BILL ANALYSIS                                                                                                                                                                                                    �







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        |Hearing Date:June 6, 2011          |Bill No:AB                         |
        |                                   |611                                |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                          Senator Curren D. Price, Jr., Chair
                                           

                          Bill No:        AB 611Author:Gordon
                     As Amended:March 22, 2011          Fiscal:Yes

        
        SUBJECT:  Private postsecondary education:  unaccredited doctoral 
        degree program. 
        
        SUMMARY:  Sets forth certain disclosure requirements pertaining to 
        accreditation status, licensure, and related limitations for 
        unaccredited doctoral programs.

        Existing law:
        
        1)Establishes the Bureau of Private Postsecondary Education (Bureau) 
          within the Department of Consumer Affairs (DCA) and provides for 
          Bureau oversight and regulation of California private postsecondary 
          institutions under the California Private Postsecondary Education 
          Act of 2009 (Act).  (Business and Professions Code(BPC) � 101 and 
          Education Code (EC) � 94820)

        2)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 





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          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.  (EC � 94897)

        3)Provides that for career fields that require licensure by the state, 
          institutions offering educational programs must have approval to 
          conduct that educational program.  (EC � 94899)

        4)Requires institutions offering programs in professions that require 
          licensure to, during enrollment, exercise reasonable care to 
          determine if a student will be eligible to obtain licensure by 
          providing the student with a written copy of the requirements for 
          licensure established by this state.  Prohibits the institution from 
          executing an enrollment agreement with a student that is known to be 
          ineligible for licensure unless the student's stated objective is 
          other than licensure; and allows an institution to discuss 
          internships or student job availability during the enrollment 
          process with certain limitations and disclosure requirements.  (EC � 
          94905)
        This bill:

        1)Prohibits an institution from offering an unaccredited doctoral 
          degree program without disclosing to prospective students prior to 
          enrollment that the degree program is unaccredited, whether the 
          degree issued is in a field that requires licensure in California, 
          and any known limitation of the degree, including, but not limited 
          to, whether the degree is recognized for licensure or certification 
          in California and other states.

        FISCAL EFFECT:  According to the Assembly Committee on Appropriations 
        analysis dated May 4, 2011, this bill will result in minor absorbable 
        enforcement-related costs to the Bureau.

        COMMENTS:
        
        1. Purpose.  The  Author  is the Sponsor of this bill.  According to the 
           Author, ensuring unaccredited doctoral degree programs disclose 
           certain information, including any known limitations of the 
           unaccredited degree and whether the degree is recognized for 
           licensure or certification in other states will further protect 
           consumers who decide to participate in these programs.  Currently, 
           unaccredited doctoral programs are not required to disclose their 
           accreditation status and related limitations in California or in 
           other states.  The Author believes that this bill will improve 
           access to information for potential consumers before they make 





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           investments in their education.  

           The Author also cites recent reports and hearings on the abuses and 
           pitfalls in the for-profit postsecondary education industry as 
           rationale for a need for greater transparency.  According to 
           information provided by the Author, from 1998 to 2008, enrollment 
           in for-profit schools jumped 236%, far outpacing growth in public 
           and nonprofit private schools which grew by around 20%.  On 
           average, only 22% of students at for-profit schools will earn 
           degrees from those institutions within six years, compared to 55% 
           and 65% at public and private nonprofit colleges and universities, 
           respectively.  The Author also notes that a quarter of borrowers 
           who attended for-profit colleges and entered repayment on their 
           loans in 2008 defaulted within three years; a higher rate than any 
           other sector in postsecondary education and states that with more 
           information, potential students can make fully informed decisions 
           concerning their education before entering into costly loan 
           agreements for programs that may not be recognized in the field of 
           intended employment.  

