Gainful Employment: The Saga Continues

Gainful Employment Rule

The Gainful Employment Rule is back in the headlines, at least within the higher education sphere. According to a fact sheet provided by the Institute for College Access & Success (ICAS), the current Higher Education Act requires that all career education programs receiving federal student aid — many of which are for-profit institutions —  “prepare students for gainful employment in a recognized occupation.” 

Watching all the changes connected to this Rule has been akin to watching a tennis match over the past six years, and it looks like there’s more to come. 

Obama Enacts Gainful Employment Rule

In 2015, the Obama Administration enacted the Gainful Employment Rule to protect unsuspecting students from unscrupulous for-profit predatory institutions. 

Needless to say, for-profit institutions hated the Gainful Employment Rule. Why? Because they could no longer rake in huge sums of tuition money, much of which came directly from the federal government, without accountability. 

In other words, they could no longer enroll unsuspecting students, issue a diploma that often wasn’t worth the paper it was written on, and leave bewildered graduates out in the cold and unable to find work. To make matters worse, these graduates were then saddled with tens of thousands of dollars in student loan debt. 

Data generated from the Education Department and crunched by the ICAS confirm that more than 350,000 students who graduated between 2010 and 2012 fell prey to predatory, low-quality for-profit institutions. These institutions could be categorized as the “bottom of the barrel” in terms of academic quality. They were dangerously close to losing their accreditation, meaning they could no longer qualify to receive federal financial aid money.  

Just how much taxpayer money did those for-profits rake in from those unsuspecting graduates who had worked so hard to make a better life for themselves and their families? Nearly $7.5 billion. The result was 350,000 men and women who found themselves strapped down in student loan debt and unable to find work. These individuals were often first-generation college students and people of color. 

Keep in mind that these figures are only for program completers (graduates). The data would be far higher if we included those who began programs and then for whatever reason had to drop out. 

New Administration, New Policy on Gainful Employment

The for-profit world was ecstatic when Donald Trump appointed Betsy DeVos as Education Secretary. Because of her background in the for-profit education business, they already viewed her as a friend. It took very little lobbying to convince her that higher education institutions shouldn’t be held accountable for their graduates’ success. 

As a result, in 2019 the Trump Administration rescinded the Gainful Employment Rule and immediately allowed schools to stop complying. It’s now as if the rule had never existed. In fact, when running a search for Gainful Employment here’s a screenshot of what you will currently find on the Education Department website: 

 

Gainful E

 

As a result, predatory for-profits have been allowed to play in the sandbox unfettered for two years without any gainful employment accountability. 

To sweeten the deal even more, the Trump Administration’s Education Department also rolled back another Obama-era decision to shut down the Accrediting Council for Independent Colleges and Schools (ACICS). This particular accrediting body caters to for-profit predators who can’t earn accreditation from other bodies. Their efforts are mostly rubber-stamped and institutions aren’t held accountable for outcomes. I’ve written previously about ACICS and the institutions it has granted accreditation in ACICS: It’s Time to Pull the Plug and The Dominoes That Didn’t Have to Fall: Vatterott College, the ECA, and Others Like Them

Rescinding the Gainful Employment Rule and ACICS went hand-in-glove. 

 

Another New Administration, Another New Policy 

According to reporting in the Chronicle of Higher Education, the Biden Administration will likely take steps to reverse the damage caused by the rescission of the Gainful Employment Rule, but it won’t happen overnight. 

The process will require a lengthy rule-making process and if approved, won’t take effect until at least mid-2022. 

That gives the predatory for-profit world enough time to mount a defense through highly-paid lobbyists. Their efforts can sway public opinion and lawmakers’ minds.

If reinstating the Gainful Employment Rule was as easy as it was to rescind it, we could protect the lives of hundreds of thousands of victimized students.  We could also save billions of taxpayer dollars that continue to fatten the bank accounts of for-profit presidents. 

