CCA said a report released today by the Education Sector on the Department of Education’s gainful employment proposal is flawed, clouding rather than clarifying the merits of the issue and, in the process, underestimating the negative impact on student access to education in critically important professional and career areas.
CCA President Harris Miller said the Education Sector's report on the gainful employment measure estimates the number of programs that will be impacted by the regulation using a very limited base of data. "That a well intentioned analyst comes up with such wildly lower guesstimates on the number of students who will lose access from the Department's own numbers and that of other independent analysts is another strong indication that the Gainful Employment proposal is not ready for prime time," Miller said. "The Department is putting the postsecondary education of millions of students at risk without the requisite facts and figures, and now an analyst has written a report that merely ‘mixes and matches’ from various sources to produce another guesstimate. The Department needs to pull back this proposal."
Flaws CCA cited in the Education Sector study include:
· --Focusing on program cost and linking cost to borrowing. While the Department of Education is careful not to focus its gainful employment metric on program cost, Education Sector is not. A true depiction of student borrowing would include elements over and above program cost such as living expenses because many students borrow more than needed for their education. In analyzing impact, the report confuses cost with debt;
· --Discussing program impacts based on assumptions rather than real data. Less than half of schools report cost on a programmatic basis;
· --Relying on the Department’s repayment metric, which wrongly ties the program in question to the overall repayment performance of students at a given institution.
“While we share the Education Sector’s interest in assuring that every student goes as far as his or her abilities and commitment will take them, let’s not be confused by a report that assumes its way to an erroneous conclusion,” Miller said.
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