crew: department of education: regarding for-profit education: 4/21/11 – 10-01704-f ous ge

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From:Sent:To:Subject:Shireman, BobSaturday, May 01 , 201 08 :04 AMShelton, JimRE:Touching Base

In stead ofbe for you tol i sten t o my speech and t hen we can t alk . You can f ind i t her e:t / c g o o g l e o / e a ? i ~ e R D h _ M 2 U 2 G Z k Y W U Z m M a M y 0 a N j J j l T g x N G l t N 2 E l O T h h M m Y 2 0 G U 4 &

h e -Bob

,, _. (b)(6)(b)(6)meTrylngTo exPTal n wnat I sai d or what I mea nt , probably the best thing would

From: Shel ton, Ji mSent : Sa t urday, May al, 2010 6: 57 AMTo: Shireman, BobSub j ect : Tou ching Base11 _ n _L

Best ,Ji m---_._----------------- ---Sent us ing Bl ackBerry

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From:Sent :To:Subject:b)(5)

From : Joanne Weiss [joanne@gourdinfamily . com]Sent : Monday, May 03, 2010 9:04 PMTo: Ka nter, Mart haCc: Wei ss, Joann eSub je ct : FW: Checki ng I nAnother conc erned friend in the f or -prof i t higher educat ion space. How shoul d we rep l y?JoanneFrom : Hugh son, William [mail to :whughson@d evry . edu]Sent : Friday, April 30, 2010 10:57 PMTo: j oanne@gourdinfami ly . comSub jec t : Checking InHi , JoanneHo pe al l ' s well with you and t hat you' r e enj oying your new j ob!I t ' s been quite a wh i rlwind fo r me, moving to Chicago and get t ing set t led into my new j ob.My two l i t t l e girls, now aged 3 Yo and 1 Yo are both doing wonderfully, and are the joy of myl i fe .The arti cle below, about Bob Shi reman's remark s t o state education regulators , i s quiteconcerni ng t o me . Wy does Bob th ink we serve our st udents poo rly? No one seems t o thinkt hat Ford' s or Ap ple ' s increasing market share means t hat t hey are cor r upt or se rving t heircustomer s poorly. In fa ct, quite to t he contrary, I t hi nk that most of us assume t he rea sonis that they are doing a bet t er j ob of appealing t o consumers who ha ve compl et el y fr ee cho iceas to whose product s t o purchase . The f act t hat our Pell grant s are growing re f lects t hesame under ly i ng reality : that st udent s have free choi ce , and t hat they are choos ing us.Why? For the same reason t hat they are choos i ng Ford and Apple product s : we pr ovi de a greateduc at ion , in f ormats which recogn ize the complex real i t ies of our st udents ' l ives, combinedwi t h outsta ndi ng st udent ser vi ces - in cluding career serv ic es .I have spen t a great deal of my f irs t seven mont hs with DeVry touring the 29 campuses whichre port t o me . At each campus, I st r es s t he impo r tance of provid i ng outs tandi ng education andouts tanding st udent service . I also emphasi ze t he import anc e of adhering st r ic t ly t o ourregulatory compl iance gu idel ines . I spend hour s speaki ng wi t h st udents , fa culty andadministra t i on. About half of t he hundreds of students I have spok en wi t h t old me t hat t heychose DeVry because a bos s, col league, fr i end or family member r ecomme nded us . What betterevidence coul d there be t hat we are se rving our s tudent s wel l ?Our "compet i t ion" - primarily public in s t i tut ion s - j ust don't serve their students al l thatwel l . All of us wish t hey woul d, becaus e t hat would be bet ter for soci et y . But they don' t .I t se em s to me t ha t ED ought to be more conce rned wi t h helping publi c in st itution s t o provide

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good educat ion and service to t heir students t ha n wi t h gett ing mad at us because we do. Thes i tuat ion seems very compa rable to t he public sc hoo ls and t he teachers ' un i on s wh o ge t mad atAspi re. Rat her ,t han waste t hei r t ime get t i ng mad at Asp i re, t hey ought t o spend thei r t i meand resources f i gu r in g out how to provid e better educat io n th emselves . If t hey did a goodjob i n t he f i rst place, Aspi re woul d never ha ve come to be . The same is t r ue of pr ivate sec to r post- se cond ary education.I would very mu ch val ue your i nsights i nto t his , because i t is very concerni ng to me and mycol leagues.Thank s!Bi l l Hu gh sonPresident , Hea l thcare Gro upDeVry I nc.3005 H ghland Pa rkwayDowners Grove, I l 60515Direct: 630-515-3138Mb i le : 331-645 -3906Our Purpose : Empowering our st udent s t o achieve t heir educat ional and career goals .From: Jamie Morley [mailto:jmorley@u sedu cat i oncorp. com]Sent : Friday, Apr i l 30, 2010 2:35 AMTo: Montgome ryX, Geo rge; Hu gh son , Wlliam; Thom as Bloom ; Jeff Ake nsSubject : FW: In side Hi gher Ed: Shi rema n 's contem pt fo r accredi to rsThi s was forwarded fr om ACrCS' regu l atory department . I highl i gh t ed t he refe rence t o DeVry .JameJamie Mo rley, ph.D.Vice Pre s i dent , Academic AffairsU.S. Ed ucat ion1001 Me na ul Blvd. NEAl buque rque, NM 87107505 -353-3931 phone/ f ax505-514-6901 blackberryjmorley@useducat ioncorp.comThis mes sage and /or any at ta c hments contain confident ia l , non-publ ic in format ion . Thismessage should not be f orwarded exc ept t o t hose per son s with a need to know suc h i nforma tionfor l egit imat e pu rposes . If you are not the inte nded reci pi ent s , please noti f y sender anddelete th i s message from you r system.From : Ant hony Bieda [mailto:AB ieda@aci cs.org]Sent : Thur sday, April 29, 2010 7:25 AMTo: Director sCc: Commiss ionersSubject : In sid e Higher Ed: Shi reman's con tempt fo r accreditor sFY I . looks l i ke we have some addit io na l out reach to do wi t h fol ks i n high places.Anthony S. BiedaAC ICS Direct or of Ext ernal Affairs750 1st St reet NE, Sui t e 980

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Wa shington, DC 28882282. 336.6781202. 905.6845 (ce l l)"Empowering Wrk force Education: 2818 ACICS l eadership Confe re nce & Meet i ng"June 8th and 9t h - Palazzo Resor t , la s Vegas Comparing H gher Ed t o Wall St reet Apri l 29,2010Whenever worried l eaders of for -profi t col l eges have i mp l ied in recent months t hat th e u .s .Educat i on Department is gunning for the in st i tut i ons . of f icia ls of the f ederal agency havedi scouraged such t alk. of fe r i ng evenhandedrhetori c about treating al l sectors t he same i n the i r pu sh f or i nc reased accountabil i ty .The wor ds have provided l i t t l e re assurance t o the colleges , s i nce they haven't always seemedt o square wi th the aggressive app roacht he Obama adm nis t rat ion is taking i n rew r i t ing federal rules governing vocat iona l and otherprogr am s .On Wedne sday, in a speech to st ate regula t ors who oversee f or-prof i t col leges. the chiefarc hi te c t of th e Educat i on Department ' s st rategy , Robert Shi reman, of fe red a mu ch morecr i t ical asses sment of the pr iva te sector in stitution s than he has i n his publi c comme nts t odate , according t o accounts given by severa l people who we re in th e room. He compared thei nst i t ut ions repeatedly t o the Wal l St reet firms wh ose behavi or l ed to the f inancial meltdownand cal led them out individually, one by one, fo r the vas t and qu i ckly i ncreas i ng sums off ederal st udent aid mon ey t hey are drawing down .Wh i l e Shireman 's comme nts we re aimed most di r ectly at t he f or -prof i t colleges themselves ,they may be mo st not eworthy for hi s i ndictment of accreditat i on. higher educat ion 's systemofin st i tut i onal peer review . In Shi rema n 's narrat i ve befor e t he annualmeet ing of the Nat ional Associationof Sta te Administ ra tors and Superv iso rs of Pr i vate Schools , the accredi ting agenci e s are tot he for-prof i t col leges wha t t he Wa l l St reet ra t i ng s agenci es were t o t he mi sbehavingf i nanc i al f i rms : ent i t i es charged wi t h regula ting an in du stry that has grown t oo quickly andt oo complex f or th em t o cont ro l , and that have an "inh erent conflic t of interest" becauset hei r exis tence depends on fin anci al contr i but i ons from t hose t hey regulate .Acc reditors lack t he "fi re power" t o regul ate t he fo r- prof i t sec to r. and the st ates and thef ederal gover nme nt don' t necessa r i ly have al l th e t ool s t hey need to do i t ei t her , Shi remansa i d. according to the notes of seve ra l in the audience. That , he sugges t ed, is why theEd uc ation Department mu st to ughen i ts ru les in the way i t is now proposing.Shirema n coul d not be reached fo r comme nt . and an Education Department spokesman said i tsoffic ia ls did not wish to comment on t his ar t ic le.To severa l people i n t he audience, Shi rem an 's comments represented a mu ch more candid (andcri tica l ) appra is al of t he for -p rofit sector than he has of f ered publ i cly s ince he becamedeputy und er sec retary of educat ion almost exact ly a yearago< http: / /www.insidehighered .com/news/2999/04/21/shi rema n> . Ma ny suppo rte rs of t he educat i oncompanies f eared his appo i ntme nt because they bel i eved his tra ck record as an advocat e f orl ow-income st udent s and a f oe of st udent debt woul d result i n a crackdown on t hei nsti tut ions . whose s t udents are di sp roportionat ely needy and di sp roportionat ely go i ntoheavy debt t o fin ance their educat i ons .But with Wa l l St reet analyst s hangi ng on hi s eve ryword l ooking f or sni ppets t hat mightt hreat en t he publ icly traded companies ' stock pr ices. Shi rema n has oft en seemed t o go out ofhi s way t o avoi d si ngl i ng the i nsti tutions out fo r cr i t ic ism.

