- If the new gainful employment rules are good for regulating for-profits, why shouldn't they be used for every single Title IV institution? Click to View the Answers
For-profit institutions have argued for the last several years that they have been targeted. After all, if federal oversight (e.g., 90/10, GE) is good for the for-profits, why isn't it good for all of higher education? This question is at the core of sector participant duress. There is an inherent unfairness that all institutions are not governed by the same rules. And let's not play games that the current regulations are structured based on statutes already passed by Congress. If we're going to establish a relationship between income and debt, it should be associated with all schools. The excuse isn't to say that Congress won't bite, but our lawyers have concocted a legal way for us to regulate at least part of the industry where we believe excesses exist.
The for-profit industry would have found the regulations much more palatable assuming that all institutions were subject to the rules. Rather than be a battle of for- vs. non-profit, the issue would have been reframed as good vs. bad institutions.
Most of the regulations apply to all types of institutions. The gainful employment regulation uses the statutory definition of career education programs, which includes most for-profit programs as well as public and non-profit programs of less than two years. If, in fact, all the schools that run afoul of the regulation end up being for-profit institutions because their students end up with worse outcomes, I hardly see that they would have cause to complain. As a friend of mine said, that would be like bank robbers complaining that the bank robbery statute only applied to them.
One fundamental rule that applies only to nonprofit and public institutions is that no one is allowed to hold an ownership interest in the college's revenues and assets. That prohibition exists to protect consumers and taxpayers. If Michael does not want that rule to apply to his colleges, then it is logical and appropriate for other rules to substitute.
- Let me ask the question a bit differently -- why shouldn't every single postsecondary programs have published debt to income ratios and repayment rates accessible to accreditors, academics, and the general public? Click to View the Answers
It should. Graduates' earnings information is already available in Florida and one or two other states, at least for public institutions. One issue that needs to be addressed is how to account for people who go to graduate or professional school after their bachelor's degree.
Bob, why didn't you insist on a level playing field? Yes, Bob and I agree that it should.
- Is there something specific to career education that requires additional scrutiny? Click to View the Answers
Career education is more amenable to accountability metrics because it is more directly related to a particular job. In their experience with the early GI Bill, Congress found that for-profit providers could not be trusted to deliver on the more vague, long-term bachelor's degree outcomes, but that career programs could be policed more easily. So for-profit providers were allowed in as long as they were focused on direct job preparation.
We are seeing a convergence of "career education" and "academic education". Metrics are metrics. Everything is measurable or should not exist.
- What are the ramifications of institutions no longer using enrollment metrics to compensate counselors, and do you feel that it goes far enough to change the culture among institutions? Click to View the Answers
The way incentive compensation was frontloaded to enrollment counselors was wrong. It is wrong not to have incentive compensation for every institution employee. There should be some bonus system based on cash, professional development programs, sabbaticals, vacation time, research time, etc. as different payment options across the board for all faculty and staff at an institution based on the outcome of the students who have graduated. These metrics should be measured for ten years after graduation, with staggered bonus programs not unlike other industries. If people are doing a great job, then they should be compensated accordingly.
As to Michael's idea, what outcomes would you measure, and how would you attribute those outcomes to individual teachers, staff and other factors? Education is not like widget factory where you can tell precisely how much value each employee is contributing and can so easily and accurately assess the quality of their work.
As to Ariel's original question, it is clear from numerous investigations of the industry that compensating recruiters based on enrollment helped produce a culture in which hungry recruiters were preying on the vulnerability of potential students struggling to earn a living and build a future. Such incentive pay, however, was not the only factor creating this predatory environment; investigations by Senator Tom Harkin and others have brought to light a series of internal documents and practices from a number of for-profit education companies teaching recruiters how to get potential students to focus on their own internal pain and turmoil – these coercive tactics often appeared to be company policy or tradition. Scrutiny has now forced several companies to disavow such approaches, at least publicly. Time – and further scrutiny – will reveal if the new regulations and internal reforms are enough to change the culture.
- Why is there no accountability in higher education regarding student outcomes? Click to View the Answers
Two developments in 2011 provided considerable momentum to efforts to encourage greater attention to student learning outcomes. The publication of Academically Adrift, revealing that vast numbers of graduates of traditional institutions failed to make any gains in critical thinking skills during college, has made it more difficult for colleges to deny that there is a problem. And the Carnegie-led reexamination of quality in the business degree has energized soul-searching by leaders in that discipline, the most popular undergraduate major. Colleges increasingly are using measures like the Collegiate Learning Assessment to identify strengths and weaknesses in their institutions, and having a focus on verified learning is becoming part of what contributes to a college's reputation.
That said, we should be careful about wishing for a college outcomes test to compare colleges. Reasonable people disagree about the goals of higher education (analytical skills, factual knowledge, communication skills, initiative, curiosity, confidence, creativity, diligence, employability). Measuring them can be tricky or impossible; and determining causation is even more difficult (the students might have done well because of their academic or family backgrounds, the professor's teaching, the advising and support, their peers, the facilities, the technology, or their own initiative). Pressing colleges to focus on the easy-to-measure can skew higher education in ways that may improve some institutions but could narrow or deaden the curriculum in many others. We need higher education to lead to boundless ingenuity; standardized outcomes are antithetical to that goal.
Which colleges are good at stimulating boundless ingenuity? The difficulty in measuring something like that explains why reputation – a brand that can be trusted – is so dominant in the higher education market. As an alternative or a supplement to some of the current efforts to produce better assessments, I am intrigued by the idea of digitally capturing the actual coursework that thousands of students do at various colleges. Examining the actual evidence of student achievement – the material that faculty judge as worthy of conferring a degree -- would value the variety that is a part of higher education's strength, and might allow some of the less measurable goals of higher education to show through.
Accountability will come about the way Adam Smith desired. The consumer and the producer will eventually establish accountability. It is my belief that the Federalization of Higher Education Movement will not bring additional needed accountability. We need to localize all aspects of education. Look at the phenomenal impact that crowd sourced evaluation is having on small business across America with startups like Yelp. What the federal government should do—as well as the states with support from all accrediting agencies—is to demand absolute, full transparency from all post-secondary educations—for-profit and not-for–profit alike—in a centralized website so the consumers can evaluate the producers. This will bring about true accountability.
Our family does not sponsor any educational institution that has something to hide. We demand clear, open transparency to our donors, our investors, staff, faculty, regulators, and—most importantly—students, their families, and employers. The only way to compete in an open free market is with open free data.
