshua
From:
Sent:
To:
SUbject:
(b)( 5)
Miller, Tony
Thursday, June 24,20107:32 AM
Kanter, Martha; Shireman, Bob; Kvaai, James; Yuan, Georgia; Ferguson, Keith
Re: Info Request
----- Original Message -----
From: Kanter, Martha
To: Miller, Tony; Shireman, Bob; Kvaal, James; Yuan, Georgia; Ferguson, Keith
Sent: Wed Jun 2322:20:152010
Subject: RE: Info Request
(b)( 5)
From: Miller, Tony
Sent: Wednesday, June 23, 2010 10:08 PM
To: Shireman, Bob; Kvaal, James
Cc: Kanter, Martha
Subject: Info Request
(b)( 5)
1
,
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(b)(5)
Pollack,Joshua
Subject:
Location:
Start:
End:
Show Time As:
Recurrence:
Meeting Status:
Organizer:
Required Attendees:
GE Meeting
Martha's Office
Thu 6/24/2010 5:30 PM
Thu 6/24/2010 6:00 PM
Tentative
(none)
Not yet responded
Miller, Tony
Kanter, Martha; Shireman, Bob; Kvaal, James; Yuan, Georgia
I
-----Original Message-----
From: Yuan, Georgia
Sent: Thursday, June 24, 2010 7:39 AM
To: Miller, Tony; Kanter, Martha; Shireman, Bob; Kvaal, James; Ferguson, Keith
Subject: Re: Info Request
(b)( 5)
----- Original Message -----
From: Miller, Tony
To: Kanter, Martha; Shireman, Bob; Kvaal, James; Yuan, Georgia; Ferguson, Keith
Sent: Thu Jun 2406:32:012010
Subject: Re: Info Request
(b)( 5)
1
----- Original Message -----
From: Kanter, Martha
To: Miller, Tony; Shireman, Bob; Kvaal, James; Yuan, Georgia; Ferguson, Keith
Sent: Wed Jun 23 22:20:15 2010
Subject: RE: Info Request
(b)( 5)
From: Miller, Tony
Sent: Wednesday, June 23, 2010 10:08 PM
To: Shireman, Bob; Kvaal, James
Cc: Kanter, Martha
Subject: Info Request
(b)(5)
2
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(b)(5)
(b)( 5)
(b)( 5)
(b)(5)
(b)(5)
(b)( 5)

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,
(b)( 5)
(b)(5)
!
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Pollack,Joshua
From:
Sent:
To:
Subject:
(b)( 5)
Miller, Tony
Thursday, May 27, 2010 3:53 AM
Rogers, Margot
Re: ATTORNEY-CLIENT COMMUNICATION-PRIVILEGED AND CONFIDENTIAL-
----- Original Message -----
From: Rogers, Margot
To: Miller, Tony
Sent: Thu May 2702:46:162010
Subject: FW: ATTORNEY-CLIENT COMMUNICATION-PRNILEGED AND CONFIDENTIAL-
FYI
From: Bergeron, David
Sent: Wednesday, May 26, 20I 0 10:54 PM
To: Gomez, Gabriella; Yuan, Georgia; Jenkins, Harold; Siegel, Brian; Madzelan, Dan
Cc: Shireman, Bob; Rogers, Margot
Subject: RE: ATTORNEY-CLIENT COMMUNICATION-PRNILEGED AND CONFIDENTIAL-
(b)( 5)
From: Gomez, Gabriella
Sent: Wednesday, May 26,201010:00 PM
To: Yuan, Georgia; Jenkins, Harold; Siegel, Brian; Madzelan, Dan; Bergeron, David
Cc: Shireman, Bob; Rogers, Margot
Subject: Re: ATTORNEY-CLIENT COMMUNICATION-PRIVILEGED AND CONFIDENTIAL-
(b)( 5)
1
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----- Original Message -----
From: Yuan, Georgia
To: Jenkins, Harold; Siegel, Brian; Madzelan, Dan; Bergeron, David
Cc: Shireman, Bob; Rogers, Margot; Gomez, Gabriella
Sent: Wed May 2620:58:162010
Subject: Fw: ATTORNEY-CLIENT COMMUNICATION-PRNILEGED AND CONFIDENTIAL-
(b)(5)
----- Original Message -----
From: Rose, Charlie
To: Gomez, Gabriella; Rogers, Margot; Martin, Carmel; Miller, Tony; Kanter, Martha; Cunningham, Peter; Shireman,
Bob; Yuan, Georgia; Rosenfelt, Phil; Miceli, Julie
Sent: Wed May 26 20:52:16 2010
Subject: Re: ATTORNEY-CLIENT COMMUNICATION-PRNILEGED AND CONFIDENTIAL -
(b)(5)
----- Original Message -----
From: Gomez, Gabriella
To: Rogers, Margot; Martin, Carmel; Miller, Tony; Kanter, Martha; Rose, Charlie; Cunningham, Peter; Shireman, Bob;
Yuan, Georgia
Sent: Wed May 26 20:31:44 2010
Subject: RE: ATTORNEY-CLIENT COMMUNICATION-PRNILEGED AND CONFIDENTIAL-
(b)( 5)
-----Original Mcssagc-v->-
From: Rogers, Margot
Sent: Wednesday, May 26,20109:26 PM
To: Gomez, Gabriella; Martin, Carmel; Miller, Tony; Kanter, Martha; Rose, Charlie; Cunningham, Peter; Shireman, Bob;
Yuan, Georgia
Subject: ATTORNEY-CLIENT COMMUNICATION-PRIVILEGED AND CONFIDENTIAL-
2
(b)( 5)
From: Gomez, Gabriella
Sent: Wednesday, May 26, 2010 9:00 PM
To: Martin, Carmel; Rogers, Margot; Miller, Tony; Kanter, Martha; Rose, Charlie; Cunningham, Peter
Subject: URGENT - Request from Obey Staff, Black Caucus Issue
(b)(5)
3
IS
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(b)(5)
4

Pollack,Joshua
From:
Sent:
To:
Cc:
Subject:
(b)(5)
Miller, Tony
Wednesday, May 12,20109:31 AM
Kanter, Martha; Shireman, Bob; Shelton, Jim; Melendez, Thelma; Martin, Carmel; Posny,
Alexa
Snyder, Jason
RE: ED List of Documents for OMB Review 05-07-10
- - - - -
From: Miller, Tony
Sent: Tuesday, May 11, 2010 6:57 PM
To: Kanter, Martha; Shireman, Bob; Shelton, Jim; Melendez, Thelma; Martin, carmel; Posny, Alexa
Subject: ED_List_oCDocuments_for_OMB_Review_05-07-1O
(b)(5)
1
Pollack, Joshua
From:
Sent:
To:
Cc:
Subject:
Attachments:
(b)( 5)
Snyder, Jason
Friday, May 07, 2010 10:31 AM
Kanter, Martha
Shireman, Bob; Dann-Messier, Brenda; Madzelan, Dan; Ferguson, Keith; Ceja, Alejandra;
Cichowski, Carol; Dannenberg, Michael; Bergeron, David; Wurtzel, Judy
RE: New Draft Spending Plan Priority
Spending Plan Priorities.5-7-10.clean.docx