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A typi ca l quotat ion, f rom la st summer: "Our overall goa l at t he Depar t ment of Edu ca t ion i n pos tsecondary education i s to make suret hat st udents . . . hav e the i nformat ion they need to make good choices , and t hat t hey havegood qual i ty post second ary education that ser ves bot h t hem as st udents and taxpayers aswel l , " Shireman said . " . . . I f the re i s not qua l i ty , we want to know about i t and if we can, wewant to do somet hing about i t . Whet he r that i nvolves a pub l i c i nsti tution, a nonpr of i t , afor -profit , a two -year , a f ou r -year , a trade program, wha teve r type or sector of i ns t i t ut i on,we want to do all we can to ma ke sure that we have good qual i t y . "Different ToneIn hi s comme nts Wednesday, Shi reman laid out t he cont ext under lying the Obamaadministrat ion' s elevation of hi gh er educat i on as a cent r al focu s of i ts dom es t i c pol i cies.The economi c sl ide creat ed in part by t he collapse of t he cr edi t market s has sent Americansst ream ng back t o college i n recor d number s, and has made i t mo re imperat i ve t han ever t hatmo re Americans get a hi gher education to st rengt hen t he count ry 's economc base fo r th efu tu re , Shi reman said.The admi nis tra tion has poured tens of bil l ions of dollar s i nto Pell Grant s and restru ctu redthe federal student l oan programs to t ry to ensure t hat Americans have access t o highereduc at ion, Shireman sai d Wednesday . Many publi c in stitu tions , f aci ng cuts i n t heir statef unding, have had to l im i t or even cut their enrol l ment s, reduci ng t heir abi l i ty to meet t hei ncreas i ng dema nd f rom st udents .The for -profit col leges, by cont ras t , have stepped up , seeing t heir enrollment s expl ode -and wi t h t hem, t he amo unt of Pe l l Grant mo ney t hat follows t he st udent s to the i nst i t utions,Shireman sai d . Anyone i n t he audience f romCorint hian Col l eges? Shirema n as ked t he assembledaudience Wednesday.A hand went up. The Ca l i fornia -based for -profi t hi gher ed company has seen i ts revenue f r omPe l l Grant s grow by 38 perc ent in th e f i r st t hree quarters of t his f i scal yea r compar ed t ot he l ast one, he said. Anyone from DeVry? Forty -two percen t inc rease, Shi reman sa i d. ITT ?St r aye r ? One by one, he ticked th rough a l i st of pub l i cly t raded compani es, point ing out t hei ncreas i ng amount s of fe deral money t he in s t i tutions were col l ect i ng ( " I t wa s like fo urthgrade, with a teacher scoldi ng st udent s over their grades, " sai d one person who was i n t heroom ) .What are taxpayer s and st udents gett i ng in return fo r t hat investment ? Shireman asked. I t ha shi storica lly been up t o t he "triad" -- the t hree- headed regul at ory sc heme i nvolvi ng t hef ederal governme nt , st at e government s and acc rediti ng agenci es -- to ensure acces s, qua lityand integrity i n hi gh er edu cation, he said.But i s t hat regu la tory system up t o th e job? To draw a paral le l , Shi reman no ted that as t hismeeting was un fol ding in St . Paul, poli t icians back in Washington we re debating poss iblereforms of Wall St reet , to t ry to fix t he "f l awed" regula t ory process t hat all owed Goldma nSachs and other purveyors of subpri me mor tgages to engage i n m sbehavior t hat helpeddevastate t he economy.One major reason t he process was f lawed, Shi reman said , was because the bond rating agencie st hat were supposed to be judging t he r i sk ines s of t he f i na ncia l i nstrument s were suppor t ed i nl arge part by f ees from the companies that were aski ng th e agencie s to rate t he f i nanciali nstrument s - - "a clear, i nherent conflict of i nterest , " Sh i reman sai d, according t o t heaccounts of seve ral in t he room.On top of that i nherent conflict, t he ra t i ng s agencie s have been st ruggl i ng to keep tabs oni ndustries t hat grew quickly and adopt ed i nc reasi ngl y compl ex practices, Shirema n said,

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sugges ting t hat t he ratings agenci es l acked the "firepower" t o regu late th e f i nancia lmarkets .In case anyo ne missed i t , Shi reman drove hi s point home, point ing out th at higher educat ionaccredi t i ng agencies are made up of (and f i nanci al l y support ed by) t hei r member col leges, andsee i t as t heir mis s ion both t o help t he in s t i tutions "i mprove" and also to ensure, in whati s essent i ally a subcont ract f rom t he f ederal gover nment , t hat t hey are of suf f i cientqual i ty . They are nonprof i t , unl i ke t he ra t i ngs agenci es , but they are run by theinst i t ut i on s t hey regul ate, in ways t ha t t he credi t agenc ie s aren ' t .The peer review na tu re of hi gher educat ion accreditation has an inherent conf l ict of i nte res ts im i l ar to the ratings agencies , Shireman sai d. Given t hat , he suggested , i t i s cruci al fo rstate and federa l agenc ies, as the othe r two pa r t s of the t r i ad, t o ste p up the i r ro le i nregulat i ng hi gher educa t ion.But do st at e regul ator s t hi nk t hey have t he "f i r epower" to keep t abs on t he big, growing andcompl ex pr i vat e market col lege sect or ? Shi reman asked th e st ate of f i ci al s i n t he room . Therespon se was underwhe lm ing. "I don ' t t hink we fe el we have th e fi re powe r we need, " Shirema nsai d, referri ng t o t he fede ra l gover nment ' s own powers , accor di ng t o member s of th e audi ence .The bo t t om l i ne of Shi reman 's t al k, he said, was th at "federal and st at e gov ernment s cannotre ly on accredit or s to ass ure th at consumers and taxpayers are protec t ed to f ul l extent tha tthey need t o be . All three l egs " of the th ree-legged s tool of hi gher educat ion qual i tyassurance need t o be operat i ng effec t ively, he said .Shi reman went f rom there i nto a revi ew of th e department ' s proposed new approaches t oensur i ng integr ity i n the f i nancial aid programs , such as requ i r ing mo st for- profit col legesand non-degree vocat i onal progr ams at non profi t col leges t o show t hat they are prepari ngst udent s for gain ful emp loyment ,Sever al people who heard t he speech sa id t hey viewed i t as a mu ch more st r i dent cr i t ique offor - prof i t col l eges , and of hi gher educat i on acc redi t at i on, t han Shi r eman has del i veredbefore. But David Dies, who heads t he Wscon sin Educat ional App roval Board and j ust f i nisheda te rm as president of the na t i onal group of st at e regulat ors, didn ' t hea r i t quit e t hat way ."I think Bob was explain ing wh y we need st a t e regulation and [Education] Department ove r s i ghtto be par t of th i s t hree -legged st ool , not j ust accredita t ion, and why we al l need t o worktoget her, " said Di es. "He was poi nt i ng out some l im t ation s of accredi t at ion, but I didn' tr eal ly see i t " as highl y cr i t i cal of accredito r s or for-profit col l eges .- Do ug Lederm anComment s on Comparing Higher Ed t o Wall St reet

Accredi t at i on agencies are set up to be corruptPost ed by St even D. Aird on Apr i l 29, 20 10 at 7:45am EDT. Shirema n is cor rect about the accreditation agenc i es . Even acc reditation agenci esfo r publ i c i nst i t ut i ons are mi red in a gigant i c confl ic t of i nt erest . They rece i ve money fromt he school s t hey accredi t . They are ru n by f ormer admi ni st ra t ors of var i ous i nst i t ut ions .They con t rol access to feder al f und s ; however , th ey are anyth i ng but t ranspare nt , and theyare beyond t he reach of th e Freedom of In format i on Act . The f ederal gove rnment needs t ocha nge thi s immediatel y. Everyt hi ng t ha t t hese agenc ies do or f ai l to do shoul d bedi scoverab le. Shi reman not immune to inher ent confl i ct s of i nt er est Posted by Glen S. MGhee, Dir . , at Flor i da Higher Education Accountabi l i ty Pro jec t onApr i l 29, 2010 at 8 :45am EDT. Sh i reman picks easy ta rget s , but mi sses t he l oom ng mel tdown caused by f urtheraggravat i ng cr edent i al i nf la t ion .

