BILL ANALYSIS
AB 48
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CONCURRENCE IN SENATE AMENDMENTS
AB 48 (Portantino and Niello)
As Amended September 4, 2009
Majority vote
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|ASSEMBLY: |70-4 |(June 2, 2009) |SENATE: | |(September 11, |
| | | | | |2009) |
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(vote not available)
Original Committee Reference: HIGHER ED.
SUMMARY : Renames the Bureau for Private Postsecondary and
Vocational Education (Former Bureau) as the Bureau for Private
Postsecondary Education (Bureau) within the Department of
Consumer Affairs (DCA) and provides for Bureau oversight and
regulation of private postsecondary institutions operating in
California. Specifically, this bill :
1)Requires the Bureau to disclose on its internet website
information on suspensions and revocations of an institution's
approval to operate, as well as any enforcement action,
including the issuance of a notice to comply, taken against an
institution by the Bureau.
2)Authorizes the Bureau to take specified action to cease
unlawful advertising including disconnecting the telephone
services of an institution if the Bureau finds that the
institution is advertising in a telephone directory without an
approval to operate issued by the Bureau.
3)Removes the Former Bureau from provisions of law requiring
ongoing review by the Joint Committee on Boards, Commissions,
and Consumer Protection.
4)Establishes the California Private Postsecondary Education Act
of 2009 (Act) and provides that any statutory or regulatory
reference to the Private Postsecondary and Vocational
Education Reform Act (Former Act) or Former Bureau shall be
construed as referring to the Act and Bureau.
5)Makes various findings and declarations regarding the
importance of private postsecondary institutions, previous
failures to regulate these institutions, the importance of
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Bureau oversight of private postsecondary institutions, and
the need for ongoing review of Bureau activities by the
Legislature.
6)Provides for a transition to the provisions of the Act,
including:
a) Any institution approved to operate by the Former Bureau
on June 30, 2007, shall maintain that approval for three
years after the expiration date of the approval;
b) An institution that had an application to renew an
approval to operate pending before the Former Bureau prior
to January 1, 2006, shall be granted approval until 2012,
and an institution that submitted an application to renew
an approval to operate after January 1, 2006, shall be
granted approval to operate until 2013; students enrolling
in these institutions are required to be notified in
writing by the institution that the institution's renewal
application was not reviewed by the Bureau;
c) Provides that the Bureau may determine that the
application for approval to operate that was pending with
the Former Bureau satisfies the requirements of the new
application for an approval to operate;
d) The Bureau shall adopt emergency regulations that
conform to the provisions of the Act, including repealing
provisions no longer relevant, by February 1, 2010, and
these regulations shall become permanent through the
regular rulemaking process within one year of the date of
enactment of the Act;
e) The Bureau shall have possession and control of all
records, supplies, and real property used by the Former
Bureau;
f) The Private Postsecondary and Vocational Education
Administration Fund be continued and renamed to the Private
Postsecondary Education Administration Fund (PPEAF);
g) The Student Tuition Recovery Fund (STRF) be continued
and provides that processing of claims pending before STRF
that were received prior to July 1, 2007, or any claims
received between July 1, 2007, and December 31, 2009.
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Provides that a student's right to recover from STRF shall
be based on the law that was in effect at the time the
student enrolled in the institution and paid a STRF fee;
h) An institution that had an application for an approval
to operate pending before the Former Bureau on July 1,
2007, and an institution that did not have a pending
application filed with the Former Bureau on June 30, 2007,
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; students enrolling in
these institutions must be notified in writing by the
institution during the enrollment process that the
institution's application for approval to operate was not
reviewed by the Bureau; and these institutions shall not
use the terms "approval," "approved," "approval to
operate," or "approved to operate" without clearly stating
that the application for approval to operate has not yet
been reviewed by the Bureau;
i) Any matter, except a STRF claim, submitted to the Former
Bureau prior to July 1, 2007, shall remain pending, and
with respect to deadlines, no time shall be deemed elapsed
from July 1, 2007 through January 1, 2010. Provides that
student complaints received from July 1, 2007 through
December 31, 2008, shall continue to be duly recorded and
investigated by the Bureau; and,
j) For any claim or cause of action that arose prior to
June 30, 2007, notwithstanding the inoperative status or
repeal of the Former Act, final judgments and/or legal
remedies available under the Former Act will be continued.