The divisive nature of our partisan politics has driven a dangerous wedge between for-profit and non-profit education, with the business models of the non-profit schools in danger of becoming obsolete. They can only survive on dwindling state and federal resources plus endowments are suffering, and fatigued donors. In California, I've not heard a single college president talk about efficiencies—every speech is to each constituency who can continue to give, grant, or fund their operations with no consideration for cost cutting or efficiencies. This is a dead end—and even the 1% can't afford it!
Don't forget about the other consumers: the employers and society at large who want college degrees to actually mean something. If these end users are not a part of the equation, then a rational consumer will simply seek the college that gives him a degree for doing nothing. Indeed, today I can go online and figure out which courses at a college are the Mickey-Mouse options where I can get an A without doing much work at all. Using some type of data transparency isn't a bad idea; what, specifically, would you suggest?
- Why do you think that problems at specific for-profit colleges end up condemning the entire private sector, while issues in the traditional sector don't raise the same concern? Click to View the Answers
Higher education is a trust market, in which the buyer has to trust that the product is what it seems. The student can't judge whether a curriculum and standards meets the expectations of employers, of a discipline, or of society, and they can't know whether it will meet the grander goal of tapping their full potential. To the extent students are able to judge their college educations it occurs when it is far too late to get a refund. Much of medical care has similar dynamics, which is why the government has a rigorous process that attempts to avoid snake-oil problems by licensing medical doctors and testing new drugs for safety and effectiveness. In higher education, the government and accreditors declare institutions as worthy of our trust who in turn anoint the faculty and staff.
Exploitation can occur in any sector, but the awesome power of the profit motive makes the scandals more likely and more audacious in the private sector. "That represents a weakness in the for-profit model," says Kaplan CEO Andrew Rosen in his recent book. "People can exploit the short-term opportunity for-profits that's inherent in this model in a way that hurts students, taxpayers, and the entire industry."
The for-profits get slammed as a sector because the incidents confirm the rational fear the companies are taking advantage of the trust relationship. In the same way, it is rational for people standing in line at the DMV to curse the lack of a customer-service profit motive in that transaction. The appropriate reaction is to acknowledge the problematic incentive while demonstrating a resolve and a system for preventing abuse. Instead, when we began our regulatory efforts at the Education Department — which applied to all sectors — the for-profit colleges portrayed our effort as an attack on the sector and turned the whole regulatory process into a referendum on for-profit higher education writ large. After that, every piece of data, every anecdote, proved the sector's outright denial to be overstated. In this sense the reputational damage to the sector was largely self-inflicted.
Bob makes some excellent points about trust. The concept that the government can declare institutions worthy of our trust is flawed. Government should empower not restrict.
Bob misses the last 30 years of powerful lobbying by large state institutions on government bureaucracies to slow down or crush entrepreneurs—rebels with a cause—who are trying to improve the education system because they are a direct threat to the status quo. This extremely powerful lobbying by the status quo has influenced public perception by taking very small problems and exploiting them across an entire sector.
Profit and power are motives that can be used for good or evil, but I believe that public opinion regarding trust of state institutions, private not for-profits, and especially community college systems are deteriorating at an almost biblical rate. It's interesting to note that over the last year and a half, we have not seen any "occupied" demonstrations on for-profit colleges—only non-profits. Might it be that the people attending the for-profits schools are completely focused on getting in, getting out, and getting on with their life with careers?
Bob, I have personally spoken with the CEOs of most of the schools who informed me that they were never invited to participate but were singled out as the sole problem in the education sector. Why hasn't the IRS begun similar investigations into the rampant abuses within the non-profit postsecondary education systems when it comes to use of funds? I must say, I take issue with your comment that it was an "apples for apples" discussion. The resulting regulatory landscape clearly does not confirm a fair and balanced equal playing field, nor has it done anything to help students get a better education at an affordable price, nor does it provide professional development, increased salaries, or benefits for faculty, nor does it attract quality leadership from the private sector to teach. I find it disingenuous to say that "the reputational damage to the sector was largely self-inflicted."
I appreciate that some students want to "get in, get out, and get on with their lives." The way to accomplish that is to skip college and just take a test that demonstrates what you already know and can do. We should figure out a way to subsidize that so that these students' time and our taxpayer dollars are not wasted. To be worth a substantial taxpayer subsidy, education needs to do more, motivating and inspiring students to learn and create beyond their previous zone of knowledge and comfort.
As for the CEOs who told you they were singled out as the sole problem in education, I can neither defend them nor can I explain or confirm the accusations. I can see an extraordinary amount of evidence produced by government and media investigators of blatant, cynical abuses in the for-profit sector resulting in serious harm to students and taxpayers. I also see problems and scandals emerging at public and nonprofit institutions regularly. They don't band together and complain that they are being attacked for being public or nonprofit. Why do so many for-profit leaders play the victim card instead of working to prevent, confine and repair the problems that do come up?
- What is a good actor in for-profit postsecondary education, and how do you define it? What is a bad actor and how do you define it? Click to View the Answers
A good actor recognizes the information asymmetry in the higher education transaction and endeavors to correct this market imperfection by serving as a neutral advisor to potential students and to enrolled students. A bad actor (in any sector) takes advantage of the information asymmetry. A very bad actor takes advantage of the information asymmetry with the most vulnerable consumers.
In the recruitment phase, good actors make suggestions of other options potential students could consider and encourage them to compare; bad actors feed on students' misperceptions about the magic that a college degree can do ("People with a BA in office management can run a hospital, making up to $180,000 or more! We're accredited by the same agency that accredits Harvard! We have classes starting tomorrow, let's get you signed up!") Very bad actors leave many students worse off, and often justify their deeds by posing as saviors of the poor.
In providing the education, good actors have a challenging curriculum that inspires and motivates students to work hard in ways that lead to deep learning; bad actors — too common in all sectors -- have a curriculum and faculty that may look fine on the surface but fails to engage students in ways that inspire lifelong learning.
Great job, Bob— you nailed it on this one! Let me just add that for the last 14 years, I have encouraged any institution that we sponsor financially or help create or manage going forward to fulfill what I lovingly refer to as our "Four Gospels of Higher Education," which are to: (1) lower tuition and fees every year; (2) provide broader access; (3) graduate faster with less debt; and (4) get an education with a purpose. Over the last ten years, it has been my experience that if the leadership of an institution can focus on those four metrics in all of their strategic planning, the "good actor" in every group emerges.
