Washington, DC, September 13, 2018 – In response to a request for public comment on the Notice of Proposed Rulemaking (NPRM) rescinding the Gainful Employment (GE) regulation, Joe May, president of Rebuilding America’s Middle Class (RAMC) and chancellor of the Dallas County Community College District, issued the following letter:

RE: Docket ID ED-2018-OPE-0042-0001

Dear Ms. Higgins:

Thank you for the opportunity to provide public comment on the Notice of Proposed Rulemaking (NPRM) rescinding the Gainful Employment (GE) regulation. RAMC is a coalition of State and individual community college systems from across the country, representing over 130 colleges and 1.5 million students. RAMC’s mission is to build a stronger, more competitive workforce, and therefore, a strong middle class by increasing access to and success in higher education. RAMC supports the rescission of this rule, as its application to community colleges has been unnecessary and resulted in little if any benefit to our students and only added reporting burden to our schools. However, RAMC does support the concept of added transparency referenced in the regulation through an augmented College Scorecard, but only if the additional data accurately reflects the outcomes of community colleges and our students, something that has been lacking from the existing College Scorecard.

Community colleges serve a population of students who are often seeking training for a specific occupation or are looking for the lowest-cost accessible institution of higher education that is geographically accessible to them. Community colleges work to ensure that our students receive the education and training they need to obtain and retain a good paying job. The current GE regulation does little to answer the real-world situation community college students are facing as they seek access to a post-secondary education.

Community colleges have many program offerings that respond to the needs of their students and the employment opportunities in their regions. Current GE regulations have hampered the ability of our schools to react and interact with employers to design and implement new training programs. If continued, this would result in less innovation and decreased employment solutions offerings for students and businesses.

This rule, which was pursued by the previous administration for its applicability to for-profit institutions, has mostly resulted in added reporting burden for our campuses. Examples of these burdens include the many data points that are required to be provided when a school creates a new program. These regulatory requirements have made establishing new programs burdensome for community colleges and slowed down colleges’ responsiveness to business and student needs.

In addition to our support for rescinding the GE rule, we offer our qualified support for the United States Department of Education’s (ED) future plans to improve the public report and data available on a program by program basis at institutions of higher education. Additional information and data can be extremely helpful to students as they make choices on what educational path to follow. However, community colleges have been long plagued by incomplete and inaccurate data reporting due to the part-time and non-first time nature of our school’s student bodies. In addition, the current College Scorecard has struggled to accurately report data on community colleges, with initial reporting excluding entire campuses. If ED is going to expand its reporting through the College Scorecard (or another means) to include program by program data, this reporting must accurately account for our students, their enrollment patterns and the fact than many take longer than the traditional time to complete their credentials or degrees. As heads of State and local community college systems we stand ready to offer our input to ED on how to remedy these short comings.

Thank you for the opportunity to provide input on this NPRM and for considering our views.

Sincerely,

Joe May

Board Chair, Rebuilding America’s Middle Class (RAMC)
President, Dallas County Community College District