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The entire pu sh for accessibilty will only succeed i n creat i ng even worse credent ia li nflation than what we now have.No one -- not even Shi reman -- has the courage and fore sight to begin a discu ssion on rampantcredent ia l ism and oversc hoo l ing in the cont ext of wh at i t t akes t o creat e conf l ic t s ofinterest in accreditation and the insti tutional field i t sel f , as well as credent ia l markets.Thi s i s the wor st conf l ic t of inte re st. one which not even Sh ireman is immune t o .My con cern i s not so muc h fo r the taxpayer, but for those st udent s that lose out i n whatamounts to a ma ssive gamble t hat t he bubble won't burst before t hey graduate . Saf eguardi ng St i mul us vs . Judgi ng Qualit yPosted by Trace Urdan Research Analyst at Signa l Hi l l on April 29, 2010 at 8:45am EDT. The con f la t ion of th e need t o sa feguard St imul us dolla rs with t he accreditingagenc ie s ' job of judging academic quali t y i s clever but ul t ima t e l y just a r het or i ca l devi cedesigned t o provide cover f or t he fac t t ha t the admnistra t ion has no actual dat a t o suppo r tth e need for new "gainful employment .. regulations . So i nst ead of defend ing the r egul at ions onthe basi s of a identifiable problem regarding graduate empl oyment , now i t turns out the rule sha ve been designed for St i mu l us pro tect ion .If th e new rules are designed to protect Stimulus dollars by ty ing those dol la r s t o outcomes ,why is th e f ocus on t he cost of the programs and not th e quality of th e emp l oyme nt? And whyi s t he Pel l spendi ng at trad i t io nal schoo ls not being safeguarded by th e new measu re s . Thel ogi c of th e rules seems t o be t hat i t hardly ma t t ers how effec tive a progr am i s i f i t i spriced low enough.The fa ct i s t hat t her e i s already a r igorou s overs i ght regi me for pro t ect i ng Pe l I dollar s andi t is no l ess effec t i ve based on the amount of dol l ars f l owi ng t hrough th e system. Over si gh tfor program i ntegrity - - are the st udent s ' eligible? and are t hey act i vel y enrol led in aproper l y-a ccredited program? -- re sts squarely wi t h t he Depa rtment of Educat ion . not with theaccredi t i ng agencies . Furthermore the Depar tment has enormo us aut hor i ty t o come down hard onany in st i tut ion gui l ty of fraud or mal feasance and ha s shown no re luctance t o use that poweri n the past .Congress has ves t ed t he accredit i ng agenci es with the res ponsi bi l i t y not fo r judgi ng t heintegr ity of t he Ti t le IV program but f or ens ur i ng a suff i cient l evel of academ c qu ali ty .The accredi t i ng agenc i es may or may not be out -ma nned in t his t ask and they may or may not beconf l i ct ed. Bu t t hey are no l ess out-ma nned or conf l icted i n j udgi ng the quality and purposeof traditional publicly-funded and not -for -profit col leges and universi t i es. In t erm s of theassociat ion wi t h rat ings agencies, t he compa r i s on is an un f ai r one . Rat i ngs agencies are forprof i t compani es wi th an interest i n growth. Accredi t i ng agencies ar e s leepy not -for -profitf irms whose f undament al work is accom pl ished by academic professionals and col l ege pres i dent swh o of t en are j ust as bia sed agai nst fo r-prof i t sc hools as Mr . Shi reman seems to be .Mr . Shireman i s a pol i t i cal l y-appointed l obbyi st and former Congressional sta f f e r who managedt o sl i p into a created pos i t ion that ha s turned out t o be t he mo st importan t ro le in theObama admin i stra t ion relat ive t o post -secondary educat ion. without f aci ng Senat econf i rmat ion. But as br ight and well - int entioned as he may be, he is no mo re equi pped t ojudge academ ic effect ivenes s than I am . And i f he i s decided to second- guess the wo r ki ngacademc prof ess ional s who actua lly provide th e over s i ght over academic in st i tut ions, at somepoint he wi l l have t o answer to Congress.* Transparent , sea rchabl e , account able* Posted by Robert Al brecht , Professor /Engl i sh and Humanities at Al f red State Co l lege on

Ap r i l 29, 2919 at 9 :90am EDT Steven D. Aird is hal f r ight : all accreditation processes and records for allin st itu t i ons shoul d be transparent and searchable ; th e out come wi l l be accountability.

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But t he cha rge tha t accredit at i on agenci es are set up t o be corrupt i s mis leading,in accurate, and final ly, I believe, wit hou t ev idence. I cannot speak for al l reg ionalcommissions, but I do know that the Middle States Commiss ion on Higher Educat ion is no t onlyfar from corrupt , but that i t f unct ions with great i ntegrity and careful al legiance to i tsdocuments . Peer review, wh ile de l ibera t e and painstaking and t ime consuming, f ina l l y involvessome three dozen inst itutions in most accredi t at i on dec is ions -- comprehensive by anystandards. Furt her, i t s accreditat ion act ions are avai l a ble to the public t hrough i t s webs i te .Robert Shireman i s right to asse rt that accred i ta t i on agencies see as one of theirobligations t o "help" i ns ti t ut i ons in tr-oubke . And he i s r ight tha t the agencie s are notcurrently f ul ly set up to fulf i l l a more r igorou s regul atory role. However, good regulati on sand peer eval uat ion should ha ve "helping" as a commo n purpose . The demands of regionalaccredi t ors for specif ic evidenc e, data col lected over t i me , and at tent ion t o planning andassessment , on one hand, and the requirements of wi se regu la t ions fr om any gover nment body,on t he ot her , need not conf lic t . Cl ear l y regional acc redi t ors mu st l ook i nward - - quickl y -to promote greater tran sparency and accountabi l i ty, and i nde ed thi s wi l l change t heir ro leand relat ion ship with member in st i tut i on s . But "corrupt" ? Show us the data.[cid: i mage001 . png@91CAE770 .DBCE0240] [cid : image002 .gif@e l CAE770.0BCE0240] Contact Us Our Staff Abou t Us Work For Us Press Releases Rights and Pe rmi ss i ons Pr i vacy< ht t p: / /www . insidehighered. com privacy_s ta tement> Adver tise Par tner s Test imon ia l s RSS l i nks Blog Roll

@ Copy r ight 2010 I nsi de Hi gher Ed

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From: Stac k, Kathryn B.sent: Monday, June 21,2010 6:16 PMTo: Walizer, Lauren ; Graham, William; Skelly, Thomas; Martin, Ca rmel; Smith, Zakiya; Campbell, Neil; Gordon, Robert M.;Rowe, David; McNeece, Erin; Lee, Nicholas C.; Lyberg, Sarah A.; Taggart, Bill; Hurt, John; Arsenault, Leigh; Francis,Ushaun; Gebhard, Margaret M.Cc: Emanuel, Elizabeth N.s v btecn RE: A enda for RESCHEDULED : f ollow-U

From: Walizer, Lauren [mailto:[email protected] ]sent: Monday, June 21, 20102 :13 PMTo: Graham, William; Skelly, Thomas; Mart in, Carmel; Smi th, Zakiya; Campbell, Neil; Gordon, Robert M.; Rowe, David;McNeece, Erin; Lee, Nicholas Co; Lyberg, Sarah A.; Stack, Kathryn B.; Taggart, Bill; Hurt, John; Arsenault, Leigh; Francis,Lishaun; Gebhard, Margaret M.Subject: Ag enda for RESCHEDULED: Follow-Up Meet ing : Student Loan Meet ing with OMS

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Fro m :Sent:To:Subject:

Stack, Kathryn B. [Kathryn_B._Stack@omb .eop.gov]Thursday, June 24, 2010 11:17 AMKvaal, JamesRe: Agenda for RESCHEDULED: Follow-Up Meeting: Student Loan Meeting with OMS

Yes. Dan is great for this. Tom Weko will be an imp ortant contributor too I assume.

From: Kvaal, James To : Stack, Ka thryn B.sent: Thu Jun 24 10:38:16 2010Su bj ect: RE: Agenda for RESCHEDULED: Follow-Up Meeting: Student Loan Meeting with OMBWe are likely to ask Dan to coordinate th is work when he return s to his permanent role, wit h representation fr om thefive offices you suggest. Make sense?

Fro m: Stack, Ka thryn B. [mailto: Ka thryn_B._S [email protected]]Sent : Wednesday, June 23, 2010 7: 13 PMTo : Walizer, Lauren; Gra ham, William; Skelly, Thomas; Martin, ca rmel; Smith, Zakiya; Campbell, Neil ; Gordon, Robert M.;Rowe, David; McNeece, Erin; Lee, Nicholas c.: Lyberg, Sa rah A.; Taggart, Bill; Hurt, John; Arsenault, Leigh; Francis,Ushaun; Gebhard, Margaret M.; Weko, Tom; Kvaal, James; Shireman, BobCc: Emanuel, Elizabeth N.Su b ject: RE : Agenda for RESCHEDULED: Follow-Up Meeting: Student Loan Meeting with OMB 1

From : Stack, Kathryn B.se n t: Monday, June 21, 2010 6 : 16 PMTo : Walizer, Lauren; Graham, William; Skelly, Thomas; Mart in, Ca rmel; Sm ith, Zakiya; campbell, Neil ; Gordon, Robert M.;Rowe, David; McNeece, Erin; Lee, Nicholas c.; Lyberg, Sarah A.; Taggart, Bill; Hurt, John; Arsenault, Leigh; Francis,l ishaun; Gebhard, Margaret M.Cc: Emanuel, Elizabeth N.Sub j e ct: RE : Agenda for RESCHEDULED: Fo llow-Up Mee ting: Student Loan Meet ing with OMB

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"From: Walizer, la uren [mailto:la uren.Walizer@ed .gov]Sent: Monday, June 21, 2010 2:13 PMTo: Graham, William; Skelly, Thomas; Martin, Carmel; Smith, Zakiya; Campbell, Neil ; Gordon, Robert M.; Rowe, David;McNeece, Erin; l ee, Nicholas c.: Lyberg, Sarah A.; Stack, Kathryn S.; Taggart, Bill; Hurt , John; Arsenault, Leigh; Francis,Lishaun; Gebhard, Ma rgaret M.Subject: Agenda for RESCHEDULED: Follow-Up Meeting: Student Loan Meet ing with OMSSee at tached the agenda fo r t omorrow 's di scussion .

Meeting to continue discuss ionsbetween OMBand ED on the student loan model, costing methodology and assumptions, and otherissues.The meeting will be held in the Dept of Education building, room 7(100.If you are not able to attend in person, please notify the organizer of the meet ing (l auren Walizer) and she will send call -ininfo rma tio n.

This is a rescheduled meet ing tha t was or iginally to be held 6/17 at 2pm .

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From :Sent:To:Subject:

From: Pauline Abe rnathy (mailto:[email protected]: Wed nesday, June 16, 2010 6:28 PMTo: Kvaa l, JamesSubject: What's your phone number these days?

Pauline AbernathyVice PresidentThe Institute for College Access & Successwww .ticas .o rg and ' ! N ' N W ~ t n s u d t . TICAS: 510.318.7900 Direct: 510.318.7903

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From:Sent:To :Subject :Attachments:

Mart in, PhilTuesday, June 01,20103:18 PMShireman, BobFW: Today's CallHEFTS_2P9_060110.pdf

FYI - ta lking to morgan Stanley today to learn more, they sent across these bullet s w ith th eir own proposal. (includesf inancing DL th rough different mechanism, treasury doesn' t support / like the idea, just wanted to make sure you had it.]Will let you know if we learn anything good on the call.