-----Origina1 Message-----
From: Kanter, Martha
Sent: Friday, May 07, 2010 12:08 AM
To: Snyder, Jason
Cc: Shireman, Bob; Darm-Messier, Brenda; Madze1an, Dan; Ferguson, Keith; Ceja, Alejandra
Subject: FW: New Draft Spending Plan Priority
(b)( 5)
From: Manheimer, Ann
Sent: Wednesday, May 05, 2010 9:44 PM
To: Snyder, Jason
1
Suhject: RE: New Draft Spending Plan Priority
(b)(5)
From: Snyder, Jason
Sent: Monday, May 03,2010 1:10 PM
To: Dann-Messier, Brenda; Kanter, Martha
Cc: Wurtzel, Judy; Cichowski, Carol; Manheimer, Ann
Subject: New Draft Spending Plan Priority
(b)( 5)
2
(b)( 5)
Draft 5-7-10
(b)( 5)
(b)( 5)
(b)( 5)
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(b)( 5)
r
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Pollack,Joshua
From:
Sent:
To:
Subject:
Attachments:
Fyi
~ ~ - _ . _ - - - - - - - - - - - - - - - - - - - -
Sent using BlackBerry
Miller, Tony
Monday, May 03, 2010 9:27 PM
Rogers. Margot
Fw: Gainful Employment - Key Questions & Analyses
Gainful Employment - Key Questions & Analyses.docx
(b)( 5)
From: Miller, Tony
To: Madzelan, Dan; Bergeron, David; Yuan, Georgia; Finley, Steve; Dannenberg, Michael; Weko, Tom; Miller, Elise;
Graham, William
Cc: Shireman, Bob; Kant er, Martha; Marti n, Carmel; Rose, Charlie
Sent: Mon May 03 20:21:37 2010
Subject: Gainful Employment - Key Questions & Analyses
1
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(b)(5)
1
(b)( 5)
(b)( 5)
(b)( 5)
Pollack, Joshua
From:
Sent:
To:
Cc:
Subject:
Kolotos, John
Tuesday, May 18, 20104:24 PM
Miller, Tony; Sellers, Fred; Shireman, Bob
Bergeron, David; Fine, Stephanie; Arsenault, Leigh; Manheimer, Ann; Madzelan, Dan
RE: Tony and Bobs comments on GE
Tony, see below. Thanks. john
From: Miller, Tony
Sent: Tuesday, May 18, 2010 3:55 PM
To: Sellers, Fred; Shireman, Bob
Cc: Bergeron, David; Fine, Stephanie; Arsenault, Leigh; Manheimer, Ann; Kolotos, John; Madzelan, Dan
Subject: RE: Tony and Bobs comments on GE
(b)(5)
-----Driginal Message-----
From: Sellers, Fred
Sent: Tuesday, May 18, 2010 2:38 PM
To: Miller, Tony; Shireman, Bob
Cc: Bergeron, David; Fine, Stephanie; Arsenault, Leigh; Manheimer, Ann; Kolotos, John;
Madzelan, Dan
Subject: FW: Tony and Bobs comments on GE
(b)( 5)
Thanks.
Fred Sellers, OPE
202 502-7502
-----Driginal Message-----
From: Kolotos, John
Sent: Tuesday, May 18, 2010 12:57 PM
To: Sellers, Fred; McCullough, Carney; Guthrie, Marty; Bergeron, David
Subject: Tony and Bobs comments on GE
To move the discussion along, here are Bob's and Tony's comments and some responses.
(b)( 5)
1
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(b)(5)
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Pollack,Joshua
From:
Sent:
To:
Cc:
Subject:
(b)(5)
Thanks.
Fred Sellers, OPE
202 502-7502
Sellers, Fred
Tuesday, May 18, 2010 2:38 PM
Miller, Tony; Shireman, Bob
Bergeron, David; Fine, Stephanie; Arsenault, Leigh; Manheimer, Ann; Kolotos, John;
Madzelan, Dan
FW: Tony and Bobs comments on GE
-----Original Message-----
From: Kolotos, John
Sent: Tuesday, May 18, 201012:57 PM
To: Sellers, Fred; McCullough, Carney; Guthrie, Marty; Bergeron, David
Subject: Tony and Bobs conunents on GE
To move the discussion along, here are Bob's and Tony's conunents and some responses.
Bobs conunents:
(b)( 5)
Tony's conunents:
1
(b)( 5)
2
i .
Pollack, Joshua
From:
Sent:
To:
Subject:
Done.
Rogers, Margot
Monday, May 24, 2010 8:43 AM
Miller, Tony
RE: Guaranty Agency FINAL Letter
-----Original Message-----
From: Miller, Tony
Sent: Sunday, May 23, 2010 11:11 PM
To: Rogers, Margot
Subject: Fw: Guaranty Agency FINAL Letter
Nonresponsive
----- Original Message -----
From: Kanter, Martha
To: Rogers, Margot
Cc: Miller, Tony; Martin, Cannel; Cunningham, Peter; Rose, Charlie; Shireman, Bob
Sent: Sun May 2319:35:532010
Subject: FW: Guaranty Agency FINAL Letter
Nonresponsive
Martha
From: Shireman, Bob
Sent: Sunday, May 23,2010 8:33 PM
To: Kanter, Martha
Cc: Gomez, Gabriella
Subject: FW: Guaranty Agency FINAL Letter
(b){5),Nonresponsive
-Bob
Robert Shireman
Deputy Undersecretary
U.S. Department of Education
1
I
(202) 260-0101
From: Moran, Pamela
Sent: Friday, May 21,2010 5:20 PM
To: David, Fanta; Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred;
Bergeron, David; Madzelan, Dan; Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan;
Siegel, Brian
Cc: Turner, Katrina
Subject: RE: Guaranty Agency FINAL Letter
Nonresponsive
-----Original Message-----
From: David, Fanta
Sent: Friday, May 21,2010 5:01 PM
To: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Bergeron, David;
Madzelan, Dan; Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan; Siegel, Brian
Cc: Turner, Katrina; Moran, Pamela; David, Fanta
Subject: Guaranty Agency FINAL Letter
All,
Nonresponsive
Fanta David
(202) 377-4668
-----Original Message-----
From: David, Fanta
Sent: Friday, May 21,2010 10:11 AM
To: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Bergeron, David;
Madzelan, Dan; Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Cc: Turner, Katrina
Subject: FW: PGA Letter 2
Importance: High
All,
Nonresponsive
Thank you.
