For-Profit Schools
Experiences of Undercover Students Enrolled in Online Classes at Selected Colleges
Gao ID: GAO-12-150 October 31, 2011
Once comprised of local, sole-proprietor ownership, the nation's for-profit institutions now range from small, privately owned schools to publicly traded corporations. Enrollment in such colleges has grown far faster than in traditional higher-education institutions. Moreover, during the 2009-2010 school year, for-profit colleges received almost $32 billion in grants and loans provided to students under federal student aid programs, as authorized under Title IV of the Higher Education Act of 1965, as amended. Because of interest in the student experience at for-profit colleges, GAO was asked to conduct undercover testing by enrolling in online classes under degree-granting programs. To conduct this testing, GAO selected 15 for-profit colleges using a selection process that included the 5 largest colleges and a random sample and attempted to enroll using fictitious identities. Once enrolled, each fictitious student engaged in behaviors consistent with substandard academic performance. Each fictitious identity enrolled for approximately one term, as defined by the college. The experience of each of GAO's undercover students is unique and cannot be generalized to other students taking courses offered by the for-profit colleges we tested or to other for-profit or nonprofit colleges. GAO intended to test colleges that were unaware of its true identity. However, there exists a possibility that these colleges identified GAO's fictitious students and altered their behavior based on the assumption that they were under observation. This product contains no recommendations. Where applicable, GAO referred information to the Department of Education for further investigation.
During the course of undercover testing, GAO documented its observations related to enrollment, cost, financial aid, course structure, substandard student performance, withdrawal, and exit counseling. Overall, GAO observed that 8 of the 15 colleges appeared to follow existing policies related to academic dishonesty, exit counseling, and course grading standards. At the 7 remaining colleges, GAO found mixed results. For example, one or more staff at these colleges appeared to act in conflict with school policies regarding academic dishonesty or course grading standards, or federal regulations pertaining to exit counseling for student loans, while other staff acted consistent with such policies. Enrollment: GAO attempted to enroll its students using fictitious evidence of high-school graduation--either a home-school diploma or a diploma from a closed high school--at all 15 colleges and successfully enrolled in 12. Two declined GAO's request for enrollment based on insufficient proof of high-school graduation. Another allowed GAO's student to begin class, but rescinded acceptance after 1 week, citing lack of high-school accreditation. Cost and Financial Aid: GAO's students took 31 classes in total at an average cost of $1,287 per class. These costs included such items as tuition, books, and technology fees. All 12 students were eligible for federal student aid, but only 10 actually received disbursements; the other students were expelled without receiving disbursements. We did not observe that a college collected federal student aid funds after the withdrawal date of any of our students (that was not fully refunded immediately). Course Structure: GAO's students were enrolled in introductory classes, such as Introduction to Computer Software and Learning Strategies and Techniques. Courses ranged in length from 4 to 11 weeks, and students took from one to four courses concurrently. Courses generally consisted of online discussion forum postings; writing assignments; multiple-choice quizzes and exams; and skills exercises, such as keyboarding tests or computer exercises. Substandard Academic Performance: GAO's students engaged in substandard academic performance by using one or more of the following tactics: failure to attend class, failure to submit assignments, submission of objectively incorrect assignments, submission of unresponsive assignments, and plagiarism. At 6 colleges, instructors acted in a manner consistent with school policies in this area, and in some cases attempted to contact students to provide help outside of class. One or more instructors at 2 colleges repeatedly noted that the students were submitting plagiarized work, but no action was taken to remove the student. One or more instructors at the 4 remaining colleges did not adhere to grading standards. For example, one student submitted photos of celebrities and political figures in lieu of essay question responses but still earned a passing grade. Withdrawal and Exit Counseling: Three of GAO's students were expelled for performance or nonattendance. Eight of the 9 students withdrew from their respective colleges without incident. At the remaining school, GAO's request to withdraw was never acknowledged and the student was eventually expelled for nonattendance. 3 students did not receive federally mandated exit counseling, advising students of repayment options and the consequences of default.
GAO-12-150, For-Profit Schools: Experiences of Undercover Students Enrolled in Online Classes at Selected Colleges
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United States Government Accountability Office:
GAO:
A Report to the Chairman, Committee on Health, Education, Labor, and
Pensions, U.S. Senate:
October 2011:
For-Profit Schools:
Experiences of Undercover Students Enrolled in Online Classes at
Selected Colleges:
GAO-12-150:
GAO Highlights:
Highlights of GAO-12-150, a report to the Chairman, Committee on
Health, Education, Labor, and Pensions, U.S. Senate.
Why GAO Did This Study:
Once comprised of local, sole-proprietor ownership, the nation‘s for-
profit institutions now range from small, privately owned schools to
publicly traded corporations. Enrollment in such colleges has grown
far faster than in traditional higher-education institutions.
Moreover, during the 2009-2010 school year, for-profit colleges
received almost $32 billion in grants and loans provided to students
under federal student aid programs, as authorized under Title IV of
the Higher Education Act of 1965, as amended.
Because of interest in the student experience at for-profit colleges,
GAO was asked to conduct undercover testing by enrolling in online
classes under degree-granting programs. To conduct this testing, GAO
selected 15 for-profit colleges using a selection process that
included the 5 largest colleges and a random sample and attempted to
enroll using fictitious identities. Once enrolled, each fictitious
student engaged in behaviors consistent with substandard academic
performance. Each fictitious identity enrolled for approximately one
term, as defined by the college. The experience of each of GAO‘s
undercover students is unique and cannot be generalized to other
students taking courses offered by the for-profit colleges we tested
or to other for-profit or nonprofit colleges. GAO intended to test
colleges that were unaware of its true identity. However, there exists
a possibility that these colleges identified GAO‘s fictitious students
and altered their behavior based on the assumption that they were
under observation. This product contains no recommendations. Where
applicable, GAO referred information to the Department of Education
for further investigation.
What GAO Found:
During the course of undercover testing, GAO documented its
observations related to enrollment, cost, financial aid, course
structure, substandard student performance, withdrawal, and exit
counseling. Overall, GAO observed that 8 of the 15 colleges appeared
to follow existing policies related to academic dishonesty, exit
counseling, and course grading standards. At the 7 remaining colleges,
GAO found mixed results. For example, one or more staff at these
colleges appeared to act in conflict with school policies regarding
academic dishonesty or course grading standards, or federal
regulations pertaining to exit counseling for student loans, while
other staff acted consistent with such policies.
Enrollment: GAO attempted to enroll its students using fictitious
evidence of high-school graduation”either a home-school diploma or a
diploma from a closed high school”at all 15 colleges and successfully
enrolled in 12. Two declined GAO‘s request for enrollment based on
insufficient proof of high-school graduation. Another allowed GAO‘s
student to begin class, but rescinded acceptance after 1 week, citing
lack of high-school accreditation.
Cost and Financial Aid: GAO‘s students took 31 classes in total at an
average cost of $1,287 per class. These costs included such items as
tuition, books, and technology fees. All 12 students were eligible for
federal student aid, but only 10 actually received disbursements; the
other students were expelled without receiving disbursements. We did
not observe that a college collected federal student aid funds after
the withdrawal date of any of our students (that was not fully
refunded immediately).
Course Structure: GAO‘s students were enrolled in introductory
classes, such as Introduction to Computer Software and Learning
Strategies and Techniques. Courses ranged in length from 4 to 11
weeks, and students took from one to four courses concurrently.
Courses generally consisted of online discussion forum postings;
writing assignments; multiple-choice quizzes and exams; and skills
exercises, such as keyboarding tests or computer exercises.