-rom : Brown, M c h e l , ~ ~ Sen t : Tuesday, June 01';'2010 2:57 PMTo: Martin, Phil; [email protected],gov; John [email protected] reas.govCc: Graham, William; Wilson, JamesSubject: RE: Today's ca ll

Gentlemen-Please see the attached t -paqe summary of the strategy that we wou ld like to discuss on today's call.Michae l Brown, Managing DirectorMorgan Stanley I Global Capital Markets1585 Broadway I Floor 04New York, NY 10038Phone: +1 212 7612110Fax' +1 212 507.5086b)(6)

From: Martin, Phil [mailto:[email protected]]sent : Tuesday, June 01, 2010 10:04 AMTo : Brown, Michael (GCM); aaron.klein@do,treas.gov; [email protected]: Chavers, Kevin (FlO ); Graham, William; Wilson, JamesSubject: RE: Today's Ca llLooping William Graham and JamesW ilson who will be on the call for ED .From: Brown, Michael _Sen t : Tuesday, June 01, 2010 10:01 AMTo: Mart in, Phil; [email protected]; John [email protected] reas.govCc: Chavers, KevinSubject: Todav's ca llGentlemen-I just wanted to check in to see if you have specific questions or topics that you wou ld like covered on today's call.Best-Michae l Brown , Managing Di recto rMorgan Stanley I Global Capital Markets1585 Broadway I Floor 04

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New YOfk. NY 10036Phone: +1 212 761-2110Fax' +1 2' 2 507_5086l(b)(6) rOfQanstanlev.com

NOTICE: Ifreceived in error. please destroy. and octlfy sender .Sender sees oct inleod 10 waive con fidential. , or prMIege. Use of this email is prohibited....nenreceived i1 error.We may morulor and store ema lls to the extent permuted by a p p l i c a b l e ~NOTICE: "received in error. please destroy. and octlfy sender. Sender eoes oct inleod 10 waive confodenliahty or privilege. Use of this email is prohibite


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From:Sent :To:Subject:

From: Shireman, BobSent : Friday, May 21, 2010 11:00 AMTo: Tobin, KatherineSubiect : RE: REMINDER : Bam Senior Staff Meetin Tomorrow -- Materia ls for those on the phoneb)(5)

From: Tobin, KatherineSent: Friday, May 21, 20 10 10:35 AMTo: Shireman, BobSubject: RE: REMINDER: Bam Senior Staff Meeting Tom orrow -- Materials for those on the phoneFasc inatingmeeting....thanks for the information below. I was on the telephone and this helped me follow.Thanks, Bob !KatherineFrom : Shi reman, BobSent: Friday, May 21, 2010 7:53 AMTo: Haro, Adrian; Mye rs, Sam; Yale, Matt; Cunningham, Peter; Miller, Tony; Wha len, Ann; Martin, Carmel; Smith,Marshall ; Snyder, Jason; Shelton, Jim; Ali, Russ lynn; Anderson, Jo; Da rnieder, Greg; Groff, Peter; Jupp, Brad ; Wa ldo,Eric; Muenzer, Me lanie; Weiss, Joanne; Rose, Charlie; Cummings, Glenn; Sepulveda, Juan; Jennings, Kev in; Gomez,Gabriella; Wilson, John ; l ee, Andrew; Immerman, Suzanne; Jones, Jacqueline; Easton, John ; Vadehra, Emma; Horwich ,ll oyd; Du ran, Maribe l; Bo rde rs, T ie : Arsenault, l eigh ; Sprow, Stephanie; Melendez, Thelma; Walle r, Jen ; Barrett, Tarik;Secretary's Conference Room (OS Managed ); Dann-Messier, Brenda ; Kan ter, Martha; Hamilton , Justin; Ab revaya, Sandra ;Tobin, Katherine; Posny, Alexa; Shelton, Betsy; Bissonnette, Michelle; Cator, Karen ; Lai tinen , Amy; Dunbar, Adrienne;Uvin , Johan; Ahuja, Kiran; Wurtzel, Judy; Ande rsen, Susie; Chong, Frank; Lamb, Michael ; Spe llma n, Rene; Harris, Carl;Aylward, Rayna ; l agdameo, Christina; Solomon, CathySubject: RE: REMINDER: 8am Senior Staff Meeting Tomorrow -- Materials for those on the phone

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Tobin, Ka therine; Posny, Alexa; Shelton, Betsy; Bissonnet te, Michelle; Catoe, Karen; la itinen, Amy; Dunbar, Adrienne;Uvln, Johan; Ahuja , Kiran; Wurtzel, Judy; Andersen, Susie; Chong, Frank; lamb, Michael; Spellman, Rene; Harr is, Carl;Aylward, Rayna; lagdameo, Christina; Solomon, CathySubject: REMINDER: Sam Senior Staff Meeting TomorrowDear all :A quick reminder about tomor row s8am Senior Staff Mee ting. Bob Shireman will give a presentation on programintegr ity. Dial -In information is listed be low . Thanks.Dial-In Informat ion:Number: 877-937-6173Participant Code: 7243925#Best,Adrian

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From :Sent :To :

Cc:Subject:

l(b)(6) bavid Hawk ins nacacnet.org]Monday, May 17, 2010 4:05 PMPauline Abernathy; Margaret Re iter; Amanda Modar; Angela Peoples; Barmak Nass irian;[email protected]; Connie Myers; Deanne Loonin; Debbie Frankie Cochrane; JamesSimpson; [email protected]; Lauren Asher; Liz Baldwin; Luke Klipp; MargaretReiter ; Steve Burd; Susan Lehr; Edie IronsMichelle Rodriguez; Luke Klipp ; Laura Szabo-Kubitz; Dannenberg, Michael; Shireman, BobChronicle letter

The Chronicle published a letter I submitted in response to an article they pub lished on state authorization a few weeksback.httD:llchronicle.com/article/Debate-Over-Proposed-Rule/655621

David HawkinsDirector of Public Policy and ResearchNational Association for College Adm iss ion Counseling1050 North Highland Street, Suite 400Arlington, VA 22201Ph. (703) 836-2222 xl09Fax (703)373-2369NACAC on theWeb: WW'N .nacacnel.org

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From:Sent:To:Subject:

I ' l l be on t he phone .

Shireman, BobFriday, May 14, 20104:32 PMMcFadden, ElizabethRe: Gainful Calendar(b)(6)

- - - - - Original Message --- - From: Mc Fadden, ElizabethTo : Shireman, BobSent : Fri May 14 15: 27 :13 2010Subject: RE: Gainful Ca lendarI will bri ng th em to t he 5:00 meeting.Georgia was referring to t he one-page summary you did.-- - - -Original Me ssage- ---From: Shirema n, BobSent : Friday, May 14, 2010 4 :20 PMTo : McFadden, ElizabethSubject : Re : Gainful CalendarElizabeth, please share t he EDMC metrics when you have a chance.When Geo rgia refer red to my calendar, did she mean the one-page summary I di d?-- - - - Orig inal Me ssage ---- From: Yuan, Georg iaTo: Ml ler , Tony; Shi reman, Bob; Bergeron, Davi d; McFadden, Elizabet h; Finley, St eve;Madzelan, DanSent: Fri May 14 14:01:48 2010Sub;ect: Ga i nf ul Ca lendar)(5)

'Georgi a

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From:Sent:To:Cc:Subjec t:

Glickman , JaneFriday, May 07 ,2010 8:27AMManheimer, Ann; Arsenault. l eighBabyak, StephanieFW: BobShirema n remarks

Ann or leigh - - Hechinger In stitute person i s as ki ng (see below)can you confirm t hat we are aimi ng fo r a Nov . 1 Final Rule and can we say th e NPRM i sexpected, therefore, some t i me t hi s summer?Thank s - - Jane and Steph-----Original Message - - jeb)(6)From : Wl len, Eli zabeth , ,"', ,'"";


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From:Sent :To:Subject:S)

Robert ShiremanDeputy UndersecretaryU.S. Department of Education(202) 260-0 10 1

Shireman, BobThursday, May 06, 2010 8:46 PMMiller, EliseRE: Quick question for you

From : Miller, EliseSent: Thursday, May 06, 2010 7:24 PMTo: Shireman, BobSu bje ct : QUick quest ion for youIf you are available for aquick question, can you give me a ca ll on my wor/( #: 202-502-73187 " Ube here pretty late. Thanks!Otherwise, I' ll touch base wi th you in the morning. t 'Elise Mil lerProgram Directo rPostsecon dary I nst i tutiona l Stud ies ProgramNati onal Cent er for Edu cation St at ist ics1990 K St ree t, NWRoom 811 3AWashing to n, DC 20006Elise.MiIler@ed .gov(202) 502-731 8(202) 219-7079 (Fax)

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Thank you for forwarding Mr. Rodriguez ' s letter to Secretary of Education Arne Duncan. We appreciatehearing from you.His letter has been forwarded to the appropriate stafTmembcr for review.Thank you again for contacting us.Sincerely,Edgar MayesDirector of Correspondence andCommunications Control UnitOffice of the SecretaryU.S. Department of EducationWashington, DC 20202

Fro- ; ; - l orena L 1 i c \ , " ) . . . J ~ I J r o d d c m Sent: Tuesday, May 04, 2010 4:07 PMTo: Duncan, ArneCc: [email protected]: Be rgeron, David; Sorensen, Howard; Aspling, David; Tighe, Kathleen S.; Shireman, BobSubject: letter to Sec retary Duncan from the Alliance for Economic Stability, I nc.Dear Sec retary Duncan,Please find attached a let ter f rom the Alliance for Economic Stability , Inc. regarding Bridgepoint Educat ion, Inc.lorena M. l I ivichuzca747 Third Avenue , 25th FloorNew York, NY 10017Tel. (212) 702-8805Fax (2 3465Email: (b)(6) mil1rockllc.com

ThiSmessage is lor the intended recipient's use only. It is not to be retransmitted without the express witten consent of the sender. This e-mail maycontain confidential. propnetary Of' legalty privileged Inlonnatioo. II you receive this message in error, please immedia tely dele te it and notify the sender .You must ro t. directly or indirectly, use , disclose. distribute . print. Of copy any part of this message il you are not the inleocled recipient.Copies of 'Mitten communcancos (ioduding e - m a may be kept and archived indefinitely. This may iodude this e-mail. and any e-mail reply made to it