2
Fanta on behalf of Katrina Turner
Fanta David
(202) 377-4668
-----Original Message-----
From: Turner, Katrina
Sent: Thursday, May 20,2010 4:27 PM
To: David, Fanta
Subject: FW: PGA Letter 2
Importance: High
Nonresponsive
Thanks
-----Original Message-----
From: Bergeron, David
Sent: Thursday, May 20, 20I°II :59 AM
To: Siegel, Brian; Duporte, Franklyn; Graham, William; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan; Baker, Jeff; Szabo,
Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: RE: PGA Letter 2
Importance: High
Nonresponsive
David
-----Original Message-----
From: Siegel, Brian
Sent: Thursday, May 20, 2010 II :46 AM
To: Bergeron, David; Duporte, Franklyn; Graham, William; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan; Baker, Jeff; Szabo,
Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: RE: PGA Letter 2
romespons;ve
3
Nonresponsive
Brian
-----Original Message-----
From: Bergeron, David
Sent: Thursday, May 20,2010 II :23 AM
To: Duporte, Franklyn; Graham, William; Siegel, Brian; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan; Baker, Jeff; Szabo,
Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: RE: PGA Letter 2
Importance: High
Nonresponsive
David
-----Original Message-----
From: Duporte, Franklyn
Sent: Thursday, May 20, 2010 II :00 AM
To: Bergeron, David; Graham, William; Siegel, Brian; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan; Baker, Jeff; Szabo,
Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: Re: PGA Letter 2
Nonresponsive
----- Original Message -----
From: Bergeron, David
To: Graham, William; Siegel, Brian; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan;
Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Sent: Thu May 2009:54:512010
Subject: RE: PGA Letter 2
Nonresponsive
i
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-----Original Message-----
From: Graham, William
Sent: Thursday, May 20, 2010 9:40 AM
To: Siegel, Brian; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Bergeron, David;
Madzelan, Dan; Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: RE: PGA Letter 2
Nonresponsive
-----Original Message-----
From: Siegel, Brian
Sent: Wednesday, May 19, 2010 7:11 PM
To: Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Bergeron, David;
Madzelan, Dan; Baker, Jeff; Szabo, Susan; Graham, William; Shireman, Bob; Martin, Phil
Subject: RE: PGA Letter 2
Nonresponsive
From: Turner, Katrina
Sent: Wednesday, May 19, 2010 4:22 PM
To: Taggart, Bill; Siegel, Brian; Bergeron, David; Madzelan, Dan; Baker, Jeff; Szabo, Susan; Duporte, Franklyn; Graham,
William; Yuan, Georgia; Shireman, Bob; Martin, Phil
Cc: Runcie, James; Turner, Katrina
Subject: FW: PGA Letter 2
All,
Nonresponsive
5

: . -
Pollack, Joshua
From:
Sent:
To:
SUbject:
Nonresponsive
Rogers, Margot
Monday, May 24, 20106:47 AM
Miller, Tony
Re: Guaranty Agency FINAL Letter
i
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----- Original Message -----
From: Miller, Tony
To: Rogers, Margot
Sent: Sun May 2322:10:472010
Subject: Fw: Guaranty Agency FINAL Letter
Nonresponsive
----- Original Message -----
From: Kanter, Martha
To: Rogers, Margot
Cc: Miller, Tony; Martin, Carmel; Cunningham, Peter; Rose, Charlie; Shireman, Bob
Sent: SunMay2319:35:532010
Subject: FW: Guaranty Agency FINAL Letter
Nonresponsive
From: Shireman, Bob
Sent: Sunday, May 23,2010 8:33 PM
To: Kanter, Martha
Cc: Gomez, Gabriella
Subject: FW: Guaranty Agency FINAL Letter
Martha:
Nonresponsive
Robert Shireman
Deputy Undersecretary
U.S. Department of Education
1
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I
I
i
(202) 260-01 01
From: Moran, Pamela
Sent: Friday, May 21, 2010 5:20 PM
To: David, Fanta; Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred;
Bergeron, David; Madzelan, Dan; Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan;
Siegel, Brian
Cc: Turner, Katrina
Subject: RE: Guaranty Agency FINAL Letter
Nonresponsive
From: David, Fanta
Sent: Friday, May 21,2010 5:01 PM
To: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Bergeron, David;
Madzelan, Dan; Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan; Siegel, Brian
Cc: Turner, Katrina; Moran, Pamela; David, Fanta
Subj ect: Guaranty Agency FINAL Letter
All,
Nonresponsive
Fanta on behalf of Katrina.
Fanta David
(202) 377-4668
-----Original Message-----
From: David, Fanta
Sent: Friday, May 21,2010 10:11 AM
To: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Bergeron, David;
Madzelan, Dan; Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Cc: Turner, Katrina
Subject: FW: PGA Letter 2
Importance: High
All,
Nonresponsive
Thank you.
