BILL ANALYSIS                                                                                                                                                                                                    






                         SENATE COMMITTEE ON EDUCATION
                              Gloria Romero, Chair
                           2009-2010 Regular Session
                                        

          BILL NO:       AB 48
          AUTHOR:        Portantino
          AMENDED:       June 29, 2009
          FISCAL COMM:   Yes            HEARING DATE:  July 15, 2009
          URGENCY:       No             CONSULTANT:Kathleen Chavira

           SUBJECT  :  California Private Postsecondary Education Act of  
          2009
          
           SUMMARY  

          This bill revises and recasts the Private Postsecondary and  
          Vocational Education Reform Act of 1989 into the California  
          Private Postsecondary Education Act of 2009 (Act), provides  
          for the transition to the Bureau for Private Postsecondary  
          Education (BPPE), outlines its responsibilities, provides  
          for the approval, regulation, and enforcement of private  
          postsecondary educational institutions, establishes  
          reporting requirements, and repeals the Act on January 1,  
          2016. 

           BACKGROUND 

          The Private Postsecondary and Vocational Education Reform  
          Act of 1989 established the Bureau for Private  
          Postsecondary and Vocational Education (BPPVE) in the  
          Department of Consumer Affairs (DCA) for the purpose of  
          approving and regulating private postsecondary and  
          vocational educational institutions in California. The  
          provisions governing the operation and administration of  
          the BPPVE and the approval and regulation of the private  
          postsecondary and vocational institutions became  
          inoperative on July 1, 2007, and were repealed as of  
          January 1, 2008.  AB 1525 (Cook, Chapter 67, Statutes of  
          2007) declared legislative intent to protect students,  
          allowed for the continuation of matters pending before  
          BPPVE, and provided for minimal oversight of institutions  
          by DCA until February 1, 2008.  SB 45 (Perata, Chapter 635,  
          Statutes of 2007) extended limited DCA oversight of private  
          postsecondary schools from February 1, 2008, to July 1,  
          2008. No state law currently regulates the private  




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          postsecondary sector in California.

          In 2006, there were over 1,500 BPPVE-approved institutions  
          operating in California.  The BPPVE reported that these  
          institutions served over 400,000 students (consisting of  
          about 300,000 students at non-degree-granting institutions  
          and about 100,000 students at degree-granting  
          institutions).

           ANALYSIS

          This bill  revises and recasts the former Private  
          Postsecondary and Vocational Education Reform Act of 1989  
          (Prior Act) into the California Private Post-secondary  
          Education Act of 2009 (Act).  Specifically it:  
           
             1)   Declares legislative intent that the Act ensure  
               minimum educational quality standards and  
               opportunities for success for students attending  
               private postsecondary California schools, meaningful  
               student protections, a regulatory structure that  
               provides appropriate oversight and a regulatory  
               governance structure that ensures a voice for  
               stakeholders and accountability and oversight by the  
               Legislature, and prevention of deception of the public  
               resulting from fraudulent or substandard degrees.
           
          Transition Provisions  

             2)   Extends, for an additional three years beyond the  
               expiration date, any approval to operate granted by  
               the BPPVE and in place at the time the Prior Act  
               became inoperative.

             3)   Grants approval until 2012, or 2013 (depending upon  
               the date received) to any applications pending action  
               before the BPPVE at the time the prior Act became  
               inoperative, and requires that students enrolling in  
               these institutions be notified in writing by the  
               institution that the institution's renewal application  
               was not reviewed by BPPVE.  

             4)   Requires amendment and repeal of prior regulations  
               and adoption of emergency regulations conforming to  
               the transition provisions established by the Act by  
               February 1, 2010, to become permanent through the  




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               regular rulemaking process within one year of the date  
               of enactment of the Act.

             5)   Deems that any unresolved matter (including but not  
               limited to, an appeal, complaint, claim, evaluation,  
               hearing or investigation) submitted to the BPPVE  
               before July 1, 2007, remain pending before the BPPE  
               regardless of any applicable deadlines and, with  
               respect to any deadline, deems that no time shall have  
               elapsed from July 1, 2007, to January 1, 2010.

             6)   Requires that the Student Tuition Recovery Fund  
               (STRF) be continued, provides for processing of any  
               STRF claims pending, and provides that a student's  
               right to recover from STRF be based on the law that  
               was in effect at the time the student enrolled in the  
               institution and paid a STRF fee.