- Why has the cost of education outpaced inflation over the fifty years? What are the mechanisms to reduce the cost of higher education? Click to View the Answers
The cost of delivering undergraduate education averages something under $10,000 annual per FTE at community colleges, about $12,000 at state colleges, and $15,000 or more at public research universities. Spending is much higher at some public institutions and especially at the brand-name private universities which have been competing for star faculty, building the most up-to-date facilities, and adding the latest equipment. Amenities to compete for students have also played a role. The escalating spending at elite colleges leads others who want to join the club to spend also if they can find the money.
At public institutions, spending has increased somewhat more than inflation because education is labor-intensive. A good professor choreographs a student's interaction with carefully-selected content, finding ways to motivate the student to put in the brain effort necessary for learning. It is difficult to replace these complex, nuanced judgments with either cheaper labor or with technology. When innovation does occur (e.g. calculators, or Rosetta Stone language learning programs) the boundless nature of higher learning means that new challenges often replace the old objectives rather than reducing the requirements for a credential.
One way to reduce costs is to demonstrate that excellent undergraduate learning can occur at colleges without star faculty and expensive facilities.
Here's another approach. "Full-time" college students today spend far less time in class and studying than college students did 40 years ago. Let's reboot the system, elevating standards to significantly increase student academic engagement while reducing many majors to three years. The result would be students who do more college-level work than they do in four years now, while finishing a year earlier.
Bob, you highlight the fact that the big issue is that college is labor-intensive. Why has government, especially while you were at the department, not created a regulatory environment to put pressure on all institutions to lower costs? I'm not an advocate of price fixing or margin monitoring, but the current system of giving more loans to students who are unaccountable to pay higher tuition of a result as such flawed policies as 90/10 seems to create a big part of the mess that we are now experiencing. Why isn't government creating accountability levels that encourage, not penalize, institutions to lower tuition? I guess my prejudice would be that government does not know how to lower costs and only knows how to demand more.
When I read the speeches regarding policy from all of the presidents and chancellors of state institutions, not once has anyone mentioned cost cutting, efficiencies, or issues like labor demanding more benefits, entitlements, salary increases, and guaranteed lifetime employment for no work called tenure. Help me, Bob, with this issue.
Regarding labor costs, I think that he is missing putting the "big turd" on the table: tenure.
When I went to pay for my daughter's parking fees at UCSB, I walked across a very large parking lot with hundreds of spaces reserved right next to the classrooms. As I doled out my $1,500 per year for a parking place, I asked the wonderful student worker clerk who all those parking places were reserved for. She snickered, "tenured faculty…a bunch of really old people who haven't been here in 15 years but they still get a parking place…and people like me have to work at this job just to try and stay in school."
Just like any of our current government financial problems, we must take a scalpel to the "entitlement mentality." We must begin to direct our limited resources where they will have the most impact.
I would argue that the enormous amount of waste in the non-profit sectors that are trying to create star faculty, building expensive buildings that are hardly used, and bragging about the latest equipment does very little to improve learning outcomes.
To effectively educate America's middle class and compete on a global basis, we need to integrate private sector professionals with the highly unionized and entrenched current faculty. No doubt, this will be a difficult endeavor for leaders. Learning is mostly about motivation, and if we inject innovation like Bob references (calculators, Rosetta Stone, or the latest Apple textbook self-publishing software), we can continue to challenge students to learn more cost effectively.
I agree wholeheartedly with Bob on "rebooting the system." The amount of actual teaching that takes place at the normal non-profit institution continues to decline every year. There must be a rebooting to compress full-time work by students, faculty, and staff— and we need to take a hatchet to the mind-numbing 60 credit hours of General Education.
In both non-profit and for-profit sectors, increased involvement and regulations from the federal, state, and special licensing institutions consumes an enormous line item budget expense. In institutions that I financially sponsor (both non-profit and for-profit), I estimate that at least one-third of the leadership team's time is spent navigating a very complex regulatory environment. Why can't we simply teach and measure the results?
When I testified with the CEO of Devry a few months ago, he got a lot of mileage out of his declaration that we should regulate based on outputs instead of inputs. Everyone nodded: we all like the idea. But no one puts forward an actual proposal for how to do that. One offered analogy was that rules regarding the construction of the building were designed to ensure that we would not be crushed by a collapsing roof or unable to exit in a fire. These rules were portrayed as a good, outcomes-based approach. After the hearing I realized the analogy made no sense at all. In fact, those rules are about inputs — the materials, the dimensions, the workmanship -- not the outputs.
We need specific proposals for measuring outcomes, not constant, repeated exhortations that outcomes measurement is the way to go. Measuring outcomes is the key to reducing costs, because it eliminates the argument that an innovation has reduced quality.
- What role does the 90/10 rule play in escalating tuition prices? Do you think that it is time to change the 90/10 rule? How should Congress change the 90/10 rule? Click to View the Answers
In the early days of the University of Phoenix, many of the students were working professionals whose employers were paying the tuition or who could support their own education. The need to satisfy this set of full-pay, more sophisticated consumers and employers meant that the program had to maintain its quality as it grew, and it needed to be priced reasonably. By requiring ten percent of a college's revenue to come from somewhere other than the U.S. Department of Education, the 90/10 rule was supposed to institutionalize the accountability that comes from the need to appeal to at least a few full-pay customers.
The 90/10 rule was an adaptation of a GI Bill rule affirmed by the U.S. Supreme Court as a "free market mechanism" designed to "minimize the risk that veterans' benefits would be wasted on educational programs of little value" by "weed[ing] out those institutions [which] could survive only by the heavy influx of Federal payments." As the Senate Committee on Veterans' Affairs found in 1976, "if an institution of higher learning cannot attract sufficient nonveteran and nonsubsidized students to its programs, it presents a great potential for abuse..." The rule avoids government micromanaging while creating an incentive for programs that are offered at a reasonable cost and that lead to employment and earnings outcomes that satisfy graduates and employers.
Unfortunately, the Education Department version of the rule was poorly drafted, allowing colleges to enroll 100 percent federal-aid students as long as they charge them more than the aid available so that at least ten percent of total revenue comes from other sources. Obviously, this defeats the purpose of the rule because it does not require any full-pay students at all. Congress needs to revise the rule so that it provides the market discipline that was intended, ensuring that colleges are providing a product that someone would be willing to buy without a government voucher.