2
Fanta on behalf of Katrina Turner
Fanta David
(202) 377-4668
-----Original Message-----
From: Turner, Katrina
Sent: Thursday, May 20, 2010 4:27 PM
To: David, Fanta
Subject: FW: PGA Letter 2
Importance: High
Nonresponsive
Thanks
-----Original Message-----
From: Bergeron, David
Sent: Thursday, May 20, 20 I0 II :59 AM
To: Siegel, Brian; Duporte, Franklyn; Graham, William; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan; Baker, Jeff; Szabo,
Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: RE: PGA Letter 2
Importance: High
Nonresponsive
David
-----Original Message-----
From: Siegel, Brian
Sent: Thursday, May 20, 2010 11:46 AM
To: Bergeron, David; Duporte, Franklyn; Graham, William; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan; Baker, Jeff; Szabo,
Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: RE: PGA Letter 2
Nonresponsive
3
Nonresponsive
Brian
-----Original Message-----
From: Bergeron, David
Sent: Thursday, May 20, 2010 II :23 AM
To: Duporte, Franklyn; Graham, William; Siegel, Brian; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan; Baker, Jeff; Szabo,
Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: RE: PGA Letter 2
Importance: High
Nonresponsive
-----Original Message-----
From: Duporte, Franklyn
Sent: Thursday, May 20, 2010 11 :00 AM
To: Bergeron, David; Graham, William; Siegel, Brian; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan; Baker, Jeff; Szabo,
Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: Re: PGA Letter 2
INonresponsive
----- Original Message -----
From: Bergeron, David
To: Graham, William; Siegel, Brian; Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Madzelan, Dan;
Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Sent: Thu May 20 09:54:512010
Subject: RE: PGA Letter 2
Nonresponsive
4
-----Original Message-----
From: Graham, William
Sent: Thursday, May 20, 2010 9:40 AM
To: Siegel, Brian; Turner, Katrina
Cc: Taggart, Bill; Runde, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Bergeron, David;
Madzelan, Dan; Baker, Jeff; Szabo, Susan; Shireman, Bob; Martin, Phil; Skelly, Thomas; Ferrier, Evan
Subject: RE: PGA Letter 2
Nonresponsive
-----Original Message-----
From: Siegel, Brian
Sent: Wednesday, May 19, 2010 7:11 PM
To: Turner, Katrina
Cc: Taggart, Bill; Runcie, James; Yuan, Georgia; Duporte, Franklyn; Jenkins, Harold; Marinucci, Fred; Bergeron, David;
Madzelan, Dan; Baker, Jeff; Szabo, Susan; Graham, William; Shireman, Bob; Martin, Phil
Subject: RE: PGA Letter 2
Nonresponsi ve
Brian Siegel
From: Turner, Katrina
Sent: Wednesday, May 19, 2010 4:22 PM
To: Taggart, Bill; Siegel, Brian; Bergeron, David; Madzelan, Dan; Baker, Jeff; Szabo, Susan; Duporte, Franklyn; Graham,
William; Yuan, Georgia; Shireman, Bob; Martin, Phil
Cc: Runde, James; Turner, Katrina
Subject: FW: PGA Letter 2
All,
Nonresponsive
5
Pollack, Joshua
From:
Sent:
To:
Cc:
Subject:
Mitchelson, Mary
Thursday, May 13, 20109:19 PM
Miller, Tony
Tighe, Kathleen S.; Clark, Teresa; Fine, Stephanie; Shireman, Bob
RE: Information on GIG audits of proprietary schools
Good, glad it's helpful. Mary
From: Miller, Tony
Sent: Thursday, May 13, 2010 6:16 PM
To: Mitchelson, Mary
Cc: Tighe, Kathleen S.; Clark, Teresa; Fine, Stephanie; Shireman, Bob
Subject: RE: Information on OIG audits of proprietary schools
Mary,
(b)( 5)
Thanks,
Tony
From: Mitchelson, Mary
Sent: Thursday, May 13, 201010:55 AM
To: Miller, Tony
Cc: Tighe, Kathleen S.; Clark, Teresa; Fine, Stephanie
Subject: Information on OIG audits of proprietary schools
Tony,
(b)( 5)
1
I
(b)( 5)
2

This message, including any attachment, is for the use of the intended recipient; it may contain information that is
privileged, confidential and exempt from disclosure under applicable law. Intended recipients should take appropriate
steps to protect the confidential nature ofthis communication. If you are not an intended recipient, please notify the sender
and delete/destroy this message.
3
!
!
!
,
Pollack, Joshua
From:
Sent:
To:
SUbject:
Miller, Tony
Friday, May 21,20103:35 PM
Fine, Stephanie
FW: Important Correspondence Summary for May 21, 2010
From: Monroe, Tanya
Sent: Friday, May 21,20102:34:53 PM
To: Anderson, Jo; Ceja, Alejandra; Cunningham, Peter; Gomez, Gabriella;
Kanter, Martha: Martin, Carmel: Miller, Tony; Rogers, Margot;
Rose, Charlie; Snyder, Jason; Tada, Wendy; Whalen, Ann; Yale, Matt
Subject: Important Correspondence Summary for May 21, 2010
Auto forwarded by a Rule
May 21,2010
MEMORANDUM FOR THE SECRETARY
CHIEF OF STAFF
FROM; Teresa A. Garland, Director (DLW for)
Office of Executive Secretariat
SUBJECT: Important Correspondence Summary
Congressman Shares Ideas about "Gainful Employment"
Congressman Ron Klein writes regarding the Department's proposed definition of "gainful employment in a
recognized occupation." He has several specific proposals he believes may help the Department weed out the
"bad actors" in the higher education system, while allowing the good quality educational institutions to continue
to thrive. To OPE for the signature of the Secretary. Copies to Tony Miller, Martha Kanter, Margot Rogers,
Matt Yale, Ann Whalen, FSA, OS/RMS, OCFO, OCO, OGC, OLCA, OPEPD, and OPEPDlBudget Service.
Klein.pdf
fumport for Regulations on Gainful Employment and Incentive Compensation
Lauren Asher, President, The Institute for College Access & Success, writes on behalf of 33 organizations to
express support for regulations on gainful employment and incentive compensation. They support regulations
that will protect students and taxpayers from the deceptive practices of programs with little or no value. They
stand ready to be of assistance. To OPE for appropriate handling. Copies to Tony Miller, Martha Kanter,
Margot Rogers, Matt Yale, Ann Whalen, FSA, OS/RMS, OCFO, OCO, OGC, OLCA, OPEPD, and
OPDPD/Budget Service.
1
Asher.pdf
GAO Final Report on HUD's Emergency Shelter Grants Program
GAO transmits the final report, "Homelessness: Information on Administrative Costs for HUD's Emergency
Shelter Grants Program." The report does not have any recommendations. To OESE for information. Copies
to Tony Miller, Martha Kanter, Margot Rogers, Matt Yale, Ann Whalen, FSA, OS/RMS, OCFO, OCO, ODS,
OGC, OIG, OLCA, OPEPD, OPEPDlBudget Service, and OPEPDIPPSS.
Final Report.pdf
Attached is an image file should you wish to see the whole document. To do so, click 011 the icon for the document, and it should open in your PC's image viewer.
2
Mayes. Ed9.:::ar:.... _
From:
Sent:
To:
Subject:
Dear Ms., Asher:
Mayes, Edgar on behalf of Duncan, Arne
Thursday, May 20, 2010 1:46 PM
'lauren Asher'
RE: letter from broad coalition seeking strong regulation of career education programs
1bank you for your e-mail to Secretary of Education Arne Duncan. We appreciate hearing from you.
Your message has been forwarded to the appropriate staff member for review.
Thank you again for contacting us.
Sincerely,
Edgar Mayes
Director of Correspondence and
Communications Control Unit
Office of the Secretary
U,S. Department of Education
Washington, DC 20202
From: Lauren Asher [mailto:LASher@tlcas.org]
sent: Thursday, May 20, 2010 1:07 PM
To: Duncan, Arne
ee: Kanter, Martha; Plotkin, Hal; Gomez, Gabriella; Shireman, Bob; Madzelan, Dan; Arsenault, Leigh; Manheimer, Ann;
Hamilton, Justin; Paullne_abernathy@tlcas.org
Subject: Letter from broad coalition seeking strong regulation of career education programs
Dear Secretary Duncan,
Please find attached a letter from a diverse coalition of more than 30 student, college, consumer and civil rights
organizations seeking strong and effective regulation of career education programs. Those signing the letter
represent manypublic institutions that are subject to the gainful employment and incentive compensation rules,
as well as advocates for college access for African-American, Hispanic and low-income students.