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About the Author: A former public school teacher and college administrator, Dr. Roberta Ross-Fisher provides consultative support to colleges and universities in quality assurance, accreditation, educator preparation and competency-based education. Specialty: Council for the Accreditation of Educator Preparation (CAEP).  She can be reached at: Roberta@globaleducationalconsulting.com 

Top Graphic Credit: princess on Unsplash

 

The Dominoes That Didn’t Have to Fall: Vatterott College, the ECA, and Others Like Them

Vatterott and the ECA

Vatterott College couldn’t have found a better partner than the Education Corporation of America (ECA), according to its president Rene Crosswhite. In a press release, she stressed that schools under the umbrella of Vatterott Educational Centers “…will be strengthened through this partnership for the benefit of our students. We believe the acquisition will provide a bright future for VEC, and it should be relatively seamless for faculty, administrators and students.”

That was January 11, 2018. The acquisition didn’t happen, and Vatterott closed its doors without warning on December 17th.

Most of the students, faculty and staff at the 17 Vatterott campuses located across the Midwest learned of their school’s closing when they arrived on campus; others heard about it from friends and colleagues as the news began to spread like wildfire. They weren’t the only ones who were caught off-guard – VEC notified the U.S. Department of Education and various state departments of higher education of the immediate closures on that same day.

In its notification letter to students, Vatterott officials laid the blame at the feet of the federal government citing, “…the U.S. Department of Education recently decided to significantly increase the restrictions on Vatterott’s participation in the federal financial aid programs.”  The letter went on to say that as a result of the USDOE’s decision, Vatterott was unable to continue to operate, and was prevented from completing its planned sale to the ECA.

But there are two problems with Vatterott’s version of the story.

 

First, despite repeated warnings over several years, they lost their accreditation due to poor academic quality and financial instability.

Effective December 5, 2018, the Accrediting Commission of Career Schools and Colleges (ACCSC) voted to withdraw Vatterott’s accreditation. However, this came as no surprise to Vatterott administrators – they had been well aware of their accreditor’s concerns for quite some time. VEC leadership had been given a formal warning by the ACCSC as early as December 2016 due to excessive turnover in management and student achievement outcomes across multiple programs that continued to be below that regulating body’s benchmarks.

A system-wide warning from the Commission was issued in February 2017, followed by another notice of continued warning in August of that same year. Based on abysmal student graduation and employment rates, the ACCSC made the decision in November 2017 to force the Vatterott Berkley, Missouri campus to stop enrolling students in one program and to cap the enrollments of four others. Effective December 31, 2017, the St. Joseph, Missouri campus closed. In each case, the U.S. Department of Education, as well as the departments of higher education in each of the states where Vatterott Educational Systems, Inc. operated were notified of the accreditor’s concerns.

By May 2018, the situation had worsened to the point that the Commission made the decision to move the entire Vatterott system from “warning” to “probation” status, citing continued low student achievement, high management turnover, and financial instability concerns. On June 8, 2018, two campuses in Iowa and Kansas closed.

Finally, the decision was made to withdraw Vatterott’s accreditation during the ACCSC’s December 2018 meeting. According to the notification letter sent to the institution, Vatterott administrators could have chosen to appeal the decision and get serious about making necessary improvements. Instead, they decided to cease operations and blindside their students, faculty, and staff.

Vatterott and the ECA Lose Their Accreditation

Second, the Education Corporation of America (ECA), which was planning to purchase Vatterott, lost its own accreditation at nearly the same time, was denied initial accreditation by another agency, and suddenly shut down its campuses, leaving approximately 20,000 students and thousands of faculty and staff out in the cold. The reason? Poor academic quality and financial instability.

The ECA was a parent company of Virginia College, LLC, which operated 69 campuses in 18 states as Virginia College, Brightwood Career Institute, Brightwood College, Ecotech Institute, and the Golf Academy of America; all had been accredited under the Virginia College, LLC umbrella by the Accrediting Council for Independent Colleges and Schools (ACICS), a regulatory body that specializes in putting its seal of approval on for-profit institutions. It should be noted that this body has faced its own set of challenges, with the Obama administration removing federal recognition of ACICS as an accrediting agency due to lax and non-compliant quality assurance practices, although Education Secretary Betsy DeVos permanently reinstated its federal recognition in November 2018.