Substandard Academic Performance: GAO‘s students engaged in
substandard academic performance by using one or more of the following
tactics: failure to attend class, failure to submit assignments,
submission of objectively incorrect assignments, submission of
unresponsive assignments, and plagiarism. At 6 colleges, instructors
acted in a manner consistent with school policies in this area, and in
some cases attempted to contact students to provide help outside of
class. One or more instructors at 2 colleges repeatedly noted that the
students were submitting plagiarized work, but no action was taken to
remove the student. One or more instructors at the 4 remaining
colleges did not adhere to grading standards. For example, one student
submitted photos of celebrities and political figures in lieu of essay
question responses but still earned a passing grade.
Withdrawal and Exit Counseling: Three of GAO‘s students were expelled
for performance or nonattendance. Eight of the 9 students withdrew
from their respective colleges without incident. At the remaining
school, GAO‘s request to withdraw was never acknowledged and the
student was eventually expelled for nonattendance. 3 students did not
receive federally mandated exit counseling, advising students of
repayment options and the consequences of default.
View [hyperlink, http://www.gao.gov/products/GAO-12-150]. For more
information, contact Richard Hillman at (202) 512-6722 or
hillmanr@gao.gov.
[End of section]
Contents:
Letter:
Background:
Results of Undercover Testing:
Appendix I: Objectives, Scope, and Methodology:
Tables:
Table 1: Federal Financial Aid and Out-of-Pocket Costs of Undercover
Student Attendance at 15 For-Profit Colleges:
Table 2: Selected Case Details from Undercover Testing at 15 For-
Profit Colleges:
Abbreviations:
Education: U.S. Department of Education:
EFC: Expected Family Contribution:
FAFSA: Free Application for Federal Student Aid:
GED: General Educational Development:
IPEDS: Integrated Postsecondary Education Data System:
NCES: National Center for Education Statistics:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
October 31, 2011:
The Honorable Tom Harkin:
Chairman:
Committee on Health, Education, Labor, and Pensions:
United States Senate:
Dear Mr. Chairman:
In recent years, the scale and scope of for-profit colleges have
changed considerably.[Footnote 1] Once comprised of local, sole-
proprietor ownership, the nation's proprietary institutions now range
from small, privately owned schools to colleges owned and operated by
publicly traded corporations. Enrollment in such colleges has grown
far faster than traditional public or nonprofit higher-education
institutions. Moreover, during the 2009-2010 school year, for-profit
colleges received almost $32 billion in grants and loans provided to
students under federal student aid programs, as authorized under Title
IV of the Higher Education Act of 1965, as amended. Proponents of
these colleges note that they offer certain advantages over
traditional universities, such as online courses, flexible meeting
times, and year-round courses.
Because of your interest in the student experience at for-profit
colleges, you asked us to conduct undercover testing by enrolling in
online classes under degree-granting programs. We selected 15 for-
profit colleges and, once enrolled, engaged in behaviors consistent
with substandard academic performance. This report describes the
college and instructor response to this substandard student
performance and also documents our overall experiences as students,
including observations related to the enrollment process, cost of the
programs, student financial aid, course structure, and the withdrawal
process.
To conduct our work, we tested 15 for-profit colleges, selected in
three stages. First, we selected the 5 largest for-profit colleges, by
student population, based on fall 2008 enrollments. Next, we selected
1 for-profit college based on unsolicited allegations of misconduct
that we received between June 10, 2010, and October 30, 2010. Finally,
using a systematic selection process, we selected 9 for-profit
colleges from the population of 2,770 reporting enrollment of at least
1 student for fall 2008, using selection criteria such as the
availability of online-only distance-education classes, class length,
and program start date.[Footnote 2] We attempted to enroll in each
college using fictitious identities and one or two possible fictitious
pieces of evidence of high-school graduation-a home-school diploma or
a diploma from a closed high school.[Footnote 3] If the student's
application at any particular college was denied, we took no further
action. We attempted to enroll in degree-granting programs that were
expected to include objectively graded coursework (such as multiple-
choice tests), for example business, medical billing, and paralegal
studies programs. None of the programs allowed for elective course
selection during the first term; our students took whatever classes
the school required.
To engage in behaviors consistent with substandard academic
performance, we used one or more of the following strategies for each
student: (1) failure to attend class,[Footnote 4] (2) failure to
submit assignments, (3) submission of objectively incorrect
assignments (e.g., submitting incorrect answers on multiple-choice
quizzes), (4) submission of unresponsive assignments (e.g., submitting
pictures when prompted to submit an essay), and (5) submission of
plagiarized assignments. We documented each college's and instructor's
response to these behaviors (as applicable), including any failure to
follow established college policies as related to academic performance
or academic misconduct. We did not evaluate the relative academic
rigor of courses or any other degree program materials, nor did we
evaluate the statements or behaviors of enrollment officials, except
in such instances that affected the student experience in the
classroom setting.
We enrolled in each college for approximately one term, as defined by
the college.[Footnote 5] As applicable, we documented the colleges'
withdrawal procedures, including whether our students were provided
with required student loan exit counseling.[Footnote 6] We tested each
college once. The experience of each of our undercover students is
unique and cannot be generalized to other students taking courses
offered by the for-profit colleges we tested or to other for-profit or
nonprofit colleges. As part of an undercover investigation, our tests
were designed to obtain observations from entities that were unaware
of our true identities. However, there exists a possibility that
tested entities were able to determine that our students were
fictitious and therefore altered their behavior based on the
assumption that they were under observation. See appendix I for more
details on our scope and methodology.
We briefed the Department of Education on our observations on October
24, 2011. As applicable, we have referred information to them for
further investigation.
Our investigative work, conducted from October 2010 through October
2011, was performed in accordance with standards prescribed by the
Council of the Inspectors General on Integrity and Efficiency.
Background:
In order for students attending a college to receive Title IV funds, a
college must, among other requirements, be (1) licensed or otherwise
legally authorized to provide higher education by a state, (2)
accredited by an agency recognized for that purpose by the Secretary
of the U.S. Department of Education (Education), and (3) deemed
eligible and certified to participate in federal student aid programs
by Education.
This is commonly referred to as the triad. Under the Higher Education
Act, Education does not determine the quality of higher-education
institutions or their programs; rather, it relies on recognized
accrediting agencies to do so. As part of its role in the
administration of federal student aid programs, Education determines
which institutions of higher education are eligible to participate in
Title IV programs. Education is responsible for overseeing college
compliance with Title IV laws and regulations and ensuring that only
eligible students receive federal student aid. As part of its
compliance monitoring, Education relies on department employees and
independent auditors of schools to conduct program reviews and audits
of colleges. Moreover, for-profit colleges participating in federal
student aid programs must enter a program participation agreement with
Education that, among other things, requires the college to derive not
less than 10 percent of revenues from sources other than federal
student aid (known as the "90/10 Rule"). According to Education, over
2,000 for-profit colleges participate in Title IV programs.[Footnote 7]
In August 2009, we reported that students who attended for-profit
colleges were more likely to default on federal student loans than
were students from other colleges.[Footnote 8] Additionally, our
August 2010 testimony on for-profit college recruiting practices found
that some colleges failed to provide clear information about program
duration and cost and exaggerated applicants' potential salary after
graduation, and made other deceptive statements.[Footnote 9]
The Stafford Loans are the largest source of federal financial aid
available to postsecondary students. In academic year 2009-10, 35
percent of undergraduate students participated in the program, which
provided an estimated $56.1 billion dollars to eligible students
through subsidized and unsubsidized loans.[Footnote 10] To qualify for
a subsidized loan, students must have a financial need as determined
under federal law. A student's financial aid need is determined by a
formula that subtracts a student's expected family contribution (EFC)
and certain other estimated financial assistance from their total cost
of attendance.[Footnote 11] In contrast to subsidized loans, students
can receive unsubsidized loans to pay for educational expenses
regardless of their financial need. Depending on their educational
expenses and level of financial need, a student may be eligible to
receive both subsidized and unsubsidized loans, which is generally
referred to as a combined loan.