Thank you for your initiative in reviewing the Department's current program integrity regulations to ensure
their consistency with federal lawand to protect both students and taxpayers. We support your efforts and stand
ready to assist you in improving the Department's regulations. Please feel free to contact me or any of the staff
listed belowshould you or your staff have any questions about this letter or the issues it addresses.

-
-
-
-
Institute for College Access & Success: Pauline Abernathy (pabemathy@ticas.org) or Debbie Cochrane
(dcochrane@ticas.org),510-318-7900
Florida State College at Jacksonville: Susan Lehr (slehr@fscj.edu)or Jim Simpson (jsimpson@fscj.edu),
904-632-3391
National Association fur College Admission Counseling: David Hawkins (dhawkins@nacacnet.org) or
Amanda Modar (amodar@nacacnet.org), 703/836·2222
National Consumer Law Center: Deanne Loonin (dloonin@nclc.org), (617) 542-8010
I
- Public Advocates: Jamienne Studley Gstudley@publicadvocates.org), (415) 431-7430
- United States Students Association: Angela Peoples (leg@usstudents.org1.J202) 640-6570
- U.S. PIRG: Chris Lindstrom (chris.lindstrom@pirg.org),617)747-4330
Sincerely,
Lauren Asher
President, Institute for College Access & Success
-------- ---
(PI9BSe note our newphone number and address!)
Lauren Asher
President
The Institute for College Access & Success
405 14th 51., 11 th Floor
Oakland, CA 94612
(510) 318-7900, x304
nasher@ticas,org
www.licas.org

www.colle!)e-insight.org
2
May 20, 2010
The Honorable Arne Duncan
Secretary of Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington. DC 20202
Dear Secretary Duncan:
As organizations representing students. higher education, consumers and civil rights, we
write to express our support for the Department of Education's efforts to make its
regulations more consistent with the program integrity provisions in Title IV of the Higher
Education Act. In particular, we urge you to propose regulations on incentive
compensation and gainful employment that will more effectively protect students from
high-pressure and deceptive sales tactics for educational programs oflittle or no benefit to
them. and will ensure that taxpayer dollars do not subsidize such practices and programs.
To protect both students and taxpayers. federal law prohibits "any commission, bonus, or
other incentive payment based directly or indirectly on success in securing enrollments or
financial aid," and requires vocational programs and nearly all programs at for-profit
institutions to "prepare students for gainful employment in a recognized occupation." Yet,
examples of overly aggressive recruiting are plentiful. Some for-profit institutions recently
made headlines by targeting homeless shelters in their recruitment efforts. i Another for-
profit institution paid $78.5 million to settle a whistleblower False Claim Act lawsuit" and
another $9.8 million to the Department of Education to resolve claims that it was paying
improper incentive compensation to its recruiters. m Yet another large for-profit institution
paid $6.5 million to settle a lawsuit brought by the California Attorney General charging "a
persistent pattern of unlawful conduct." including the inflation ofjob placement and
starting salary information in order to recruit students to enroll in costly vocational
programs, and falsification of records provided to the government,"
While most schools may not engage in such practices, federal data suggest these are not
isolated incidents. Students at for-profit schools are the most likely to borrow and borrow
the most. According to the most recent federal data, one in five for-profit school students
defaults on their federal loans. A full 44% of all defaulters attended for-profit institutions,
even though just 7% ofall students attend for-profit schools. v Low-income, first-
generation and minority students attend for-profit institutions at disproportionate rates,
making them particularly vulnerable to illegal or unscrupulous acts by these schools."
Incentive Compensation. In direct conflict with federal law prohibiting institutions of
higher education from providing "any commission. bonus, or other incentive payment
based directly or indirectly OD success in securing enrollments or financial aid." current
regulations permit incentive payments that are not "based solely" on the number of
students recruited, admitted, enrolled or awarded financial aid. Some schools have
aggressively exploited this and other loopholes in the current regulations to do just what
the statute is intended to prohibit. Consistent with the Department's proposals during the
negotiated rulemaking process. the proposed new regulations should conform to the law
.'
and prohibit any employee or contractor compensation "based directly or indirectly" on
successfully securing student enrollments or aid. To avoid creating additional loopholes, it
is important that the prohibition include compensation based directly or indirectly on
applications or enrollment up to and including completion, as well as payments for
prospective student contact information.
Gainful Employment Each year, students borrow and taxpayers spend billions of dollars
to subsidize attendance at programs required to "prepare students for gainful employment
in a recognized occupation." Yet, the Department's current regulations include no official
definition of "gainful employment." We urge you to develop regulations that define
gainful employment in a way that is measurable, enforceable, not overly burdensome to
schools, and is aligned with the following principles:
• Include all debt incurred at any affiliated school. All debt incurred at a school
under the same control structure must be included in any measure of gainful
employment that considers debt. Otherwise, schools controlled by the same
company could simply move students from one school or program to
another. Excluding debt from unaffiliated schools also has the benefit ofallowing
low-cost schools to enroll and graduate students with high debt from unaffiliated
schools without fear of penalty.
• Include all private loans known to the school and its affiliates. Debt-related
measures of gainful employment must include all private loans that should be
known to the school. Excluding private loans would create a perverse incentive for
schools to promote risky private loans before students have exhausted their safer
federal loan options. Private loans that should be known to the school must include
all credit provided by any school under the same control structure as well as any
loans provided by lenders with which the school has a preferred lender
arrangement.
• Avoid loopholes for programs with hoth high student horrowing and low
completion rates. A low completion rate is one of the ways schools can fail to
prepare students for gainful employment. Students who borrow but do not
complete are often left carrying substantial debt without the increased earning
power that should come from a completed degree or certificate. The definition of
gainful employment should not create a loophole for schools to discourage
completion by students they consider likely to have trouble repaying their loans.
• Use only data that are accurate and consistent across colleges and programs.
Existing requirements for the calculation and reporting ofcompletion and
placement rates are not sufficient for use in any success-based measure ofgainful
employment. Accrediting agency requirements vary widely and allow for
substantial variation in the calculation of rates, and some schools have been found
to have falsified and manipulated their placement data. It is therefore essential that
the data and reporting standards are clear, consistent and independently verified.
Again, we applaud your initiative in reviewing the Department's current program integrity
regulations to ensure their consistency with federal law and to protect both students and
2
taxpayers. We support your efforts and stand ready to assist you in improving the
Department's regulations.
