On August 19, representatives from the AACS, including Greg Jones, Christine Gordon, Anthony Fragomeni, and Tom Netting, met at the White House with a special assistant to the president on education policy and an Office of Policy Development senior advisor. The discussion centered on the urgency of a pending Final Rule on Gainful Employment scheduled for completion by November 1, 2014, with implementation scheduled for July 1, 2015.

The one-hour conversation was prompted by AACS’ response to the “2014 Notice of Proposed Rulemaking on Program Integrity: Gainful Employment.” The proposal seeks to establish measures for determining whether certain postsecondary training programs prepare students for gainful employment, and the requirements for these educational programs to remain eligible for student financial assistance.

AACS representatives advocated on behalf of AACS member schools and individuals seeking to pursue an education in the beauty and wellness industry. They stressed concerns about the lack of complete and comprehensive data, which would correctly calculate institutions’ eligibility. Among these flaws are the integrity of data used to calculate debt-to-earnings (D/E) metrics and program cohort default rates (pCDR). In addition, they called for review and revision of the procedures and methodology used to establish aggregate mean and median rates, and provided analysis showing the current calculations are inherently flawed and incomplete. Finally, they advocated for alternative methodologies to assess an institution’s meeting of Gainful Employment thresholds, such as a requirement to meet either a D/E or pCDR threshold, but not both metrics.

Administration officials acknowledged by the end of the meeting that the current information and metrics used in determining eligibility calculations could potentially lead to inaccurate outcomes, which could be detrimental to both students and institutions.

Anthony Fragomeni emphasized that AACS’ leadership on Gainful Employment serves not only schools and students, but also the beauty and wellness industry and its consumers. “Our industry is incredibly interconnected,” he said. From the schools that prepare students to the employers that hire beauty and wellness professionals to the consumers they serve. AACS is committed to working with lawmakers, regulators, and policy makers to preserve and protect choice, equity, and access for those in our industry and those wishing to join our industry.”

AACS will continue to publish regulatory news and updates as the November 1st Final Rule approaches. More information can be found at www.aacsaction.org.

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