The Return On The Federal Investment in For-Profit Education: Debt Without A Diploma
The Return On The Federal Investment in For-Profit Education: Debt Without A Diploma
The Return On The Federal Investment in For-Profit Education: Debt Without A Diploma
Executive Summary......................................................................................................................Page 1
Investigation Background............................................................................................................Page 3
Introduction...................................................................................................................................Page 3
Fast Growing Schools…...............................................................................................................Page 4
…Fast Departing Students...........................................................................................................Page 5
The High Cost of Withdrawal......................................................................................................Page 6
Large and Growing Profits..........................................................................................................Page 8
Growing Dependence on Federal Aid.........................................................................................Page 9
Rapidly Increasing Federal Dollars...........................................................................................Page 10
Conclusion...................................................................................................................................Page 11
Methodology................................................................................................................................Page 12
Executive Summary:
For-profit education companies claim to offer access to higher education to low-income and
minority students. Data analysis of 16 for-profit schools indicates that they are more likely to
offer their students debt without a diploma.
Enrollment is growing even more quickly than previously understood and masks high withdrawal
rates:
Annual enrollment measures fail to capture that, because of high withdrawal rates, schools must recruit
large numbers of new students each year to maintain, or grow, their enrollment levels.
In 2008-09, one school started the year with an enrollment of 71,246 and ended the year with an enrollment
of 89,479. However, the school added 120,638 new students over the course of that year. Recruiters had
to enroll 120,000 new students to increase enrollment by a net of 18,000 for the following year.
Fourteen out of 16 schools analyzed recruited a greater number of new students than their entire starting
enrollment in 2008-09, however their net enrollment only increased by 22 percent.
The data received and analyzed by the Committee provides new evidence that, at many schools, more
than half of students withdraw within two years of enrollment.
In total, out of 16 for-profit schools analyzed, 57 percent of students who entered school between July
2008 and June 2009 have withdrawn.
Over a three year period, an estimated 1.9 million students have left the 16 for-profit schools, most with
nothing to show for their time in a for-profit school but student loan debt.
Two large for-profit schools that enroll a combined 44,000 students across the country in associates
degree programs have withdrawal rates above 75 percent for 2008-09 enrollees.
Almost all students at for-profit schools take out student loans to pay high tuition and they are
likely to amass significant debt even in a few months:
For 2008-09 students withdrawing from associates or bachelors programs, median attendance was
approximately 20 weeks. A student who attended for that length of time would pay approximately
$8,800 to $11,000 in tuition.
Most students at for-profits borrow to pay tuition. More than 95 percent of students at two-year for-
profit schools and 93 percent at four-year for-profit schools took out student loans in 2007, while only
16.6 percent of students attending community colleges and 44.3 percent at public four-year institutions
borrowed during the same period.
-1-
According to a 2005 report published by the National Center for Public Policy and Higher Education,
students who drop out without completing their degree were ten times more likely to default on their
student loans, which may foreclose the opportunity to earn their diploma at another school.
High enrollment and withdrawal is driving up the amount of federal dollars flowing to for-profits:
Across the schools analyzed, the amount of federal dollars flowing to for-profit schools is escalating
rapidly. Eight schools have more than doubled the amount of Pell grant dollars they received between
2006 and 2009, with three more schools nearly doubling. At least two additional companies have seen
increases of 85 percent or more in Pell grant funding between fiscal year 2009 and 2010.
Federal programs outside the Department of Education are also experiencing rapid growth in funds
flowing to for-profits. Between fiscal year 2009 and 2010, two schools saw increases of $56 million in
non-Title IV student aid funds received and a third is on pace to see an increase of up to $85 million.
Despite dismal student outcomes, for-profit institutions are raking in record profits:
For the 16 companies analyzed, profits in 2009 totaled $2.7 billion. Between fiscal year 2009 and 2010
alone one company doubled its profits from $119 million to $241 million, while a second went from
$235 million to $411 million.
For-profit college revenues are largely made up of the taxpayer dollars intended to support
student success:
This report for the first time provides a full picture of the federal revenues flowing to some for-profit
schools.
Across 14 schools analyzed, federal dollars total 87.4 percent of 2009 revenues and ranged from 93.1
percent of revenues to 85.2 percent of revenues.
Enrolling low-income students requires a commitment to provide support and resources to ensure those
students succeed. Based on the poor outcomes at many for-profit schools, those schools are falling short
in adequately assisting the students they claim to be serving.
