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Ron Holt brings 26 years of experience in a broad range of commercial and general litigation matters, including 15 years of experience in representing institutions of higher learning in litigation, regulatory matters and business transactions.
Dunn & Davison, LLC maintains offices in Kansas City, St. Joseph, Missouri and Leawood, Kansas and offers a full range of legal services in the areas of arbitration and dispute resolution, asset protection planning, banking, business, commercial litigation, construction, employee benefits, ERISA, estate planning, higher education, mergers and acquisitions, and tax planning. |
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Analysis of Proposed Gainful Employment Regulation
 By Ronald L. Holt, Esq., Partner
The author is an attorney practicing in the Higher Education practice at the firm of Dunn & Davison, LLC.
On July 26, 2010, the U.S. Department of Education ("DOE") issued a notice of proposed rulemaking (the "GE NPRM") that proposes a two-part 'gainful employment' test (the "GE Standards") intended to be used to measure Title IV eligibility of the following academic programs:
(1) ALL Title IV eligible academic degree and non-degree programs offered by for profit institutions (excluding any liberal arts baccalaureate degree program); and
(2) All Title IV eligible non-degree programs offered by any nonprofit and public institutions (mostly community colleges).
Assuming the final version of the GE regulations is published by November 1, 2010, the regulation would become effective as of July 1, 2011. By its current terms, however, it will not apply to most programs until July 1, 2012 but on July 1, 2011 it will be applied to the lowest 5th percentile in performance of each kind of program (as explained in Part H below on page 11). The GE NPRM is published at 75 Federal Register 43615-43708 (July 26, 2010); it can be accessed at
http://www.ifap.ed.gov/fregisters/FR072610ProgramIntegrity.html
A separate NPRM, which was issued on June 18, 2010 and which covers a wide range of proposed new 'integrity' regulations, establishes new requirements for colleges to make disclosures to students and the DOE about various components of the GE Standards. For each program, the institution must annually report its CIP code (Classification of Instructional Programs), the SOC codes (standard occupational code) of occupations for which the program provides training, the graduates in the institution's last fiscal year and the federal and private debt of those graduates. The institution also must disclose to all students: the cost of each program, the on-time graduation rate of each program, the median debt load for each program (as defined in the GE Standards), and the placement rate for each program beginning by June 30, 2013.
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