             7)   Provides that any institution that had an  
               application for an approval to operate pending before  
               BPPVE on July 1, 2007, or that had no application  
               pending but that began operations on or after July 1,  
               2007, may continue to operate but must comply with the  
               Act and submit an application for approval to operate  
               within six months of the application becoming  
               available (unless BPPVE determines that the pending  
               application satisfies the new requirements), and to  
               notify enrolling students as specified.

             8)   Requires that any student claims based upon a  
               violation of the Prior Act remain pending, that  
               student complaints received during the time the Prior  
               Act was inoperative through December 31, 2009, be  
               recorded and investigated by the BPPE, and, with  
               respect to any deadlines, deems no time to have  
               elapsed during the time the Prior Act was inoperative.  


             9)   Provides that final judgments and/or legal remedies  
               available under the Prior Act be continued for any  
               claim or cause of action that arose prior to the  
               inoperative status or repeal of the Prior Act, except  
               for STRF claims.

           Exemptions
           




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             10)Exempts all postsecondary education entities that  
               were exempt from the 1998 Act and BPPVE oversight and  
               additionally exempts:

                  a)        Institutions that provide solely  
                    educational programs for total charges of $2500  
                    or less (subject to BPPVE adjustment based upon  
                    the California Consumer Price Index), with no  
                    part of the charges paid by state or federal  
                    student financial aid programs.  

                  b)        Institutions accredited by the Council of  
                    the Section of Legal Education and Admissions to  
                    the Bar of the American Bar Association, or a law  
                    school or law study programs subject to approval,  
                    regulation, and oversight of the Committee of Bar  
                    Examiners.

                  c)        A nonprofit public benefit corporation  
                    that qualifies under Section 501 (c) (3) of the  
                    United States Internal Revenue Code and is  
                    organized specifically to provide workforce  
                    development or rehabilitation services as well as  
                    accredited for those services by an accrediting  
                    organization recognized by the Department of  
                    Rehabilitation.

                  d)        Until January 1, 2015, institutions that  
                    are accredited by a Regional Accrediting Agency.

           Bureau Powers and Duties
           
             11)Requires the BPPE to adopt regulations necessary to  
               implement the Act by January 1, 2011, to develop and  
               implement an enforcement program and to develop a  
               program to proactively identify unlicensed  
               institutions and take all appropriate legal action.

             12)Requires BPPE to establish a website to be updated at  
               least annually, on or before June 30, 2010, that  
               includes, specified information.  

             13)Requires the BPPE to provide the information  
               specified in (12) to the California Postsecondary  
               Education Commission (CPEC) and requires the CPEC to  
               include the information in its internet web site  




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               directory of school performance data. 

             14)Requires BPPE to conduct outreach to secondary and  
               postsecondary school students about how to make  
               informed decisions when selecting an institution.

             15)Requires BPPE to appoint an advisory committee  
               comprised of institutional representatives, student  
               representatives, consumer advocates and employers who  
               hire students.

             16)Authorizes the BPPE to conduct workshops to assist  
               institutions in complying with the Act, and to empanel  
               visiting committees to assist in evaluating  
               institutional applications.

             17)Requires BPPE to make a summary of the nature and  
               disposition of complaints against an institution  
               within the last five years available to the public  
               upon request, for complaints that have reached final  
               disposition.

           Approval to Operate
           
             18)Requires that all private postsecondary institutions  
               operating in California have BPPE approval, except for  
               any institutions exempt from the Act, establishes a  
               process for BPPE to issue institutional  
               approvals/renewals to operate, and establishes the  
               term of these approvals to be for five years.  

             19)Requires that all institutions granted an approval to  
               operate by means of accreditation comply with all  
               other applicable requirements of the Act. 

           Substantive Changes to Approval to Operate
           
             20)Requires prior authorization from BPPE for  
               institutions wishing to make substantive changes, such  
               as a change in ownership or educational objectives,  
               and adoption of related regulations by January 1,  
               2011.  

             21)Provides that the institution's approval may be  
               suspended or revoked for failing to obtain BPPVE  
               authorization prior to a substantive change.  




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             22)Requires an institution granted approval to operate  
               by means of its accreditation to only make substantive  
               changes in accordance with accreditation standards and  
               to notify BPPE of the changes.