The data analyzed suggests that some for-profit schools are efficient government subsidy collectors first
and educational institutions second. Under current law, a for-profit school can be extremely profitable
while failing a majority of its students. This is clearly not what Congress intended when it allowed for-
profit schools to access federal student aid dollars.
-2-
Investigation Background:
In June of this year, Senator Tom Harkin, Chairman of the Senate Committee on Health, Education,
Labor and Pensions (HELP Committee) began investigating whether the rapidly growing investment in
for-profit schools is benefiting taxpayers, through a more educated citizenry, and students, by allowing
them to obtain the skills and education they need to increase their lifetime earning power. As part of a
hearing on June 24, 2010, the Chairman released an initial report titled “Emerging Risk?: An Overview
of Growth, Spending, Student Debt and Unanswered Questions in For-Profit Higher Education.”
The HELP Committee held a second hearing on August 4, 2010, focused on recruitment and marketing
practices and featuring a report by the Government Accountability Office (GAO). The GAO testified
that investigators visited 15 for-profit schools and found deceptive, misleading or fraudulent recruitment
practices at every one. 1 On August 5, 2010, the Chairman issued a document request to 30 for-profit
education companies to better understand the range of practices across the for-profit spectrum.2 This
report is based on an analysis of information provided in response to that document request. It focuses
on the eight largest publicly traded and the eight largest privately held for-profit education companies
that offer certificate, associates or bachelors programs.
Introduction
Because of the power of higher education to improve both individual lives and our economy, the federal
government will invest more than $140 billion to aid postsecondary students this year alone. For this
investment of federal dollars to pay off, higher education institutions must increase the knowledge and
skills of their students. 3
-3-
For-profit colleges offer access to programs that are on average significantly more expensive than public
institutions of higher education. A student who attends a for-profit school, even for a short period of
time, can amass a significant amount of debt that can take years to repay.5
Almost all of the 1.9 million students who withdrew from the 16 colleges analyzed in this report over the
past three years will leave with substantial debt.6 Students who leave school without earning a diploma
are ten times more likely to default on their loans according to a National Center for Higher Education
Policy report.7
These outcomes are of particular concern to Congress and the federal government because of the extent
to which for-profit colleges reap this profit from federal
subsidies. The 14 schools that provided comparable data
Almost all of the 1.9 million students for this report received 87.4 percent of their revenue from
who withdrew from the 16 colleges federal taxpayer dollars in 2009.8 Moreover, despite high
analyzed in this report over the withdrawal rates, and heavy debt burdens for students, the
past three years will leave with companies are generating tremendous profits. The total
substantial debt. Students who do fiscal year 2009 profit for the 16 schools examined was
not get a diploma are ten times more $2.7 billion dollars.
likely to default on their loans.
If for-profit schools are leaving large numbers of students
worse off, and costing taxpayers and students significant
amounts of money with no real benefit, it is incumbent on Congress to look closely at that federal
investment. This report suggests more should be done to ensure that taxpayer dollars are being spent
effectively on educating the students attending for-profit schools. Alarmingly, the data collected in this
report show that for the majority of students enrolled at for-profit institutions, debt is a far more certain
outcome than a degree.
160,000 students.9 Starting Enrollment New Students Added July 1 - June 30 Ending Enrollment
-4-
While School H demonstrates the largest growth, almost every school examined in this report is engaged in
rapid enrollment growth. In 2008-09, 14 out of 16 schools analyzed recruited a greater number of students
than their entire starting enrollment.10
School B began the 2008-09 year, with an enrollment of 71,246 and ended the year with an enrollment
of 89,479. However, over the course of the year it added 120,638 new students. Recruiters at School
B had to enroll 120,000 new students to increase enrollment by only 18,000 students for the following
year.11
As a group, the 16 schools had one million students enrolled as of July 1, 2009. Over the next 12 months
they brought in 1.2 million new students. These high numbers are consistent with the aggressive recruitment
practices detailed in the HELP Committee’s August 4th hearing.
For-profit schools present themselves as responding to the growing demand for education in a down
economy. In particular, they claim to be responding to the needs of working adults and low-income
students. However, growing enrollments only tell part of the story. In fact, while students are entering
for-profit schools at phenomenal rates, they do not appear to be staying in school. The 16 schools
added 1.2 million new students to their starting enrollment of 1 million. However, the schools ended the
year with only 1.3 million students, meaning nearly one million students departed those schools in the
course of the year. Only a fraction of those students left with a degree.12
Data collected for this report indicates that students are overwhelmingly departing most for-profit institutions
before completing their degree or diploma.13 The Committee analyzed data for each student who enrolled
at each of 16 for-profit schools between July 1, 2008 and June 30, 2009 (2008-09) looking at whether the
student was continuing, had completed or had withdrawn by August 2010. The conclusions were striking.