Student eligibility for grants and subsidized student loans is based
on student financial need.[Footnote 12] In addition, in order for a
student to be eligible for Title IV funds, the college must ensure
that the student meets the following requirements, among others: (1)
has a high-school diploma or a recognized equivalent (such as a
General Educational Development [GED] certification), or completes a
secondary-school education in a home-school setting as recognized
under state law, or is determined to have an "ability-to-benefit" from
the education by a method approved by Education or a state, or the
college;[Footnote 13] (2) is working toward a degree or certificate in
an eligible program; and (3) is maintaining satisfactory academic
progress once in college.
Completion of the Free Application for Federal Student Aid (FAFSA) is
the first step in securing federal financial assistance. After
Education processes an applicant's FAFSA, a report is sent to the
applicant or made available online. This report includes the
applicant's EFC, the types of federal aid for which the applicant
qualifies, and information about any errors--such as questions the
applicant did not complete--that Education identified during FAFSA
processing. Colleges send applicants award letters after admission,
providing students with types and amounts of federal, state, and
institutional aid, should the student decide to enroll.
As required by law, a college must make available upon request to
prospective and enrolled students a statement of any refund policy
with which the college must comply; the requirements for the treatment
of Title IV funds when a student withdraws; and the requirements and
procedures for officially withdrawing from the college.[Footnote 14]
In addition, Education guidance states that a student should be able
to estimate how much federal student aid he or she will retain and how
much he or she will return upon withdrawing. Finally, a student or
prospective student should be informed that if he or she withdraws,
charges that were previously paid by federal student aid funds might
become a debt that the student will be responsible for paying.
[Footnote 15]
Once students have completed or withdrawn from colleges, the Higher
Education Act requires that schools provide exit counseling (which may
be provided electronically), typically within 30 days, for all
students with federally guaranteed loans. According to Education, this
counseling is a critical requirement in explaining to borrowers both
their rights and responsibilities. In requiring students to be advised
of both the wide array of repayment options available and the negative
consequences of default, such as adverse credit reports, delinquent
debt collection, and litigation, the law seeks to facilitate repayment
and prevent defaults. In addition, during the exit interview, colleges
must require that the student submit to the institution the following
information: the borrower's expected permanent address; the name and
address of the borrower's expected employer; the address of the
borrower's next of kin; and any corrections needed in the
institution's records relating to the borrower's name, address, social
security number, references, and driver's license number.
Results of Undercover Testing:
The experience of each of our undercover students is unique and cannot
be generalized to other students taking courses offered by the for-
profit colleges we tested or to other for-profit or nonprofit
colleges. During the course of our testing at the selected colleges,
we documented our observations related to the following phases of the
student experience: enrollment, cost, financial aid, course structure,
substandard student performance, withdrawal, and exit counseling. In
addition, on the basis of our observations for the courses we tested,
8 of the 15 colleges appeared to follow existing policies related to
academic dishonesty, exit counseling, and course grading standards. At
the 7 remaining colleges, we found mixed results. For example, at
least one issue was identified in which college staff or an instructor
appeared to act in a manner inconsistent with college policies,
federal regulations, or course grading standards; whereas others acted
in a manner consistent with such policies. Of the 7 colleges, as
discussed below, instructors at 2 colleges appeared to act in a manner
inconsistent with college policies regarding academic dishonesty,
instructors at 4 colleges appeared to act in a manner inconsistent
with course grading standards, and 3 colleges appeared to act in a
manner inconsistent with federal regulations on exit counseling. More
specific details on Colleges 1 through 15 can be found in table 2.
Enrollment: We attempted to enroll undercover students at 15 colleges,
and were successful in enrolling at 12. Two colleges (Colleges 13 and
14) declined our student's request for enrollment based on
insufficient proof of high-school graduation. In both cases, we
attempted to enroll using a fictitious home-school diploma, but were
told that the college would not accept our home-school credentials.
[Footnote 16] We also attempted to apply using a fictitious diploma
from a closed high school, but were rejected because the school was
considered to lack accreditation. College 15 stated that it did not
accept any home-school credentials but accepted our fictitious closed-
school diploma and allowed us to begin class, but rescinded our
acceptance after 1 week of classes, stating a lack of high-school
accreditation as the reason for expulsion. We were not billed for the
1 week of class that we finished, nor did the school appear to receive
any student loans on our behalf. In all 3 instances where our
fictitious students were ultimately rejected, we were encouraged to
pursue a GED in order to be allowed to enroll at the college.
At College 10, our student requested part-time enrollment, meaning
that the student would take two courses per term. However, we found
three courses that were fully accessible to our student through the
school's online student portal website over our single enrollment
term. The third class was clearly noted in our activity and grade
report as being scheduled for completion during that term. Once our
student had completed the class, we were informed by college staff
that by accessing the class, the student had effectively converted to
being a full-time student. We were further told that our student would
be charged for full-time attendance, although the school had only
processed financial aid paperwork for the student as a part-time
student.
All 12 accepted students did not select any elective coursework during
their enrollment period. Students were automatically enrolled in
courses selected by the school by their schools' administrative staff
and were informed of course start and end dates as they were enrolled.
However, College 4 scheduled self-paced courses for our student on a
revolving enrollment basis, wherein the student was enrolled in as
many as four courses concurrently with the requirement that all
coursework be completed and submitted prior to the specific course end
date. College personnel stated that they could not provide us with an
advance schedule including course start and end dates; they could only
provide us with the start and end dates for those courses in which we
were currently enrolled or a list of the courses that are required to
complete a portion of our selected degree program (without start and
end dates). For one class in which we enrolled at this college, the
student's advisor provided us with an incorrect course end date, which
resulted in our student missing a key deadline to submit assignments.
Cost and Financial Aid: All of our students were eligible for federal
student aid in the form of subsidized and unsubsidized student loans
and submitted the appropriate documentation to the school in support
of this (i.e., FAFSA). Only 10 of our students actually received
federal loan disbursements, according to documentation we received;
the other 2 students were expelled without the college requesting or
receiving any federal student aid funds (Colleges 3 and 12). In 8 of
these 10 instances (Colleges 1, 2, 4, 5, 6, 9, 10, and 11), we
observed that the colleges received at least one student aid
disbursement, of which all or a portion was refunded to Education upon
our early withdrawal from our program of study. In the remaining 2
instances (Colleges 7 and 8), the student aid disbursements were fully
kept by the school and applied toward the student's cost of
attendance. In no instances did we observe that a college collected
federal student aid funds after the withdrawal date of any of our
students (that was not fully refunded immediately). However, one
college (College 4) told our student that they had not ever received
any financial aid funding, even though the student was eligible and
had received documentation from their lender indicating that the
school had drawn down several thousand dollars of aid. The college did
not respond to inquiries regarding this discrepancy, nor did they
respond to requests for detailed information regarding the student's
overall cost of attendance.
Our students took 31 classes in total at an average cost of $1,287 per
class. These costs included such items as tuition, books, and
technology fees. Because our students withdrew early from their
programs of study, the cost per course may not reflect what the
average cost per course would be if the student had completed the full
program. Some costs, such as technology fees, may be charged to the
student as a lump sum at the start of the program, rather than spread
over its lifetime. In addition, one college (College 7) provides a
laptop for each student at the time of enrollment, the cost of which
is charged to the student. When we specifically told our enrollment
advisor that we did not want the college to provide us with a laptop,
we were asked to fill out the "laptop agreement form" anyway. When we
did, our student was shipped a laptop without further notification or
explanation prior to shipping. When we asked about returning it and
expressed concern about potentially expensive shipping costs
associated with the return, we did not receive a response. One of the
colleges we tested (College 6) did not require our undercover student
to pay any out-of-pocket costs; all our coursework at this college was
covered by student loans.
Table 1 contains information on the total costs incurred by each
student during their attendance period, made up of subsidized student
loans, unsubsidized student loans, and out-of-pocket costs. Total
costs of attendance for individual students ranged from $45 to $5,412.