           Fair Business Practices  

             23)Prohibits institutions, among other things, from  
               using the state seal on a diploma, promising  
               employment, advertise using inaccurate or misleading  
               information, compensating or providing gifts to  
               students for recruitment activities, making untrue or  
               misleading statements, willfully falsifying or  
               destroying documents, improperly implying approval or  
               licensure or failing to completely disclose what  
               approval or licensure means, directing an individual  
               to violate the Act or persuading a student not to file  
               a complaint, compensating an employee by bonus or  
               commission for recruitment or student assistance  
               except as specified, and requiring prospective  
               students to provide personal contact information to  
               access program information via the institution's  
               internet website.

             24)Prohibits institutions from merging classes unless  
               students receive the same amount of instruction,  
               making unscheduled suspensions of classes unless  
               caused by circumstances beyond institutional control,  
               changing the day or time of the class unless certain  
               other requirements are met, moving the location of  
               classes more than 25 miles without meeting certain  
               requirements, or converting the means of delivery of  
               instruction.

             25)Requires that institutions offering educational  
               programs that require licensure by the state have  
               approval to conduct that educational program.

             26)Authorizes institutions offering courses with a term  
               of four months or less, to require payment of all  
               tuition and fees on the first day of instruction.  

             27)Prohibits an institution, for programs designed to be  
               four months or longer, from requiring more than one  
               term of advance payment at a time until 50% of  




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               coursework has been completed and provides exemptions  
               from these requirements for the purposes of federal  
               and state financial aid payments.

             28)Authorizes, under certain conditions, students to  
               choose to pay all fees and tuition upon enrollment.  

             29)Requires that institutions providing private  
               institutional loan funding to a student ensure that a  
               student is not obligated for indebtedness that exceeds  
               the total cost of the current period of attendance.

           Recordkeeping
           
             30)Requires an institution maintain specified  
               student/educational program records for at least five  
               years except for accredited institutions if required  
               to abide by similar recordkeeping requirements under  
               accreditation.

           Enrollment Agreements and Disclosures
           
             31)Provides that students enroll solely by signing an  
               enrollment agreement; and outlines the conditions that  
               must be met for it to be enforceable.

             32)Prohibits students from waiving any terms or receipts  
               of any disclosure.

             33)Requires an "ability to benefit student" (defined as  
               a student without a certificate of graduation from a  
               school providing secondary education) to take a U.S.  
               Department of Education (USDE) prescribed examination  
               and achieve a USDE specified score showing the student  
               may benefit from the training offered before executing  
               an enrollment agreement.  

             34)Requires institutions offering programs in  
               professions that require licensure to provide a  
               potential enrollee with a written copy of the  
               requirements for state licensure, prohibits execution  
               of an enrollment agreement with a student known to be  
               ineligible for licensure unless the student's stated  
               objective is other than licensure, and establishes  
               limitations and disclosure requirements if an  
               institution discusses internships or student job  




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               availability during the enrollment process.

             35)Requires an enrollment agreement to be written in  
               easily understood language, entitles a student to a  
               clear explanation of the agreement in his/her primary  
               language, as specified, and requires the agreement and  
               related disclosures be in the same language used in  
               recruitment.

             36)Prohibits an enrollment agreement from requiring a  
               student to invoke internal institutional dispute  
               procedures before enforcing any contractual or other  
               legal rights or remedies.

             37)Requires information or statements required to be  
               included in the catalog, School Performance Fact  
               Sheet, or enrollment agreement to be printed in at  
               least the same size font as the majority of the text  
               in that document.

             38)Requires an institution to provide a school catalog  
               to a student prior to enrollment that includes, at  
               minimum 15 specified categories of information and  
               disclosures 

             39)Requires an institution to provide a prospective  
               student a School Performance Fact Sheet containing  
               completion rates, placement rates, license examination  
               passage rates, if applicable, and starting salaries if  
               the school makes claims regarding starting salaries.

             40)Requires an enrollment agreement to include at  
               minimum, ten specified categories of information and  
               disclosures.

           Consumer Loans to Students
           
             41)Requires an institution extending credit or lending  
               money for educational costs to notify the student in  
               the lending documents of specified rights and  
               information, provides that such a lending note is not  
               enforceable unless the institution held an approval to  
               operate at the time of execution, and requires  
               institutional compliance with the Federal Truth in  
               Lending Act.





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           Cancellations/Withdrawals/Refunds
           
             42)Requires all institutions, whether they participate  
               in and comply with federal student aid program  
               regulations under Title IV of the Higher Education Act  
               of 1965 to establish a refund policy, to advise  
               students that cancellation notices must be in writing  
               and that a withdrawal may also be noticed by a student  
               not attending courses, to provide a pro rata refund of  
               nonfederal student financial aid program moneys to  
               students who completed 60% or less of the period of  
               attendance, and to refund 100% of the amount paid less  
               a reasonable deposit not to exceed $250 if notice of  
               cancellation is made through attendance at the first  
               class or the seventh class day after enrollment,  
               whichever is later.