Outcomes for Students Enrolling in 2008-‐09 At 16 Schools Through August 2010
ent
raw d
d
m
lle
Wi nrolle
al
roll
raw
nro
t En
ithd
lled
All E
thd
E
n
Bef Days
ed
den
raw
ts W
nro
ed
plet
ts S
l Stu
ithd
plet
ore
All E
dian
den
den
om
Com
% W
Tota
% C
% S
Me
Stu
Stu
Associates Degree Students 450,500 38,003 8.4% 123,391 27.4% 289,106 64.2% 136
Cer?ficate Students 198,211 111,865 56.4% 6,406 3.2% 79,940 40.3% 112
Bachelors Degree Students 310,509 14,325 4.6% 118,481 38.2% 177,703 57.2% 141
Students at 5 Largest Schools By Enrollment 701,484 121,532 17.3% 170,995 24.4% 408,957 58.3% 127
Students At All Schools 959,220 164,193 17.1% 248,278 25.9% 546,749 57.0% 131
Nine hundred and fifty nine thousand students enrolled at the 16 schools during 2008-09. Five hundred
and forty seven thousand of those students, or 57 percent, withdrew by August 2010. Among associates
degree students at these 16 schools, 64.2 percent of students withdrew before completion. By contrast,
only 8.4 percent have completed, while 27.4 percent are still attending. Bachelor degree students have
not fared much better as 57.2 percent have withdrawn by the end of the second year.
-5-
There is some variation across the 16 schools. At
one publicly-traded school, 84.4 percent of the nearly Highest Departure Rates
8,000 students pursuing associates degrees starting
during 2008-09 withdrew by August of this year. At Associates Degree Students
a second school 76 percent of its 36,000 associates School
degree seekers withdraw over the same period. The I
top five schools by enrollment, all publicly traded 76% 15% 9%
School
For-profit schools are enrolling a growing
D number of students. What this data suggests,
26.6% 1.5% 72.0% however, is that not all of these schools are
providing students with a real opportunity to earn
School a degree or certificate. While these institutions
G may be successful as companies, the withdrawal
32.2% 2.0% 65.8% rates, combined with high debt, raise serious
Withdrawn Still Enrolled Completed concerns about whether they are successful as
educational institutions.
The vast majority of students who attend a for-profit college take out loans to finance their education.
According to the National Postsecondary Student Aid Survey, 95.4 percent of students at two-year for-
profit schools, and 93.4 percent at four-year for-profit schools, took out federal student loans in 2007-
08.14 By comparison, only 16.6 percent of students attending community colleges took out loans during
the same time period. At four-year public schools the borrowing rate was 44.3 percent, still half the rate
of four-year for-profit colleges. 15
-6-
Unlike their peers at non-profit institutions,
Tui/on Cost for Average Withdrawing Bachelors Student
almost all of the students who withdraw
$12,000
$11,328 from a for-profit school will leave school
with loan debt. Many of those students have
$10,560
$10,000
$8,904 low-incomes and will have greater difficulty
$8,000
$8,200
dealing with the substantial loan debt they
$6,730
have incurred compared with more affluent
$6,000
students. Further, by failing to complete
a degree, these students will miss out on
$4,000 most of the financial benefits associated
with higher education. According to a 2005
$2,000 report published by the National Center for
Public Policy and Higher Education, students
$0 who drop out without completing their
School I School G School P School C School N
degree were 10 times more likely to default
on their student loans.16
The harsh reality for students attending for-profit colleges is that even a brief enrollment can result in
significant debt. The high rate of borrowing by students attending for-profit schools is due in part to
higher tuition rates. According to GAO’s August 4th testimony at a hearing of the HELP Committee,
of the 15 schools investigated, 14 had higher tuition than the nearest public college offering a similar
program.17 One particular for-profit college offered a “computer-aided drafting certificate” for $13,945,
when the same program at a community college would cost $520.18 The cost of an associates degree
offered by the second largest for-profit is over $38,000, and a bachelors degree from the same school
can cost up to $96,500.19 Thus, a student who enrolls in a for-profit school even for a short period of
time can amass many thousands of dollars of debt that can take years to repay.