Subsidized and unsubsidized student loan amounts represent the total
loan amounts accepted by the college on each student's behalf after
any refunds associated with our early withdrawal.
Table 1: Federal Financial Aid and Out-of-Pocket Costs of Undercover
Student Attendance at 15 For-Profit Colleges:
School: 1;
Number of classes attempted: 2;
Subsidized student loans (dollars): $0;
Unsubsidized student loans (dollars): $0;
Out-of-pocket expenses (dollars): $3,097;
Total cost (dollars): $3,097.
School: 2;
Number of classes attempted: 1;
Subsidized student loans (dollars): $1,134;
Unsubsidized student loans (dollars): $0;
Out-of-pocket expenses (dollars): $1,272;
Total cost (dollars): $2,406.
School: 3;
Number of classes attempted: 2;
Subsidized student loans (dollars): $0;
Unsubsidized student loans (dollars): $0;
Out-of-pocket expenses (dollars): $45;
Total cost (dollars): $45.
School: 4;
Number of classes attempted: 3;
Subsidized student loans (dollars): $0;
Unsubsidized student loans (dollars): $0;
Out-of-pocket expenses (dollars): $4,770;
Total cost (dollars): $4,770.
School: 5;
Number of classes attempted: 2;
Subsidized student loans (dollars): $1,162;
Unsubsidized student loans (dollars): $950;
Out-of-pocket expenses (dollars): $1,117;
Total cost (dollars): $3,229.
School: 6;
Number of classes attempted: 2;
Subsidized student loans (dollars): $34;
Unsubsidized student loans (dollars): $2,591;
Out-of-pocket expenses (dollars): $0;
Total cost (dollars): $2,625.
School: 7;
Number of classes attempted: 3;
Subsidized student loans (dollars): $1,185;
Unsubsidized student loans (dollars): $2,030;
Out-of-pocket expenses (dollars): $829;
Total cost (dollars): 4,044.
School: 8;
Number of classes attempted: 5;
Subsidized student loans (dollars): $1,162;
Unsubsidized student loans (dollars): $1,990;
Out-of-pocket expenses (dollars): $650;
Total cost (dollars): $3,802.
School: 9;
Number of classes attempted: 2[A];
Subsidized student loans (dollars): $1,162;
Unsubsidized student loans (dollars): $1,990;
Out-of-pocket expenses (dollars): $1,088;
Total cost (dollars): $4,240.
School: 10;
Number of classes attempted: 3;
Subsidized student loans (dollars): $1,162;
Unsubsidized student loans (dollars): $1,990;
Out-of-pocket expenses (dollars): $2,260;
Total cost (dollars): $5,412.
School: 11;
Number of classes attempted: 4;
Subsidized student loans (dollars): $1,162;
Unsubsidized student loans (dollars): $1,990;
Out-of-pocket expenses (dollars): $410;
Total cost (dollars): $3,562.
School: 12;
Number of classes attempted: 2;
Subsidized student loans (dollars): $0;
Unsubsidized student loans (dollars): $0;
Out-of-pocket expenses (dollars): $2,676;
Total cost (dollars): $2,676.
School: 13;
Number of classes attempted: n.a.[B];
Subsidized student loans (dollars): n.a.;
Unsubsidized student loans (dollars): n.a.;
Out-of-pocket expenses (dollars): n.a.;
Total cost (dollars): n.a.
School: 14;
Number of classes attempted: n.a.[B];
Subsidized student loans (dollars): n.a.;
Unsubsidized student loans (dollars): n.a.;
Out-of-pocket expenses (dollars): n.a.;
Total cost (dollars): n.a.
School: 15;
Number of classes attempted: n.a.[B];
Subsidized student loans (dollars): n.a.;
Unsubsidized student loans (dollars): n.a.;
Out-of-pocket expenses (dollars): n.a.;
Total cost (dollars): n.a.
Source: GAO.
n.a. = not applicable:
[A] Fictitious student attempted the same class twice.
[B] Student was denied enrollment.
[End of table]
Course Structure: The assignments and course structure were similar at
all 12 tested schools. Since our students were just starting their
respective programs, most classes were introductory in nature, such as
Introduction to Business, Introduction to Computer Software,
Keyboarding, and Learning Strategies and Techniques. Individual
courses ranged in length from 4 weeks to 11 weeks, and our students
took from 1 to 4 courses concurrently. Since we attended online
courses only, most, if not all, interaction with instructors and other
students occurred through the school's online student portal software,
including submission of coursework and later receipt of related
feedback. Coursework generally consisted of (1) online discussion
forum postings, both responses to original questions posed by the
instructor and responses to fellow students; (2) written assignments,
generally essays of varying lengths on course-specific topics; (3)
skills exercises, such as keyboarding tests or specific computer-
application exercises; and (4) multiple-choice quizzes and exams. Some
courses also included a "participation" grade, which often included
considerations for attendance, completion of ungraded exercises, and
attendance at real-time chats or seminars. These real-time chats and
seminars, when they occurred, were conducted either through written or
audio chats, and allowed for full interaction between the student, the
instructor, and peers.
At the beginning of all classes, the student was provided with a
course syllabus, which outlined the basic purpose and structure of the
course, as well as some grading information and course expectations.
During enrollment, instructors interacted with our students through
mechanisms such as providing postings in the course's online
discussion forums, providing direct feedback on specific assignments
through the course e-mail system or gradebook, and providing reminders
of assignment due dates or other assignment-related guidance to all
students through the course e-mail system.
Substandard Performance: While all 12 enrolled students engaged in
behaviors consistent with substandard academic performance, each
instructor in each class responded to such substandard performance
differently. The behaviors our students engaged in included a
combination of the following: a failure to attend class and submit
assignments, submission of incorrect or unresponsive assignments, or
both, and plagiarism. Detailed information on the substandard
performance can be found in table 2, but highlights include the
following:
Examples of Instructor or College Behavior in Accordance with Policies
or Standards:
* At College 1, our undercover student logged in to class but did not
submit any assignments or participate in discussions. Her instructor
repeatedly tried to contact the student through class and personal
contact information to provide help and allow for submission of missed
assignments. When the student refused to commit to completing
assignments, the instructor locked the student out of class.
* One instructor at College 5 awarded our undercover student a failing
grade on an assignment due to a technological failure which prevented
the instructor from seeing the student's correctly submitted
assignment. However, when contacted by the student about the
discrepancy, the instructor promptly regraded all affected assignments
and provided new feedback.
* College 3 had a conditional admittance policy stating that students
will be expelled by the school, with no financial obligation, for
failing to maintain a 65 percent average during the first 5 weeks of
the program. Our student did not meet the conditional admittance
criteria, as her grades were below the 65 percent average at the 5-
week mark, and was expelled by the college in accordance with this
policy.
Examples of Instructor or College Behavior Not in Accordance with
Policies or Standards:
* At College 4, our student submitted work in one class that did not
meet the requirements of the assignment (such as photos of political
figures and celebrities in lieu of essay question responses). The
student further failed to participate in required real-time chat
sessions. The instructor did not respond to requests for grade details
and some substandard submissions appeared to have no effect on the
student's grade, which ultimately resulted in the student passing the
class.
* According to College 6's policies, students caught cheating will
receive no credit on the first dishonest assignment and will be
removed from class on a second. Our undercover student consistently
submitted plagiarized material, such as articles clearly copied from
online sources or text copied verbatim from a class textbook. For the
first plagiarized assignment, the instructor told the student to
paraphrase, but gave full credit. The instructor gave no credit on two
additional plagiarized assignments. The student continued to submit
plagiarized work, but the instructor did not note the plagiarism and
gave credit for the work. The student received a failing grade for the
class, but no action appeared to have been taken by the instructor or
college related to the academic misconduct, which appeared to be
inconsistent with the college policy on academic dishonesty.