Because the future of ACICS was in jeopardy, the bottom line of institutions accredited by that agency would be negatively impacted, meaning at some point students enrolled in their programs would be ineligible to receive federal financial aid. Very few students enrolled in the various entities owned by the ECA could afford to attend without receiving significant financial aid and ECA was dependent on those tuition dollars to keep the doors open and the lights on. To that end, ECA made the decision to seek accreditation through another quality assurance agency that serves for-profit institutions– the Accrediting Council for Continuing Education & Training (ACCET). However, that effort was unsuccessful and resulted in ACCET denying ECA’s initial accreditation, citing the institution’s non-compliance in 19 standards covering a broad spectrum pertaining to academic quality, financial procedures, and organizational structure.

Two months later, ECA leadership received a show-cause directive from its original accrediting body ACICS, after it learned of the company’s dire financial problems that had resulted in lawsuits and possible bankruptcy. After being unable to make a convincing argument that it was financially stable, ECA’s accreditation was withdrawn by suspension. The next day, the ECA notified the USDOE that it planned to close its doors at all campuses by December 18.

Similar to Vatterott, in his notification letter to students ECA President & CEO Stu Reed blamed the company’s woes on added requirements placed upon it by the USDOE, although he did not elaborate on what those additional requirements were. He went on to say that those requirements, “…resulted in an inability to acquire additional capital to operate our schools.”

 

Vatterott and the ECA: Two Failed Companies, Many Similarities

Through its acquisition by the ECA, president Rene Crosswhite stated that Vatterott’s programs would be strengthened, and that its students would benefit. After all, their programs, procedures, and organizational structure were alike in a lot of ways, making it a relative seamless transition for all. It turns out that the two for-profit entities shared other similarities: Poor management, high turnover rates, low academic quality, unacceptable student success rates, and roller coaster-like financial instability.

There is rarely a single reason for the kind of systemic failure experienced by Vatterott Educational Centers and the Educational Corporation of America. Managing campuses in multiple states can be challenging for a lot of reasons, not the least of which is complying with programmatic and quality assurance practices required within each state entity. Regulations across state departments of higher education can vary widely and are subject to change as new laws are written and statutes approved. However, both institutions willingly made the decision to operate multiple campuses across multiple states. Furthermore, along with every other institution of higher education in the nation, they were responsible for monitoring, understanding, and complying with federal regulations which are also subject to periodic review and change.  In other words, laying blame at the feet of the federal government is not a viable excuse for the failure of VEC nor ECA.

Red Flags

In addition to similar concerns cited by their respective accreditors, these two institutions shared something else in common:

Vatterott and the ECA

 

President Crosswhite:  According to Vatterott President Crosswhite’s LinkedIn page, she has a master’s degree in Health Administration and is a licensed CPA. Ms. Crosswhite worked primarily in financial oversight for various hospitals before joining Vatterott Educational Centers in 2013 as its Chief Financial Officer; she held that post until March 2016 when she took over as President. Ms. Crosswhite described her role by stating, “As President, I am responsible for all aspects of the college including Academics, Operations, Marketing, Regulatory, Compliance, Financial Aid, Information Technology and Finance.”  As stated previously, Vatterott received its first formal warning from its accreditor in December 2016, three years after Ms. Crosswhite joined the company’s leadership team.

CEO Reed:  ECA’s chief executive Stu Reed holds a master’s degree in management. He joined the Educational Corporation of America in October 2014 as Chief Operating Officer and served in that capacity for four months before transitioning to CEO in January 2015. Prior to that, Mr. Reed held positions at IBM, Motorola, and Sears. His LinkedIn page lists Management, Process Improvement, and Customer Satisfaction as his top skills.

So, Who’s to Blame?