90/10 is outdated, unmanageable, and just plain stupid. It's amazing how people that are in the education business can come up with such ignorant policies. All that has been accomplished through 90/10 is a negatively profound impact on pricing, which is an unfair, un-American approach attacking for-profit institutions. Most non-profit institutions could never comply with this rule. 90/10's only solution for institutions is to raise prices, thus hurting the consumer. It is bad policy and needs to be eliminated! Why can't we come up with solutions that are innovative to accomplish the same goal? Bob, why can't non-profit institutions outsource via very specific government contracts to for-profit institutions? They could assure that the right students get the right education with the right outcomes. We can institute much more rigorous metrics as an opt-out to 90/10, but it won't happen unless we level the playing field among all institutions.
Why can't the government create a regulatory environment for free market solutions to flourish? This doesn't happen by trying to over-manage, over micromanage with "one size fits all" regulating all the details. Why not set up some pilot programs based on the private-public partnerships concept? Why not invite people like Michael Dell, Bill Gates, Steve Jobs, Mark Zuckerberg, etc. into this process to improve education?
The rule is a free-market mechanism, testing whether anyone values the product enough to buy it at that price without a government voucher. The fact that some for-profit colleges have perverted the rule into an excuse to raise tuition is not a reason to eliminate the rule, it is a reason to fix it so the colleges can't do that. And if in the process you want to apply it to all colleges, that's fine with me.
- Do we as a society need to have 4,000 institutions of higher education? Would it be preferable to see a consolidation of higher education institutions to eliminate duplicative costs? Click to View the Answers
A convincing economics literature suggests there are inadequate incentives for public and nonprofit entities to combine even when it clearly would be efficient to do so (the participants sit tight because they can't sell out their shares to monetize the efficiency as a for-profit would do). This calcifying dynamic does seem to be at play in higher education and in K-12 education.
Bob brings up an interesting point that I never thought about—incentives. I have seen over and over again little fiefdoms created in the non-profit and public entities. They only want to "combine" when they are out of cash. In the last year or so, my phone has been ringing off the hook with public and non-profit entities scrambling for cash. They want another Grand Canyon University—instantly! I think GCU has spent an estimated $120 Million plus on new buildings in the last 18 months and a similar amount going forward. And this is done by providing the only private university degree program in the State of Arizona at more than 15 percent less than Arizona State University's in-state tuition with Ritz-Carlton-like facilities, world class faculty, and Nordstrom's-like personal service! Gee, I wonder why they're doing so well?
My answer would be that we need more than 4,000 institutions of higher education. We need more specialized institutions to address the global job market. We need fewer institutions that try and be all things to all people. I would much rather see institutions with the highest quality, expert faculty on very specific job niches with the cross-pollination of bloated expenses, facilities, bureaucracies, and internal politics that cost so much time and money for a normal state/public/non-profit institution. This will require a tremendous upgrade in the accrediting commission's abilities to monitor more and more multiple institutions. No longer can you have a volunteer 30-year English teacher from a community college in Nebraska reviewing a high-tech technology department that offers the latest SEO technology with marketing and business support for an evaluation. We need to have specific horses for specific courses. We need to become much more localized in our administration and approach to education. Local citizens will understand how to leverage local resources to compete globally.
For our family, we will continue to donate and invest in institutions that become more and more specific, relevant, and intentional in providing the highest quality programs in the marketplace to help people live better lives. That is the culture and mission that drives our support of institutions.
- Advocates of the for-profit sector suggest that many private sector institutions have seen greater success with at-risk demographics at less of a cost when compared to urban public universities and community colleges that serve a similar demographic. Is this true? If so, would it make sense to outsource this role? Click to View the Answers
Advocates for every type of postsecondary institution have told me of their effectiveness, but rarely do any of them have evidence that stands up to much real, independent scrutiny. While awaiting better evidence, doing no harm is a good interim rule. Certainly when there is evidence that a practice is particularly effective, it makes sense to replicate it. (Whether "outsourcing" is the right approach depends on whether outsourcing is a necessary element of the practice.)
Bingo! Bob gets an "A" on his answer. I agree completely. The private sector or for-profit institutions are having greater success with at-risk demographics at a lower cost when compared to public universities and community colleges based on their financial model. "Mr. Market" will not allow you to continue to sell a shoddy product. More and more we will see a focus in private for-profit institutions on completion rates and job placement—not because of the Federalization of Higher Education Movement's intrusion from a regulatory standpoint—but because it is just good business.
We have been thrilled to financially sponsor a 70-year-old Christian university in Memphis branded Victory University, which is primarily a school for working adult females. I am amazed at the energy, commitment, integrity, and mission-driven, valued-centric enthusiasm from our average student profile, which is a 34-year-old African American female. Why can't the U.S. government reward an institution which is investing, taking risks with investment dollars, and working closely with the local community to empower this wonderful group of vital citizens to help live better lives for their families? By creating a supportive environment, rather than a divisive, venomous, attack-causing uncertainty, the government can indeed help its citizens not only in Memphis at our little institution, but nationwide with these best practices.
Sorry, I think Michael misunderstood my answer. I'm saying every college asserts its greatness, and it is difficult to test the claim. Recent research that attempts to take multiple factors, including student characteristics, into consideration shows worse outcomes at for-profit institutions on average. But I don't want to fall into the trap of sounding as if I think outcomes are measured well, or that all public and nonprofit institutions are better than all for-profit institutions.
Michael wants the U.S. government to reward college owners for taking investment risks. But Michael, you take a risk because you may earn enormous profits, as you have in the past. That's how capitalism is supposed to work. What additional "reward" do you think you deserve?
- Many postsecondary education companies are implementing quality enhancing initiatives, and Apollo Group implemented its orientation program, while Kaplan rolled out its Kaplan Commitment plan. In your opinion, are these moves sufficient to prevent misrepresentation? Click to View the Answers
They are good steps. I like the concept of a no-risk free trial that helps students to understand what they are getting into.
I was recently asked an accrediting commission meeting to define "quality"…I said it is like pornography…I know it when I see it. We all need to better define "quality". It is my belief that we will see many more initiatives like this in the near future, but not based solely on the regulatory pressure. I also like the "test drive" concept. It's a very innovative approach to introducing students to the institution and should be instituted at all public state and non-profit organizations as well.