Sincerely,
American Association ofCollegiate Registrars and Admissions Officers
American Association of University Women
American Federation of Teachers
American Medical Student Association
California Community College Student Financial Aid Administrators Association
California Tomorrow
Campus Progress Action
Center for Law and Social Policy
Community College League of California
Consumer Action
Consumer Federation of California
Crittenton Women's Union
Demos: A Network for Ideas & Action
Empire Justice Center
Florida State College at Jacksonville
Greater Boston Interfai th Organization
The GreenIining Institute
The Institute for College Access & Success and its Project on Student Debt
NAACP
National Association for College Admission Counseling
National Association of Consumer Bankruptcy Attorneys
National Center for Public Policy and Higher Education
National Consumer Law Center (on behalf of its low-income clients)
National Consumers League
National Council of La Raw
Neighborhood Economic Development Advocacy Project (NEDAP)
New York Community College Association of Presidents
Public Advocates Inc.
Public Higher Education Network of Massachusetts
Rainbow PUSH Coalition
. Student Senate for California Community Colleges
U.S. PIRG
United States Student Association
i Golden, Daniel, "Homeless Dropouts From High School Lured by For-Profit Colleges," Bloomberg.com,
April 30, 2010. Available at http://www,w..oombere·COml312pstnews?I)Ld=newsarchjye&sjd-aA2 EI.YUaS..k
ii O'Reilly, Cary and Daniel Golden, "Apollo Settles University of Phoenix Recruiting Suit," Bloomberg.com,
December 14, 2009. Available at hnP'/lwwwhloowbm <jom!apps/pews?pid=2060l{!8Z&sid-aQ
'" Gilbertson, Dawn, "Student-recruitment tactics at University ofPhoenix blasted by feds," The Arizona
Republic, September 14,2004. Available at hup'f/www fm;entral
i, California Attorney General's office July 31,2007 press release on settlement with Corinthian Schools at
hthrUag Cft
v.TICAS press release available at !)ltp:l/1lrojectonS1uden«lebt.on:/rmb yiew.php?idx=537
Based On calculations by the Project on Student Debt on data from the 2008 National Postsecondary
Student Aid Study (NPSAS).
3
taxpayers. We support your efforts and stand ready to assist you in improving the
Department's regulations.
Sincerely,

American Association of Collegiate Registrars and Admissions Officers
American Association of University Women
American Federation of Teachers
American Medical Student Association
California Community College Student Financial Aid Administrators Association
California Tomorrow
Campus Progress Action
Center for Law and Social Policy
Community College League of California
Consumer Action
Consumer Federation of California
Crittenton Women's Union
Demos: A Network for Ideas & Action
Empire Justice Center
Florida State College at Jacksonville
Greater Boston Interfaith Organization
The Greenlining Institute
The Institute for College Access & Success and its Project on Student Debt
NAACP
National Association for College Admission Counseling
National Association of Consumer Bankruptcy Attorneys
National Center for Public Policy and Higher Education
National Consumer Law Center (on behalf of its low-income clients)
National Consumers League
National Council of La Raza
Neighborhood Economic Development Advocacy Project (NEDAP)
New York Community College Association of Presidents
Public Advocates Inc.
Public Higher Education Network of Massachusetts
Rainbow PUSH Coalition
Student Senate for California Community Colleges
U.S. PIRG
United States Student Association
1 Golden, Daniel, "Homeless Dropouts From High School Lured by For-Profit Colleges," Bloomberg.com,
April 30. 2010. Available at htu)'J(www bloomberg
u O'Reilly, Cary and Daniel Golden, "Apollo Settles University of Phoenix Recruiting Sun," Bloomoerg.com,
December 14, 2009. Available at bttp'Uwww,bloombeTg comlapps/news'i'pid=20601087Jtsid""atLTscSKjRBr&pos=5
til Gilbertson, Dawn, "Student-recruitment tactics at University ofPhoenix blasted by feds," The Arizona
Republic, Septe mber 14, 2004. Available al.http:Uwww.azcent rnl.comtspecialsispecia! 42/anicieslO914apolloJ4,html?&wired
IV California Attorney' General's office July 31, 2007 press release on settlement with Corinthian Schools a1
hmrllag
v.TICAS press release available at view php')idx=537
vt Based on calculations by the Project on Student Debt on data fromthe 2008 National Postsecondary
Studenl Aid Study (NPSAS).
3
RON KLEIN
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May 20, 2010
The Honorable Arne Duncan
Secretary
United States Department of Education
400 Maryland Avenue SW
Washington, DC
20202-0008
Dear Secretary Duncan,
COMMITTEE ON flNANClAL SERVICES
CI\P1TAL MAIU:'ETS. INSURANCE'. AND
GQVtllNMENl·SPOl>lSQRED ENttAPfll!lE5
Flf,jAN(;'IA,L II'\l:STITlJTlQN:S ofl,NO
CON:>lJMl:n CREDIT
DV£n,sI(i,H'T !>ND IN'V[STlQRTlONS
COMMITTEE ON fOREIGN AFFAIRS
MI801.e cAST ....ND SOLlTI1 ASIA, VICE CHAIA
"fIlIlAOAtSM. NQNPR{IUF€AATlQN, ANO TIIAQI
WtSTUlN HrUISPHI!IU!
STEERING ANa POLIcY COMMITTEE
I would like to thank you for taking the time to meet with me and other members of Congress this past
Tuesday to discuss the Department's proposal for defining "gainful employment in a recognized
occupation." As we discussed after the meeting, I have several spedfic proposals that I think may help
the Department weed out the "bad actors" in our higher education system (those schools with abysmal
graduation, job placement and default rates), while allOWing the good quality educational institutions to
continue to thrive.
I strongly believe that a robust disclosure policy, with real penalties for schools that fail to disclose
information or misrepresent themselves in any way, will help students make informed decisions on both
the quality of the program and the amount of debt they stand to incur. These are the components that I
believe should be a part of that disclosure policy.
Debt-to-Income ratio disclosure:
Schools would be required to disclose the estimated debt-to-income ratio each student stands to
incur based on data from either the 8ureau of Labor Statistic's 25
th
and 75'h percentile of wages for
careers the program prepares students to enter, or based on the actual wages of graduates of the
program when sufficient data Is available. These ratios would be calculated on 10, 15and 20 year
repayment plans so that students understand their repayment options and what each plan will cost
them in the long run.
Programmatic accreditation disclosure:
Schools would be required to disclose whether or not a program has programmatic accreditation if
the program is supposed to prepare students for acareer that requires professional licensure. This
piece Is critical because, as I'm sure you know, certain professions, such as psychologists, nurses,
engineers and more require graduation from an accredited program before that student can begin
practicing as a licensed professional.