 

Executive Level Leadership

President Harry S. Truman had a sign on his desk in the oval office with a message as applicable today as it was during his administration. That sign said, “The Buck Stops Here.” Thus, the responsibility for any institution’s success or failure lands squarely on the shoulders of its executive leader. While numerous faculty and staff may be tasked with specific roles within an organization, the president or CEO is the person ultimately responsible for that institution’s overall performance outcomes. However, there are other entities who could have done more to support both Vatterott and the ECA as problems began to be revealed.

Accrediting Bodies

The primary role of accrediting bodies such as the Accrediting Commission of Career Schools and Colleges (ACCSC), Accrediting Council for Independent Colleges and Schools (ACICS), and Accrediting Council for Continuing Education & Training (ACCET) can be summed up with two words — quality assurance. By granting an institution accreditation, these bodies are placing a seal of approval on that institution’s programs, faculty, financial stability, and outcomes. In essence, accreditors serve as consumer watchdogs to protect students and to ensure that institutions provide high-quality educational experiences by meeting specific standards. It is the responsibility of accreditors to hold institutions accountable when those standards are not met.

In the case of Vatterott Educational Centers and the Educational Corporation of America, it appears as though ACCSC and ACCIS accountability mechanisms were not effective in protecting students and ensuring high-quality educational experiences. These institutions were allowed to operate for years despite significant concerns and as a result, thousands of students trying to make a better life for themselves and their families now find themselves deep in debt with credits that may or may not transfer to another school. Betrayal of trust seems to be an understatement in this context.

Federal and State Departments of Education

Governmental and regulatory agencies must also share responsibility for the failure of these two institutions and others like them. After all, it is those very agencies that grant authorization to operate after an institution submits an application and completes a lengthy review process. Earning state program approval requires yet another layer of scrutiny. Typically, state departments of higher education and the U.S. Department of Education require annual reports that provide updated information about an institution’s programs, such as enrollment, retention, and graduation rates; employment data, and student performance on examinations required for state licensure or certification.

What accountability measures did the USDOE and each state department of higher education have in place to monitor the quality of Vatterott College and all the various colleges operating under the ECA umbrella? Since each was approved to operate by those entities, do they share no responsibility in protecting students who enroll?

 

USDOE’s Recommendations

Per the directive of Education Secretary Betsy DeVos, the USDOE recently published two white papers targeted at accreditation and higher education. However, in Rethinking Higher Education, many of the department’s recommendations may actually do little for quality assurance – some focus on empowering institutions and innovators to an even greater extent, such as:

  • Provide regulatory relief by removing overreaching regulatory burdens, revising costly or ambiguous regulations, and providing a greater understanding of Department expectations concerning regulatory compliance;
  • Carefully construct accountability measures that take into account the unique mission of an institution and the needs and goals of its students;
  • Ensure that accreditors evaluate institutional quality in the context of the students an institution serves and the institution’s unique mission;
  • Reform the accreditation system to promote change and innovation, to allow accrediting agencies to accommodate educational innovation, and to reduce the cost of quality assurance; and
  • Identify new ways to expedite approvals for new programs and program modifications in order to keep pace with changing technologies and employer demands.

While the students at most colleges and universities could benefit from such reforms, predatory institutions where turning a profit is the top priority could take advantage of the latitude offered by the USDOE in these recommendations.

 

Common Sense Solutions Needed

Unfortunately, very little can be done to help the thousands of students who put their trust in the schools run by Vatterott Educational Centers and the Educational Corporation of America. The USDOE may or may not forgive their student loans, and the various state departments of higher education may or may not assist them with finding other schools who will accept their credits for transfer. For now, the extent of support seems to be mostly limited to posting a fact sheet about the school’s closure along with referral to numerous links and phone numbers for students to wade through on their own. One state site encourages these students to “explore their options for continuing their education” while another provides a link to that state’s Attorney General’s office if students wish to file a formal complaint. This is unacceptable, but a few common-sense steps could start to make a difference. For example:

Learning from Those Who Are Most Impacted

Lawyers, governmental staffers, accreditors, and political leaders should not be making regulatory recommendations and decisions without truly understanding how the lives of students, faculty, businesses, and communities will be impacted. Instead, a “best practice” recommendation is to host an ongoing series of roundtable discussions about student and workforce needs, academic quality indicators, consumer protection, etc. These discussions need to involve all stakeholder groups, and their input should be taken seriously. In many instances, those “in the trenches” often have the best insights and solutions.