             43)Authorizes BPPE to adopt, via regulation, an  
               alternate refund calculation method for instruction  
               delivered by means such as distance education, and  
               authorizes any institution for which the  
               aforementioned refund calculations cannot be utilized  
               to petition BPPE for alternative methods of  
               calculating tuition refunds.

             44)Prohibits a student from waiving any of these  
               provisions.

           Student Tuition Recovery Fund (STRF)
             
             45)Requires BPPE to adopt regulations governing the  
               administration and maintenance of STRF by January 1,  
               2011, continually appropriates STRF monies to the  
               BPPE, and prohibits the STRF from exceeding $25  
               million. 

           Closures
           
             46)Requires an institution to notify BPPE in writing at  
               least 30 days prior to closing, and requires the  
               notice to include a closure plan that addresses, among  
               other things, provision of teach-outs or arrangements  
               for refunds, a provision of information on federal  
               financial aid programs and institutional closures, if  
               applicable, and the disposition of student records.





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             47)Provides that an institution is in default of an  
               enrollment agreement if it closes prior to a student's  
               completion of the program and provides for the amount  
               of the refund to students, as specified.  

             48)Requires an institution to provide BPPE with  
               specified information including student records and  
               transcripts. 

             49)Require all institutions, including those otherwise  
               exempt, to provide student records, or a retention  
               plan for records and transcripts approved by the  
               institution's accrediting agency, to the BPPE prior to  
               closure.  

           Completion, Placement, Licensure, and Salary Disclosure
           
             50)Defines various terms and calculations used in this  
               section.

             51)Requires an institution to annually report to BPPE,  
               (as part of the annual report and the School  
               Performance Fact Sheet) completion rates for each  
               program, calculated as specified, and authorizes the  
               substitution of   graduation data as reported to and  
               calculated by the Integrated Postsecondary Education  
               Data System (IPEDS) of the United States Department of  
               Education; job placement rates, calculated as  
               specified; the total number of graduates employed in  
               the field and the percentage of those who earned  
               salaries at or above the claimed level, if the  
               institution or makes any express or implied claim  
               about the salary that may be earned after completing a  
               program.

             52)Requires the institution to document and maintain the  
               information used to substantiate job placement and  
               salary rates and to provide a list of employment  
               positions determined to be "within the field" for the  
               calculation of placement rates.

           Fees  

             53)Establishes a differentiated fee schedule for  
               applications to obtain approval to operate, to renew  
               approvals, and to process authorization of a  




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               substantive change to an approval.

             54)Authorizes the bureau to adjust the established fee  
               schedule, prohibits implementation of any increases  
               without legislative approval, and authorizes the  
               bureau to reduce fees if its annual costs for  
               providing oversight and review are less than the  
               established fees.

             55)Requires that all fees be used by the BPPE to cover  
               costs of administering the Act, that the fee schedule  
               provide adequate resources to implement the Act, that  
               specified late payment penalties be assessed against  
               institutions, and that the BPPE publish a publicly  
               available fee schedule. 

           Compliance, Enforcement, Process, and Penalties
           
             56)Establishes the BPPE authority to determine an  
               institution's compliance with the Act, to require  
               additional filing of reports, to send staff for  
               institutional site visits, to require documents and  
               responses from any institution in order to monitor  
               compliance, to make both announced and unannounced  
               inspections, to investigate institutions and to take  
               appropriate action.  

             57)Requires the BPPE impose penalties, including  
               mandating a specified timetable for remedying  
                                              noncompliance, imposing fines, placing the institution  
               on probation, or suspending or revoking approval, as  
               deemed appropriate by BPPE and depending on the  
               severity of the violation.

             58)Requires an institution to submit an annual report  
               that includes specified information to the BPPE.

             59)Requires BPPE staff to issue a notice to comply for  
               minor violations detected during inspection, to issue  
               a citation for noncompliance if such a finding is made  
               as the result of an investigation, and outlines the  
               processes to be followed by the institution and the  
               BPPE as a result.

             60)Authorizes BPPE to place an institution on probation,  
               or suspend/revoke its approval to operate upon a  




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               finding of fraud or repeated violations of the Act  
               that have caused harm to students.  