7)Provides that the Bureau shall adopt a process whereby an
institution exempt under this article may request and obtain
verification of their exempt status and allows the Bureau to
charge a fee to the institution to cover any costs associated
with the Bureau verifying the exemption. Exempts from the
requirements of the Act and from the oversight of the Bureau:
a) Institutions offering solely vocational or recreational
educational programs;
b) Institutions offering programs sponsored by trade,
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business, professional, or fraternal organizations solely
for that organization's members;
c) Institutions operated by the federal or state government
or their subdivisions;
d) Institutions offering test preparation for examinations
required for admission to postsecondary institutions and
continuing education or license and examination preparation
where the institution or program is certified or sponsored
by a government agency licensing persons in a particular
field, a state-recognized professional licensing body, or a
trade, business, or professional organization;
e) Institutions owned, controlled, and operated and
maintained by a non-profit religious organization that meet
several other outlined requirements;
f) Institutions that provide solely educational programs
for total charges of $2500 or less, and do not offer
degrees, with no part of the charges paid by state or
federal student financial aid programs. Allows the Bureau
to adjust this cost threshold based upon the California
Consumer Price Index;
g) Law schools that are 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
program that is subject to the approval, regulation, and
oversight of the Committee of Bar Examiners;
h) Nonprofit public benefit corporations that are organized
specifically to provide workforce development or
rehabilitation services and accredited by an accrediting
organization for workforce development or rehabilitation
services recognized by the Department of Rehabilitation;
i) Nonprofit institutions that have been accredited for at
least 10 years, that have operated in the state for at
least 25 years continuously, and that meet several other
outlined conditions;
j) Institutions accredited by the Accrediting Commission
for Senior Colleges and Universities or the Accrediting
Commission for Community and Junior Colleges and
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Universities of the Western Association of Schools and
Colleges (WASC); and,
aa) Until January 1, 2016, all other institutions that are
accredited by a non-WASC Regional Accrediting Agency,
except that these institutions are required to participate
in the STRF.
8)Provides the Bureau with powers and duties, including:
a) Provides the Director of DCA (Director) with the powers
set forth in the Act; allows the Director to delegate the
duties to a bureau chief, appointed by the Governor,
subject to Senate Confirmation, and exempt from the State
Civil Service Act; provides that the bureau chief may
delegate any powers and duties to a designee; and provides
that the Director may, in accordance with the State Civil
Service Act, appoint and fix compensation of personnel;
b) Requires the Bureau to, in accordance with the
Administrative Procedures Act, adopt regulations by January
1, 2010 necessary to implement the Act in accordance with
existing law; requires the Bureau to develop and implement
an enforcement program to implement the Act, including a
plan for investigating complaints filed with the Bureau;
and requires the Bureau to develop a program to proactively
identify unlicensed institutions, identify material or
repeated violations of this chapter and regulations, and
take all appropriate legal action;
c) Requires the Bureau to maintain a Web site, to be kept
current, with information provided by the institutions and
establishes that the website shall include a searchable
directory of all approved institutions, the status of the
institution's approval to operate, the information provided
by the institution in the annual report and the Student
Performance Fact Sheet, and specified information regarding
pending and finalized disciplinary actions taken against
the institution, and an explanation of the Bureau's
transition plan and scope of authority;
d) Requires the Bureau to provide all of the aforementioned
information to the California Postsecondary Education
Commission;
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e) Requires the Bureau to conduct outreach to secondary and
postsecondary school students about how to make informed
decisions when selecting an institution and allows the
Bureau to conduct workshops to assist institutions in
complying with the provisions of the Act;
f) Establishes a 12-member advisory committee to be
comprised of consumer advocates, past or current students
of institutions, representatives of institutions,
employers, and public members. Provides for appointments
to the advisory committee from the Senate Committee on
Rules, Speaker of the Assembly, and Director. Requires the
Bureau to actively seek input from, and consult with, the
advisory committee regarding the development of regulations
to implement this chapter; and,
g) Allows the Bureau to empanel visiting committees to
assist in evaluating institutional applications, requires
visiting committee members to serve at no expense to the
state, establishes that the Bureau may facilitate
reimbursements from an institution under evaluation to
cover travel and per diem, and entitles visiting committee
members to defense and indemnification.