It is my belief that innovators creating the 3.0 and 4.0 (see link to previous article) versions of post-secondary education will radically turn payment terms and conditions upside down in the future. For example, my dear friend Ken Blanchard suggested that people only get admitted to an institution once they have completed all the course work. He also suggested payment plans based on grade point average, speed to completion, and other metrics so performing students graduate at a much lower cost.
In the future I can see auction sites (not unlike eBay) as platforms for students bidding on various courses. As technology develops, we will begin to see "roll your own" degree programs that will enable students to take various courses from specialized universities, culminating in a degree and a resume for their dream job. To market various degree programs on a bid basis, institutions can manage the enrollment process across the board by having flexibility in placing a student in the right degree program just like many other industries.
We see a time when faculty will become more involved in the entire enrollment process, and the walls between faculty and admissions will come down. We see a time when compensation packages for faculty are performance-based and tied directly to student outcomes and overall financial health of an institution. I believe that if the faculty were more engaged in the overall operations of an institution with commensurate compensation packages, we would see dramatic, positive change across the board in public, private non-profit, and for-profit institutions.
In the future I predict that we will see regionally accredited institutions that can be profitable without title four student loan funds. As technology continues to create efficiencies, as staff and faculty embrace innovative online delivery models, and as legislators, regulators, taxpayers, and accrediting agencies are faced with increased challenges regarding access, we will see these new all cash models emerging. Institutions will provide degrees in exchange for 10% of the student's salary for a better than average return on investment. Students will own stock in for profits after graduation as a bonus for completing on all metrics above average. Innovation will be spread across the sector in all departments.
Fortunately, companies like Apollo and Kaplan had the ready cash available from their for-profit model to institute innovative new programs. The U.S. government should encourage this type of risk-taking investment by the for-profit sector to create tomorrow's best practices for all institutions of learning. "Bravo!" to our friends at Apollo and Kaplan for stepping up in response to the attacks on their to resolve these problems.
While I recognize the nod to Justice Stewart's famous line, I would have preferred a comparison to measuring beauty, virtue, integrity, or faith. Your Honor, let the record show that after insisting that we should measure outcomes, Michael's specific suggestion for how to accomplish that is to show it to him because he knows quality when he sees it.
- Many for-profits have engaged in substantial self-regulation in addition to complying with the new regulations. Presumably this is having the effect of improving the student experience and protecting consumers (possibly to the detriment of an institution's financial condition). As such, can one say that Bob Shireman and the Department of Education are heroes in that they catalyzed needed reforms? Click to View the Answers
The Department of Education and Bob should be credited for identifying real problems that the for-profit sector should have self-regulated. Unfortunately, in my opinion the prescription did not fit the diagnosis. Thank goodness that this is not brain surgery, except for the poor students' brains. Then Congress mucked it up with bipartisan bickering that did nothing but hurt the institution and students. Then came Wall Street to monetize the bickering. The solution should have been the accrediting agencies working with the state governments.
This all began with my calling Bob for a cup of coffee. Many thought that I was meeting with Darth Vader. Some thought that it was an act of valor. I honestly enjoyed my time with Bob over coffee and subsequent communications immensely. Freedom is the ability to agree to disagree in a civil forum. Thank you Bob for following through on your commitments.
The public policy issues in higher education are complicated and fascinating. They also matter in a big way, especially for the disadvantaged, for upward mobility, for the vitality of our future economy. I appreciate higher education leaders and innovators who dive in and grapple with the questions about how to address those tough public policy dilemmas; I look forward to more good dialogue.
- What do you think of the role that investors and sell-side research analysts play in the education space, in regard to regulatory/legislative developments, as well as uncovering some of the challenges and opportunities that exist in the higher education industry? Click to View the Answers
In both the student loan and for-profit college arena, I find many of the analysts to be sorely lacking in objectivity. They tell me this is because they must be cheerleaders in order to have access to information from company officials.
It would be wonderful if federal and state regulators and especially the accrediting commissions could hire third party research analysts to provide the exact same analysis that shrewd investors get for for-profit institutions in parallel to state and non-profit institutions. This would add to my strong belief that total transparency with level playing field rules will produce a desired outcome of improving higher education for all U.S. citizens. Imagine if all institutions were subject to the quarterly scrutiny! Imagine if the entire non-profit segment was subjected to the intense quarterly detailed financial and operational scrutiny on a quarterly basis, like the for-profit public companies experience! Everyone would win.
- Was Steve Eisman a credible witness? Are we better or worse for having Steve Eisman testify in front of Congress? Click to View the Answers
There is good reason to be skeptical of commentators who have a financial interest in the outcome of an issue. The challenge, of course, is that those with a financial interest, positive or negative, are often the ones who have studied the industry most intensively.
One of our Founding Fathers clearly stated that a free democracy does not work unless it has a small element of corruption. Steve Eisman is one of the smartest people on the planet. This misanthropist seized on the fear of the investment community, the grandstanding hunger of weak politicians seeking headlines and favor from unions, and a totally arrogant, unprepared leadership of for-profit education institutions. Eisman jumped right into the middle creating a perfect storm for his pocketbook and those of his investors. Sometimes I wish Steve Eisman was running the Department of Education.
- Are the program integrity rules sufficient to maintain appropriate conduct by institutions over the long haul? Click to View the Answers
History suggests not. The regulators, the colleges, and consumer groups all need to be vigilant so that problems do not re-emerge.
Hopefully, just like the Japanese Admiral said in Tora Tora, the last two years has indeed awoken a Sleeping Giant. From my travels with the leadership of both large non-profit universities as well as for-profit universities, it is clear that this wake-up call has launched the first real, unified lobbying effort for postsecondary education beyond the non-profit scramble for public money and grants. The for-profit industry better continue to fund, pay attention, and make a legitimate case based on real outcomes and real data, all driven by innovation if it deserves to maintain its licenses. By the way, I hate our system whereby the only way to win is with lobbyists.
Misrepresentation has always been the real problem in this business sector. In fact, misrepresentation is always the problem in any business or non-profit sector. Lying is wrong. Bob, I'm interested to know—why do you think that the rules you promoted are actually working? Did the bureaucracy get your intention wrong? What would you like to see the outcome be for the future if you had it to do over again?