* Our undercover student at College 10 took two classes in which she
was awarded points for assignments that she did not complete, in
violation of grading standards for the class. In one class, the
student submitted only 2 of 3 required components of the final
project, but received full credit for the assignment, resulting in an
overall passing grade for the class. In the second class, the student
received full credit for assignments that failed to meet technical
requirements, including (1) submission length, (2) use of proper
software tools, or (3) citation format and accuracy. The student also
received full credit for an assignment which had already been
submitted in another class and contained a clear notation that it was
prepared for the other class. However, the student received a failing
grade for this class on the basis of total grades received on all
assignments.
Withdrawal: Generally, our students who were not expelled for
performance or attendance reasons were able to withdraw from their
respective colleges without incident. At 3 of the tested schools
(Schools 3, 8, and 12), our students were expelled for failure to meet
college policies; once for failure to meet conditional acceptance
criteria, once for nonattendance, and once for academic performance
issues. At the remaining 9 colleges, we requested to be withdrawn. At
8 of the 9 colleges, this withdrawal request was handled without
incident. However, one college (College 4) never acknowledged our
request to withdraw and instead eventually expelled us for
nonattendance nearly a month later. Such a delay may violate federal
regulations, which require that the college use the date that the
student began the withdrawal process or provided notification or
intent to withdraw as the official withdrawal date.[Footnote 17] One
college (College 10) provided our student's information to a
collections agency before providing us with a final bill. When we
inquired, college personnel stated that this is how they handle all
student accounts.
Exit Counseling: Most of our students that received student loans
received exit counseling in a timely manner in accordance with federal
law. Federal law and regulations dictate that after a student with
federal loans has completed or withdrawn from a college, the college
must provide exit counseling, typically within 30 days. Students with
federal loans that withdraw or are expelled prior to their expected
graduation date may receive a disbursement of student loans that would
need to be refunded by the college to Education in accordance with the
school's stated Title IV Refund Policy. Two of our three expelled
students received no federal student loans and therefore their
colleges were not required to provide federally mandated exit
counseling (Colleges 3 and 12). Two additional students received
disbursements of student loans that were fully refunded to Education.
Although it is unclear from statute whether exit counseling is
required in this situation, one college provided exit counseling
(College 1) and one did not (College 4). Of the 8 students who
received disbursements of federal student aid that were applied toward
their educational expenses, 5 received the federally mandated exit
counseling from their colleges in a timely manner, generally in the
form of a website or a short written document. Two of these colleges
(Colleges 5 and 7) provided additional follow-up letters in the months
following the original exit counseling. The remaining 3 students
(Colleges 6, 10, and 11) received no exit counseling.[Footnote 18]
When we inquired with one of these schools (College 10) about exit
counseling, school staff told us that the exit counseling had been
provided during the entrance interview. Because the regulations
concerning exit counseling specifically state that it must be
conducted shortly before or after withdrawal, this practice would be
inconsistent with federal law.[Footnote 19] We have referred the names
of the colleges that did not provide exit counseling to the Department
of Education.
Table 2 contains details about our undercover testing at the 15
colleges that we tested. Specifically, for each college, the table
includes information about the program in which the student was
enrolled; the time frame for attendance; the student's final
eligibility for student aid; the student's substandard behavior
scenario(s);[Footnote 20] observations on college responses to
substandard behavior scenario(s); final grades; exit counseling; and
any college policies specifically relevant to the college's actions.
The names of the classes each student took have been generalized to
protect the identities of the 15 tested schools. A "D-minus" is
considered the minimum passing grade for each class.
Table 2: Selected Case Details from Undercover Testing at 15 For-
Profit Colleges:
Program and enrollment: College 1;
2-year Associate's Degree-Paralegal Studies;
Enrolled for classes beginning in January 2011;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Plagiarism.
Class 1: Introduction to Legal Writing;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "incomplete" for the
class. For example:
* On the first assignment, student submitted partially plagiarized
essay questions. Instructor gave student a "C" and instructions to
develop independent answers;
* For remainder of class, student logged in but did not submit
assignments or participate in discussions;
* Instructor repeatedly tried to contact our student through several
available communication mechanisms (i.e., school e-mail, personal e-
mail, and phone) to provide help and allow for submission of missed
assignments. When student refused to commit to completing missed
assignments and a final exam, Instructor locked student out of class.
Withdrawal and Exit Counseling;
We withdrew in February 2011. Although it is unclear from statute
whether exit counseling was required, it was provided in a timely
manner.
Program and enrollment: College 2;
2-year Associate's Degree-Business;
Enrolled for classes beginning in January 2011;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
Class 1: Learning Strategies and Techniques;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "F" for the class. For
example:
* Student consistently submitted assignments that did not meet the
requirements described in instructions and received no credit or
minimal credit;
* Support staff provided frequent reminders for our student to log in
to classes for attendance purposes, and to complete required
assignments;
When this class-which was required for advancement through the program-
was failed, the school temporarily enrolled the student in the next
class in the program, only to remove them without notice in order to
reenroll them in a repeat of the failed class.
Withdrawal and Exit Counseling;
We withdrew in March 2011. Exit counseling was provided in a timely
manner.
Program and enrollment: College 3;
2-year Associate's Degree-Paralegal Studies;
Enrolled for classes beginning in January 2011;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
College Policy;
College has conditional admittance policy. Students may be expelled by
the college, with no financial obligation, for failing to maintain a
65 percent average during first 5 weeks of the program.
Class 1: Learning Strategies and Techniques;
Instructor gave appropriate credit in accordance with grading
standards and ultimately the student received an "incomplete" for the
class. For example:
* Student missed required seminars and failed to take quizzes and turn
in assignments;
earned a grade of 43 percent at the end of week 5;
Class 2: Introduction to Paralegal Studies;
Instructor gave appropriate credit in accordance with grading
standards and ultimately the student received an "incomplete" for the
class. For example:
* Student missed required seminars and failed to take quizzes and turn
in assignments;
earned a grade of 19 percent at the end of week 5.
Withdrawal and Exit Counseling;
Student did not meet the conditional admittance criteria and was
expelled by the college in accordance with their stated policies in
February 2011. No exit counseling was required since the student did
not receive any student loans.
Program and enrollment: College 4;
2-year Associate's Degree-Business;
Enrolled for classes beginning in January 2011;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
College Policy;
Classes occurred on a revolving enrollment basis and all classwork was
self-paced, to be completed by the class end date.
Class 1: Learning Strategies and Techniques;
With one exception, student consistently submitted work that did not
meet the requirements of the assignments but received a passing grade
of "C-minus," which would appear to be inconsistent with established
grading standards. For example:
* For a written exam that required the student to submit detailed
explanations to four questions, the student submitted photos of
political figures and celebrities;
* Student further failed to participate in required real-time chat
sessions;
The student's advisor provided an inaccurate class end date, resulting
in the student mistakenly missing assignment submission deadlines.
After the advisor contacted the instructor, the student was allowed to
submit two missing assignments due to class end date inaccuracies
(which were submitted as unresponsive and incorrect). The instructor
did not respond to any requests for grade details and ultimately those
submissions appeared to have no effect on the student's final grade;
Class 2: Keyboarding, and; Class 3: Introductory Computing;
Both classes were taught by the same instructor. Instructor gave
appropriate credit in accordance with grading standards and ultimately
the student received an "incomplete" for both classes. For example:
* Student turned in assignments late, failed to complete them in
accordance with instructions, or failed to submit them altogether and
generally earned failing grades on multiple-choice quizzes;
* Instructor posted numerous offers to help through the student portal
and warned student of the effect that nonparticipation would have on
the student's grade. Further, she noted that we had open opportunities
to retake Class 3's multiple-choice quizzes and that "they are open
book so there should not be any failure. All answers are right in the
book and there is not [a] time limit."
Withdrawal and Exit Counseling;
We requested to withdraw in February 2011, but the request was not
acknowledged. Student received an official notice of expulsion for
nonattendance dated approximately 1 month after request for
withdrawal. Although it is unclear from statute whether exit
counseling was required, it was not provided.