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Alliance For Economic Stability, Inc.747 Third Avenue, 25th FloorNew York, New York 10017

May 4, 2010Arne Duncan. SecretaryU.S. Department of EducationLBJ Education Building400 Maryland Avenue, SWRoom II 7W311Washington, DC 20202Dear Secreta ry Duncan :We believe that Bridgepoint Education. Inc . is operating counter to the intent and explicit provisions ofcurrent U.S . Jaw covering post-secondary educational institutions receiving funds as pan of Title IV ofthe Higher Education Ac t of I% 5, as reauthorized (the " I lEA') .As you may be aware, Bridgepoint owns Ashford University and the University of tbe Rockies. though itis Bridgepoint's administration of Ashford University that is of particular concern. In 2004, Bridgepointwas started by a Wall Street private equity fund in partnership with former executives from ApolloGroup. Inc. In 2005, Bndgepomt acquired the Franciscan University ofthe Prairies, a religious-afftliat edinstitution with approximately 300 students , with revenues estimated to be less than SIO million .Bridgepoint renamed the inst itution Ashford Un iversity, and drove enrollment through Ash ford ' s onlineprogram to a reported 65,788 students as ofMarc h 31, 2010. with revenues ofS526 million in the lasttwelve months.This g rowth has come not from educational pe rformance but from an incenrivized sales force of over1,400 sa lespersons equal to one for every 44 students, and growing. Astonishing ly, the vas t majority ofthis sales personnel growth occurred while the Office of Inspector Genera l (" DIG") of the Department ofEducat ion ("DOE' '} was supposedly work ing to remediate Bridgepoint 's use of taxpayers ' funds to paysales pe rsonnel in vio lat ion of DOE regulations .See Table I, which shows the growth in Bridgepoint 's student enrollment, and Table 2, which shows thegrowth in Bridgepoinr's revenues .Our foremost concern about Bridgepoint is that the company is directly violating DOE regulationssurrounding "Safe Harbors" for incentive compensation payments to employees . Bridgepoint em ployeeswho enroll students a re compensa ted sole ly and exclusively for their sales work.Bridgepoint 's business relics upon paying its massive sa les force for enrolling ind ividuals ....he have littleto no ability to evaluate their alternatives or the cost and benefit of a Bridgepoint education.Bridgepoint sets its tu it ion fees to be significan tly low cr than other large, publicly-traded companiesoperating for-p rofit online universities . The tuition fees of Argo s)' University, the University of Phoenix,


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Secretary DuncanMay 4, 2010Page 2 of2and DeVry University are 37% to 55% higher than those of Bridgcpoint's Ashford University. See Table3.

Even with signifi cantly lowe r tuition fees, Bridgepoint consi stently spends more tuition revenue onmarke ting than on actual instruction. See Table 2. Bridgepoint spent more than $44 million on marketingand promotions in the quarter ended March 3 1. 2010. This was nearly triple the amount that Bridgepointspent for the same period of 2008. This increase was during the time of the compliance audit of AshfordUnive rsity conducted by OIG.Bridgepoint also devotes a far lower portion of its tuition revenue to providing instruction than similarcompanies. See Table 3. Bridgepoint devotes a far, fur lower portion of tuition fees to instruction thanmore traditional and reputable not-for-profit educational institutions.While other companies operating for-profit, online universities have been able to obtain deferentialtreatment from the DOE, we believe that Bridgepoint ' s abuse of regulations surrounding Title IV fu ndingand of the intent of the HEA is far more egregious than even any of its for-profit counterparts.Bridgepoint evidences aggressive enrollment tactics, illegal incentive compensation, and an incrediblylow port ion of tuition devoted to instruction. Even in an industry built on abuses of a governmentprogram, Bridgepoun's irregu larities stand out.The DOE has the authority not only to pursue typical sanctions, but to conduct a more broad-based reviewof abuse by Bridgepoim of DOE regulations and of the intcnt of the HEA and to issue sanctions moremu ch more severe than the sanctions the DOE has typically imposed upon for-profit, onl ine educationproviders. The DOE' s past sanctions offor-profit education providers have fa iled to rcmediate hann andhave had the contrary effect of providing incentive to engage in the abuses discussed above.On a personal note, for over a decade, I have been an adjunct professor of business at various communityand four-year colleges, and I know fi rsthand the effects that a lack of financial aid has on students' abilityto obtain a college degree within a reasonable amount of t ime. Many students find themselves workingfull -time or pa rt-time jobs just to fund a portion of their higher education. Tbe enrichment of theseprivate enterprises at the expense of Am erican students who arc this country's fu ture is dep lorable.

cc: Peter Cunn ingham, Assistant SecretaryOffice of Communications and OutreachKa thleen S. Tighe, Inspector General.Off lcc of the Inspector Gene ralDavid Bergeron, Director of Policy ,Planning and Innovat ionOffice of Postsecondary Education

Enc losures

Robert Shireman. Deputy UndersecretaryOffice of the Under SecretaryDavid J.Aspling, Assistant Special Agent in ChargeOffice of the Inspector GeneralHoward Sorensen, General CounselOffice of Inspector General


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Brldgepolnt EducatIon, Inc. IBPI)Table 3Tui tion Fees Per Undergraduate Cred i t Hou r fo r BPr s Ashford University and Comparables

University UickerlAshford University (BPI)DeVry Universrty {DV)University of P h o e n i (APOl )American InlerContinenlal University {CECD)Strayer Un iversity (STRAtArgosy University (EDMC)

Average Tuition

Tuition Fee372

5755303903535"455

% above (below) Ashford

55%42%5%-5%37%

22%

1: The American InterContinental Universily tuition fee listed isfor non-degree students laking undergraduate level classes.2: Strayer charges $1 .590 per course for undergraduate part-time students: al lcourses are 4.5 credit hours. CPLA and APEI are not included. as Capella has a complicated fee structure, varying byundergraduate course level. and APEI caters more to the military community than Title IVrecipients.

Prepared 4119110


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From:Sent:To:Subject:Attachments :

Shireman , BobTuesday, May 04, 2010 4:05 PMCunningham, Peter; Hamilton, JustinFW: THE SUB-PRIMING OF STUDENTS: WHAT YOU NEED TO KNOW BEFOREENROLLINGSub-priming for studente-e financial crisis in education.doc

Fro; ; ;Lehr, Susan M.I(b)(6) f s c j e 1s ent: Tuesday, May 04, 2010 3:30 PMTo: Sellers, FredSubjec t: FW : -mE SUB PRIMINGOF STUDENTS: WHAT YOU NEED TO KNOW BEFORE ENROLUNGTh ought you might like to see what we have done!SusanFrom: Co rby, Michael E.sent: Tuesday, May 04,2010 3:10 PMSubject: -mE SUB-PRIMING OF STUDENTS : WHAT YOU NEED TO KNOW BEFORE ENROLUNG

Media AdvisoryMarketing and Communications

MEIlIA ADVISORYMedia contact:1\.1 ichael Corby904-632-3310

May 4, 2010

TI lE SUB-PRIMING OF STUDENTS: WHAT YOU NEE D TO KNO W BEFORE ENROLLING"College. Inc." FRONTLINE May 4 broadcast sheds light on/o r-profit educational instinaionsThere' s trouble at the intersection of Wall Street and College Avenue of Dreams. Two Florida State

Co llege at jacksonville administ rators want 10 help students-eny studcnts-c-steer clear of a serious financi alcrisis in education.

In a May 4 airing o f Front line, Public Broadcasting System affiliates, including WJCT in Jacksonville(Comcast ch. 8 and ch. 440 at 9 p.m.), will explore "Co llege, Inc.," a report on government funding offo r-profi tcolleges and universities. From the PBS Frontline press release:

"Higher education is a $400 billion industry fueled by taxpayer money. One of the fastest-growing--andmost controversial-csectors of the industry is the for-profit colleges and universities. Unlike traditional collegesthat raise money from wealthy alumni and other donors. many for-profit schools sell shares to investors on WallStreet. But what are students gelling out o f the deal? Critics say a w orthless degree and a mountain o f debt .. ."

Data released by the Department o f Education seems to support that stance. As reported in the May 3Chronicle o f ll igher Education, the default rate was higher for borrowers who attended for-profi t schoo ls {at

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LINKS :

11.9 percent) than for borrowers who attended public colleges (at 6.2 percent) or private colleges (at 4 .1percent).

The two Florida State College administrators. Vice Pres ident for Government Relations Susan Lehr andAssociate Vice President for Workforce Development Jim Simpson, have followed the money rigorously andadd their perspectives. with some startling facts about the path that money takes. Their interest stems from theirCollege' s involvement as a state leader in workforce development. The reality is that many oft he fantast ic jobsand salaries promised by the for-profit schools never materialize, and as Lehr explains:

"The way it works is this: The student is recruited . The student comes. they sign them up for loans. thetuition is paid. the school gets its money. the student gets the debt. and when the student defaults. the taxpayerhas to pay that."

In a comparison of the origins of Jacksonville student loan defaults. the facts are alarming. Accordingto Simpson's calculations. for-profit schools account for 8.7 percent of post-secondary enrollments inJacksonville. Yet they account for 48.4 percent-nearly half-of student loan defaults. More than one in sevenof their students, or 14.4 percent of their enrollment, end up in default on their loans. Compare that with 1.24percent of the total enrollment of students in public institutions who de fault on their loans.

For Lehr and her College, it' s not about competition for students. Enrollment increased 35% over thepast three years at Florida State College at Jacksonville.

There are other concerns tied in with this very complicated issue, but it ' s primari ly an issue o fconsumer awareness.

"The student needs to understand what it is they're seeking. ... said Lehr. "What kind of training, docs mattraining have specified types of accreditation? The other thing they need to look at is cost. ... is it an amountthey can affo rd? If something isn't affordable. it's not very good access: '

Lehr and her colleague Jim Simpson have spent weeks listening and talking to legislators in Tallahasseeand on Capitol Hill. They have amassed fa cts and details about costs; accreditation issues that affect students'ability to transfer credits t o another school or degree program; job placement and employment opportunities;and defaults on student loans. What's their purpose?