- Should for-profit and non-profits operate under the same set of rules? Click to View the Answers
Mostly, yes. But there are differences between for-profits and nonprofits that should not be ignored. Owners of for-profit companies have the right to seize the uncommitted net assets of the enterprise at any time, creating an incentive for efficiency and growth. This incentive can have an ugly side, especially when the consumers are unsophisticated and the government is largely paying the bill. Managers of nonprofit (and public) institutions relinquish their claim on the unrestricted net assets of the enterprise as a way of assuring customers and funders that the resources are dedicated to education. With a product that is difficult to judge, this invites trust that the college will not cut corners or grow in ways that undermine quality.
Treating for-profits the same as nonprofits would mean that for-profit owners would have to give up their equity stake in the company. Some have taken this step. However, for those who choose to maintain an equity stake it is appropriate for public policy to recognize the potential hazards and apply appropriate protections.
Bob, I read your response three times. I must say that it irritates me when government leaders insult students, their families, counselors, and employers as "unsophisticated." This is the haughty, typical government-run approach to over-regulation. Our Founding Fathers believed that each American was smart enough to govern themselves under the Constitution to seek life, liberty and the pursuit of happiness; they never said that people were unsophisticated, stupid, and lacked the ability to make choices! I have answered hundreds of student inquiry telephone calls, reviewed numerous application essays, and interfaced with parents, employers, high school counselors over the last 12 years. I also have met with immigrants who barely speak or read English that want to get into our colleges. Never, in all of those encounters, have I met a student who was "unsophisticated." Nor have I met a student who says, "I really hope that the U.S. government helps protect me from your school." These students are vigilant shoppers; they ask the right questions. We, as an industry—both non-profit and for-profit—need to have more transparency, with full disclosure on all issues to help them in their search. These students understand better than the government that they are making a gigantic time commitment plus possibly the largest financial commitment that they will make in their life other than a home mortgage.
At our sponsored institutions, we understand the magnitude of the decision that a student is making—and Bob, let me tell you—so do they.
The state and federal government with regulators need to refocus, redefine what they term "consumer protection." They need to create a crowd-sourced review process not unlike Netflix, Yelp, and other state-of-the-art review operations.
Now that I have ranted and raved about an issue that irritates me, Bob, let me just say that unless the federal and state governments with the regulators create a very fair, level playing field that treats all post-secondary education institutions equally with full transparency, there will always be a way for someone to game the system. It is the same philosophy required when one has two or more children in your family.
Michael is putting words in my mouth and then overreacting. He himself praised my earlier assertion that there is an information asymmetry that makes some consumers vulnerable. I suppose I can agree that unless there is "full transparency, there will always be a way for someone to game the system." But what, pray tell, is "full transparency," and how do we get there? Specifics, please.
- Should the government provide student loans rather than the private sector, and if so why? Click to View the Answers
The conservative economist Milton Friedman first suggested a government loan program as the right approach to a market failure that tends to cause people to under invest in their own training. If the government is shouldering all of the default risk and is making the underwriting decisions (who can borrow, how much, at what price, for what training, at which institutions) then taxpayers should also get any earnings on capital to help compensate for the cost of those risks. That said, the government should and does rely on private sector companies to do the actual work of collecting payments on the loans. (See a video of my explanation of the history and finance structure of the student loan program at http://www.newamerica.net/events/2009/future_federal_student_loans).
Adam Smith might be suicidal if he reviewed the philosophical approach to what is now a governmental monopoly of underwriting and servicing student loans. What is the tricky area of "student" loans? Credit risk. Most students that I have spoken to don't even understand what they are getting into. Yet the United States Department of Education holds the schools responsible for the students' use of the money they borrow.
The schools do all their work getting the money, educating the student on what they are getting into, and then hand it to the student, hoping and praying that the student uses it for school, and then the schools get penalized if the student doesn't pay it back even if they didn't use it for school. Wow. What a broken system.
To add insult to injury, the government contracts out all loan collection which creates a layered, bureaucratized structure ensuring that it will cost more money to collect the loans than a traditional, purely private sector context. Do the numbers.
Fundamentally, my friend Bob's Shireman's thinking (known lovingly in some circles as the "Shirementality") is a micro view of student loans, which reflects a macro view to extend government intrusion or takeover of most of the U.S. economy. We've seen the recent federal government push green energy lending. Does anyone want to invest in Solyndra? How about those electric cars? When are we going to see the administration riding around in a Volt limousine? Or, how about a new space colony on the moon. Democrats, Republicans, yuk.
While we're on the topic of loans—like mortgages—let's take a look at where the government really has demonstrated its credit granting skills with Fannie and Freddie currently at a $150 plus Billion of losses—and still counting.
As a follower of Jesus Christ, one of my principles is to try and lend money to those that need it with little or no interest, and I don't expect to get it back. When I'm in business, however, I must always demonstrate that my business model can indeed pay back the bank plus interest so that they can help other small businesses like mine. Many of the people developing these programs for the Federalization of Education Movement have zero visceral understanding of the private sector because they have spent their entire intellectual life marinating in governmental jobs and think tanks! Maybe they need to watch/learn how a bank works by viewing "It's a Wonderful Life!"
Unfortunately, our people are split now between the different philosophies of earning a living and paying for goods and services like an education, or getting easy money loans to do the same. Bob, help me understand how the current direct lending program has improved customer service for students, contributed to better learning, and—most importantly—helped lower the cost of education. Help me understand your thinking, because I am missing something important, I am sure.
Clearly you didn't watch the video. The decision to involve the government in backing student loans was made when I was four years old, and I was not asked for my opinion at the time so you really can't blame me for that. Despite the demagoguery about government takeovers, the recent shift from guaranteed to direct student loans changed how the private sector is paid for its role, it did not expand the government's portfolio or risk. And it reduced the taxpayer costs.
How the loans are delivered has nothing to do with the default rate issue that Michael complains about. I agree that default rates are deeply flawed as an indicator of quality. What measures or processes would you suggest for determining whether schools did their job with the taxpayer funds they receive?
- Should Congress consider imposing some kind of risk-share program on for-profit schools? Click to View the Answers
I like the concept, but operationally it is severely flawed: the school most able to set aside funds for risk-sharing would be the school that spends the least on instruction while charging the highest tuition possible. Clearly there's some serious design work that needs to be done for the concept to work.
I don't like any kind of notion of Congress "imposing" any programs on any schools, whether they be non-profit or for-profit. The federal government should stay out of the "imposing" business in higher education.