Identifying the Root Cause

Since 2016, approximately 173 colleges and universities have shut their doors; 75 were for-profit institutions. We can and must do a better job of ensuring the fiscal health and academic quality of our colleges and universities. In order to do that, we’ve got to take a serious look at each institution and determine the reason(s) for their failure. After identifying patterns of failing institutions, agencies can create a set of red flags to identify at-risk schools. For example:

  • Does the school have enrollment quotas?
  • Are there open enrollment policies that accept almost all applicants, regardless of whether students demonstrated a propensity for success?
  • What are the student retention and graduation rates? If the rates are poor, are they across all programs, or specific to certain ones?
  • On average, must the school’s graduates have to take their state licensure examination more than twice before passing?
  • Has the institution had continued high rates of faculty and/or leadership turnover?
  • From an employer perspective, does the school prepare its graduates well for their chosen career?
  • From an alumni perspective, does the school provide a high-quality educational experience that is relevant and meaningful to their chosen career?
  • How much prior experience do executive leaders have working within a similar institution?

 

Triaging the Wounds of Vatterott, the ECA, and Others Like Them

Accreditors and governmental agencies should do more to hold institutions accountable. Going through an accreditation review or state approval process can be rigorous, but submitting an annual report containing basic information without follow up is simply not effective, as evidenced by the fate of Vatterott and the ECA.

No institution should be allowed to continue to operate poorly for months or years. That approach helps no one – not the institution, not businesses counting on a skilled workforce, and certainly not students. When there are concerns about an institution’s performance, accreditation staff should establish a system to provide guidance and support as needed. A triage model could be implemented based on the level of concern: Cuts and scrapes are easy to take care of, but an institution should never be allowed to digress to the level of intensive care or hospice without significant intervention.

Shared Responsibility, Shared Accountability

Simply stated, all entities should be working together as partners toward achieving successful outcomes. Institutions are responsible for innovations, operations and data-driven decision making with the goals of continuous program improvement. Federal and state departments of education serve as the umbrella for authorizing those institutions to operate, while accrediting bodies must set high expectations, ensure standards are met, and provide assistance to institutions that are struggling. Each entity shares in an institution’s success and likewise, in its failure.

 

Vatterott and the ECA: KEY EVENTS

 

Vatterott and the ECA: RELATED RESOURCES

 

OTHER IMPORTANT SOURCES

 

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About the Author: Dr. Roberta Ross-Fisher has expertise in higher education quality assurance, educator preparation, and competency-based education. A former public school teacher and college administrator, Roberta is now an educational consultant specializing in the Council for the Accreditation of Educator Preparation (CAEP). 

Twitter: @RRossFisher

Email: globaleducationalconsulting@gmail.com 

               

 

 

Top image credit: lapertenencia.wordpress.com

Alternative Educator Preparation: A Viable Option, or a Non-Starter?

There’s an interesting article about alternative teacher preparation programs entitled Analysis Finds Alternatively Credentialed Teachers Performed Equal to Peers in First Two Years–while the results are inconclusive on several fronts it does present some thoughtful information to consider, including:

  • Are traditional educator preparation programs the ONLY way to train future teachers successfully? Are they BEST way?
  • Can alternative (non-traditional) educator preparation programs support student learning in a positive way, whilst supporting supply and demand challenges faced by multiple school districts across the nation?
  • What are the long-term impacts of educator preparation on our country’s workforce? And, what are the long-term impacts of what we view as an educated society?
  • Will how teachers are prepared impact our standing in the world relative to student achievement?
  • How would we know? What research questions need to be posed?

 

An experienced consultant can help with these questions, and more. Reach out to me for program development, collaboration, accreditation, clinical partnerships, and other matters related to preparing educators with excellence.