9)Provides that, except for any institutions exempt from the
Act, all private postsecondary institutions operating in
California must have the approval of the Bureau and requires
the Bureau, by January 1, 2011, to establish minimum operating
standards for institutions. Establishes that approvals to
operate shall be for five-year terms. Establishes a process
for the Bureau to issue institutional approvals to operate,
and to renew approvals to operate.
10)Requires prior authorization from the Bureau for institutions
wishing to make substantive changes, such as a change in
ownership or educational objectives, among other outlined
changes. Provides that the institution's approval may be
suspended or revoked for failing to obtain prior approval.
Requires the Bureau to adopt regulations by January 1, 2011,
establishing a process for reviewing requests for
authorization to make substantive changes. Provides that an
institution granted approval to operate by means of its
accreditation shall make substantive changes in accordance
with accreditation standards and shall notify the Bureau of
the changes.
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11)Establishes fair business practices, which:
a) Prohibits institutions from: using the seal of the
state on a diploma, promising employment or otherwise
overstating the availability of jobs in the local economy
upon graduation, presenting or advertising specified
information including inaccurate information, failing to
include distance education information in advertisements,
inaccurately advertising approval or accreditation status,
using "help wanted" ads to solicit students, 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 before being granted access to
educational program information via the institution's
internet website, among other outlined prohibited
practices;
b) Prohibits institutions from merging classes unless
students receive the same amount of instruction; prohibits
institutions from, after a student has enrolled, making
unscheduled suspensions of classes unless caused by
circumstances beyond institutional control; and prohibits,
during the period of attendance, changing the day or time
of the class unless certain other requirements are met;
prohibits institutions from moving the location of classes
more than 25 miles without meeting certain requirements;
and prohibits converting the means of delivery of
instruction;
c) Provides that, for career fields that require licensure
by the state, institutions offering educational programs
must have approval to conduct that educational program;
and,
d) Allows institutions, when offering courses with a term
of four months or less, to require payment of all tuition
and fees on the first day of instruction; prohibits an
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institution from requiring more than one term (up to four
months) of advance payment at a time until 50% of
coursework has been completed; provides exemptions from the
aforementioned requirements for the purposes of federal and
state financial aid payments; and allows, under certain
conditions, students to choose to pay all fees and tuition
upon enrollment. Requires that institutions providing
private loan funding ensure that a student is not obligated
for indebtedness that exceeds the total cost of the current
term of enrollment.
12)Requires an institution to maintain specified student and
educational program records for not less than five years.
Provides that the recordkeeping requirements do not apply to
accredited institutions so long as the institution is required
to abide by similar recordkeeping requirements under the
accreditation.
13)Establishes various requirements for enrollment agreements,
and catalogs Student Performance Fact Sheet disclosures to
students, which:
a) Provides that students enroll solely by signing an
enrollment agreement; and outlines the conditions that must
be met for it to be enforceable;
b) Prohibits students from waiving any terms or receipts of
any disclosure;
c) Requires an "ability to benefit student" (defined as a
student without a certificate of graduation from a school
providing secondary education) to take a United States
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;
d) 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;
e) 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;
f) Prohibits an enrollment agreement from requiring a
student to invoke internal institutional dispute procedures
before enforcing any contractual or other legal rights or
remedies;
g) 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;
h) 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;
i) 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 salary and wage information, if the
school makes any express or implied claims related to
preparing students for a particular career, occupation,
vocation, trade, job or job title; and,
j) Requires an enrollment agreement to include at minimum,
10 specified categories of information and disclosures.