Having stated my philosophy, I think that states should provide a free market regulatory environment based on risk sharing for both non-profit and for-profit schools. It is time for some innovative pricing models that reward students, faculty, and staff for desired positive outcomes. If the federal government tries to impose a one-size-fits all program, it will be a disaster like 90/10. I like the concept.
- Could the federal government do a better job at accreditation than the accreditors? Click to View the Answers
Without private accreditors to rely on, the federal government would have to turn to someone to help make expert judgments about quality. It's likely to be the same types of people and organizations who are now involved in accreditation. So I'm not sure it would end up much different than what we're seeing now.
The concept of regional accreditors works because it is much more localized. The leadership at WASC knows what the citizens of California and Hawaii need better than the people in the Department of Education in Washington D.C. The more localized that we can make education, the better that we will be able to compete globally. If I could wave a magic wand, I would give more power to innovative accreditors like Dr. Ralph Wolff at WASC, Dr. Sylvia Manning at HLC, and Dr. Belle S. Wheelan at SACS. They are on the front lines intervening, interacting, innovating, instituting, and providing a "get it done" atmosphere for educators. Give them more resources and more power and let them level the playing field between non-profit and for-profits in order to inject more efficiencies and better outcomes for students.
- What are your thoughts regarding public private partnerships between non- and for-profit institutions? Click to View the Answers
Among four-year colleges, I expect we will see more partnerships with for-profits taking on a vendor role, bringing innovation and efficiency through new platforms and processes for teaching and learning while leaving the ultimate decisions about quality to the nonprofit institutions. The growth of for-profit institutions may be stronger in vocational education, where the clearer objective makes accountability easier. For-profits have performed best in that space.
We are seeing such incredibly explosive and rapid changes, driven by Silicon Valley's digerati not across every business sector, that dinosaur-type leadership in K through 20 education is hurting students and employers. I am astonished at the public school system here in San Diego, which has huge gaps in their teaching of hands-on, real-world knowledge. Students aren't taught how to open a bank account, vote, balance a checkbook, or write a resume, and high school students don't' have a grasp on American history for the first 100 years of our country. They do not know how to collaborate or process critical thinking, and their communication skills—other than texting or Facebook—is almost nil. The classroom configurations are outdated and ineffective. I cringe when I drop my 14-year-old daughter off at high school, thinking that she will be fixed in an uncomfortable chair looking straight ahead for six long hours at a 27-year-old talking head who is reading from last year's notes. It is a painful experience to subject my very bright, creative teenager to at this time in her life. No wonder she is completely diverted by her community of friends rather than thirsting for knowledge!
Bob, why didn't you encourage in the new rules you proposed more public-private partnerships? Your answer baffles me because all the new regulations discourage this concept. Again, why can't we level the playing field? Why did the DOE almost kill companies like 2Tor, Altius, Embanet, IPD, and Deltak, that provides such valuable outsourcing to both non-profits and for-profits?
It is my belief that various education consortiums within specific niches would lower costs, increase access, and provide much more best practice professional development for staff and faculty.
For example, we are currently sponsoring an initiative to create a consortium of Christian colleges. We are providing money, marketing and management, especially in the area of online and integrated flex programs, to greatly enhance this niche. I have a personal fondness for these wonderful local institutions that have been anchors of positive morality in their communities for 50, 60, or 70 years. By bringing together in public-private partnerships within the Christian niche of colleges, it is my hope and prayer that we will be able to accomplish lower tuition, broader access, faster graduation with less debt, and provide an education with a purpose to help people live better lives.
I'm all for inculcating a thirst for knowledge. But I don't know what sin of omission Michael is accusing me of ("why didn't you encourage…"), and I don't know what specifically Michael is suggesting about niches and consortia and playing fields and best practice. Without specifics, it's just gibberish.
- Do you feel that every person is intellectually equipped to pursue a four year college degree? If not every person is intellectually equipped to pursue a four-year college degree, then what can government do about sorting out who should have access to government funding for a four year degree and who should not? Click to View the Answers
It drives me nuts when I hear people within the federal government take on the God-like responsibility to decide whether or not a student has potential or deserves funding for an education. My belief has been that an educator's job is to meet students where they are and then teach them through graduation. The educators that I know are very passionate do so. I have seen Ph.D. business professors at a school in Cleveland that we sponsored donate time to help freshman incoming inner-city students with very basic math tutoring, while stepping into the classroom to teach super-energized, high-level Fortune 500 business executives. Their passion is the same—which is to teach.
Let me tell you a story…I have seen over and over again young people who are not motivated in their freshman and sophomore high school years for many reasons, including trying to fit in socially and find themselves. All of a sudden, in their junior year, they become very motivated and "put the pedal to the metal" in their junior and senior years and get great grades. They have a high expectation of going to college, but are devastated when they submit their four-year average and are denied access because the government has decided that they are "not intellectually equipped" to pursue a four-year degree. The potential of a young person is killed with over-regulation.
I am very proud that the educators that we sponsor have begun AP and Dual Enrollment programs to help motivated juniors and seniors in high school gain a positive pathway into our institutions, or any regionally accredited institution. It is a costly program, but the rewards of helping those students overcome traditional barriers to entry are worth every penny.
We need to see a merger of the four years of high school and the four-year bachelor's degree. High school needs to become a two and a half year experience, and the four-year bachelor's degree needs to become a three-year or less experience. Programming needs to be fully integrated based on an Individualized Learning Plan with a heavy integration of personality testing, skills evaluation, passion meters, and exploratory internships over a full six-year period based on new internships every semester. This simple concept, executed at the local level, would jump-start our high school and bachelor programs immediately.
Funding from the federal government is available for all types of postsecondary credentials, not only four-year degrees. Institutions have a responsibility to ensure that students are capable of benefiting from the programs they pursue, and federal funds are only available if students are making satisfactory academic progress. Accreditors should review these aspects of a college's operation.
- Should the State of California make available the applicant lists of students who are turned away from the state systems to help provide alternative access? Click to View the Answers
That California education systems have not made the 400,000 qualified applicants list of students who were turned away from the state system available is a crime. These people are missing out on an opportunity to review alternative places to receive an education in the for-profit sector. Special interest groups have literally locked up the lists in order to use them as leverage on the state legislature. It has been my belief that WASC should create a centralized enrollment center to protect consumers while expanding access, creating competition (which will lower costs), with an opportunity to monitor real time a student's progress from inquiry to completion.
