http://www.twitter.com/caichildlaw

Read CAI's Blog!

 

 

 

 

 

 

CSAAVE Rulemaking Proposal

View Public Comments Submitted by the Center for Public Interest Law,
Children's Advocacy Institute, Veterans Legal Clinic, Public Law Center,
Public Counsel, and Housing and Economics Rights Advocates (Dec. 7, 2018)

Click here to view CSAAVE's Notice of Proposed Rulemaking

 
Documents Cited/Referenced in Comments Citation/URL (where available)
Harkin Report Senator Tom Harkin, The Senate Health, Educ., Labor & Pensions Comm., Department of Defense Data Reveals For-Profit Colleges are Taking in the Bulk of Military Education Benefits,
http://www.help.senate.gov/ranking/ newsroom/press/harkin-report-reveals-troubling-realities-of-for-profit-schools      
Case:Armistead v. Personnel Board Armistead v. State Personnel Board (1978) 22 Cal.3d 198, 204
News Article: Congress expands GI Bill, helping veterans burned by for-profit schools https://money.cnn.com/2017/08/03/pf/college/gi-bill-benefits-for-profit/index.html
List of for-profit universities and colleges https://en.wikipedia.org/wiki/List_of_for-profit_universities_and_colleges
Colleges Sanctioned by the Government https://www.collegeaffordabilityguide.org/online-colleges-sanctioned-by-government-organizations/
PBS: Dept. of Ed names 20 schools facing financial investigation after ‘severe’ audit findings

https://www.pbs.org/newshour/education/dept-ed-names-schools-facing-financial-investigation-severe-audit-findings;

Chronicle of Higher Education: State Attorneys General Open New Investigations Into For-Profit Colleges https://www.chronicle.com/article/State-Attorneys-General-Open/144255
Huffington Post: State Attorneys General Open Major Investigations of Big For-Profit Colleges https://www.huffingtonpost.com/davidhalperin/state-attorneys-general-o_b_4677145.html
Market Failure John O. Ledyard (2008). "market failure,"  The New Palgrave Dictionary of Economics, 2nd Ed.
New Yorker: The Rise and Fall of For-Profit Schools James Surowiecki, The Rise and Fall of For-Profit Schools, The New Yorker (Nov. 2, 2015), available at http://www.newyorker.com/magazine/2015/11/02/the-rise-and-fall-of-for-profit-schools.
Xavier Beccera: California AG: For-Profit Colleges https://oag.ca.gov/consumers/general/for-profit-schools
Case: Max Cleland, Administrator of the Veterans Administration, et al. v. National College of Business Max Cleland, Administrator of the Veterans Administration, et al. v. National College of Business 435 U.S. 213 (1978).
20 U.S.C. § 1094(a)(24) 20 U.S.C. § 1094(a)(24)(2014)
38 U.S.C. § 3680A(d)(1) 38 U.S.C. § 3680A(d)(1) (2014)
Law Review Article: Closing the 90/10 Loophole in the Higher Education Act: How to Stop Exploitation of Veterans, Protect American Taxpayers, and Restore Market Incentives to the For-Profit College Industry

Daniel J. Reigel, Closing the 90/10 Loophole in the Higher Education Act: How to Stop Exploitation of Veterans, Protect American Taxpayers, and Restore Market Incentives to the For-Profit College Industry, 81 Geo. Wash. L. Rev. 259 (2013).

Article: For-profit colleges have been ripping off veterans since World War II https://www.businessinsider.com/for-profit-colleges-have-been-ripping-off-veterans-since-world-war-ii-2016-6
Article: Veterans feel ripped off by Colorado for-profit college https://www.coloradoindependent.com/2017/01/26/veterans-colorado-tech-for-profit-college-debt/
CNBC article: Are for-profit colleges unfairly ‘targeting’ vets? https://www.cnbc.com/2013/11/11/are-for-profit-colleges-unfairly-targeting-vets.html
Slate article: This Army Veteran Wanted to Become a Video Game Animator. Instead, he got played by two for-profit colleges. https://slate.com/human-interest/2016/07/why-are-people-so-easily-exploited-by-for-profit-colleges-stealing-americas-future-explains-a-veterans-story-of-student-loan-debt.html
New York Times article: Exploiting Veterans for Profit https://www.nytimes.com/2017/11/24/opinion/exploiting-veterans-profit.html
MarketWatch article: Dan Rather on for-profit colleges: ‘It’s hard to find anything more outrageous than this’

https://www.marketwatch.com/story/new-film-exposes-how-for-profit-colleges-exploit-veterans-and-single-moms-2017-11-14