14)Requires an institution extending credit or lending money for
educational costs to a student, to place a notice in the
lending documents informing the student that they may assert
against the holder of the promissory note all of the claims
and defense that could be asserted against the institution up
to the amount already paid under the promissory note; provides
that such a lending note is not enforceable unless the
institution held an approval to operate at the time of
execution; and provides that institutional loans to students
must comply with the Federal Truth in Lending Act.
15)Establishes specified requirements for student cancellations,
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withdrawals, and refunds.
16)Provides that the Bureau shall adopt regulations governing
the administration and maintenance of STRF, including
requirements related to assessments on students and student
claims against STRF; provides that STRF monies are continually
appropriated to the Bureau; and provides that STRF may not
exceed $25 million at any time. Provides that DCA may
disperse claims after the sunset of the Bureau until all
claims or paid or until the fund becomes insolvent.
17)Establishes specified requirements for institutional closures
and teach-outs.
18)Requires each institution to annually report to the Bureau
and to annually publish specific data, such as completion
rates and job placement rates, in its School Performance Fact
Sheet.
19)Establishes a specified fee schedule and provides that all
fees collected are to be, upon appropriation by the
Legislature, used for Bureau expenditure to cover the cost of
administering the Act. Provides that the Bureau may change
fee amounts under specified circumstances. Provides for late
payment penalties to be assessed against institutions failing
to submit fee payments within the Bureau-specified timeline.
20)Establishes processes and penalties in regards to compliance
with and enforcement of the Act, including:
a) Establishes that the Bureau shall determine any
institution's compliance with the Act, and that the Bureau
shall have the authority to require additional reports be
filed by an institution, to send staff for institutional
site visits, and to require documents and responses from
any institution in order to monitor compliance. Provides
that when the Bureau has reason to believe that an
institution is out of compliance, it shall conduct an
investigation of that institution, and if the Bureau finds
the institution has violated any applicable law or
regulation, requires the Bureau to take appropriate action;
b) Provides that, as part of its compliance program, the
Bureau shall perform announced and unannounced inspections
of institutions at least every two years. Provides that on
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or before January 1, 2011, the Bureau shall adopt
regulations setting forth policies and practices to ensure
that institutions are subject to an equal number of
announced and unannounced inspections for each two-year
period. The regulations shall also set forth policies and
practices for providing notice to students enrolled at an
institution of the results of each inspection of the
institution;
c) Provides that the Bureau shall 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 the Bureau and depending on the severity of
the violation;
d) Requires an institution to submit an annual report by
July 1 to the Bureau, in a format prescribed by the Bureau,
that includes: the total number of students enrolled,
degrees awarded, degrees offered, educational program
completion rates, and the total charges for each
educational program, including a statement indicating
whether the institution is current in remitting STRF
assessments, along with any other information deemed
necessary by the Bureau;
e) Requires Bureau staff who detect a minor violation of
the Act during inspection, to issue a notice to comply
before leaving the institution; establishes a process for
the issuance of a notice to comply, and requires the Bureau
to take administrative enforcement action against an
institution that fails to correct the issues raised in a
notice to comply within 30 days;
f) Requires, as a consequence of an investigation and upon
a finding that the institution has committed a violation,
the Bureau to issue a citation for noncompliance of the Act
or regulations found during an investigation, and provides
that the citation may contain an order of abatement that
may require the demonstration of future compliance, and/or
an administrative fine not to exceed $10,000 per violation.
Provides specific criteria for the Bureau to consider when
assessing the amount of administrative fines. Provides
that the citation shall be in writing and shall contain
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specified information regarding the violation and the
institution's right to a hearing within 30 days. Provides
that an administrative fine is due either 30 days from
citation or 30 days from the final judgment following a
hearing. Provides that all administrative fines are to be
deposited into PPEAF;
g) Allows the Bureau to place an institution on probation
or suspend or revoke an institution's approval to operate
for fraud or for material or repeated violations of the Act
that have caused harm to students. Defines "material
violation" to include, but not be limited to,
misrepresentation, fraud in the inducement of a contract,
and false or misleading claims or advertising, upon which a
student reasonably relied in executing an enrollment
agreement and that resulted in harm to the student.