To estimate the student loan burdens of students withdrawing from these institutions this analysis looked at
how long they remained enrolled. Among students who withdrew from the 16 schools, median attendance
was approximately 20 weeks. If that student attended full-time and took 12 credits per term he or she
could still incur a substantial debt. For the five schools in the chart above, a student attending for 15 to 22
weeks could incur a tuition debt from $8,800 and $11,300.
While grant aid would likely offset some of the cost According to the National Postsecondary
of tuition for some students, others are equally likely Student Aid Survey, 95.4 percent of
to have borrowed above the cost of tuition in order students at two-year for-profit schools, and
to cover living expenses while going to school. As a 93.4 percent at four-year for-profit schools,
result, most still face the likelihood of accumulating took out federal student loans in 2007-
considerable debt in just four or five months.
08. By comparison, only 16.6 percent of
students attending community colleges
For many students attending a for-profit college,
withdrawing does not allow them simply get on with
took out loans during the same time period.
their lives and start over. Their decision to enroll in At four-year public schools the borrowing
college has likely left them with a financial burden rate was 44.3 percent, still half the rate of
that could take many years to repay. While federal four-year for-profit colleges.
-7-
loans do have flexible repayment options, they are non-dischargeable in bankruptcy. Furthermore,
students who are in default on their student loans are not eligible for additional student loans, meaning
that many may find the opportunity to try again to attain a degree foreclosed. Given the low rate of
borrowing at community colleges, students are risking far less in pursuing higher education at these
public institutions.
Profit growth has not slowed despite high rates of student withdrawal or the economic challenges facing
most of the country. For two companies with recently completed fiscal years, dollar profits have nearly
doubled between fiscal year 2009 and 2010.
-8-
provided by for-profit colleges does not go so far as to show that they are profiting off of the failure of
their students. However, it undoubtedly shows that they are extremely profitable in spite of poor results
for the majority of the individuals they enroll.
0.9%
0.41% 7.4%
7.4% 6.9%
6.9%
11.4%
11.4%
85.6% 85.6%
85.6%
85.6%
91.3% 81.77%
-9-
New information gathered for this report provides a more accurate picture of the full universe of federal
dollars flowing to for-profit schools. For the 14 schools that provided comparable data, when the full
amount of Title IV cash receipts are added together with federal non-Title IV federal dollars flowing to
for-profit schools, the aggregate federal share of the schools revenues is actually 87.4 percent.23
Among the 14 schools the share of federal dollars received ranges as high as 93.1 percent of revenues.
State dollars also provide a significant revenue source to some for-profit schools, as much as 2.9 percent
in at one school. Even the school with the smallest share of Title IV aid, 11 percent, receives 93.1
percent from federal taxpayer dollars because of money they receive from other federal programs.
It is important to note that to the Committee’s knowledge, all of the schools analyzed are in compliance
with the 90/10 rule including the four schools receiving more than 90 percent federal aid. Given the
many sources of federal revenue that are excluded, it appears that the 90/10 rule as currently written
provides insufficient protection to taxpayers. Based on this analysis, at least the largest publicly traded
and privately held for-profit colleges are nearly completely reliant on federal revenues.
$1,200
Rise in Federal Dollars, 2006-‐Rise in Federal Dollars, 2006-09
Rise in Federal Dollars, 2006-‐09
09 Rise in Federal Dollars, 2006-‐09
$1,800
$1,800
$1,000 $250
$1,600
$1,600
$1,400
$800 $1,400
$200
Revenue (in millions)
Revenue (in millions)
$1,200
$1,200
Revenue (in millions)
$600
$1,000
$1,000 $150
$800
$400 $800
$100
$600
$600
$200
$400
$400 $50
$200
$0 $200
06 07 08 09 06 07 08 09 06 07 08 09 06 07 08
$0 $0
School
$0 06 07 08 09 06 07 08 09 06
School 06 07 08
07 08 09 09 06 07 08 09
School
06 07 08 09 06 07 08 09 06 07 08
School
09
1 School
06 07 08 09 School 06 07 School
08 09 16 School 07
06 08 09 School 06 07 4
08 School
09 School School 13
1 School 16 School 4 13 School 15 School 11 14 5
1 16 4 13
Pell Grant Dollars Pell Grant Dollars
Stafford Loan Dollars Other Federal Dollars Stafford Loan Dollars Other Federal Dollars
Pell Grant Dollars Stafford Loan Dollars Other Federal Dollars
Pell Grant Dollars Stafford Loan Dollars Other Federal Dollars
- 10 -
The Committee has previously noted the rapidly increasing enrollment in for-profit institutions. That
enrollment growth is paralleled by an increasing share of federal Pell grants and federal Stafford loans,
as well as other federal programs.