CBS News: For-profit colleges linked to almost all loan fraud claims https://www.cbsnews.com/news/study-most-student-loan-fraud-claims-involve-for-profits/
Mother Jones article: How Pricey For-Profit Colleges Target Vets’ GI Bill Money https://www.motherjones.com/politics/2011/09/gi-bill-for-profit-colleges/
LA Times article: For Profit Colleges are Using the GI Bill to Make Money off Veterans Chris Kirkham and Alan Zarembo, For-Profit Colleges are Using the GI Bill to Make Money Off Veterans (Aug. 18, 2015). Available at http://www.latimes.com/business/la-fi-for-profit-colleges-gi-bill-20150809-story.html
Huffington Post article To Get Value from For-Profit Colleges, Create the Right Incentives Robert Shireman, To Get Value from For-Profit Colleges, Create the Right Incentives (May 31, 2013). Available at http://www.huffingtonpost.com/robert-shireman/forprofit-colleges-gettin_b_3367622.html.
L.A. Times article: Anger Grows Over GI Bill Profiteers David Zucchino & Carla Rivera, Anger Grows Over GI Bill Profiteers, L.A. Times (Jul. 16, 2012), http://articles.latimes.com/2012/jul/16/nation/la-na-vets-colleges-20120716
Is the New GI Bill Working?: For-Profit Colleges Increasing Veteran Enrollment and Federal Funds Staff of S. Health, Educ., Labor, and Pensions Comm., 113th Cong., Is the New GI Bill Working?: For-Profit Colleges Increasing Veteran Enrollment and Federal Funds (2014)
New York Times article: Fix the New G.I. Bill Tim Hsia & Anna Ivey, Op-Ed., Fix the New G.I. Bill, N.Y. Times (Nov. 10, 2014), available at http://www.nytimes.com/2014/11/11/opinion/fix-the-new-gi-bill.html?_r=0 
Federal Student Aid: Official Cohort Default Rates for Schools

Three-year Official Cohort Default Rates for Schools, Federal Student Aid, http://www2.ed.gov/offices/OSFAP/defaultmanagement/cdr.html  (last updated Sept. 24, 2014)

Washington Post Article: Why the Defense Department is Kicking the University of Phoenix Off Military Bases Danielle Douglas-Gabriel, Why the Defense Department is Kicking the University of Phoenix Off Military Bases (October 9, 2015). Available at https://www.washingtonpost.com/news/grade-point/wp/2015/10/09/why-the-defense-department-is-kicking-the-university-of-phoenix-off-military-bases/
Reveal News article: University of Phoenix barred from enrolling Veterans in 7 Programs Aaron Glantz, University of Phoenix barred from enrolling Veterans in 7 Programs (July 30, 2014). Available at https://www.revealnews.org/article-legacy/university-of-phoenix-barred-from-enrolling-veterans-in-7-programs/
HELP Report Executive Summary

Comm. on Health, Educ., labor, and pension, For Profit Higher Education: The Failure to Safeguard the Federal Investment and Ensure Student Success, S. Rep. No. 112-37, at 19 (2d Sess. 2012).

LAO Report: Oversight of Private Colleges in California https://lao.ca.gov/reports/2013/edu/oversight/oversight-121713.aspx
Oregon regulation related to labor market information requirement

OAR 715-045-006

Wisconsin regulation related to required documentation of labor market needs Wis. Adm. Code SPS 404.04
Wisconsin guidance related to required documentation of labor market needs

https://dsps.wi.gov/Documents/EASchoolAndProgramApprovalGuide.pdf

Federal Workforce Innovation and Opportunity Act 29 U.S.C.S. § 3112
Federal Workforce Innovation and Opportunity Act 29 U.S.C.S. § 3102
News article from Dec. 5 on San Diego school closure - quote from veteran https://www.nbcsandiego.com/news/local/brightwood-college-kearny-mesa-chula-vista-closure-education-corporation-of-america-students-502031331.html?akmobile=o
Submission from Robert F. Muth, Managing Attorney of the Veterans Legal Clinic of the University of San Diego School of Law Correspondence from Robert F. Muth, Managing Attorney of the Veterans Legal Clinic of the University of San Diego School of Law to Phil McAllister, Esq., Regulatory Actions Coordinator, California Department of Veterans Affairs (Dec. 7. 2018)

 

 
     
 
© 2018 CAI
All rights reserved
Children's Advocacy Institute
University of San Diego School of Law
5998 Alcalá Park, San Diego, CA 92110
Telephone: 619.260.4806
Fax: 619.260.4753