"Our concern is that students are being inappropriately enticed into believing that they' re going to getsomething that they may or may not get. and it's costing them a fortune." Lehr explained. "When thathappens. the students o ften end up on our doorstep, and a lot of t imes we can't help them. They've maxed outon federal financial loans and they have no more capacity for loans. It happens quite often."

l\IEDIA OPPORTUNITY: Susan Lehr and Jim Simpson ar e available for interviews. CGs areat tached from DVD of interviews with Lchr and Simpson and copies of the DVIl ar e available 10 mediaas well. A cur rent student who discovered too late that credits from her former college would not transferto a state school, is also wtlllng to talk to media, upon request.-30-FlOrida State College at Jacksonville isaccredited by the Commission on Colleges 01the Southern Association of Colleges and Schools 10award the baccalaureate degree aod the associate degree . Contact the CommiSSion on Colleges at 1866 Southern lane. Decatur, Georgia30033-4097; or call 404-679-4501 for coestcos about the accreditation of Flofida State College at JacksonviMe.

4'


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Chronicle of Higher Education : http:U chronicie.com/ art icte/ OefaultRates-for-Student/ 65387/Frontline: ht tp:Uwww.pbs .org/wgbh/pages/ front line/ collegeincl

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H f a c e son vut eMEDIA ADVISORYMedia contact:Michael Corby904-632-3310 desk; 904-608-0415 cell

Media AdvisoryMarketing and CommunicationsMay 4, 2010

TIlE SUR-PRIMING OF STUDENTS: WHAT YOU NEED TO KNOW IIEFOREENRO LLING"College. Inc.. " FRONTLINE broadcast sheds light on/or-profit educational institutionsThere' s trouble at the intersect ion ofWall Street and College Avenue of Dreams. Two

Florida State College at Jacksonville administrators want to help stud ents-carry students - s teerclear of a serious financial crisis in education.

In a May 4 airing of Frontline. Public Broadcasting System affiliates, including WJCfin Jacksonville (Ccmcast ch. 8 and ch. 440 at 9 p.m.), will explore "College, lnc.," a report ongovernment funding of for-profit colleges and universities. From the PBS Frontline pressrelease :

"H igher education i s a $400 billion industry fueled by taxpayer money. One of thefastest-growing-end most controversial- sectors of the industry is the for-profit colleges anduniversities. Unlike traditional colleges that raise money from wealthy alumni and otherdonors, many for-profi t schools sell shares to investors on Wall Street. But what arc student sgetting out of the deal? Cri tics say a wo rthless degree and a mountain of debt .. ."

Data released by the Department of Education seems to support that stance. Asreported in the Ma y 3 Chronicle of 11igher Education, the default rate was highcr for borrowerswho attended for-profit schools (at 11 .9 percent) than for borrowers who attended publiccolleges (at 6.2 percent) or private colleges (at 4 .1 percent).

The two Flo rida State College administrators, Vice President for Government RelationsSusan Lehr and Associate Viee President for Workforce Development Jim Simpson, havefollowed the money rigorously and add their perspectives, with some startling facts about thepath that money takes. Their interest stems from their College's involvement as a state leaderin workforce development. The reality is that many of the fantastic jobs and salaries promisedby the for-profi t schools never material ize, and as Lehr explains:

"The way it works is this: The student is recruited. The student comes, they sign themup for loans, the tuition is paid, the school gets its money, the student gets the debt, and whenthe student de faults, the taxpayer has to pay that."


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In a comparison ofthe origins of Jacksonville student loan de faults, the facts arealarming. According to Simpson' s calculations, for-pro fit schools account for 8.7 percent ofpost-secondary enrollments in Jacksonville. Yet they account for 48.4 percent- nea rly hal f- -a fstudent loan defaults. More than one in seven of their students , or 14.4 percent of theirenrollment, end up in default on their loans. Compare that with 1.24 percent of the totalenrollment of students in public institutions who default on their loans.

For Lehr and her College, it' s not about competition for students. Enrollment increased35% over the past three years at Florid a State College at Jacksonville.

There are other concerns tied in with this very complicated issue, but it' s primarily anissue of consumer awareness.

"The student needs to understand what it is they're seeking," said Lehr. "What kind oftraining, does that training have specified types of accreditation? The other thing they need tolook at is cost. ,., is it an amount they can afford? I f something isn't affordable, it's not verygood access."

Lehr and her colleague Jim Simpson have spent weeks listening and talking tolegislators in Tallahassee and on Capitol Hill. They have amassed facts and details about costs;accreditation issues that affect students ' ability to transfer credits to another school or degreeprogram; job placement and employmen t opportunities; and defaults on student loans . What' stheir purpose?

"Our eoncern is that students are being inappropriately enticed into believing thatthey're going to get something that they mayor may not get, and it's costing them a fortune,"Lehr explained .....When that happens, th e studen ts often end up on our doorstep, and a 101 oftimes we can't help them. They've maxed out on federal financial loans and they have nomore capacity for loans. It happens quite often."

!\lEOlA OPPORTUNITY: Susan Lehr and Jim Simpson are available forinterviews. CGs arc attached from DVD of interviews with Leh r and Simpson and copiesof the DVD are available 10 media as well. A current student who discovered too lat e thatcredit s from her former college would nollransfer 10 a sta te school, is also willing 10 talkto media, upon request.-30-

Florida State College at Jad


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LINKS:Chronicle of Higher Education: http:Uch ronicle.com/article/Default-Ra tes-for-S tudent/65387/Frontline: http:/ /www.pbs .org/wgbh/pagesL l ro"! I!nelco lIege!nct

eGs : Susan LehrN P. Government Relations/Flor ida State College Jim SimpsonfAVP, Workforce DevelopmenUFlorida State Co llege

Susan Lehr's log sheet:"Hello. I am Susan Lehr, Vice President for Government Relations for Florida State College atJacksonville.-"The US Department of Education is writing a new set of rules that govern the higher educationact which governs all of the institutions of higher education in the nation. The focus of theseparticular ru les relates to federal financial aid and the amount of money that students mayborrow to go to college. While this affects all institutions, it really has the most dramatic effect onthe for-profit industry because the regulations don't touch degree programs in public institutionsand not-for-profit institutions.""Congress first authorized for-profit institutions to have access to federal financial aid , under thecondition that they prepared students for ga inful employment. That's in the law for the for-profitinstitutions and for institutions that do training for less than a degree. For example, Florida StateCollege at Jacksonville has a lot of vocational programs that are non-degree programs. All ofthose programs are impacted by this negotiated rule that the Department of Education is justabout to put out."'There was no definition for gainful employment. There really never has been. So, there' s atremendous difference between the public sector - at least in Florida - and the for-profit sector.The public sector in Florida has third-party verification of employment. The for-profit sector iswelcome to participate , but choose not to. A very small percentage of for-profit schoolsparticipate in third-party verification of employment and how much the person earns."' The for-profit industry is se lf-reported. So they report whe ther or not a person goes to work,they report how much a person earns; whereas in Florida , in the public sector, the state verifieshow much a person is earning and indeed whether or not they're working at all. ""How we got interested in it is... a number of students came to our institution that have alreadygraduated or completed credits or certificates from some of these for-profit schools but theydon 't have a job and they have a lot of debt. They come to our college hoping they can eithertransfer those credits into our programs or ge t a credential that will allow them to get a good paying job.""One of the differences between our institutions and the for-profit institutions has to do withremed iation. As you know, I think it's approaching 70 percent of the students tha t go to postsecondary school have to have remediation. Well, there's a reason that they need remediationin order to do upper level work. Most of the for-profits don't offer remediation. Frankly, a lot ofthe students, they buy the quick-and-easy. Quality education isn't quick-and-easy. It requiressome preparation and work on the students' behalf. A lot of times, students are look ing for theshort cuts , and it costs them a lot of money."


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"When the debt becomes so big and the student can't earn enough to make the payments, itgoes into default. The student cannot discharge, except in very rare circumstances, they cannotdischarge that debt through bankruptcy. It will follow them their entire lives. They cannot goback to school until those debts are paid so it really stops their educat ion and it straps themfinancially. A lot of times they can't afford to buy a car. Very often the payments on these loansare the size of a mortgage so they can' t buy a house or really participate in the economicrecovery of the nation:"It's very much like sub-prime mortgages, where the pitch was, 'Oh you deserve this wonderfulhome. Don't worry about your salary, I am sure you're going to make more money in the future;we're going to get you into this mortgage really inexpensively, and... Sign here.' People buy thatAmerican dream of owning their own home. That's exactly what's happening; in fact it's calledthe sub-priming of students. What happens is the for-profit companies, corporations and schoolsrecruit these students, they sell the dream. 'Come here, we're going to help you get a greatca reer, you're going to earn lots of money, don't worry about the size of this loan because you'regoing to make this money in no time in your new career.'"We have a tremendous increase in students at Florida State College at Jacksonville. We reallydon't need to go out and recruit more students. Our concern is that students are beinginappropriately enticed into believing that they're going to get something that they may or maynot get, and it's costing them a fortune. When that happens, the students often end up on ourdoorstep, and a lot of times we can't help them. They've maxed out on federal financial loansand they have no more capacity for loans. It happens quite often."