Conclusion
For-profit colleges are growing at an astounding rate, propelled by significant investments in marketing
and an aggressive recruitment model. However, the new enrollments are hiding real institutional
problems. More than half of students will withdraw from for-profit colleges within the first two years.
At some schools, students pursuing associates degrees withdraw at a rate of more than 75 percent within
the first two years. For students attending a for-profit school a degree is a possibility, but debt without a
diploma is far more likely.
The high withdrawal rates raise a fundamental question about the value of for-profit schools for low-
income students. These institutions ask students with the most modest financial resources to take a
big risk by enrolling in their high-tuition schools. If students succeed they may increase their income.
However, if they drop out, as an overwhelming majority does at some institutions, they are left with
significant debt, and a serious risk of default. Debt will not only make day-to-day life more difficult for
former students, it may also hinder them from returning to school and completing their degree.
That companies are incredibly profitable even as hundreds of thousands of their students leave every
year is deeply concerning. That these institutions should derive these profits almost entirely from
federal revenues raises serious questions about federal policies regulating this sector. It is the obligation
of Congress and federal regulators to provide effective government oversight and regulation of federal
financial aid dollars. However, many for-profit schools appear to be operating without the academic
quality that would generate interest from a broad range of students and financial commitments from
outside the federal financial aid system.
- 11 -
Finally, the high withdrawal rates, coupled with high profits, suggest that not all for-profit schools are
quality educational institutions. Some appear to be nothing more than highly efficient government
subsidy collectors. For these companies, high dropout rates and low student success rates appear to be
irrelevant. The schools can be profitable, and many are, even if most of their students fail, so long as
their federally subsidized marketing machine can continue to convince more Americans to enroll.
Methodology
Unless otherwise noted, the source of all charts and tables in this report is the HELP Committee
majority’s analysis of documents provided by for-profit schools between August 26, 2010 and
September 29, 2010. The analysis covers information from the eight largest publicly traded and the
eight largest privately held for-profit education companies that were asked to provide documents and
that offer certificate, associates or bachelors programs.
The federal share of each school’s revenue is calculated using the cash receipts submitted as a percent
of the revenue reported by the school for the fiscal year 2009 90/10 calculation. In calculating revenue
for 90/10 purposes, schools count all tuition fees and other institutional charges, student tuition, 50
percent of the value of institutional loans, scholarships or tuition discounts, ECALSA exclusions, and
campus based activities. The revenue number does not include Federal Work Study funds paid to
students, Leveraging Educational Assistance Program (LEAP) funds, institutional matching dollars,
lender refunds or book and supplies. The aggregate share is calculated as an average of those shares and
is not weighted based on enrollment. Profits and profit margins are calculated based on the operating
income (revenues minus the costs spent on education, marketing, and administration before taxes and
depreciation) and revenues reported by the companies.
For purposes of calculating enrollment and withdrawal figures, companies were asked to provide two
sets of data. One set tracking continuing enrollment, new enrollments, withdrawals, and completions
on a program-by-program basis for fiscal years 2007, 2008, and 2009. And a second set tracking
enrollment, completion, and withdrawal on a student-by-student basis for students who enrolled between
July 1, 2008 and June 30, 2010.
The “withdrawals” category includes all students that each school defined as no longer enrolled.
This includes students who may have been dismissed. The analysis relied on each school’s own
categorization of whether a student was actively enrolled or not. Most schools define enrollment as
whether a student has attended class in some specified number of days; with most of them defining
enrollment as attending class once in the past 30 days. However, this period to measure active
enrollment ranged from attendance in the past 10 to 90 days.
- 12 -
1
U.S. Government Accountability Office, Undercover Testing Finds Colleges Encouraged Fraud and Engaged in Decep-
tive and Questionable Marketing Practices, GAO-10-948T, pgs. 16-17 (August 2010). http://www.gao.gov/new.items/
d10948t.pdf.
2
The 30 schools receiving requests include the fifteen for-profit education companies that are publicly traded, as well as
fifteen privately held for-profit education companies, selected based on varying size and geography. Together the schools
make up a significant share of the for-profit sector that received $24 billion in federal student aid in 2009. The request
seeks information including tuition, marketing, revenue sources, student persistence and performance, and institutional fi-
nancial aid practices. The Committee commends the companies for their cooperation with this effort to better understand
the industry and looks forward to their continued cooperation as the production of information continues.
