EVALUATING FOR-PROFIT SCHOOLS Peter C Harvey Former New

EVALUATING FOR-PROFIT SCHOOLS Peter C. Harvey Former New Jersey Attorney General Patterson Belknap Webb & Tyler LLP May 24 , 2016 pbwt. com 8928759 v 1

For-Profit Schools - Overview Association of Private Sector Colleges and Universities (APSCU) - Over 600 member schools - Colleges and Universities - Technical/Trade Schools • Pink Collar Administrative (Secretaries/Administrative Assistants) • Health Care (Nurses) • Culinary • Transportation (Truck Drivers) • Construction • Technology (Computer Diagnostics/Repair) • Trade (Plumbing/Electrical/Hair Styling) • Visual/Performance Arts (Acting/Dance) 2

For-Profit Schools - Overview 2011 − 2012 EDUCATED/TRAINED - Over 855, 562 Graduates Nationwide New Jersey - 93 Private Sector Colleges (Total Colleges: 165) - Students: 54, 576 (Total College Students: 591, 647) - Employees: 3, 300 full-time New York - 140 Private Sector Colleges (Total Colleges: 461) - Students: 122, 369 (Total College Students: 1, 717, 883) - Employees: 8, 221 full-time 3

For-Profit Schools’ Student Demographics New Jersey/New York NEW JERSEY • 32% African American • 2% All Degrees • 25% Hispanic/Latino • 5% Associate’s Degrees • 31% White • 2% Bachelor’s Degrees • Total Students: 70% Women • 1% Master’s Degrees • 88% All Certificates NEW YORK • 28% African American • 5% All Degrees • 24% Hispanic/Latino • 14% Associate’s Degrees • 31% White • 3% Bachelor’s Degrees • Total Students: 68% Women • 2% Master’s Degrees • 65% All Certificates 4

SUGGESTED EVALUATION CRITERIA FOR COLLEGES Use same factors for non-profit and for-profit colleges 1. School Purpose and Student Demographics 2. Accreditation 3. Post-Graduate Job Placement 4. Job Availability in Sectors Advertised/Taught by School 5. Graduation Rates 6. Average Cost Per Student 7. Average Debt Per Student 8. Post-Graduate Earnings 9. Representations by School About Job Placement/Graduation Rate/Cost 5

EXAMPLE: Hypothetical For-Profit College Courses: • Accounting • Interior Design • Fashion Merchandising & Management • Graphic Design • Information Technology Management • Justice Studies/Criminal Justice • Marketing Communications • Medical Insurance, Billing & Coding (Certificate) • Surgical Technology • Medical Assistant (Certificate) • 11 other courses of study College Accreditation: Middle States Commission on Higher Education Certificate Programs: § § Practical Nurse Program – approved by State, Board of Nursing Medical Assistant – accredited by Commission on Accreditation of Allied Health Education Programs Surgical Technology Program – Accredited by Commission on Accreditation of Allied Health Education Programs Online Education – Quality Standards Certification – United States Distance Learning Association 6 (USDLA)

EXAMPLE: Hypothetical For-Profit College (cont’d) Tuition & Fees: Average Federal Student Loan Debt GRADUATES (2014 -2015) Certificate Programs: Certificate Programs $11, 696 (NJ) $16, 450 (Annually) Associate’s Degree: $31, 425 (Annually) Bachelor’s Degree $28, 650 (NJ) $31, 487 (NY) $24, 750 (Annually) Practical Nurse: $17, 466 (NJ) $22, 473 (NY) Students Receiving Aid: Institutional Aid: * 83% Federal Grants: 67% State Grants: 42% Federal Loans: 72% * College Awarded over $49 million in Institutional Aid (2014 -2015) 7

Average Annual Cost of Tuition & Fees (20152016) Elite Colleges: $68, 470 AVERAGE DEBT PER STUDENT: UNKNOWN Private Colleges: $59, 341 Public Colleges: $28, 387 Source: Forbes (2016) 8

EXAMPLE: Hypothetical For-Profit University (cont’d) Graduation Rates Employment Rates Associate’s: 25% (3 yrs) (2011 -14) Degree in Major: 79. 5% Bachelor’s: 31% (6 yrs) (2008 -14) Overall Degrees: 95. 3% Certificate in Major: 75. 2% Certificate Overall: 83. 1% 9

Comparison – Four Year Non-Profit Colleges Random Sample of Graduation Rates – US Department of Education 2008 -2011 University of Alabama 38% LSU 27% University of Arizona 34% Michigan State 48% University of Arkansas 34% UNLV 13% California State: Fullerton 15% University of New Mexico 11% Colorado State University 36% Montclair State University NJ) 31% Florida State University 48% North Dakota State 22% Georgia State University 18% Oregon State University 30% Kansas State University 26% University of Oklahoma 31% University of Kentucky 32% GRADUATE EMPLOYMENT RATES: UNKNOWN 10