In what reads like a Student’s Bill of Rights, a 76 page Assurance of Voluntary Compliance, CEC must clearly and conspicuously disclose to prospective students a “Single-Page Disclosure Sheet” that contains the following information:
- the anticipated total direct cost for the program of study at the prospective campus; provided, however, that this provision shall not be interpreted to restrict CEC’s ability to change tuition, fees, or expenses;
- the median debt for completers for the program of study for the most recent reporting period, if available;
- the program cohort default rate for the most recent reporting period if available;
- the program completion rate for the most recent reporting period, if available;
- the transferability of credits disclosure;
- the median earnings for completers for the program of study for the most recent reporting period, if available; and
- the job placement rate disclosure for the program of study at the prospective campus for the most recent reporting period, if available.
This Single-Page Disclosure Sheet must be provided to students before they execute an enrollment agreement or before they begin a new program of study if already enrolled. A copy must be emailed to the student prior to starting the first day of class of a new program of study.
I noticed that CEC may calculate and disclose information with respect to the income earned by CEC’s graduates, provided that such information is not false, misleading, or deceptive. They are not required to provide any graduate income information.
If CEC discloses that it has articulation agreements for the transfer of credits to other schools, then, they must also list the specific schools, list the classes for which the receiving school allows credits, disclose any conditions upon the acceptance of transferred credits, and disclose if for elective credit only.
Rules were established for the disclosure of additional information regarding things like job placement rates, likelihood of employment, etc.
CEC is not required to disclose a program completion rate, a program cohort default rate, a median debt for completers, or a job placement rate for any program of study at a location with fewer than ten students.
For former students who are self-employed following graduation, limitations were established as to when the person is to be deemed “employed”.
Several provisions eliminate misleading and false representations regarding transferability of credits, the type of accreditation and the accrediting agency, the student/faculty ratio; the percentage of faculty holding advanced degrees in the program, the names and qualifications of full-time faculty members, the course credits and any requirements for completing a program of study such as clinicals, internships and externships, and completion rates for each program of study, cost of attendance, etc.
Interestingly, CEC is now required to record all telephone calls and online chats between Admissions Advisors or Financial Aid Advisors and students/prospective students when the purpose of the calls is to discuss recruiting, admissions, or financial aid. However, these calls are not required to be kept for more than 90 days. 90 days is not nearly long enough, most people won’t realize there is a problem until much later. This term should have been extended to the expiration of the statute of limitations for a fraud or breach of contract claim, or at least to one year following graduation.
There is much much more in this exhaustive agreement that all but two states signed (California and New York). I wonder if this will become sort of an industry standard that all for-profit schools should strive to meet. I certainly hope so. I’ve talked to hundreds if not thousands of former students of schools such as this, who were the victims of the types of misleading representations that this agreement seeks to eliminate.
What this agreement does not do is eliminate federal or private loans for former students who accrued large amounts of debt relying upon the misrepresentations of for-profit schools. For that the former students must reach out to legal counsel to see what options may exist.