Where a student applies to college seems to me like a private matter, so I do not support the idea of turning over those names to third parties without the student's permission. With all of the advertising out there, people know there are other options. What they need is objective help figuring out what is a good fit for them and how to safely pay for it. If WASC can offer that service, great.
- Technology, innovation, and the discipline associated with capital investment in the commercial world have provided great benefits to society -- would you agree that we can expect similar leaps forward if these principles are applied to education? Click to View the Answers
The market of education providers is robust, with companies every day applying capital investment to innovation in education. This will produce leaps; the role of public policy is to help increase the chance that those leaps are indeed in the forward direction.
We are going to see an International Invasion of Educators primarily from India, China, and Brazil in the next ten years driven by low-cost structures, incredible academic work ethic, freer regulatory environments, built-in ethnic constituencies in America, and a global perspective of capitalism. I predict that many new institutions from India, China, and Brazil will set up shop in the United States and offer state-of-the-art programs based on current job openings, much lower tuitions, and better facilities, combined with much more current, innovative, and dramatically more intelligent faculty, staff, and leadership. This will be the next wave of change in education in the United States and will begin to dominate our lives in the next few years. No longer do India, China, and Brazil revere the United States' education system as in the past; they clearly believe that theirs is better, so they will be coming to take market share from both non-profit and for-profit institutions.
This invasion from international schools, which is driven by technology, innovation, and discipline, is because they are getting more investment capital than our institutions—especially in the last two to three years—due to over-regulation, uncertainty, and the vitriolic attacks on for-profit schools. We are asleep at the wheel with the U.S. education system, both in the for-profit and non-profit world. Additionally, they are free of regulatory impediments and are backed by the national pride of India, China, and Brazil's new billionaire club. Shame on us if Indian, Chinese, and Brazilian educational institutions take over America's system!
Bob, why doesn't the federal government support innovative education initiatives in the for-profit sector like they supported Solyndra? Why is there a hostile, divisive attack on an emerging industry that can actually help solve problems? Why discourage hundreds of millions of dollars of capital coming in to the education space, both to enhance non-profit schools through outsourcing as well as for-profit schools to fulfill certain niches by stifling invention, innovation across the board? Why disregard investment in education for a Volt?
Bob, from where you sit with your experience in government, what can be done to improve these relations? What should all the stakeholders do to win win win?
In working in three regional accrediting areas over the last 12 years, I have found that WASC, SACS and HLC leaders have demonstrated the right kind of governance to encourage private-public partnerships, innovation, and capital attraction and provide a better student experience. Why can't the Department of Education learn from these people that are helping empower a better student experience? Why must there always be an "Us or Them" approach?
Why not begin merging key agencies at the state level to provide a seamless, integrated education system with the business community? Why have a Department of Education, a Department of Commerce, a Department of Agriculture, a Department of Post-secondary Education, a Department of Vocational Education, or any other departments for that matter? Read George Washington's farewell address when he begged for Americans to be Americans and avoid partisan politics. Read how our Founding Fathers wanted freedom from excessive regulatory governance in order to pursue life, liberty, and the pursuit of happiness. Why can't we, on a local level in our communities, merge these warring, tax-sucking agencies into a seamless, lifelong learning integrated academic, socially responsible, scientific, health-oriented, purpose-driven, profit-making compassionate capitalistic system?
Michael, you keep accusing advocates of holding schools accountable for using taxpayer money wisely and educating our students as engaging in "a hostile, divisive attack." This drumbeat does nothing to address the real challenges in higher education. When I asked one commentator why he wrote that I wanted to kill for-profit colleges, he told me that "everyone" told him that. How does it help for you and other for-profit leaders to play the victim? Not one of our regulatory proposals was restricted to for-profit institutions, yet the for-profit colleges keep telling the public otherwise.
Even leaders of for-profit colleges admit the incentives can be problematic. Kaplan's Andrew Rosen: "An investor who wants to make a quick hit can. . . buy an institution, rev up the recruitment engine, reduce investment in educational outcomes" and deliver "a dramatic return on investment....[T]here will always be some leaders who choose to manage for the short term. . . particularly when they hold the highly liquid equity stakes that the leadership of private-sector institutions sometimes receive as part of their compensation."
How, specifically, would you suggest the incentives for innovation be steered toward good and away from ill? It's not enough to say the government should measure outcomes or be fair or smart or treat everyone equally. Specifics, please.
- What is the future and role of online in higher education, and how should the Department of Education confirm the quality of online programs? Click to View the Answers
It is my belief that online education has just begun disrupting K through 20 education. Again, I feel that all of these quality outcome governance issues should be as localized as possible, with the accrediting bodies being given most of the power.
Twenty years from now, educators will look back at those "cute, beautiful things called campuses." While there will always be a place for a campus experience, there is no way to educate the United States—let alone the world—without delivering education via mobile phone-like units. Online education delivered from the cloud, anywhere, anytime, on any device will create a lifelong learning approach to education. "Roll-your-own" degree programs will enable a student to take a history course from a specific institution and a specific professor in a very specific niche while taking math from another institution's professor, with their entire educational experience culminating into a degree that is the resume for their desired job and career. Global corporations will begin to write the resumes for potential employees before the student starts college, with assorted payment plans attached to performance upon graduation. All of this can be done through the technology of online education.
A high-quality education is not a one-way interaction that can just be "delivered." Unfortunately, much of higher education is not high quality, and I am eager for new approaches that can inspire and guide learning. Technology is key, but I do not expect it to replace all live or face-to-face human interaction in education.
- What should the role of the for-profit sector be in educating future generations in face of dwindling federal and state funding? Click to View the Answers
As I shared elsewhere in this interview, I believe that we will see emerging for-profit institutions that do not rely on Title IV funding. The deployment of technology in the online learning space combined with innovative approaches by regional and national accrediting agencies will create this global phenomena. Many free degrees already are being offered, but the next key will be when the accrediting agencies adopt all of these new emerging models. I believe that we will soon see an "all-you-can-eat" online regionally accredited model based on a monthly subscription fee of perhaps $99.00 per month to serve as a self-paced, self-motivated accredited degree program.
I agree we are seeing the development of some pretty interesting options for the self-motivated learner. The real efficiency will come with innovations that motivate the student who is not self-motivated, providing them with expert guidance without involving nuanced judgment by people who need to be paid.
Due to time constraints, I was unable to ask all the questions submitted by industry leaders and postsecondary stakeholders. If you would like to submit additional questions that may be answered at a later time please click here.