Comment to the Department of Education recommending stronger debt-to-earnings standards in the gainful employment rule

This letter urges the Department of Education to strengthen the debt-to-earnings test that assesses whether for-profit colleges are adequately preparing graduates for gainful employment. It recommends that the Department revise the debt-to-earnings metrics so that they accurately depict graduates’ debt burdens, clarify how performance will be measured, and limit opportunities for exploiting loopholes.