             61)Authorizes the BPPE to make an emergency decision to  
               protect students, prevent misrepresentation to the  
               public, or prevent the loss of public funds or monies  
               paid by students, as specified.

             62)Authorizes the BPPE to bring an action for equitable  
               relief for violations of the Act to supplement but not  
               supplant other legal remedies or penalties.

             63)Authorizes an institution to request a hearing  
               pursuant to existing law if an adverse administrative  
               action is taken by the BPPE.

             64)Authorizes individuals to file complaints with the  
               BPPE against an institution, requires the BPPE to take  
               action to ascertain facts and verify complaints and to  
               take appropriate administrative enforcement action,  
               and requires the BPPVE to order payment of appropriate  
               refunds/restitution to a student or group of students  
               if an institution caused them damage or loss through  
               violation of the Act. 

             65)Establishes that operation of an institution without  
               BPPE approval or provision of false information to  
               BPPE on an application as infractions and public  
               offenses.

             66)Requires an institution to maintain an agent for  
               service of process within the state and to provide  
               specified information to the BPPE which must make this  
               information publicly available upon request.

             67)Caps the fine for operating without BPPE approval at  
               $50,000.

             68)Deems any institution subject to the Act to have  
               authorized BPPE or its accrediting agency to provide  
               the Attorney General (AG), district attorney, or city  
               attorney copies of all institutional documents and  
               other materials.  

             69)Provides that nothing in the Act precludes the  
               enforcement of rights or remedies under any other law,  




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               or limits or precludes the AG, a district attorney, or  
               a city attorney from taking any other legally  
               authorized action. 

           Reporting
           
             70)Requires BPPE to provide annual progress updates to  
               the Legislature, as specified, in the form of  
               oversight hearings by appropriate policy and fiscal  
               committees. 

             71)Requires the Legislative Analyst's Office (LAO) to  
               conduct a comprehensive review of the BPPE, the  
               appropriateness of the exemptions provided in the Act,  
               and the extent to which BPPE has implemented the  
               provisions of the Act, and to report to the  
               Legislature and the Governor by October 1, 2013.

             72)Requires the LAO to report on the exemption of  
               institutions accredited by a regional accrediting  
               agency by January 1, 2013, and to recommend whether to  
               continue, remove or adjust the exemption.

           Termination
           
             73)Repeals the Act on January 1, 2016.

             74)Appropriates $580,000 from the Prior Act to BPPE to  
               fund five education administrator positions, to be  
               included in the annual budget for the BPPE.

           STAFF COMMENTS  

           1)   Double-referral  .  This bill was previously heard by  
               the Business, Professions and Economic Development  
               Committee (BP&ED) on July 6, 2009.  The author  
               accepted a committee amendment, to be adopted in this  
               committee, to incorporate an exemption for "good  
               schools" which meet specified criteria regarding  
               accreditation, length of operation, fiscal solvency,  
               default rates on student loans, refund policies,  
               cancellation rights and non-profit status.  Staff  
               notes that the "good schools" exemption existed under  
               the prior law. Staff recommends the bill be amended to  
               include the "good schools" exemption agreed to in  
               BP&ED.




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           2)   Author's amendments  . The author seeks to amend the  
               bill to make several technical and clarifying  
               corrections.  Staff recommends the attached list of  
               amendments be adopted.

               The author also proposes amending the bill to prohibit  
               an institution from offering or granting a  
               doctoral-level degree program unless it is accredited,  
               arguing that it cannot be ensured that these programs  
               adequately prepare students in their field of study.   
               Unlike programs granted approval to operate by virtue  
               of their accreditation, these programs would be  
               subject to review by the BPPE before they could  
               legally operate in California. Additionally, section  
               94899 of the bill requires that an institution  
               offering programs that require licensing be approved  
               by the appropriate state licensing agency to conduct  
               that program (in this case, the California Board of  
               Psychologists).  Given these two layers of review, it  
               is unclear why this amendment is necessary.   

          3)   Recent history  .  During 2002, the BPPVE completed its  
               first Sunset Review before the Joint Legislative  
               Sunset Review Committee (JLSRC).  In its 2003 report,  
               the JLSRC concluded that the statutes under which  
               BPPVE operated appeared complex, vague, and  
               contradictory, the time period for final approval was  
               often extremely long, and there was no clear rationale  
               for the varied exemptions and differing reporting  
               requirements among institutions.  

