DeVry Education Group supports reasonable regulation concerning accountability and affordability in higher education. Today’s proposed Gainful Employment regulations issued by the U.S. Department of Education moves closer to that mark, but is not there yet. As currently drafted, the rule would seriously undermine the Obama administration’s goal of increasing the number of U.S. college graduates, especially lower-income Americans. Data shows that independent students who start out with the lowest income have the highest debt-to-income ratios after graduation – and would be disproportionately affected by the programmatic CDR measure. Public sector and independent institutions do not have the capacity to serve these displaced students, who would be left with limited educational options due to this proposed rule. The proposed rule holds private-sector programs to a higher standard than public-sector or independent programs. The DOE’s own data shows the average debt-to-earnings ratio for all bachelor’s degree graduates in their first year of repayment is 13 percent (12 percent public and 16 percent independent). Under the proposed rule, private-sector colleges and universities would be held to an 8 percent standard. Why the different standards? A fair rule would be one applied equally to all. By applying these arbitrary standards and casting too broad a net, the proposal snares many good and historically productive programs in critical areas like information technology and healthcare. And public-sector schools do not have the funding to increase their capacity. It would cost $5.2 billion to provide the capacity to accommodate the estimated 630,000 students displaced by this proposed rule. 1 That level of funding is unlikely to materialize anytime soon. We see a way forward, through regulations that truly gauge the quality of a program, through measures like actual employment, affordability and commitment to serving non-traditional and low-income students. We remain committed to working with the DOE to improve these rules.