        2. Background.  After numerous legislative attempts to remedy the laws 
           and structure governing regulation of private postsecondary 
           institutions, AB 48 (Portantino, Chapter 310, Statutes of 2009), 
           established the Act and created the Bureau within DCA for the 
           purpose of regulating private postsecondary educational 
           institutions that provide educational services in California.  The 
           Act made many substantive changes that both created a new, solid 
           foundation for oversight and responded to the major problems with 
           the Former Act.  The Act as created by AB 48 requires all 
           unaccredited colleges in California to be approved by the new 
           Bureau, and all nationally accredited colleges to comply with 
           numerous student protections.  It is important to note that not all 
           private institutions are covered by the provisions of the Act; full 
           and partial exemptions are provided for low-cost programs, 
           recreational schools, schools accredited by regional accrediting 
           agencies, among other types of institutions.  For those 
           institutions that are covered by the Act, they are required to 
           follow a Bureau evaluation and approval process, required to abide 
           by numerous "fair business practices" aimed at protecting students, 
           required to disclose information to students in enrollment 
           agreements and catalogs, required to participate in a Student 
           Tuition Recovery Fund (STRF), and required to pay application and 
           annual fees to the Bureau to support the oversight structure.  The 
           Act also establishes processes for penalties for non-compliance, 
           providing the Bureau authority to perform site visits and 
           investigations, order fines and student tuition refunds, and 





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           ultimately suspend or revoke an institution's approval to operate.  
           Finally, the Act requires evaluation and reporting from the 
           Legislative Analyst's Office (LAO) and the Bureau of State Audits 
           (BSA).
             
        3. Concerns Regarding Private Postsecondary Institutions.  Media 
           outlets, efforts at the Federal level and increased scrutiny by 
           state legislatures have recently highlighted unease about the 
           operations and functions of private postsecondary schools.  While 
           the sector serves upwards of ten percent of postsecondary students 
           and provides a path to higher education that may not always be 
           available for all students, there are increased questions about 
           these institutions and their accurate representation of what they 
           are able to offer students.  There are also concerns that schools 
           provide training at a steep cost that does not balance the earnable 
           income an individual may be eligible for based on that training or 
           upon completion of a program. 

           Last fall, the U.S. Department of Education (DOE) adopted new rules 
           to rein in the recruiting practices of for-profit colleges by 
           changing standards for students to use federal Title IV money at 
           these institutions.  The effort gained momentum following a report 
           by the U.S. Government Accountability Office (GAO) that found 
           potential deception by schools to students about graduation and job 
           placement rates in the process of getting them to enroll and sign 
           up for state and federal loans.  Using undercover testing, GAO 
           found some schools encouraging students to falsify their financial 
           aid applications in order to qualify for federal grants.  Other 
           schools misrepresented their programs' graduation rates, 
           job-placement rates and costs while recruiting students.

           According to the National Conference of State Legislatures (NCSL), 
           17 states are considering legislation to further regulate these 
           institutions.  In California, for-profit schools now face 
           restriction on the ability to receive state monies in the form of 
           Cal Grants, which provide over $20 million more annually to the 
           schools than to community colleges.  Just recently, Maryland's 
           House and Senate enacted measures that would eliminate all state 
           aid to for-profit schools, ban commissions or bonuses for student 
           recruiting, and make all for-profit schools in the state contribute 
           to a fund to protect students if any college in their group 
           breaches a contract. 

           Recent budgetary and capacity issues in California's public 
           postsecondary schools, coupled with the current economic crisis 
           have led to growth in enrollment at private postsecondary schools, 





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           as employees are increasingly out of work and more inclined to 
           enter training programs in the hopes of obtaining gainful 
           employment, at a cost they may not be able to make up once they are 
           employed.  This Committee, at its March 2009 hearing entitled "The 
           Role of Private Education Institutions in Preparing California's 
           Diverse Workforce:  Meeting the Challenges of our Workforce and Job 
           Training Needs" examined the ability of private postsecondary 
           institutions to fill the career preparation needs of California's 
           workforce and evaluated policy options that allow them to expand 
           their workforce development programs with the requisite amount of 
           oversight required to protect students.  The private postsecondary 
           school sector has responded to additional regulation and oversight 
           proposals by noting that career colleges are an essential part of 
           the solution for restoring this country's global educational and 
           economic standing, citing the role these schools play in helping 
           lower unemployment, boost global competitiveness, fill jobs in key 
           industries, and increase the number of college graduates by 2020.  
           According to federal data, more than 2.2 million students enrolled 
           in a private for-profit institution in the fall of 2009, almost 25 
           percent more than the previous year. 
             