-It's called OPPAGA, Office of Policy, Planning and Government Accountability, OPPAGA, did astudy between the for-profit institutions that do vocational training and the public institutions, andthey identified programs that were offered in both types of institutions, and what they found wasthat the public institutions have a much higher probability of being accredited in the differentdisciplines. Even when you count the state subsidy that the legislature provides to publicinstitutions, even when you add that plus the students' tuition, it is still costing the state lessmoney - certainly less for the student.""The student needs to understand what it is they're seeking, what kind of training, does thattraining have specified types of accreditation? The other thing they need to look at is cost. Theamount of money it's costing them to go to whatever school they choose to go to, is it anamount they can afford? Access and affordability go hand in hand. If something isn't affordable,it's not very good access:

J im Simpson log sheet:"Hello. I am Jim Simpson, Associate Vice President, Florida State College at Jacksonville.""Susan Lehr and myself were negotiators for the Title IV Program Integrity Rules that werebeing negotiated at the US Department of Ed."One of the issues that we have in this country is an extremely high default rate on studentloans. For example, in Florida, we have about 1.2 million students in post-secondary education.These are students enrolled in private institutions, for profit, and public institutions. Of thosestudents, about 167,000 take out loans. Of those, about 15 percent or over 25,000 studentsdefaul t on those loan s."[In response to the question "Some for-profit schools claim that the legislation would limit accessto education for many students. Is that the case?"] :


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"Actually, that's not the case. Even the US Department of Education's own analysis indicatesthat only six to eight percent of the programs in the United States would be impacted. Basically,what they're trying to do is go after programs that really are abusing students - what they callthe bad apples.""To give you a case in point. here in Jacksonville, we have three for-profits that only account forjust about 4 percent of the total post-secondary enrollments in Jacksonville, but they account forover 41 percent of the defaults. Now think of it - three institutions whose enrollments are lessthan 17 times the enrollments of UNF and Florida State College at Jacksonville. 17 timessmaller, yet the total defaults that those three institutions are greater than the defaults at theUniversity of North Florida and Florida State Co llege:'Those institutions account for 4.6 percent of the total post secondary enrollment and 40.7percent of all defaults.""Think about that. If their product is defective, would you go out and buy an automobile if youknew that the automobile would blow up? Shouldn't it have some sort of regulation to protect theconsumer, if one in seven is going to default?""First and foremost. students should look at education as any consumer product they're going topurchase. They should look around. They should shop, There's a vast different between what itcosts to receive an education at any of the institutions that are located in Jacksonville. Thatgoes for the for-profits, that goes for the publics :"The highest level of accreditation is regional, not national. That causes confusion with student.so they should ask, are you regionally accredited? If not, my advice is to tum around and walkout the door: -


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From :Sent:To:Subject:Cunningham. PeterFriday. April 30. 2010 12:11 PMShireman. Bob: Hamilton. JustinRE: interview request from dan goldenlbloomberg news

5)

From: Shi reman, BobSent : Friday, Apri l 38, 2818 9:28 AMTo: Ham l t on, Jus t inCc : Cunni ngham Peter 1: 1.,. .. . _

)(5) gol den/ bloomberg news

From: DAN GOLDEN, BLOOMB ERG / NEWSROOM : (b)(6)Sent : Thur sday, Apr i l 29, 2819 11 :37 ~ - - - - - - - - - - - - - - - - - - - - To: Shireman, BobSubj ect : RE: i nt erview request from dan golden/bloomberg newsBob,

you also be availab leprefer) about why youi t ref lects a shift in

(o r even if I don ' t f or some reason) , wouldPerhaps we could talk (on background if youyour public comment s on th i s i ssue, whetherOn ce I ge t t he speecht o chat further about it?decided to be stronger indepartment stra tegy, etc .I al so must confe ss a bi t of fr ust r at ion on one mat t er (fo r wh ich you ' re not respons i bl ein any way I know; I 'm grateful fo r your cooperation wi t h my stor ies) . I ' ve been requestingan i nte rv iew wi t h Arne Du ncan on for -pro f i t co l leges fo r mon th s wi t hout success .Now I under stand he t alk ed t o Front l i ne . Given that I and Bloomberg have devot ed so much

t ime, energy and space t o expo si ng probl ems i n t hi s sect or , and t hat Front l i ne (a very highqual i t y oper at i on t o be sure) appea rs to have basical ly fol lowed my stor ies and interviewed abun ch of people I quoted, I t hi nk I deserve at l east equal t rea tment and access t o t hesec reta ry . An y good word you coul d put i n f or me would be much appreci ated .

Yo urs ,Dan-- -- - Or iginal Me ssage -- - --From: Bob Shi reman


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U.S. Depa rtment of Educat ion( 202) 260 -0101= -_=c - : : : : = ::-===-:-::== :-:- I(b)(6) IFrom : DAN GO LDEN BLOOMBERGI NEWSROOM : o o b Sent : Thursday, Apri l 29, 2010 10:01 AMTo: Sh ireman, BobSubject : RE : in terview request f rom dan golden /bloomberg newsHi Bob,

Thanks very much f or your help wi t h t he home less story. which i s i n the i ssue of Busi nes sWeek on the stands tomo r row .I understand (f rom reading Inside Hi gher Ed) t hat you gave a great speech about th e forprof i t sector yesterday. Woul d you mnd sendi ng me a copy as soon as possibl e ? W ' d l ike t odo a news story on i t .Your s ,Dan--- - - Or ig i nal Me ssage - ----From: Bob Shi reman


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From: Bob Shi reman


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Yours,Dan Gn l de n

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From:Sent :To:Subject :

Shireman, BobFriday, April 30, 2010 10:39AMHamilton, JustinFW: Arne's Frontline interview today

(I was not interviewed on camera for Fron tline).From: Shireman, Bobsent: Friday, April 30, 2010 10:00 AMTo: Rogers, Margot; Kanter, Martha; Rose, Charlie; Miller, Tony; Martin, Carmel; Gomez, GabriellaCc: Cunningham, PeterSubject: FW : Arne's Frontline interview todayPeter asked me to forward this again. t-ly noteson Arne 's responses are at the BOlTOM.-BobFrom: Shireman, Bobsent: Wed nesday, March 24, 2010 10:14 PMTo: Cunningham, Peter; Rogers, Margot; Kanter, Martha; Miller, Tony; Martin, Ca rmel; Rose, Charlie; Yuan, Georgia;Gomez, Gabriella; Madzelan, DanCc: Man heimer, Annubi , e:

b)(5)

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From :Sent:To :Cc:Sub ject:

Good Afternoon,

Williams. GenaI(b)(6) [email protected]. April 27, 2010 2:49 PMShireman, Bob; Yuan. GeorgiaAndrews, DwayneMeeting request on behalf of the Charleston School of la w and Blank Rome GovernmentRelationsI am wr iting to request a meeting on behalf of the Charles ton School of Law r CSl ") to discuss the impact that thereported draft regulations defining "gainful employment" w ill have on proprietary law schools like CSl . CSL would l ike todiscuss some mod ifications that it thinks will address its concerns. We would like to have this discussion as soon aspossible, and depending on the timing a sen ior member of CSl 's leadership team will attend, as well as Dwayne Andrewsand Michael Cioff i from Blank Rome .Thank you for your consideration . Please feel free to contact me if you have any questions or concerns about thismeeting request.

Gena Wi lliams I Secretary to Dwayne And rews. Princ ipal 1Blank Rome Government Relations lLCWatergate 600 New Hampshire Avenue, NVI/ 1war hinoton y 20037Phone; 202.944.35111 Fax: 202.772.5858 1 { b)(6) BlankRome.com,

-----_._--_ -._- _.__--__- - - - - -_This message and any attachments may conta in confidential or privileged information and are on ly for the use of the Intendedrecipient of this message. If you arc not the intended recipient, please nolif)' the sender b)' re tu rn email, and delete or destroythis and all copies of Ihis message and all at tachments. Any unauthorized disclosure, use, distr ib ution, or reproduction of thismessage or any attachments is prehibltcd and may be unlawful.............................._ .Any Federal tax advice contained herein is not intended or written to be used, and cannot be used byyou or any other person, for the purpose of avoiding any penalties that may be imposed by theInternal Revenue Code. This disclosure is made in accordance with the rules of Treasury DepartmentCircular 230 governing standards of practice before the Internal Revenue Service. Any writtenstatement contained herein relating to any Federal tax transaction or matter may not be used by anyperson without the express prior written permission in each instance of a partner of this f irm tosupport the promotion or marketing of or to recommend any Federal tax transaction(s) or matter{s)addressed herein.***************************************************************************

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From :Sent:To:Subjec t:

Shireman, BobThursday, April 22, 201 0 7:56 AMDAVID BAIMERE: Hoping to schedule

Today would be better - we could ta lk t his af ternoon. Otherwise, work wi th leigh.arsenault @ed.govto find a t ime nextweek (but she is out today).From: DAVID BAIMEl(b)(6) Waacc.nche.eduJSent: Thursday, April 22, 20106 :24 AMTo : Shireman, BobSubject: Hoping to schedulea ten minute call w ith you ear ly next week. Two topics, ga inful employment and the TAA program.If you can do thi s how would I arrange it?

David

This email has been scanned for all viruses by the MessageLabs Emai lSecurity System.


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From:Sent:To:Subject:DAVID BAIMEI


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From :Sent:To:Cc:Subject:

Jordan , StaceyThursday, April 22 , 2010 6:12 AMShirem an, BobHoneysett. AdamRe:CCA outreach to Mayors agains t gainful emp loymen tOk l et us know if we can hel p i n anyway- - - - - Or ig i nal Message -- - - From: Shi reman, BobTo: Jo rdan, StaceySent : Wd Apr 21 21:52:58 2el e

...... .. rr .

Robert Shirema nDeput y Undersecreta ryU.S. Department of Educat io n( 282) 268 -8181From: Jordan, St aceySent : Wednesday, Apr i l 21, 2818 1:48 PMTo : Shirema n, BobSubj ect : RE: CCA out r each t o Mayors against gai nful emp loyme nt


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From :Sent:To:Cc:Subject:Attachments :

Tina Milanol(b)(6) ~ c s P O h j o . o r g lWednesday, Apri121. 2010 10 :45 AMShireman, BobDamieder. GregGoing AheadimageOO4.jpg; image005.jpg; image006.jpg

Bob, just read your comments in the Going Ahead with Gainful Employment article in Inside Higher Education. I applaudyour stand and the work you are doing. Just, fyi, at CSP we have ended our awards for students who elect to attendproprietary schools. Keep up the great work in DC ...we continue to count on you. Let me know if there is anything I canever do to help.Warm regards,TinaChristina R. MilanoCEOCleveland Scholarship Programs

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From :Sent:To:- ..(b)(6)

Shireman , BobWednesday, April 14, 201 0 5:45 PMArsenault, Leigh; Yuan, Georgiac .