3
S. Department of Education, Budget Service, Fiscal Year 2011 Budget Summary. http://www2.ed.gov/about/overview/
budget/budget11/summary/edlite-section3d.html#tables.
4
U.S. Senate HELP Committee majority staff analysis of documents.
5
U.S. Senate HELP Committee majority staff analysis of documents.
6
U.S. Department of Education, National Center for Education Statistics, 2007–08 National Postsecondary Student Aid
Study (NPSAS: 08). http://nces.ed.gov/pubs2009/2009166.pdf (U.S. Senate HELP Committee majority staff analysis of
documents).
7
National Center for Public Policy and Higher Education, Borrowers Who Drop Out: A Neglected Aspect of the College
Student Loan Trend by Lawrence Gladieux and Laura Perna (May 2005).
8
U.S. Senate HELP Committee majority staff analysis of documents.
9
U.S. Senate HELP Committee majority staff analysis of documents.
10
U.S. Senate HELP Committee majority staff analysis of documents.
11
U.S. Senate HELP Committee majority staff analysis of documents.
12
U.S. Senate HELP Committee majority staff analysis of documents.
13
U.S. Senate HELP Committee majority staff analysis of documents.
14
U.S. Department of Education, National Center for Education Statistics, 2007–08 National Postsecondary Student Aid
Study (NPSAS:08). That borrowing level included students in short term certificate programs as well as associates and
bachelors degree programs.
15
U.S. Department of Education, National Center for Education Statistics, 2007–08 National Postsecondary Student Aid
Study (NPSAS: 08). http://nces.ed.gov/pubs2009/2009166.pdf
16
National Center for Public Policy and Higher Education, Borrowers Who Drop Out: A Neglected Aspect of the College
Student Loan Trend by Lawrence Gladieux and Laura Perna (May 2005).
17
U.S. Government Accountability Office, Undercover Testing Finds Colleges Encouraged Fraud and Engaged in Decep-
tive and Questionable Marketing Practices, GAO-10-948T, pgs. 16-17 (August 2010). http://www.gao.gov/new.items/
d10948t.pdf.
18
U.S. Government Accountability Office, Undercover Testing Finds Colleges Encouraged Fraud and Engaged in Decep-
tive and Questionable Marketing Practices, GAO-10-948T, pgs. 16-17 (August 2010). http://www.gao.gov/new.items/
d10948t.pdf.
19
U.S. Senate HELP Committee majority staff analysis.
- 13 -
20
The theory of this requirement was that if the schools provided a quality education, then they could attract enough stu-
dents who would be willing to pay tuition from their own pockets, not only with student aid dollars.
21
The 2008 reauthorization of the Higher Education Act also changed the impact of a 90/10 violation from immediate
suspension of Title IV eligibility to a provisional eligibility status for two years. Institutions that violate 90/10 for two
consecutive years lose their federal aid eligibility for at least two years.
22
This includes the Post 9/11 Veterans Educational Assistance Act that pays for educational benefits for active duty military
and their family members, other veterans benefits, the Workforce Investment Act that provides educational benefits to job
seekers, and the Vocational Rehabilitation program that provides benefits to individuals with disabilities, among other
sources.
23
This calculation was performed by adding fiscal year 2009, cash basis federal and state revenue provided by the 16
companies to the Committee, and dividing that total by the amount of tuition revenues the schools themselves used to
determine their required 90/10 rule calculation. For example, if a school had $100 million in 90/10 revenues and $75
million in Title IV receipts (excluding ECALSA loan increases), they would have a 90/10 of 75 percent. The analysis
added all Title IV dollars and non-Title IV federal funds for each school, for a new total (for example $80 million) which
was divided by the reported revenue number to determine a more accurate federal share. These numbers were then aver-
aged together for 14 schools. Two schools provided cash receipt numbers in excess of reported 90/10 revenues making
it impossible to accurately calculate the federal share for these two schools, in a timely manner. Most schools subtracted
payments for student living expenses from Title IV receipts. Three schools, N, P and C provided a total amount of liv-
ing expense payments but did not track those payments or subtract them from Title IV receipts. In calculating revenue
for 90/10 purposes, schools count all tuition fees and other institutional charges, student tuition, 50 percent of the value
of institutional loans, scholarships or tuition discounts, ECALSA exclusions, and campus based activities. The revenue
number does not include Federal Work Study funds paid to students, Leveraging Educational Assistance Program (LEAP)
funds, institutional matching dollars, lender refunds or book and supplies.
- 14 -