Program and enrollment: College 5;
3-year Bachelor's Degree-Business;
Enrolled for classes beginning in January 2011;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
Class 1: Learning Strategies and Techniques;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "F" for the class;
Class 2: Introduction to Business;
With one exception, instructor gave appropriate credit in accordance
with grading standards and ultimately student received a passing grade
of "D" for the class. For example:
* Instructor awarded the student a failing grade on an assignment due
to a technological failure which prevented him from seeing the
student's correctly submitted assignment. However, when contacted by
the student about the discrepancy, he promptly regraded all affected
assignments and provided new feedback;
* Instructor awarded the student an "A" on an assignment the student
had not, in fact, submitted. The instructor provided specific feedback
on the assignment, which suggests that there may have been a technical
error which improperly associated some other submission with our
undercover student. The instructor provided no additional details on
the discrepancy and the student did not inquire further.
Withdrawal and Exit Counseling;
We withdrew in February 2011. Exit counseling was provided in a timely
manner. Further reminder e-mails and a letter were sent by the school
several months after withdrawal to remind the student that loan
payments would soon be due.
Program and enrollment: College 6;
2-year Associate's Degree-Business;
Enrolled for classes beginning in January 2011;
Observations: Substandard Performance Behaviors Used;
* Plagiarism;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
Submission of unresponsive assignments.
College Policy;
Students caught cheating will receive no credit on the first dishonest
assignment and will be removed from class on a second.
Class 1: Introduction to Business;
Student consistently submitted plagiarized material-such as articles
clearly copied from online sources or text copied verbatim from a
class textbook-some of which was noted by the instructor;
no action was taken to remove the student, who ultimately received an
"F" in the class. For example:
* For the first two plagiarized assignments, instructor noted the
plagiarism and told the student to paraphrase, but gave credit for the
assignments, which would be inconsistent with college policy;
* Instructor noted plagiarism on two additional assignments and gave
no credit, but did not appear to take any additional disciplinary
action;
* Student continued to submit plagiarized work, but instructor made no
note of it and gave credit for the work;
Class 2: Introductory Computing;
On several occasions, student plagiarized material, including
submitting a slide presentation in which the title slide gave an
author name other than the student's, but the instructor never noted
the plagiarism; the student ultimately received an "F" in the class.
Withdrawal and Exit Counseling;
We withdrew in April 2011. Exit counseling was required but not
provided;
however, as student loan grace period was ending, the college
contacted the student by mail with a reminder to repay.
Program and enrollment: College 7;
2-year Associate's Degree-Business;
Enrolled for classes beginning in May 2011;
Observations: Substandard Performance Behaviors Used;
* Plagiarism;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
College Policy;
All violations of academic policy (including plagiarism) are
documented and included in the student's academic record. Upon
confirmation of the violation, the student will immediately be
notified and one or more of the following actions may be taken: (1)
Reduction in grade on the violating assignment;
(2) Loss of credit for the violating assignment;
(3) A failing grade for the course, and/or;
(4) Suspension or dismissal from the college.
Class 1: Learning Strategies and Techniques;
Student consistently submitted plagiarized material-such as articles
clearly copied from online sources or discussion posts copied from
other students-nearly all of which was noted by the instructor but no
action was taken to remove the student, who ultimately received an "F"
in the class. For example:
* On multiple plagiarized discussion posts, the instructor noted that
the submission was not in the student's own words and requested that
the student resubmit a new post to receive credit. When the student
did not resubmit, minimal or zero credit was given; however, no
further disciplinary action was taken;
* Partway through the course, the instructor told the student that if
the student submitted another plagiarized assignment, an incident
report would be submitted. On multiple subsequent occasions of
plagiarism, the instructor stated that she was submitting an incident
report. However, the student did not receive any notification from the
college that an incident report had been submitted and no further
disciplinary actions were taken;
Class 2: Introduction to Psychology;
Student consistently submitted plagiarized material-such as articles
clearly copied from online sources or discussion posts copied from
other students-some of which was noted by the instructor but no action
was taken to remove the student, who ultimately received an "F" in the
class. For example:
* For several assignments, the student submitted material that had
been copied verbatim from an online source and included a citation to
that source; the instructor awarded credit along with feedback noting
that the student should use more credible sources. The instructor did
not note the plagiarism;
* During the last week of class, the professor noted plagiarized
assignments and stated on multiple occasions that an incident report
would be submitted. However, the student did not receive any
notification from the college that an incident report had been
submitted and no disciplinary actions were taken;
Class 3: Introductory Computing;
Student consistently submitted plagiarized material-such as articles
clearly copied from online sources or discussion posts copied from
other students-but the instructor never noted the plagiarism, and the
student ultimately received an "F" in the class. For example:
* For an assignment requiring the student to create and format their
own resume and cover letter, the student submitted a resume downloaded
from an online source which was clearly under a name other than the
student's. Full credit was given on the assignment and no feedback was
provided;
* On six additional assignments, the student submitted plagiarized
spreadsheets or slide presentations that had little to no relation to
the assignment instructions or objectives but received full credit.
Withdrawal and Exit Counseling;
We withdrew in July 2011. Exit counseling was provided in a timely
manner. A further reminder letter was sent by the college
approximately 2 months after withdrawal.
Program and enrollment: College 8;
2-year Associate's Degree-Business;
Enrolled for classes beginning in April 2011;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
Class 1: Learning Strategies and Techniques;
For multiple-choice quizzes, instructor (who also taught class 2)
awarded grades in accordance with grading standards;
for one subjective assignment-an essay-instructor admitted that she
was awarding a grade in excess of what would be allowable based on the
work submitted, which would appear to be inconsistent with established
grading standards. Student ultimately received an "F" for the class.
For example:
* When the student failed two multiple-choice quizzes, the instructor
reminded the student that each quiz could be retaken and that since
the correct answers were displayed after completing it the first time,
"it's not hard to get a 100% on the second try; just jot down the
correct answers and take the quiz again";
* For a written essay where the student had submitted responses to
only half of the questions asked, the instructor noted that while the
student had only submitted work "worth 50% of the final grade," the
instructor "[struggled] with giving [the student] a failing grade" and
awarded 75% credit;
Class 2: Keyboarding;
Instructor (who also taught class 1) gave appropriate credit in
accordance with grading standards for skills assignments (i.e., typing
speeds); for writing assignments, instructor awarded passing grades
for submissions that did not meet technical requirements (e.g.,
format, submission length). Student ultimately received an "F" for the
class;
Class 3: Introductory Law;
For objective assignments, such as multiple-choice quizzes, instructor
gave appropriate credit in accordance with grading standards; for
subjective assignments, such as writing assignments, instructor
generally awarded grades that were higher than the grading rubric
would allow, which would appear to be inconsistent with established
grading standards. Student ultimately received an "F" for the class.
For example:
Student consistently submitted written assignments that were only
responsive to a portion of the assigned discussion topics, but
received high passing grades, though the instructor provided feedback
noting that the student had not fully responded to the question;
Class 4: Introductory Math;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "F" for the class;
* Instructor consistently attempted to provide additional help to the
student on skills assignments. About halfway through the class, the
instructor offered to allow the student to "unofficially" submit an
assignment for correction outside of the normal submission mechanism,
which the instructor would return with corrections and allow the
student to submit as their own work;
Class 5: Introductory Computing;
Student consistently submitted incomplete and incorrect work but
received full or partial credit; no credit was given for assignments
that were not submitted at all. Student ultimately received an "F" for
the class.
Withdrawal and Exit Counseling;
We were expelled for academic-performance reasons in July 2011. Exit
counseling was provided in a timely manner.
Program and enrollment: College 9;
2-year Associate's Degree-Business;
Enrolled for classes beginning in December 2010;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
Class 1: Learning Strategies and Techniques;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received a high "F" for the class.