.....lASl REPlY TO;
,
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1560651-7594
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1600 GUtES ROAD
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15611 M4-GS10
(9661113-1303
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313 Housl! OJ'RC'E
WMrHlNGTON. DC20515
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F,lox IZ021 225-8396
Standardlzed disclosure forms:
Schools are already required to disclose graduation and job placement rates, as well as types of
employment typically obtained by graduates. We would also require schools, as part of their
obligation to disclose debt-to-income ratios and programmatic accreditation to potential students,_
to include ali this information in one standardized disclosure form to be given to students prior to
enrollment. The school would have an obligation to interact with the student and convey the
importance of this information.
Consequences for schools that do not comply;
Schools regulated under this proposal that fail to disclose this information prior to enrollment, or
misrepresent this information in anyway would be subject to fines and/or risk temporarily or
indefiniteiy losing their Title IV eligibility.
,
Ifthe goal of defining "gainful employment" is to prevent students from being taken advantage of by
institutions that strap them with enormous levels of debt, while failing to prepare them for Jobs within
their fields of study, then increased disclosure could realistically meet that goal by encouraging students
and investors (in the case of for-profit institutions) to take their money to schools that offer more
quality products. Like any business, these institutions are only as good as the services they provide, so if
we make It abundantly clear that an institution fails to deliver to students within a particular program,
students will take their business elsewhere, and the school will have new incentives to improve.
Igreatly appreciate the time you have devoted to this issue and your consideration of my ideas. Irealize
this is a difficult clause to define, but an important one none the less to ensure students are protected
from the unfair practices of a few "bad actors" In our higher education system. Ilook forward to
working with you toward a successful resolution of this matter and encourage you to contact me with
any questions you may have.
regards,

Ron Klein
Member of Congress
Mayes, Ed9:.;;;,ar;... _
Good morning!!! it!!!!!!!!!!!1!
From:
Sent:
To:
SUbJect:
Attachments:
Toye, Theresa
Friday, May 21, 2010 11:02 AM
Mayes, Edgar
FW: letter on gainful employment
Klein letter to Secretary Duncan on Gainful Employment PDF. pdf; Klein letter to secretary
Duncan on GainfUl Employment.doc
·····Original Message-----
From: Gomez, Gabriella
Sent: May 21,2010 11:01 AM
To: Toye, Theresa
Subject: FW: letter on gainful employment
PIs log in
From: Neale, Virginia [mailto:Virginia,Neale@maiI.house.gov]
Sent: Thursday, May 20, 2010 5:05 PM
To: Gomez, Gabriella
Subject: letter on gainful employment
Thanks again for your help with our independent living council- I spoke with Andy Peppin (sorry if I'm spelling
his name wrong) and we're going to set up a meeting to work everything out.
On another note- here is a letter from Congressman Klein with a more specific alternative proposal for the
gainful employment proposed rule, as we talked about earlier, I've attached the pdfand the word document.
Thank you so much for your consideration of our ideas. Please let me knowif you have any questions.
All the best,
Virginia
1
Virginia Neale
Legislative Assistant
Congressman Ron Klein (FL-22)
313 Cannon House Office Building
202.225.3026
2

Pollack,Joshua
From:
Sent:
To:
Subject:
I
Rogers, Margot
Thursday, April 29, 20107:49 AM
Miller, Tony
FW: Here's the story: "Comparing Higher Ed to Wall Street"
,
(b)(5)
From: Shireman, Bob
Sent: Thursday, April 29, 2010 7:44 AM
To: Hamilton, Justin; Kanter, Martha; Cunningham, Peter; Rogers, Margot
Subject: RE: Here's the story: "Comparing Higher Ed to Wall Street"
Robert Shireman
Deputy Undersecretary
U.S. Department of Education
(202) 260-0I01
From: Hamilton, Justin
Sent: 'Thursday, April 29, 2010 7:30 AM
To: Shireman, Bob; Kanter, Martha; Cunningham, Peter; Rogers, Margot
Subject: Here's the story: "Comparing Higher Ed to Wall Street"
Comparing Higher Ed to Wall Street
Whenever worried leaders of for-profit colleges have implied in recent months that the U.S. Education Department is
gunning for the institutions, officials of the federal agency have discouraged such talk,
<http://www.insidehighered.com/news/2009/06/ 16/cca> offering evenhanded rhetoric about treating all sectors the same
in their push for increased accountability.
The words have provided little reassurance to the colleges, since they haven't always seemed to square with the aggressive
approach <http://www.insidehighered.com/news/2010/04/2l/gainful> the Obama administration is taking in rewriting
federal rules governing vocational and other programs.
On Wednesday, in a speech to state regulators who oversee for-profit colleges, the chief architect of the Education
Department's strategy, Robert Shireman, offered a much more critical assessment of the private sector institutions than he
has in his public comments to date, according to accounts given by several people who were in the room. He compared
the institutions repeatedly to the Wall Street firms whose behavior led to the fmancial meltdown and called them out
individually, one by one, for the vast and quickly increasing sums of federal student aid money they are drawing down.
While Shireman's comments were aimed most directly at the for-profit colleges themselves, they may be most noteworthy
for his indictment of accreditation, higher education's system of institutional peer review. In Shireman's narrative before
the annual meeting <http://www.nasasps.org/conference/registration-materials> of the National Association of State
1
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Pollack,Joshua
From:
Sent:
To:
Subject:
,
Rogers, Margot
Thursday, April 29, 2010 7:49 AM
Miller, Tony
FW: Here's the story: "Comparing Highe r Ed to Wall Street"
,
I
,
,
I
(b)( 5)
From: Shireman, Bob
Sent: Thursday, April 29, 2010 7:44 AM
To: Hamilton, Justin; Kanter, Martha; Cunningham, Peter; Rogers, Margot
Subj ect: RE: Here's the story: "Comparing Higher Ed to Wall Street"
From: Hamilton, Justin
Sent: Thursday, April 29, 2010 7:30 AM
To: Shireman, Bob; Kanter, Martha; Cunningham, Peter; Rogers, Margot
Subject: Here's the story: "Comparing Higher Ed to Wall Street"
Comparing Higher Ed to Wall Street
Whenever worried leaders of for-profit colleges have implied in recent months that the U.S. Education Department is
gunning for the institutions, officials of the federal agency have discouraged such talk,
<http://www.insidehighered.comlnews/2009/06/1 6/cca> offering evenhanded rhetoric about treating all sectors the same
in their push forincreased accountability.
The words have provided little reassurance to the colleges, since they haven't always seemed to square with the aggressive
approach <http://www.insidehighered.comlnews/20 I 0/04/21/gainful> the Obama admini stration is taking in rewriting
federal rules governing vocational and other programs.