-- - - - Or igina l Mssage -- - -From : r s u l t ~ Lei ghTo: Shireman, BobSent : Wed Apr 14 16 :07 :09 2010Sub j ect : FW Can I get a t ime wit h Bob?FYI- - I haven' t r es ponded yet . Wnted t o chec k wi t h you f i r st .-- - - -Or i g i nal Mes sage - -- - -Fr om : Ca rie l l o, Denni s M. [mai l t o :dca r i e l l o@ sonnenschein . com]Sent : Tuesday, Apr i l 13, 2810 7:42 PMTo: Arsenault , Le ig hSubjec t : RE: Can I get a t ime wi t h Bob?l e i gh ,I j us t wan t ed t o f ol l ow up - any shot at ge t t i ng a meet ing wi t h Bob i n t he com ng weeks ?Denni s

Dennis M Ca r i e l l oSonnensc hei n Nath & Rose nt hal l lPTwo World Fi nanci al CenterNew Yo rk, NY 10281Di rect : 21 2.398. 7636Cell : 917- 61 3-3235Fax : 212.768 .6800dca rie l lo@sonnenschein .comwww.sonnensc hein.com---- ------------------------- ------ --------------------- ------ ---------CONF IDENTIAL I TY NOTE:This e -ma i l and any attachments are confident i al and may be protected by l egal priv i l ege. Ifyou are not t he i nte nded re cipient , be awa re th at any di sclos ur e , copyi ng, di st r ibut io n oruse of t his e-mail or any at t achment is pro hi bited . I f you have recei ved t hi s e -mai l i ner ro r , please not i f y us i mmedi at e l y by r et urn ing i t t o the sender and del ete t hi s copy f r omyour sys tem. Thank you f or your coope rat i on.IR5 CI RCULAR 230 NOTICE:To compl y wi th r equi rement s imposed by the I RS, we in f orm you t hat any U.S . fe der al t axadvice conta ined here in (incl udi ng any at t achments) , unle ss s pec i f ica l ly sta t ed otherwise, is

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not intended or wr i t ten t o be used, and cannot be used, for the purpose of ( i ) avoidingpenal t ie s und er the Inte rnal Revenue Code or ( i i ) promoting. marketing or recommending anyt r ansact i on or mat ter addressed herein t o another party .

- - - - -Original Message--- - From: Cariello. Dennis M.Sent: Monday, April 12, 2919 11:44 AMTo: Arsenault. leighSubj ect : Can I get a t ime with Bob?l ei gh .I hope you are doi ng wel l . I wanted to se e i f Bob had any date s this week to t alk aboutgainful employme nt? I repre sent I nf i l aw, a system of f or -prof i t accredi ted law sc hoo ls(i .e. , Fl or i da Coas ta l l aw Sc hool ) t ha t have some thoughts about the proposed rule .If poss ible , t he Undersecretary and Georgia Yuan woul d be helpful i nv i t ees as we l l .also be trying to meet with Tony Miller al so - so i f i t makes sense for him to come,would be great . Otherwi se I can mee t with him separate l y.Thanks.Denni s

-- - - -Original Message-----From : Arsenault, leigh [mai l to : leigh [email protected])Sent : Friday, February 26 , 2919 4 : 12 PMTo: Cariello, Dennis MSubject : RE: How are you

I wi l lthat

Hi Dennis ,Un f ort un at ely Bob was out of the off ice on t hese days. Pl ease l et me know Brent wi l l bet rave l i ng to DC in the near f uture - -wi l l be happy to accommodate .leighOffic e of the Under Secre taryu.S. Department of Educationleigh .a r senaul t@ed .gov

-- -- -Or i gi nal Mess age- - - - -Fr om : Cariello. Denni s M " " - - - - - - - - - - - ' e h Sen t : Monday, February 22 , 2919 8 :18 PMTo: Smi t h, ZakiyaCc : Arse na ul t , l eighSubject : Re: How are youThanks so much for get ting back t o me - and congrats on the move !l eigh- t hanks i n advance for con sidering thi s request . I f you'd l i ke t o ta lk, I ' m at 917 613 -3 235 .

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Thanks,Denni s

Denn i s M CarielloSonnenschei n Nath &Rosent hal LLPTwo Wo r l d Financi al CenterNew Yor k, NY 18281Di rect: 212.398 .7636Cel l : 917-613-3235Fax: 212. 768 . 6888[(b)(6) @sonnenschei n . cOll!'' 'www . sonnensche in .c om------------- --- ---------------------------------------_._-------------CONFIDENTIALITY NOTE :Thi s e-mail and any atta chments are confident ia l and ma y be protec ted by legal privilege . I fyou are not the intended reci pient , be aware tha t any disclosure , copying , distribution oruse of t hi s e-mai l or any atta chment is prohibited . I f you have recei ved t hi s e -mai l i ner ro r , pl ease not i fy us immediately by ret urni ng i t t o the se nder and delete th is copy fromyou r sys t em. Thank you f or your cooperation .IRS CI RCULAR 238 NOTICE:To comp ly wi t h requi rements impo sed by the IRS, we i nformyou t hat any U.S . fede r al taxadvice cont ai ned herei n ( i ncluding any attac hment s ) , unl es s spec i f i cal ly st at ed ot herwise , i snot i nt ended or wr i t te n to be used, and cannot be used, f or the purpose of ( i ) avoidingpenalties under t he I nt er nal Revenue Code or ( i i) pr omo t i ng, market ing or recommending anyt ransact i on or matter addressed herein t o anot her par t y .

-- - - - Or i gi nal Mssage ---- -Fr om : Sm t h , Zakiya To: Carie l l o , De nni s M.Cc : Arsenault , Leigh Sent : Mon Feb 22 18:58:24 2919Subject : Re : How are youHi Dennis -In th e time that you 'v e been gon e, I ' ve act ua l l y moved over to OPEPD.Lei gh (copied here) i s now wo rki ng with and keeping t r ack of Bob th ese days .Sent fr om my iPhoneOn Feb 22, 2919, at 7 :24 PM, "Ca rie l l o, Dennis M" wrote :

with Brent?

Brent Richardson, the CEO of Gra nd Canyonpub l i cly t raded, propri etary sc hool - wi l lThursday morning and wanted to see i f he

I t 's been t oo long see we l ast connect ed.

Thanks so much.

I hope you are well .I had a quest i on for you.Uni versi ty i n Ar iz ona - abe in DC on wednesday and> could meet with Bob.> Does he have 39 minutes he coul d spare to meet

>>

> Zakiya,>>>>>>

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)> Dennis)))> Dennis M Car i e l lo> Sonnenschein Nath &Rosenthal LLP) Two Wor ld Financial Cent er> New York, NY 10281> Direct: 212 .398 . 7636) Ce l l : 917-613-3235

a 212 . 768. 68e0>J www .sonnenschein . com))> - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ . - - ) CONFIDENTIALITY NOTE :> This e i and any at t a chment s are conf ident i a l and ma y be protected> by l egal pr iv i l ege . I f you are not t he intended re cipient , be awa r e) that any di sclosure, copyi ng. dist r i but ion or use of t hi s e - mai l or> any at ta chment i s prohibited . I f you have recei ved t his e - mail in> er ro r . ple ase no t i f y us i mmediat ely by r e t urning i t t o the se nder and) del e t e thi s copy f rom your syst em. Thank you for your coopera t i on.> IRS CIRCULAR 230 NOTICE :> To comply with requirements imposed by t he IRS, we info rm you that any> U.S. fe deral tax adv i ce contained here in ( i ncluding any atta chme nts),> unless spec i f i cal l y st a t ed otherwise, i s not i nt ended or written to be> used, and canno t be used, for the pu rpose of ( i) avo i di ng penalties> under t he Inte rnal Revenue Code or ( i i) pr omot ing, mar ket ing or> recommending any t ra nsact ion or matter addressed herein t o anot her> part y .)> - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - -)))

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From :Sent :To: .Subject :

Arsenault, LeighTuesday, April 13, 2010 2:03 PMBabyak , Stephan ie; Gl ickman, JaneFW: Press Question on Gainful Employment Gains

From: Shireman, Bobsent : Tuesday, April 13, 2010 1:51 PMTo : Hami lton , Justin; Arsenault, l eigh

From : Hamilton, JustinTo : Arsenault, Leigh; Shireman, BobSen t : Tue Apr 13 12:40:48 2010Subj ect : Press Question on Ga inful Employment Ga insBob,Does any of th is sound familiar?------ Forwarded MessageFrom: Doug Lederman Date: Tue, 13 Apr 2010 09:24:57 -0500To: "Ham ilton, Just in" < justin.hamil [email protected]>Subject: Fwd: Signal Hill - Post-Secondary Edu cation : Relief: Gainful Emp loyment Ga ins A lternat ive MeasureJustin:The analysts seem to be putt ing their ow n spin on information that they say they've got ten from OMB ... is there anyway to make sure th at they 're presenting th is info rmation accurate ly, etc.?I'd love to get my hands on t he document, or at least the po r tion related to gainful employment. If t here's any way ofdoing that , please let me know ...Thanks,Doug

---------- Forwarded message ----------From : Trace A. Urdan Date: r ue, Apr 13, 2010 at 7:20 AMSubject: Signal Hill - Post -Secondary Ed ucat ion: Re lie f : Ga inful Emp loyment GainsAlternat ive MeasureTo: [email protected]

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----------------------------------------------------------------------------BusinessServices - Education Services

Indust ry UpdateApr il 13, 2010 Relief: Ga inful Employm ent Gains Alternative Measure

Trace Urdan) (b)(6)Our Call :As ant icipated, Department of Ed ucat ion (USDOE) draft regulations went to theOffice of Management & Budget (OMB) last Friday 4/9 for review pr ior to th eirpublicat ion in the Federal Register -- l ikely 5/15. A credible source close toOMB tells us that wh i le the 8% median debt/ income measure, and the 90% studentloan repayment measures appear to be essent ial ly unchanged from the te rmspresent ed by the USDOE in January, a th ird alternative measure has been added .This measure would allow programs with a graduat ion rate of 50% or bett

crew: department of education: regarding for-profit education: 4/21/11 – 10-01704-f ous ge

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