For example:
* Student received no credit for assignments not submitted;
* Instructor provided extremely detailed constructive feedback on
written assignments, including specific changes to grammar and
sentence structure;
* After failing this class, student was abruptly reenrolled in a
repeat of the class without notice; the repeated class was taught by
the same instructor;
Class 1 (repeated): Learning Strategies and Techniques;
Instructor suggested that the student resubmit the same work that had
been previously submitted during the first attempt at this class, but
including corrections based on the previously provided feedback. The
instructor further provided the student with copies of these prior
submissions and the related feedback. Following these instructions,
the student received a higher grade on several assignments, which was
significant enough for the student to pass the class on the second try
with a final grade of "D".
Withdrawal and Exit Counseling;
We withdrew in March 2011. Exit counseling was provided in a timely
manner.
Program and enrollment: College 10;
2-year Associate's Degree-Criminal Justice;
Enrolled for classes beginning in December 2010;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
Class 1: Introductory Computing;
Instructor awarded credit to the student for a major assignment that
was not completed. Specifically, the student received 100% of the
available points on their final project, despite submitting only 2 of
3 required components, which would appear to be inconsistent with
established grading standards. The student received a passing grade of
"D-plus" for the class;
Class 2: Learning Strategies and Techniques;
Instructor awarded credit to the student for multiple assignments that
failed to meet technical requirements set forth in instructions,
though the student ultimately received a final grade of "F" for the
class. For example:
* Student submitted numerous assignments that were (1) insufficient in
length, (2) developed without using required software tools, or (3)
lacking proper and accurate citations;
* Student received full credit for an assignment that had already been
submitted for Class 3 and contained a clear notation that it was
prepared for the other class;
Class 3: Introduction to the Criminal Justice Program;
Instructor noted that the student was not meeting technical
requirements and was submitting unresponsive assignments, gave
appropriate credit, and provided constructive feedback; the student
ultimately received an "F" for the class.
Withdrawal and Exit Counseling;
We withdrew in March 2011. Exit counseling was required but not
provided. College staff told the student that the required exit
counseling was provided during the entrance interview; In the months
following withdrawal, the student received an average of 1.4 e-mails
per week from a school "Re-entry Specialist" encouraging the student
to return to the college.
Program and enrollment: College 11;
2-year Associate's Degree-Medical Billing and Coding;
Enrolled for classes beginning in December 2010;
Observations: Substandard Performance Behaviors Used;
* Failure to submit assignments;
* Submission of objectively incorrect assignments;
* Submission of unresponsive assignments.
Class 1: Introductory Computing;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "F" for the class;
Class 2: Introduction to Medical Billing Program;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received a "D" for the class;
Class 3: Critical Thinking;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "incomplete" for the
class. Instructor attempted to contact the student on a number of
occasions to offer help;
Class 4: Introduction to the Medical Billing Program II;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "incomplete" for the
class. Instructor attempted to contact the student on a number of
occasions to offer help.
Withdrawal and Exit Counseling;
We withdrew in March 2011. Exit counseling was required but not
provided.
Program and enrollment: College 12;
2-year Associate's Degree-Medical Billing and Coding;
Enrolled for classes beginning in January 2011;
Observations: Substandard Performance Behaviors Used;
* After displaying no substandard performance behaviors for the first
14 days of class, failure to attend class.
College Policy;
Students who fail to log into the student portal to indicate
attendance for 14 consecutive days will be expelled from the college.
Class 1: Introductory Computing;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "incomplete" for the
class;
Class 2: Introduction to the Medical Billing Program;
Instructor gave appropriate credit in accordance with grading
standards and ultimately student received an "incomplete" for the
class.
Withdrawal and Exit Counseling;
Student was expelled from college in February 2011 after 14
consecutive days of nonattendance. No exit counseling was required.
Program and enrollment: 13;
Observations: Student's enrollment request was denied. Per school,
student did not meet requirements for acceptance based on insufficient
evidence of high school graduation.
Program and enrollment: 14;
Observations: Student's enrollment request was denied. Per school,
student did not meet requirements for acceptance based on insufficient
evidence of high school graduation.
Program and enrollment: 15;
Observations: Student's enrollment request was denied. Per school,
student did not meet requirements for acceptance based on insufficient
evidence of high school graduation.
Source: GAO.
[End of table]
As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to relevant congressional committees and the Department of Education.
This report will also be available at no charge on GAO's website at
[hyperlink, http://www.gao.gov]. If you or your staff have any
questions about this report or need additional information, please
contact me at (202) 512-6722 or hillmanr@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs can be found
on the last page of this report.
Sincerely yours,
Signed by:
Richard Hillman:
Managing Director:
Forensic Audits and Investigative Service:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Because of your interest in the student experience at for-profit
colleges, we agreed to conduct undercover testing by enrolling in
online classes under degree-granting programs. We selected 15 for-
profit colleges and, once enrolled, engaged in behaviors consistent
with substandard academic performance. As part of an undercover
investigation, our tests were designed to obtain observations from
entities that were unaware of our true identities. However, there
exists a possibility that tested entities were able to determine that
our students were fictitious and therefore altered their behavior
based on the assumption that they were under observation. In order to
determine the population of colleges eligible for selection, we
queried the publicly available Integrated Postsecondary Education Data
System (IPEDS),[Footnote 21] the core postsecondary education data
collection program for the National Center for Education Statistics
(NCES) to identify schools meeting the following characteristics: (1)
U.S. only; (2) Title IV Participating; and (3) 4-year or above private
for-profit, 2-year or above private for-profit, or less than 2-year
private for-profit.[Footnote 22] From this query, we identified 2,770
institutions at which 1,804,246 students were enrolled in fall 2008.
Because IPEDS data are sometimes reported on a per-campus basis, it is
possible for a parent college to have multiple listings, and therefore
these 2,770 records do not represent 2,770 different colleges. To
identify the parent college, we used a 15-character name-based
summarization, resulting in 1,346 parent colleges.[Footnote 23]
To conduct our work, we tested 15 colleges, selected in three stages.
In determining which colleges to test, we used the following
enrollment and program logistical requirements: (1) the selected
college must allow students to complete online-only courses in pursuit
of an associate's or bachelor's degree; (2) the expected enrollment
period (one term, as defined by the college) needed to be limited in
length to no more than 10 weeks; and (3) the selected college must
allow students to enroll over the phone or Internet. Since, IPEDS does
not contain information on these college characteristics, during each
stage of the selection, allowances were made to take into account the
possibility of selecting a college that could not be tested. A
determination as to whether the college offers online courses in
pursuit of a degree was made based on queries of the respective
colleges' websites. Identification of the colleges' expected
enrollment period was done through online or telephone inquiries.
Determination as to whether the college allowed phone or Internet
enrollment was made by attempting to enroll.
First, we selected the 5 largest for-profit colleges, by student
population, based on student enrollments for fall 2008. For this
purpose, we used the parent college-level summarization of campus-
level data. In total, these 5 colleges represented 654,312 of the
1,804,246 students (36 percent) and 325 of the 2,770 campuses
reporting for fall 2008 (12 percent). All 5 colleges were further
found to offer online-only coursework in pursuit of a degree, with
limited enrollment period lengths and online and telephone
enrollments, and were therefore fully eligible for testing.
Next, we selected 1 for-profit college based on unsolicited
allegations received by GAO. We received 94 unique unsolicited
allegations of misconduct at for-profit colleges between June 10,
2010, and October 30, 2010. We selected the college that had the most
specific allegations of misconduct that had not already been selected
under the first part of this selection methodology. This college met
all the logistical requirements for selection. We considered 1 other
for-profit college based on allegations received, but did not select
it for testing due to logistical issues we identified as an impediment
to testing (i.e., lack of online-only coursework).