Provides that the Bureau shall adopt regulations governing
probation and suspension of an approval to operate and that
the Bureau may seek reimbursement from an institution, but
provides that an institution shall not be responsible for
paying the cost of an investigation to more than one
agency;
h) Provides that if the Bureau determines the need 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, it may do so
pursuant to an outlined process and in accordance with
Bureau-adopted regulations;
i) Provides that the Bureau may bring an action for
equitable relief for violations of the Act, including
restitution, a temporary restraining order, the appointment
of a receiver, and a preliminary or permanent injunction,
and that the action may be brought in the county in which
the defendant resides or in the county in which any
violation has occurred or may occur; and provides that
these remedies supplement and do not supplant any other
remedies and penalties provided under law;
j) Provides any individual who believes an institution has
violated the Act or subsequent regulations may file a
complaint with the Bureau and that the Bureau shall take
action to verify the complaint, and provides the Bureau
with authority to take appropriate administrative
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enforcement action upon discovering the facts in regards to
the complaint;
aa) Provides that if the Bureau finds that an institution's
violation of the Act or subsequent regulations has caused
damage or loss to a student or group of students, the
Bureau may order the institution to pay appropriate refunds
or restitution to that student or group of students;
bb) Requires the Bureau to establish a toll-free telephone
number staffed by a Bureau employee by which a student or
member of the public may file a complaint under the Act.
Provides that the Bureau shall make a complaint form
available on its Internet Web site and that the Bureau
shall permit members of the public to file a complaint
under the Act through the Bureau's Internet Web site;
cc) Establishes that knowingly operating an institution
without approval or knowingly providing false information
to the Bureau shall be considered infractions and are
public offenses;
dd) Requires an institution to maintain an agent for service
of process within the state and provide the agent's name
and contact information to the Bureau; makes the
aforementioned information available to the public upon
request;
ee) Provides that the Bureau may not subject any person to a
fine exceeding $50,000 for operating an institution without
Bureau approval;
ff) Provides that each institution subject to the Act shall
be deemed to have authorized the Bureau or accrediting
agency to provide the Attorney General (AG), district
attorney, or city attorney copies of all documents and
other materials concerning the institution. Requires an
accrediting agency to provide such materials free of charge
within 30 days of receiving written notice to share
documents; and,
gg) Provides that nothing in the Act shall preclude the
enforcement of rights or remedies under any other
applicable statute, or limit or preclude the AG, a district
attorney, or a city attorney from taking any action
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otherwise authorized under any other applicable statute or
law.
21)Provides for severability of the Act, in that, if any
provisions in this Act are held as invalid, that invalidity
shall not affect other provisions, so long as those provisions
do not require the invalid provisions in order to be applied.
22)Requires the Legislative Analyst's Office, by October 1,
2013, report to the Legislature and the Governor on the
appropriateness of the exemptions provided by the bill.
23)Requires the Bureau to contract with the Bureau of State
Audits (BSA), by August 1, 2013, to conduct a performance
audit to evaluate the effectiveness and efficiency of the
Bureau operations. The BSA is required to report the results
of the audit to the Legislature and the Governor.
Appropriates $270,000 from the PPEAF to the BSA for the costs
of the audit.
24)Repeals the Act on January 1, 2016, unless a later statute is
enacted to extend this date.
25)Appropriates $580,000 from the Former Act to the Bureau for
the purpose of funding five education administrator positions,
and provides that these positions shall be included in the
annual budget for the Bureau.
