Sophia McArdle
The Department of Education
400 Maryland Ave. SW
Washington, DC 20202

Dear Ms. McArdle:

Student Debt Crisis is writing to you in response to Federal Register notice ED-2018-OPE-0041. The Department’s proposal would delay the 2016 rule regarding state authorization of distance education programs. We urge the Department to reconsider the delay and modification of these rules as it has created confusion for students, institutions, and states. The regulation was developed during two prior negotiated rulemaking sessions and has received proper review and scrutiny. We encourage the Department to immediately implement the 2016 rule.

Delaying regulations would have a major impact on current and future student loan borrowers:

  • Students leave distance-education-only, for-profit education programs with significantly higher student debt loads than the average for students in programs not entirely online.
  • Borrowers enrolled in distance-education-only programs carry higher loan debt on average at for-profits than their counterparts at brick-and-mortar for-profit programs.
  • The average cumulative federal student loan debt for graduating borrowers at distance-education-only programs is highest at for-profit institutions; and is higher than those not enrolled in entirely-online programs.

Students enrolled in distance education programs are older, poorer, and more likely to be an underrepresented minority than those enroll in non-distance-education-programs. These students are more likely to be exposed to fraud and abuse by low-quality, costly education programs. Further, nearly 1 in 5 veterans are enrolled at riskier online-only, for-profit schools.

Delaying the 2016 rule removes consumer protections that are vital for vulnerable students to make informed financial and education decisions. The state authorization rule is essential to ensuring program quality and integrity for consumers. Additionally, the regulation provides additional protections that include a way to file consumer complaints and creating a way for states and institutions to address them.

For nearly a third of students enrolled in distance education programs, delaying rules that protect students could mean life-long student loan debt. Students should be offered the piece of mind that their education program will actually provide credentials that meet industry standards and are valuable to the current job market.

Finally, the Department has an obligation to provide students with disclosures and information that help people make informed decisions about their education financing. Reviewing regulatory rules for the third time is an unnecessary delay that puts many students and borrowers at risk of falling victim to expensive, low-quality education programs.

Again, we urge the Department to immediately implement the 2016 state authorization regulations.

Student Debt Crisis is a nationwide advocacy group with over 1,000,000 supporters calling for fundamental reforms to student loan policies.

Sincerely,

Student Debt Crisis

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