               After holding hearings to review the findings of the  
               JLSRC, the Legislature enacted SB 1544 (Figueroa,  
               Chapter 740, Statutes of 2004), which required the  
               Director of the Department of Consumer Affairs to  
               appoint an Operations and Administrative Monitor  
               (Monitor) to assess the BPPVE's administrative  
               operations and provisions of the Reform Act and to  
               report findings to the Legislature.  In December 2005  
               the Monitor submitted a report outlining the problems  
               identified and recommending changes.  In January 2006,  
               the Consumer Services Agency, the Department of  
               Consumer Affairs, and the staff of the Business  
               Professions and Economic Development Committee, began  
               meeting on a regular basis with the Monitor in an  




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               effort to develop and refine the law prior to its  
               sunset.  The list of ensuing legislation attempting to  
               implement a new regulatory structure or maintain  
               elements of the prior law include: 

                SB 489 (Liu)  generally stated legislative intent  
               regarding the regulation of private postsecondary  
               education.  The measure was set for hearing in the  
               Business and Professions Committee in April 2009 but  
               was not heard. 

                SB 823 (Perata  ) of 2008, which was vetoed by the  
               Governor, was similar to this bill and would have  
               re-established the Bureau with specified functions and  
               student protections.  

                AB 2746 (Niello  ) of 2008, which was held in the  
               Assembly Appropriations Committee, was similar to this  
               bill.  

                AB 1182 (Niello  ) of 2007, which was not heard in  
               committee, was similar to this bill.  

                AB 1525 (Cook, Chapter 67, Statutes of 2007)  , stated  
               legislative intent regarding the protection of  
               students, allowed for the continuation of matters  
               pending before BPPVE, and provided for minimal  
               oversight of institutions by DCA until February 1,  
               2008.  

                SB 45 (Perata), Chapter 635, Statutes of 2007)  ,  
               extended limited state oversight of private  
               postsecondary schools from February 1, 2008, to July  
               1, 2008.  

                AB 2810 (Liu)  of 2006 was vetoed by the Governor, but  
               would have extended the sunset date of the Prior Act  
               for one year and established a working group to  
               develop recommendations for changes in the Prior Act.   


                SB 1473 (Figueroa)  of 2006, which was held in the  
               Senate Appropriations Committee, would have revised  
               and recast the provisions of the Prior Act based on  
               the Monitor's recommendations.  





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           4)   What if we don't pass this bill  ?  The private  
               postsecondary education sector has been unregulated  
               since July 2008. The Committee may wish to consider  
               the following:

                       Institutions accredited by either a national  
                  or regional accrediting association may still  
                  participate in federal student aid programs under  
                  Title IV of the Higher Education Act, but currently  
                  do so with no requirement to comply with any state  
                  consumer protection provisions.  
                
                        While the Boards of Psychology and Behavioral  
                  Sciences have taken specific action to allow  
                  graduates of schools approved under state BPPVE law  
                  to sit for licensure exams for the next three  
                  years, new students will be unable to sit for  
                  licensing exams offered by those Boards, or state  
                  licensure exams offered by other boards and bureaus  
                  within the DCA in the absence of a state law.  

                       A March 23rd, informational hearing held by  
                  the BP&ED Committee entitled "The Role of Private  
                  Education Institutions in Preparing California's  
                  Diverse Workforce: Meeting the Challenges of our  
                  Workforce and Job Training Needs" found that: 

                  o         California will receive $488 million  
                    federal American Recovery Reinvestment Act (ARRA)  
                    funds to supplement, not supplant the state's  
                    workforce development activities. 

                  o         Key industries are facing shortages in  
                    hiring workers with the minimum skills needed for  
                    entry into the field.

                  o         Private postsecondary schools face  
                    difficulty in expanding their educational and  
                    vocational programs due to the lack of state  
                    regulation. 

                  o         Without access to private postsecondary  
                    institutions' performance data, the efficacy and  
                    role of these institutions in preparing skilled  
                    workers is unknown.





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           1)   Exemptions and accreditation  . The Prior Act and all  
               previous legislation dealing with BPPVE contained a  
               specific exemption for schools accredited by the  
               western regional accrediting agency (WASC).  According  
               to information from the BPPVE, about 30 of the  
               approximately 300 private degree-granting institutions  
               which they regulated are accredited by a regional body  
               other than WASC.  Challenges to this exemption arose  
               and in 2007, the US District Court in  Daghlian v.  
               DeVry  ruled that California's practice of solely  
               exempting WASC accredited schools from state oversight  
               by the BPPVE violated the Commerce Clause of the  
               federal Constitution.  While the case is still on  
               appeal, this bill was recently amended to exempt  
               institutions that are accredited by a regional  
               accrediting agency in response to an oral opinion from  
               Legislative Counsel that the exemption of one regional  
               accrediting agency (WASC) could be determined to be  
               discriminatory.  