–rrf

 

Dr. Roberta Ross-Fisher is a national leader in educator preparation, accreditation, online learning, and academic quality assurance. An accomplished presenter, writer, and educator, she currently supports higher education and P-12 schools in areas such as competency-based education, teacher preparation, distance learning, and accreditation through her company, Global Educational Consulting, LLC. She can be reached at: globaleducationalconsulting@gmail.com

The Drive-Thru Approach to Teacher Preparation

The Drive-Thru Approach to Teacher Preparation

I read yet another article about national teacher shortages; this one was entitled Teacher Shortages Spur a Nationwide Hiring Scramble (Credentials Optional). As a result of their desperation to staff classrooms, school district officials are putting pressure on states to relax teacher licensure requirements. In some cases, this has led to the watering down of standards and expectations. Some are taking advantage of the current climate, smelling the sweet aroma of serious revenue by offering what is essentially a drive-thru teacher preparation program: The “customer” arrives at the window, attracted by the bright lights and yummy-looking food pics. Enrollment counselors take their order and send them on. Worker bees behind the scenes serve up a program that may be of questionable or untested quality and the customer is on their way in record time. They don’t know that their fries were cold or there was no straw until they are miles down the road. Programs know such a model is cheap to build and cheap to operate; it’s easy money and there are so many students rolling through the drive-thru lane that they can afford to have some unhappy customers and still turn a profit.

In the short term, school districts are happy because they have a less difficult time hiring teachers, and program completers are happy because they’ve gotten through their program at break-neck speed and haven’t had to “waste” their time on courses they perceive as useless. However, in the long term, a host of new cyclical problems are revealed, including:

  • Individuals are admitted to the programs who really shouldn’t be—they sometimes lack the academic preparation or the professional dispositions necessary for success in the classroom.
  • Program completers are often ill-prepared to enter the classroom; they require a great deal of on-site training by the school district.
  • Many new teachers quickly become disillusioned and leave the profession because they didn’t know how challenging teaching really can be. Some leave in the middle of a school year.
  • Students often suffer due to constant turnover and lack of consistency.
  • Test scores lag and fall behind state averages; impact outcomes tend to be dismal.

 

Not all for-profit alternative certification programs are of poor quality, but many are. While accrediting bodies have recently come under greater scrutiny for their standards and expectations, many of these programs fly under the radar and are not regionally accredited*, which is the foundational accreditation any legitimate institution of higher education should attain. Some are taking the easy path to accreditation through bodies that focus mostly on career schools** such as beauty schools, truck driving schools, at-home hypnosis training, etc. just to state on their program’s website that they are accredited. These programs use “sleight of hand” language with the lay public, saying they are “accreditation eligible” which in reality means nothing but it sounds very convincing to those who are not well versed in the lingo.  Make no mistake: The drive-thru teacher preparation model is very real, and it is having a very real impact on our P-12 schools. The question is: Are we going to accept it as the new normal, or are we finally going to draw a line in the sand and insist on academic excellence for our children?

Dr. Roberta Ross-Fisher is a national leader in quality assurance, educator preparation, and empowerment-based learning. She supports educational institutions in areas such as accreditation, institutional effectiveness, competency-based education, and virtual teaching & learning.  Roberta can be contacted for consultations, webinars, and on-site workshops through her site (www.robertarossfisher.com). 

 

*The regional accreditation bodies in the United States include: (1) Higher Learning Commission (HLC); (2) Middle States Commission on Higher Education (MSCHE); (3) New England Association of Schools and Colleges (NEASC-CIHE) Commission on Institutions of Higher Education; (4) Southern Association of Colleges and Schools Commission on Colleges (SACSCOC); and (5) WASC Senior College and University Commission (WSCUC).

**The Distance Education Accrediting Commission (DEAC) awards accreditation to degree-granting, high school, military, and post-secondary schools. A search of accredited post-secondary schools, which would apply to alternative teacher certification programs, includes the Hypnosis Motivation Institute, At-Home Professions, and the Modern Gun School, to name a few.