        4. Accreditation.  Accreditation is a voluntary, non-governmental peer 
           review process utilized for the purpose of determining academic 
           quality of higher education institutions and programs.  Under 
           federal law, DOE is required to publish a list of recognized 
           accrediting agencies deemed reliable authorities on the quality of 
           education or training provided by their accredited institutions.  
           Only those institutions accredited by a DOE-recognized accrediting 
           organization are eligible to participate in the federal student 
           financial assistance programs.  Unaccredited degrees can limit a 
           student's career options.  Some career fields and employers require 
           degrees from accredited colleges; this is especially true in 
           professions like education and health care, where certification or 
           licensure is a pre-requisite for employment.  While California 
           licensure requirements in the health care field vary, physicians, 
           dentists, clinical social workers, optometrists, and chiropractors 
           must obtain their required degrees from accredited institutions or 
           institutions approved by their respective licensing boards.  

        5. Similar and Related Legislation.  This bill contains the same 
           technical, clarifying provisions as  AB 1889  (Portantino, 2010).  In 
           addition, AB 1889 contained provisions regarding doctoral degrees 
           offered by unaccredited institutions, the calculation of placement 
           rates, and Bureau employment requirements.  AB 1889 was vetoed by 
           Governor Schwarzenegger due to concerns over Bureau employment 
           requirements.





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            AB 1013  (Assembly Committee on Higher Education) of 2011 makes 
           clarifying changes to the Act and related Bureau oversight.  This 
           bill is set for hearing in this Committee on June 6, 2011.

            SB 498  (Liu) of 2011 abolishes the Bureau and transfers the 
           Bureau's powers and duties under the Act to the California 
           Postsecondary Education Commission.  The bill is a two-year bill 
           pending hearing in this Committee.

            SB 619  (Fuller) of 2011 exempts flight instructors or flight 
           schools that do not require the upfront payment of tuition or fees, 
           and that do not require students to enter into a contract of 
           indebtedness in order to receive training, from Bureau regulation.  
           The bill is pending in the Assembly.

            SB 675  (Wright) of 2011 requires that private postsecondary 
           institutions subject to the Act administer a test of English 
           language proficiency to a nonnative speaker of English, as defined, 
           prior to enrolling the student.  The bill failed passage in this 
           Committee.

            AB 797  (Conway) of 2011 exempts schools of cosmetology, as defined, 
           from the Act.  The bill has not been set for hearing in the 
           Assembly Committee on Higher Education.

            AB 2393  (Ammiano, 2010) altered the definition of "graduates 
           employed in the field" for apprenticeship and nursing programs.  
           The bill was vetoed by the Governor.
           
        6. Arguments in Support.  According to the  California Psychological 
           Association  (CPA), this bill is "a step in the right direction to 
           re-affirm current law ensuring that students who attend approved 
           schools will know the limitations of their degrees once they enter 
           the workplace." CPA also believes that graduates from 
           non-accredited institutions with state approval have faced problems 
           in obtaining full employment and that these individuals were never 
           aware of any barriers to practice.
           
           The  California Physical Therapy Association  (CPTA) writes in 
           support of this bill, noting that this bill is necessary to protect 
           prospective students from enrolling in a doctoral degree program 
           they believe is accredited when in fact it is not.

        NOTE:  Double-referral to Education Committee (second).
        





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        SUPPORT AND OPPOSITION:
        
         Support:  

        California Psychological Association (CPA)
        California Physical Therapy Association (CPTA)

         Opposition:  

        None on file as of May 31, 2011


        Consultant:Sarah Mason