Welcome to Gainful Employment: Where We Stand, APC’s blog dedicated specifically to furthering national discourse on this critically important higher education issue. There are a great many voices and opinions coming from all corners on this contentious matter, and not all of them reflect a full or fair 360-degree view on the subject, leading to many misrepresentations, misperceptions and misunderstandings. This blog is designed to help bring relevant information, data, and insight to the fore to ensure a more balanced conversation going forward.

To be clear from the outset, APC wholly endorses the work that the Department of Education is doing to regulate any institution with very poor outcomes or ethics, regardless of sector. We simply have clear and significant concerns that in the current tunnel-vision rush to “do something,” many valuable programs with good, solid outcomes will be unfairly penalized and even shut down due to the wrong metrics being put into place, which is how we view those in the current draft of the Gainful Employment Rule. Indeed, as we wrote in our comments submitted following its release:

“…The proposed rule does not do what it is intended to do (measure whether programs prepare their students for good jobs), it lacks any rational basis, and if implemented it would be a public policy debacle, leading to the ineligibility of thousands of programs that in fact prepare students for gainful employment, as Congress intended that term. To the extent that the Department is determined to address this issue by regulation, it nevertheless should suspend this rulemaking until it has fully studied the flaws in its proposal that would cut off educational opportunities for hundreds of thousands or millions of students who rely on these programs as their step to a better life.”

Over the course of the next several weeks, we’ll introduce you to a number of well-established, wholly respected proprietary colleges that are producing quality outcomes for their students, far surpassing the caliber of program offerings or the graduation and placement rates of neighboring public and community colleges. These exceptional institutions, from any vantage point, do not rightly deserve to be placed in the public crosshairs, yet there they stand, rendered suddenly vulnerable because of a government initiative that, no matter how well intentioned, relies on the wrong metrics. We’ll also share with you the perspectives of educators, researchers, academic think-tanks, and other third-parties that share our concerns and are themselves questioning the methodology that the Department has settled on.

We will also point out areas where the proposed Rule fails to protect students or unnecessarily punishes institutions with excellent outcomes for many years.

We encourage your input and comment, and hope that this can be a forum for improving everyone’s understanding of the importance of “getting it right” with the Rule – and the detrimental consequences to students, employees and local economies across the country if we do not.