           2)   Accreditation equals approval to operate  .  Some states  
               have implemented regulation of the private  
               postsecondary sector by authorizing certain  
               accrediting bodies to certify operations in the state.  
               Others provide a process by which the state itself  
               approves each institution.  The Prior Act required  
               state approval in order to legally operate in  
               California.  This bill grants approval to operate by  
               virtue of an institution's accreditation.  However,  
               with specified exemptions, the accredited institution  
               is still subject to regulation and oversight by the  
               BPPE.  Arguably, this process allows the BPPE to  
               facilitate the conduct of business by reputable  
               schools, and to focus its resources and efforts on  
               monitoring and taking appropriate enforcement action  
               against disreputable schools.

           3)   Reporting requirements  . This bill establishes a number  
               of reporting requirements in order to ensure that the  
               new Act is effectively and efficiently implemented and  
               enforced. While the LAO can provide an objective,  
               data-driven assessment of the exemption policy, LAO  
               does not have the resources and experience necessary  
               to conduct the comprehensive review called for in the  
               bill.  Staff recommends the bill be amended to  
               consolidate the provisions requiring the LAO to  




                                                                 AB 48
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               conduct two reports on exemptions into one report in a  
               single section of the bill.   Staff further recommends  
               the bill be amended to require the comprehensive  
               review be done by the Bureau of State Audits and to  
               insert the following:  "The bureau shall contract with  
               the Bureau of State Audits to conduct a performance  
               audit to evaluate the effectiveness and efficiency of  
               the bureau's operations consistent with the  
               requirements of this chapter.  The Bureau of State  
               Audits shall report the results of the audit to the  
               Legislature and the Governor on or before August 1,  
               2013. "  

           4)   Enhanced legislative oversight  .  Staff notes that  
               several bureaus within the DCA currently require  
               Senate confirmation of the appointed bureau chief,  
               including the Professional Fiduciaries Bureau, Bureau  
               of Automotive Repair, Bureau of Electronic and  
               Appliance Repair, and the prior Bureau for Private  
               Postsecondary and Vocational Education.  Regulation of  
               the private postsecondary sector has been accompanied  
               by concerns over the effectiveness of consumer  
               protections as well as a lack of efficiency and  
               clarity in the bureau's operation. In light of this  
               problematic history, it may be prudent to provide the  
               Legislature an opportunity to raise any questions or  
               concerns regarding the functioning of the bureau under  
               the new law.  Staff recommends the bill be amended on  
               page 22, line 33 to require Senate confirmation of the  
               bureau chief.  
           
          5)   Data  .  This bill directs the BPPE to provide data  
               collected from the institutions to the California  
               Postsecondary Education Commission (CPEC).   
               Information from the private postsecondary education  
               sector is critical to the evaluation of workforce and  
               financial aid policy decisions.  In order to  
               facilitate the usefulness of the information received  
               by the CPEC staff recommends the bill be amended on  
               page 24, line 9, to insert, "To the extent possible,  
               the bureau shall provide this information consistent  
               with that collected for IPEDS reporting, including  
               institutional characteristics, completions, annual  
               enrollments and graduation rates."  
           
          6)   Last legislative effort  .  SB 823 (Perata) of 2008  




                                                                 AB 48
                                                                Page 19



               which was somewhat similar to this bill, was passed by  
               the Legislature but ultimately vetoed by the Governor,  
               whose message read, in pertinent part:

                    I have repeatedly stated that a reform act  
                    must be written clearly, should not be subject  
                    to varied interpretations, should treat  
                    schools as uniformly as possible, and provide  
                    reasonable roles and responsibilities for the  
                    Bureau. Our collective objective should be to  
                    successfully strike a balance between  
                    protecting students, while being firm, yet  
                    fair to schools.  Unfortunately, this bill  
                    does not meet those goals.  Instead, this bill  
                    would create a statute that would be a  
                    challenge to successfully implement. If a  
                    statute is not clearly drafted, reasonably  
                    enforceable, or easily understandable to  
                    students, schools, and regulators, no one is  
                    well served??.I encourage the Legislature to  
                    pass a bill early in the next session that  
                    proposes a regulatory framework that can be  
                    successful.