On Wednesday, in a speech to state regulators who overs ee for-profit colleges, the chief architect of the Education
Department's strategy, Robert Shireman, offered a much more critical assessment of the private sector institutions than he
has in his public comments to date, accordi ng to accounts given by several people who were in the room. He compared
the institutions repeatedly to the Wall Street firms whose behavior led to the financial meltdown and called them out
individually, one by one, for the vast and quickly increasing sums of federal student aid money they are drawing down.
While Shireman's comments were aimed most directl y at the for-profit colleges themselves, they may be most noteworthy
for his indictment of accreditation, higher education's system of institutional peer review. In Shireman's narrative before
the annual meeting <http://www.nasasps.org/conference/registration-materials> of the National Association of State
t
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Administrators and Supervisors of Private Schools, the accrediting agencies are to the for-profit colleges what the Wall
Street ratings agencies were to the misbehaving financial firms: entities charged with regulating an industry that has
grown too quickly and too complex for them to control, and that have an "inherent conflict of interest" because their
existence depends on financial contributions from those they regulate.
Accreditors lack the "firepower" to regulate the for-profit sector, and the states and the federal government don't
necessarily have all the tools they need to do it either, Shireman said, according to the notes of several in the audience.
That, he suggested, is why the Education Department must toughen its rules in the way it is now proposing.
Shireman could not be reached for comment, and an Education Department spokesman said its officials did not wish to
comment on this article.
To several people in the audience, Shireman's comments represented a much more candid (and critical) appraisal ofthe
for-profit sector than he has offered publicly since he became deputy under secretary of education almost exactly a year
ago <http://www.insidehighered.comlnews/2009/04/21/shireman> . Many supporters of the education companies feared
his appointment because they believed his track record as an advocate for low-income students and a foe of student debt
would result in a crackdown on the institutions, whose students are disproportionately needy and disproportionately go
into heavy debt <http://www.insidehighered.comlnews/2010/04/27/debt> to finance their educations.
But with Wall Street analysts hanging on his every word <http://www.insidehighered.comlnews/2009/06/01/qt#200115>
looking for snippets that might threaten the publicly traded companies' stock prices, Shireman has often seemed to go out
of his way to avoid singling the institutions out for criticism.
A typical quotation, from last sunnner: <http://www.insidehighered.comlnews/2009/06/16/cca> "Our overall goal at the
Department of Education in postsecondary education is to make sure that students ... have the information they need to
make good choices, and that they have good quality postsecondary education that serves both them as students and
taxpayers as well," Shireman said. "...If there is not quality, we want to know about it and if we can, we want to do
something about it. Whether that involves a public institution, a nonprofit, a for-profit, a two-year, a four-year, a trade
program, whatever type or sector of institution, we want to do all we can to make sure that we have good quality."
Different Tone
In his comments Wednesday, Shireman laid out the context underlying the Obama administration's elevation of higher
education as a central focus of its domestic policies. The economic slide. created in part by the collapse of the credit
markets has sent Americans streaming back to college in record numbers, and has made it more imperative than ever that
more Americans get a higher education to strengthen the country's economic base for the future, Shireman said.
The administration has poured tens of billions of dollars into Pell Grants and restructured the federal student loan
programs to try to ensure that Americans have access to higher education, Shireman said Wednesday. Many public
institutions, facing cuts in their state funding, have had to limit or even cut their enrollments, reducing their ability to meet
the increasing demand from students.
The for-profit colleges, by contrast, have stepped up, seeing their enrollments explode -- and with them, the amount of
Pell Grant money that follows the students to the institutions, Shireman said. Anyone in the audience from Corinthian
Colleges? Shireman asked the assembled audience Wednesday.
A hand went up. The California-based for-profit higher ed company has seen its revenue from Pell Grants grow by 38
percent in the first three quarters of this fiscal year compared to the last one, he said. Anyone from DeVry? Forty-two
percent, Shireman said. Strayer? ITT? One by one, he ticked through a list of publicly traded companies, pointing out the
increasing amounts of federal money the institutions were collecting ("It was like fourth grade, with a teacher scolding
students over their grades," said one person who was in the room).
What are taxpayers and students getting in return for that investment? Shireman asked. It has historically been up to the
"triad" -- the three-headed regulatory scheme involving the federal government, state governments and accrediting
agencies -- to ensure access, quality and integrity in higher education, he said.
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But is that regulatory system up to the job? To draw a parallel, Shireman noted that as this meeting was unfolding in St.
Paul, politicians back in Washington were debating possible reforms of Wall Street, to try to fix the "flawed" regulatory
process that allowed Goldman Sachs and other purveyors of subprime mortgages to engage in misbehavior that helped
devastate the economy.
. ,
One major reason the process was flawed, Shireman said, was because the bond rating agencies that were supposed to be
judging the riskiness of the financial instruments were supported in large part by fees from the companies that were asking
the agencies to rate the financial instruments -- "a clear, inherent conflict of interest," Shireman said, according to the
accounts of several in the room.
. ! On top of that inherent conflict, the ratings agencies have been struggling to keep tabs on industries that grew quickly and
adopted increasingly complex practices, Shireman said, suggesting that the ratings agencies lacked the "firepower" to
regulate the financial markets.
In case anyone missed it, Shireman drove his point home, pointing out that higher education accrediting agencies are
made up of (and financially supported by) their member colleges, and see it as their mission both to help the institutions
"improve" and also to ensure, in what is essentially a subcontract from the federal govermnent, that they are of sufficient
quality.
The peer review nature of higher education accreditation has an inherent conflict of interest similar to the ratings agencies,
Shireman said. Given that, he suggested, it is crucial for state and federal agencies, as the other two parts of the triad, to
step up their role in regulating higher education. But do state regulators think they have the "firepower" to keep tabs on
the big, growing and complex private market college sector? Shireman asked the state officials in the room. The response
was underwhelming.
The federal govermnent's own powers may be insufficient to do the job, too, Shireman suggested, according to members
of the audience. That is why the department needs new approaches to ensuring integrity in the financial aid programs, he
said, such as requiring most for-profit colleges and non-degree vocational programs at nonprofit colleges to show that
they are preparing students for gainful employment.
Several people who heard the speech said they viewed it as a much more strident critique of for-profit colleges, and of
higher education accreditation, than Shireman has delivered before. But David Dies, who heads the Wisconsin
Educational Approval Board and just finished a term as president of the national group of state regulators, didn't hear it
quite that way.
"I think Bob was explaining why we need state regulation and [Education] Department oversight to be part ofthis three-
legged stool, not just accreditation, and why we all need to work together," said Dies. "He was pointing out some
limitations of accreditation, but I didn't really see it" as highly critical of accreditors or for-profit colleges.
- Doug Lederman <mailto:doug.lederman@insidehighered.com>
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