Gainful Employment is a Bad Idea, Period.

My latest post on the CCAP blog:

I've been openly critical of the gainful employment proposal being considered by the Department of Education (here and here). The proposed rule is overly harsh and would likely result in many programs and schools going out of business and hundreds of thousands of students being shut out of postsecondary educational opportunities. An analysis by economic consulting firm Charles River Associates concluded that up to 1/3 of the students currently served by for-profit schools would be denied access. An analysis by financial aid expert Mark Kantrowitz concluded that the proposed rule is flawed, unrealistic and would lead to unintended consequences.

While I generally think that for-profit sector does more good than harm, there is some anecdotal evidence of foul play in the sector. This is by no means pervasive among the entire industry, nor is it limited to for-profit schools (Kevin Carey recently highlighted the scam of Southeastern University that was knowingly permitted to occur over multiple decades). There are admittedly scam artists in every sector of society, including the government and non-profit world. Does this mean that we need to regulate ourselves out of jobs, economic growth and individual liberty in an unrealistic effort to safeguard every nook and cranny of our lives, turning over human responsibility to far-off bureaucrats who have proven repeatedly ineffective at protecting its citizens? We simply can't prevent every crime or wrong doing in society.

By and large, economic interventionist policies by the government have lead to unintended consequences that are far worse than the situation present before the rules were implemented. Individual decisions and markets are the best allocator of resources, not central economic planners. So what are the unintended consequences likely to result from gainful employment?

First and foremost, hundreds of thousands of students will be shut out of the educational opportunities to improve their lives. The public and non-profit sectors do not have the capability or capacity to absorb these students, nor do they offer programs or schedules that meet the needs of this segment of the population. This is a negative for college access.

Second, it will be counterproductive to making college more affordable and productive, as the for-profit sector is the one bright spot in postsecondary education today that is showing real signs of management efficiency and innovation. It would also weaken competition and restrict the supply of education, which as economics 101 tells us, will lead to an increase in price.

Lastly and as I mentioned earlier this week, it will attack our freedom and individual liberty to make decisions that have consequences. Are we really willing to surrender this rare freedom and turn over our decision making to bureaucrats and politicians?

Apparently this group of folks (a consortium of politically left and special interest groups) thinks that all of the above negative consequences are acceptable, as they have written a letter to Secretary Duncan calling for even stricter gainful employment rules.

The solution to the problems of misleading advertising regarding employment and high levels of debt are really quite simple:

Mandate that colleges disclose to all prospective students the typical level of debt occurred by their students, program completion rates, data on where students have been placed and how much they are earning, and what the likely debt-to-income ratio will be for students finishing the program. This information would give students all the information that they need to make an informed and rational decision on what school and program to pursue. If prospective students don't like what they hear, then they can vote with their feet and go elsewhere. Because of the incentives, schools would seek to offer programs that provide relatively high rewards for students, while programs with costs that exceed the benefits would likely go wayside, and thus, eliminating most of the problem. For the remainder, violators and cheats would be dealt with harshly with loss of Title IV eligibility and possibly criminal punishment.