The Senate amendments add findings and declarations; expand the
number of institutions that are exempt from Bureau oversight;
make the Bureau Chief subject to Senate confirmation; expand the
information that is to be reported on the Bureau's Web site;
strengthen the role of the advisory committee and provide for
Legislative appointments to the advisory committee; establish
specified institutional fee amounts in the fee schedule; expand
Bureau enforcement authority; increase the number of disclosures
that institutions are required to provide to students; and other
technical and non-technical clarifying changes.
EXISTING LAW relating to the regulation of private postsecondary
education is inoperative. Recently inoperative statute
expressed the intent of the Legislature to provide for the
protection and interests of students and institutions that have
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matters pending under the Former Act, which became inoperative
on July 1, 2007; provided for the continuation of all matters
pending before the Former Bureau on July 1, 2007, until July 1,
2008; and allowed, until July 1, 2008, limited state oversight
of private postsecondary schools by the DCA. The statutes
became inoperative on July 1, 2008.
AS PASSED BY THE ASSEMBLY, this bill was substantially similar
to the version passed by the Senate.
FISCAL EFFECT : According to the Senate Appropriations
Committee:
Fiscal Impact (in thousands)
Major Provisions 2009-10 2010-11
2011-12 Fund
Bureau operations $5,385 $8,411 $8,411
Special*
- Fee revenue** ($5,038) ($10,076)
($10,076)
Appropriation $580
Special*
Reporting requirements
$220-$270 Special*
* PPEAF
** The Bureau shall establish a reasonable fee to reimburse the
bureau's costs associated with implementation of the act. Costs
and revenues based on DCA projections.
COMMENTS : Purpose of this bill : According to information from
DCA, there are approximately 1,500 private postsecondary
institutions that had been approved by the Former Bureau to
operate in California. This includes approximately 1,200
vocational training schools and 300 branch satellites, as well
as, approximately 300 degree-granting institutions with an
estimated student enrollment of approximately 400,000. The
Former Bureau also registered approximately 700 private
institutions providing short-term career/seminar training,
continuing education, intensive English language programs, and
license exam preparation courses. The author intends for this
bill to establish the Bureau's authority to regulate private
postsecondary institutions and enforce the provisions of the
Act.
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Overview of previous private postsecondary regulatory attempts :
During the late 1980s, when regulation of the private
postsecondary education industry was carried out by a division
within the State Department of Education, the state developed a
reputation as the "diploma mill capital of the world." As a
result of concerns over the integrity and value of the degrees
issued by these institutions, the Former Act was enacted to
overhaul the state's regulatory program, transferring oversight
responsibility for the program to a 20-member Council.
Concurrently, the Maxine Waters School Reform and Student
Protection Act (Waters Act) was enacted. The regulatory
framework established by the merging of the Waters Act and the
Former Act led to duplicative and conflicting statutory
provisions, plaguing California's oversight of these
institutions with problems that continued through the sunset of
the law on January 1, 2007.
In 2004, in response to the persistent problems with the Former
Bureau, the Legislature enacted SB 1544 (Figueroa), Chapter 740,
Statutes of 2004, which required the appointment of an
Enforcement Monitor (Monitor) to provide an in-depth and
impartial examination of the Former Bureau's operations. The
Monitor's report, presented to the Joint Committee on Boards,
Commissions and Consumer Protection on December 7, 2005,
outlined a "twenty-year record of repeatedly identified,
fundamental problems in every one of the Bureau's key
operations." The report found that the Former Bureau both
inadequately protected consumers and impeded the expansion of
quality postsecondary and vocational educational opportunities.
The concerns and recommendations raised by the Monitor were
generally consistent with concerns raised by the California
Postsecondary Education Commission in 1995, an independent
report from Price Waterhouse in 1997, a BSA report in 2000, and
the DCA's own internal investigation in 2002. The Former
Bureau, by the time of its sunset, had not addressed many of its
fundamental problems with oversight and enforcement; however, as
the Monitor's report identifies, many of the root causes of
enforcement and oversight failures can be traced back to
deficiencies within the Former Act.
Analysis Prepared by : Laura Metune / HIGHER ED. / (916)
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319-3960
FN: 0003073