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| 24 8,000 students enrolled in 95 graduate programs located
25 in 22 states. The average total enrollment per school, 
1 as was alluded to earlier, is 143. Schools range from 2 about 20 students to a maximum of around 600, so these 3 are small institutions. 26 of the 56 schools are 4 private -- are considered private proprietary 5 institutions, or for-profit, that are offering graduate 6 programs, many of which will be negatively impacted 7 without reasonable revisions to the GE regulations. 8 Three of these institutions actually happen to be 9 located in Texas, and three of the institutions -- or at 10 least two of them are providing testimony before you 11 today. 12 So, first, I want to emphasize that ACAOM 13 fully supports the concept of Gainful Employment and, 14 more fully, the protection of student loan borrowers 15 from any institution that employs misleading, deceitful, 16 or predatory admissions, financial aid, or other 17 practices that negatively impact students. 18 Second, ACAOM supports the Department's 19 decision to delay implementation of the regulations 20 pending an appropriate review or revision process to 21 eliminate the unintended consequences that the current 22 regulations will have on the institutions that ACAOM 23 accredits. You've heard some of the issues already. My 24 comments are based on the perspective from the 25 accreditor and this limited narrow field of acupuncture 
5 positions, and the majority of graduates who choose this 6 profession by default typically become small business 7 owners. These regulations simply do not accommodate the 8 differences between established and mature professions 9 with salaried positions in large organizations and 10 developing professions where you have to create your own 11 path and your own business. Any of you that have 12 started your own business know that it takes a while 13 before you're able to bring home the paycheck. 14 There are a couple of other reasons these 15 regulations need refinement. The GE regulations purely 16 are discriminatory between private proprietary, or 17 for-profit institutions, and nonprofit institutions 18 based purely on their organizational structure, and have 19 assumption of things that -- or perceptions of things 20 that have happened in the past, rather than an actual 21 practice or institutional outcomes. As an accrediting 22 agency, we monitor these outcomes, including default 23 rates, graduation rates, national Board scores, and I 24 can tell you, there is no statistical, significant 25 difference between the schools that we accredit when it
1 comes to their organizational status. Whether they're 2 for-profit or nonprofit, it makes no difference. For 3 example, loan default rates. The national average right 4 now for grad schools for nonprofit institutions is 5 6.5 percent. It's 14 percent for for-profit 6 institutions, nationally. Within ACAOM schools, those 7 numbers are 4.16 percent for nonprofit and 4.43 percent 8 for the for-profit institutions. So, basically, there 9 is no difference in those institutions. 10 ACAOM graduate programs lead the licensure, 11 currently, in 46 states and the District of Columbia. 12 And the program length, which is the primary determinant 13 of an overall program cost is, in large part, determined 14 by state regulation and accreditation standards. 15 Therefore, schools have little control over the income 16 thresholds encountered by their graduates and the known 17 challenges with utilization of the Social Security 18 income data. They have very little control over that, 19 and so it's very challenging to hold schools responsible 20 for those issues. 21 As far as the Borrower Defense to Repayment 22 regulations, in our evaluation of that, there are two 23 examples of areas that we believe need revision to 24 include -- which include the low burden of proof 25 required to initiate claims of misrepresentation --
1 MR. MARTIN: Time. 2 MR. McKENZIE: -- and then due process 3 issues inherent in THE regulations regarding letter of 4 credit requirements. So I thank you for your time. 5 Appreciate the opportunity. 6 MR. MANNING: Thank you. 7 MR. MARTIN: Okay. We're going to take 8 approximately a 15-minute break and we'll reconvene at 9 2:30. Oh, I should say we do have available time slots 10 for the afternoon if any of you wish to sign up for 11 those. Okay. On second thought here, we do have 12 somebody here. Ms. Pamela Gant-Lee here? 13 MS. GANTT-LEE: Yes, I'm here. 14 MR. MARTIN: Why don't we have you come 15 speak now, and then we have one other person after that. 16 That's Pamela Grant-Lee, G-r-a-n-t L-e-e, is that 17 correct? 18 MS. GANTT-LEE: It's G-a-n-t-t. 19 MR. MARTIN: Oh, I'm sorry. It's Gantt. 20 Pamela Gantt, G-a-n-t-t hyphen L-e-e. I'm sorry. 21 MS. GANTT-LEE: Good afternoon, everyone. 22 MR. MANNING: Good afternoon. 23 MS. GANTT-LEE: The right to education. 24 Education is a fundamental human right and essential for 25 the exercise of all human rights. It promotes
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