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Comments on the Proposed Rule on Program Integrity: Gainful Employment

U.S. Department of Education
Attention: Ashley Higgins
1990 K Street NW
Room 8037
Washington, DC 20006-8502
Filed via on May 27, 2014

Re: Comments on the Proposed Rule on Program Integrity: Gainful Employment
[Docket ID ED–2014–OPE–0039]

To whom it may concern:

Young Invincibles is a non-profit, non-partisan organization that works to expand
economic opportunity for young people ages 18 to 34. We thank you for the opportunity to comment on the Notice of Proposed Rulemaking regarding the gainful employment (GE) regulation (NPRM).

Young Invincibles represented students throughout the gainful employment negotiated rulemaking process. Though we appreciate the years of effort that the Department of Education (the Department) has put into crafting a GE rule to protect students from predatory schools, the draft rule is too weak to achieve this goal. Many programs that leave students with enormous amounts of debt and few job prospects will continue to receive federal financial aid under the proposed language.

We were further disappointed when the Department issued a weakened draft regulation that made several adjustments proposed by the for-profit college industry at the expense of students and taxpayers. Worse, the draft rule appears to lack any of the recommendations called for by a coalition of more than 50 organizations that work on behalf of students and college access, veterans, consumers, and civil rights. The
Department now has a rare opportunity to learn from the experiences of actual students who have been through these programs and ensure that taxpayer dollars do not continue to benefit failing schools. For these reasons, Young Invincibles urges the Department of Education to protect students who attend gainful employment programs and taxpayers who pay for them by promulgating a strong rule. The rule should:

1. Provide relief for students in programs that lose eligibility
2. Strengthen core accountability standards and close loopholes
3. Fix the glaring problem with the certification requirement
4. Limit enrollment in poorly performing programs until they improve
5. Strengthen consumer information and disclosures

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