Blog: PlattForm Executive Chairman Responds to “Form Letter” from Democratic Congressman Dennis Moore

By Michael Platt

After dozens of my peers received a "form letter" from Kansas Congressman Dennis Moore, I attempted to send him a response. Unfortunately, despite claiming that he accepts email communication from his constituents, his office refused to provide an email address. So I am addressing this as an open letter to Congressman Moore in hopes that through social networking (please feel free to post this link EVERYWHERE), he will receive the message.

Congressman Moore:

Let me start by saying that the use of a "form letter" in response to numerous opposing comments from many of my peers was considered by all to be a statement to your lack of concern for the opinio
ns of your constituents. I must say that I was personally surprised at your limited knowledge and partisan perspective. That said, allow me to comment on your "form letter" in hopes that you will open your mind (as many Democrats have recently done) to the damaging gainful employment proposal your "form letter" supports. This is your letter to one of my peers. My commentary is in

Dear Rebecca:

Thank you for sharing with me your concerns regarding the Department of Education’s proposed "gainful employment" rule. I appreciate hearing from you on this issue. (Appreciation is an odd word to use here as your use of a "form letter" suggests you had staffers handle this reply.)

As you know, for-profit postsecondary education has long played an important role in the nation’s education and training system. In recent years, enrollment at for-profit universities and colleges has boomed, increasing by an average of 9 percent per year over the past 30 years. (Have you asked yourself why career colleges continue to grow while community colleges continue to struggle to gain real traction? Low-income Americans and adult learners continue to choose career colleges despite higher tuitions because they do their homework and understand that they will receive a better education from these schools and that employees value career-focused training over traditional education for most vocations.) For-profit universities now educate almost 2.6 million students. (You should be saying "thank you.") In 2009, these institutions received $26.5 million in federal grants and student loans. It seems, however, that taxpayers and students may receive dubious benefits in return from some of these schools. (As opposed to … what options? Career colleges train and place people in the workforce and meet the standards of placement rates imposed by the DOE. How about community colleges and state universities? Why are they not held to similar standards? Aren’t traditional university and community college students using taxpayer money as well?) Student loan debt is higher among graduates of for-profit institutions, as there are 18 student loan defaults for every 100 graduates of for-profit schools compared to only 5 student loan defaults for every 100 graduates of public institutions, and investigations and news reports have also highlighted low-quality for-profit programs that leave students with large amounts of debt and poor employment prospects. (At what point will you acknowledge the demographic served by career colleges – a demographic community colleges and traditional universities have failed? According to numerous studies, repayment rates have more to do with the income level and financial status of those served, than on the quality of education.) As a recent New York Times article stated, "Critics say many schools exaggerate the value of their degree programs, selling young people on dreams of middle-class wages while setting them up for default on untenable debts, low-wage work and a struggle to avoid poverty." (Critics? Are you referring to short-sellers like Steve Eisman or the DOE, whose community colleges have failed to effectively compete with career colleges on graduation rates and outcomes? What about the numerous articles written in major publications that have opposed the proposed gainful employment regulations? How about a balanced perspective instead of pointing only to what supports your party’s position?)

The Higher Education Act of 1965 requires that all for-profit universities must demonstrate that their course work prepares students for "gainful employment" in recognized occupations in order to be eligible for federal financial aid. There has never been agreement, however, on how to measure or demonstrate this performance standard. (The 1992 Reauthorization of Higher Education Act placed numerous restrictions on access to Title IV for the "for-profit" colleges only, including graduation rates, placement rates, repayment rates and default rates, as a means of judging whether or not the for-profit colleges are effectively preparing students for gainful employment. Every thriving career college has met and exceeded these guidelines while many traditional universities and community colleges would find themselves shut down if held to these same targets.) The Department of Education recently released a proposed rule defining this "gainful employment" standard using data on incomes and debt loads as well as completion, job placement, and loan repayment rates. A final rule has not yet been released or adopted. You can read the proposed rule at The public may submit comments on the proposal until September 9, 2010. (If you’d have read the letters submitted by your constituents, you would know that most were submitted by people who already understood this proposed rule. Also, the fact that your staff sent this "form letter" two weeks after the due date for comment shows just how little thought went into the formation of this letter.)

As you may also know, on August 4, 2010, at a Senate Committee on Health, Education, Labor, and Pensions hearing on for-profit colleges, the Government Accountability Office (GAO) released a report highlighting the results of a recent investigation into the practices of for-profit schools. GAO’s investigation found evidence of deceptive practices or fraud at all 15 of the for-profit institutions visited by undercover investigators. Senator Tom Harkin [D-IA], the chairman of the committee, has announced that, due to these findings, he plans to examine and investigate the accreditation process of for-profit postsecondary institutions. You can read the report by visiting (The Harkin hearings have been anything but balanced. It validated the opinion of a short-seller, Steve Eisman, whose objective was obvious, and did NOT communicate how many mystery shopping sessions it took to come up with 15 negative situations. There is no doubt the sector needs to better self-monitor, but aiming for the destruction of a critical sector of higher education – and please do not attempt to make me believe that is not the agenda – in order to funnel Title IV dollars to a community college system already in disarray, is not in the best interests of those you serve. Low income Americans will no longer be served should this effort be successful. Look at a map and THEN tell me which community colleges will serve the inner-city? This plan will simply remove all hope of transformation through education from those who need it most.)

While I understand your concerns, and am sure that some of these schools, including your own, (Why do you assume that everyone "opposing" the gainful employment proposal works for a school? I personally know of many people with opposing views that do not work in this sector. With all due respect sir, you should reprimand whichever staffer wrote this for exposing your lack of interest in who your constituents are and what they have to say.) may deliver a genuinely useful and worthy education, I am also concerned that some for-profit institutions are more concerned with generating profits than providing students with a valuable, high-quality education. I am glad you feel that your institution falls into the former category, but I believe it is imperative to ensure all students are served well by these schools.

Thank you again for contacting me. I hope you will continue to keep in touch and please feel free to let me know whenever I may be of assistance.

Very truly yours,

Member of Congress

P.S. Please sign up for my e-mail newsletter to receive periodic updates on federal legislation at my Web site: (None of the people I know who received this “form letter” are interested in your newsletter. But thank you sir for ensuring that this group of people now have a better understanding of your position.)

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