Finally, we selected the remaining 9 for-profit colleges using a
systematic selection process. Although the selection in each of the
first two stages was done at the college level, the selection in the
third stage was done at the campus level. For the selection of the
remaining 9 colleges, we randomly sampled from the population of 2,770
campuses that were neither selected nor eliminated due to known
logistical issues through the previous two selection methods and had
Fall 2008 enrollment of at least one student, and in which the campus
(as reported to IPEDS), served as the selection unit. Because of the
potential that colleges selected randomly would not meet logistical
requirements, we selected a sample of 150 campuses to increase the
likelihood that 9 testable colleges would be selected. Of the 150
campuses, only 24 were found to offer online-only coursework in
pursuit of a degree. Each of these 24 campuses was associated with a
different parent college. Additional phone-based research was
conducted on these 24 to verify conformity with logistical
requirements. Based on that research, a further 8 colleges were
removed for reasons including: (1) term length in excess of 10 weeks;
(2) physical classroom attendance requirements; (3) college would not
provide required logistical information without in-person interviews;
(4) infeasible program start date; and (5) requirement for prospective
students to submit field-specific certification credentials. To select
the 9 colleges from the remaining 16, we contacted all 16 colleges on
November 23, 2010, to determine the next available start date for an
online-only degree-granting program. We then selected the 9 colleges
with the soonest start dates. During the course of testing, 2 of these
selected colleges were replaced with the next available schools (by
start date) as a logistical consideration.
At each of the 15 selected colleges, we attempted to enroll using
fictitious identities and one or two possible fictitious pieces of
evidence of high-school graduation-a home-school diploma or a diploma
from a closed high school.[Footnote 24] If the student's application
at any particular school was denied using both pieces of fictitious
graduation documentation, we took no further action. We attempted to
enroll in degree-granting programs that were expected to include
objectively-graded coursework (such as multiple-choice tests), such as
business, medical billing, and paralegal studies programs. All
fictitious students we successfully enrolled in for-profit colleges
participated in degree programs that did not allow for elective course
selection during the first term; our fictitious students took whatever
classes the college required. We enrolled in each college for
approximately one term, as defined by the college.[Footnote 25]
To engage in behaviors consistent with substandard academic
performance, we used one or more of the following strategies for each
student: (1) failure to attend class,[Footnote 26] (2) failure to
submit assignments, (3) submission of objectively incorrect
assignments (e.g, submitting incorrect answers on multiple-choice
quizzes), (4) submission of unresponsive assignments (e.g., submitting
pictures when prompted to submit an essay), and (5) submission of
plagiarized assignments. We documented the college's and instructor's
response to these behaviors (as applicable), including any failure to
follow established college policies as related to academic performance
or academic misconduct. We did not evaluate the relative academic
rigor of courses or any other degree program materials, nor did we
evaluate the statements or behaviors of enrollment officials, except
in such instances that affected the student experience in the
classroom setting. As applicable, we documented the colleges'
withdrawal procedures and whether the colleges provided required exit
counseling for students that received financial aid. We tested each
college once. The experience of each of our undercover students is
unique and cannot be generalized to other students taking courses
offered by the for-profit colleges we tested or to other for-profit or
nonprofit colleges.
Our investigative work, conducted from October 2010 through October
2011, was performed in accordance with standards prescribed by the
Council of the Inspectors General on Integrity and Efficiency.
[End of section]
Footnotes:
[1] For-profit colleges are institutions of higher education that are
privately owned or owned by a publicly traded company and whose net
earnings can benefit a shareholder or individual. In this report, we
use the term "college" to refer to all of those institutions of
postsecondary education that are eligible for funds under Title IV of
the Higher Education Act. This term thus includes public and private
nonprofit institutions, proprietary (or for-profit) institutions, and
postsecondary vocational institutions. 20 U.S.C. §§ 1001, 1002.
[2] See appendix I for complete details of the selection process.
[3] Each fictitious student was, at the time of application, eligible
for federal financial aid in the form of subsidized and unsubsidized
student loans.
[4] For online classes, attendance was tracked for students using
student portal logins.
[5] The length of individual classes and terms differed by school. In
some cases, our students were withdrawn or expelled prior to the
completion of a full term.
[6] Once students have completed or withdrawn from schools, the Higher
Education Act requires that schools provide exit counseling, typically
within 30 days, for all students with federal loans.
[7] The Department of Education's Office of Federal Student Aid
administers these programs, which include, among others, the William
D. Ford Federal Direct Loan Program, the Federal Pell Grant Program,
and campus-based aid programs. The Federal Supplemental Educational
Opportunity Grant, Federal Work-Study, and Federal Perkins Loan
programs are called campus-based programs and are administered
directly by the financial aid office at each participating college. As
of July 1, 2010, new federal student loans that are not part of the
campus-based programs come directly from Education under the Direct
Loan program.
[8] GAO, Proprietary Schools: Stronger Department of Education
Oversight Needed to Help Ensure Only Eligible Students Receive Federal
Student Aid, [hyperlink, http://www.gao.gov/products/GAO-09-600]
(Washington, D.C.: Aug. 17, 2009).
[9] GAO, For-Profit Colleges: Undercover Testing Finds Colleges
Encouraged Fraud and Engaged in Deceptive and Questionable Marketing
Practices, [hyperlink, http://www.gao.gov/products/GAO-10-948T]
(Washington, D.C.: Aug. 4, 2010).
[10] The federal government pays the interest on behalf of subsidized-
loan borrowers while the student is in school. Unsubsidized-loan
borrowers are responsible for all interest costs. Regardless of loan
type, borrowers must be either a U.S. citizen or eligible noncitizen,
and be enrolled at least half time in a degree or certificate program.
[11] The EFC represents the amount the applicant and the applicant's
family can reasonably be expected to contribute toward the applicant's
postsecondary education. The "cost of attendance" in the context of
student financial assistance is defined by 20 U.S.C. § 1087ll.
[12] Grants do not have to be repaid by students, while loans must be
repaid whether or not a student completes a degree program.
[13] If the college makes the determination of ability to benefit, the
student must have satisfactorily completed six credit hours of
coursework applicable toward a degree or certificate offered by the
college.
[14] 20 U.S.C. § 1092(a)(1).
[15] U.S. Department of Education, Federal Student Aid Handbook,
Volume 5--Overawards, Overpayments, and Withdrawal Calculations, 2010-
2011 (August 2010).
[16] Although our student did not successfully enroll at School 13,
several weeks after we were denied admission we received a letter
noting that since we were "not enrolled at least half-time," we were
being provided with exit counseling. We did not respond to this letter
and do not know why we received it.
[17] 34 C.F.R. § 668.22(b), (c).
[18] We do note, however, that at College 6, while the student did not
receive exit counseling at the time of withdrawal, the college did
contact the student by mail near the end of the student's federal
student loan grace period to remind them to repay.
[19] 34 C.F.R. § 685.304.
[20] As previously noted, substandard behavior scenarios for each
student included one or more of the following behaviors: (1) failure
to attend class, (2) failure to submit assignments, (3) submission of
objectively incorrect assignments (e.g., submitting incorrect answers
on multiple-choice quizzes), (4) submission of unresponsive
assignments (e.g., submitting pictures when prompted to submit an
essay), and (5) submission of plagiarized assignments.
[21] Colleges participating in or applying to participate in Title IV
federal financial assistance programs are required to complete the
surveys that are used to populate IPEDS.
[22] The most recent cycle of data available through IPEDS at the time
of our engagement was fall 2008.
[23] Due to the potential imprecision of such name-based
summarization, we conducted a visual inspection of the summarized data
and corrected any obvious errors.
[24] Each fictitious identity was, at the time of application,
eligible for federal financial aid in the form of subsidized and
unsubsidized student loans.
[25] The length of individual classes and terms differed by college.
In some cases, our students were withdrawn or expelled prior to the
completion of a full term.
[26] For the purpose of this engagement, in consideration of the
testing of online-only classes, failure to attend class was achieved
through failure to log in to a college's student portal.
[End of section]
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