           SUPPORT  

          American Massage Therapy Association - California Chapter
          Faculty Association of California Community Colleges  
          (FACCC)
          Goodwill Industries
          License Instruction Schools
          Valley Industry and Commerce Association
          Western Association of Schools & Colleges Accrediting  
          Commission (WASC)
          One individual

           OPPOSITION

           Civil Justice Association of California
          Consumer Federation of California
          Consumers Union
          Savannah College of Art and Design and Park University
          One individual





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                                 AB (48) Portantino
                         Technical and Clarifying Amendments
          
          1.   On page 22, lines 4-6, to change the sunset date for the  
               regional accrediting agency exemption from 2015 to 2016 to  
               conform with the sunset of the Act.

          2.   On Page 24, on line 21, after "students.", insert "The  
               advisory committee shall advise the bureau on the  
               administration, including annually reviewing the fee  
               schedule, licensing, and enforcement provisions under this  
               chapter."

          3.   On page 34, line 26, strike out "the student" and insert  
               "all students enrolling in such programs". On line 27,  
               before the period insert, ", including any applicable  
               coursework requirements established by the state. If the  
               requirements of the educational program exceed the minimum  
               requirements for state licensure, the institution shall  
               disclose this information, including a list of those  
               courses which are not required for state licensure"


          4.   On page 35 line 36, after "and" add "a description of the  
               instruction provided in each of the courses offered by the  
               institution,"

          5.   On page 37, line 37, after the period insert " In addition,  
               if the institution has a student brochure the institution  
               shall disclose the brochure to the student and to any  
               interested parties."

          6.   On page 37, line 29, after "transfer." Insert "If the  
               credits or degree you earn at this institution are not  
               accepted at the institution to which you seek to transfer,  
               you may be required to repeat some or all of your  
               coursework at that institution."

          7.   On page 38, line 26, delete "At least one" and insert  
               "All".  Delete lines 27-31 and insert:

                  1)  A description of how the figures described in  
                    subdivisions (a) to (d), inclusive, are calculated or  
                    a statement informing the reader of where he or she  
                    may obtain a description of how the figures described  
                    in subdivisions (a) to (d), inclusive, are calculated.
                  2)        A statement informing the reader of where he  
                    or she may obtain from the institution a list of the  
                    employment positions determined to be within the field  




                                                                 AB 48
                                                                Page 22

                    for which a student received education and training  
                    for the calculation of job placement rates as required  
                    by subdivision (b) is available to the student.
                  3)        A statement informing the reader of where he  
                    or she may obtain from the institution a list of the  
                    objective sources of information used to substantiate  
                    the salary disclosure as required by subdivision (d).

          8.   On Page 38, after line 34 insert: "(C) A student or any  
               member of the public may file a copliant about this  
               institution with the Bureau for Private Postsecondary  
               Education by call (toll free phone number) or by completing  
               a complaint form, which can be obtained on the Burea  
               website (web site address)."





          9.   On Page 40, after line 17 strike "statement" and insert  
               "statements".  On line 19 before "Any" insert "(1)".  After  
               line 24 insert "(2) A student or any member of the public  
               may file a copliant about this institution with the Bureau  
               for Private Postsecondary Education by call (toll free  
               phone number) or by completing a complaint form, which can  
               be obtained on the Burea website (web site address)."

          10.  On Page 39, line 21, strike out "BUYER'S" and insert  
               "STUDENT'S"

          11.  On page 40, after line 7 insert "(h) The transferability  
                          disclosure required in the school catalog and specified in  
               94909(a)(15)."

          12.  On Page 44, line 35, after "may" delete "include" and  
               insert "separately state" 

          13.  On Page 52, line 18, after (a) insert "The bureau shall  
               establish a toll free number staffed by a bureau employee  
               where a student or a member of the public may file a  
               complaint.  Additionally, the bureau shall make a complaint  
               form available on its website. (b)"

          14.  On page 53, after line 20, add "Section 94944.6 Within 30  
               days of receiving written notice from the bureau, the  
               Attorney General, any district attorney or city attorney,  
               or the Student Aid Commission, an accrediting agency shall  





                                                                 AB 48
                                                                Page 23

               provide the requesting official with all documents or other  
               material concerning an institution accredited by that  
               agency that are designated specifically or by category in  
               the written notice."