BILL ANALYSIS                                                                                                                                                                                                    �







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        |Hearing Date:  April 28, 2014      |Bill No:SB                         |
        |                                   |1069                               |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                              Senator Ted W. Lieu, Chair
                                           

                         Bill No:        SB 1069Author:Torres
                         As Amended:March 26, 2014Fiscal: Yes

        
        SUBJECT:  Student Tuition Recovery Fund: claims. 
        
        SUMMARY:  Requires the Bureau for Private Postsecondary Education  
        (BPPE) to adopt regulations to make students who utilize a Cal Grant,  
        a Pell Grant, or both, eligible to apply for payment from the Student  
        Tuition Recovery Fund.

         NOTE:   This bill was heard by the Senate Committee on Education on  
        April 24, 2014 and passed 8-0.  In that Committee, the Author agreed  
        to take amendments which are reflected in this analysis.    
        
        Existing law:
        
        1) Authorizes the Cal Grant Program, administered by the California  
           Student Aid Commission (CSAC), to provide grants to financially  
           needy students to attend college.  The program consists of the Cal  
           Grant A, Cal Grant B, and Cal Grant C programs and eligibility is  
           based upon financial need, grade point average, California  
           residency, and other eligibility criteria, as specified.   
           (Education Code (EC) � 69430-69433.9)

        2) Provides for student protections and regulatory oversight of  
           private postsecondary schools in the state pursuant to the  
           California Private Postsecondary Education Act of 2009 (Act).  The  
           Act is enforced by the Bureau for Private Postsecondary Education  
           (Bureau) within the Department of Consumer Affairs.  (EC � 94800 et  
           seq.)  

        3) Requires BPPE to adopt regulations governing the administration and  
           maintenance of the Student Tuition Recovery Fund (STRF), including  





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           requirements relating to assessments on students and student  
           claims.  (EC � 94923)

        4) Limits the amount in the STRF to no more than twenty-five million  
           dollars ($25,000,000) at any time.  (EC � 94925)

        5) Provides that at least 30 days prior to closing, an institution  
           must notify BPPE in writing of its intention to close and provide a  
           closure plan which must include, but not necessarily be limited to,  
           all of the following:  (EC � 94926)

           a)   A plan for providing teach-outs of educational programs,  
             including any agreements with any other postsecondary educational  
             institutions to provide teach-outs.

           b)   If no teach-out plan is contemplated, or for students who do  
             not wish to participate in a teach-out, arrangements for making  
             refunds within 45 days from the date of closure; or for  
             institutions that participate in federal student financial aid  
             programs, arrangements for making refunds and returning federal  
             student financial aid program funds.

           c)   If the institution is a participant in federal student  
             financial aid programs, it shall provide students information  
             concerning these programs and institutional closures.

           d)   A plan for the disposition of student records.

        This bill:  Provides that a student who utilizes a Cal Grant, Pell  
        Grant, or both to pay tuition at a qualifying institution is eligible  
        to apply for payment from the Student Tuition Recovery Fund.


        FISCAL EFFECT:  Unknown.  This bill is keyed "fiscal" by Legislative  
        Counsel.

        
        COMMENTS:
        
        1. Purpose.  This bill is sponsored by the  Author  .  According to the  
           Author, this bill is in response to the abrupt January 24, 2014  
           closure of Career Colleges of America (CCA).  According to the  
           Author, about 800 students were enrolled at campuses in San  
           Bernardino, South Gate, and mid-city Los Angeles and the school was  
           unable to negotiate a teach-out plan prior to closure.  According  
           to the Author, with no plan in place, the credits the students  





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           earned were not transferred to other schools and students who had  
           spent years attending CCA, paying upwards of $37,000 for their  
           programs, were now forced to start over. 

           The Author is particularly concerned that current regulations  
           outlining eligibility for reimbursement under the BPPE administered  
           Student Tuition Recovery Fund (STRF) does not allow students to  
           seek relief for institutional costs paid by thirds parties like  
           Pell and Cal Grants.  According to the Author, "CCA students are  
           low-income and received federal Pell Grants. Both Pell and Cal  
           Grants have lifetime use limits of 6 and 4 years respectively.  As  
           a result of the school's closure these students have not only lost  
           time, but they have lost debt-free funding opportunities that could  
           be used for future educational needs."  The Author believes that  
           STRF funds should be available to students, like those impacted by  
           the CCA closure, as a means of mitigating Pell and Cal Grant losses  
           by setting funds aside for students' subsequent enrollment in other  
           institutions.

        2. Background.  The Bureau of Private Postsecondary Education (BPPE)  
           is responsible for oversight of private postsecondary educational  
           institutions operating with a physical presence in California.   
           Established by Assembly Bill 48 (Portantino, Chapter 310, Statutes  
           of 2009), after numerous legislative attempts to remedy the laws  
           and structure governing regulation of private postsecondary  
           institutions, the bill took effect January 1, 2010, to make many  
           substantive changes that created a new, solid foundation for  
           oversight and gave the new BPPE an array of enforcement tools to  
           ensure schools comply with the law.  

           One important tool to assist students is the Student Tuition  
           Recovery Fund (STRF).  The STRF is designed to relieve or mitigate  
           losses suffered by students who attend approved institutions, such  
           as when institutions close, fail to pay or reimburse loan proceeds  
           under a federally guaranteed student loan program, or fail to pay  
           judgments against them.  School closures have a significant impact  
           on the lives of, and educational opportunities for students  
           enrolled at the time of a closure.  While some schools close simply  
           because the cost of doing business is to high compared with their  
           ability to earn a profit, others close suddenly and abruptly,  
           leaving students in the lurch, many of whom have paid high up-front  
           tuition costs and all of whom believed that they were investing in  
           training that would eventually lead to greater job and economic  
           opportunities.  The Bureau plays a role in assisting students  
           subject to a school closure and can also force a school to close if  
           it is violating the Act to such a significant degree that consumers  





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           are harmed by continued enrollment.

           To fund STRF, institutions are required to charge students fifty  
           cents ($.50) per one thousand dollars ($1,000) of institutional  
           charges, rounded to the nearest thousand dollars which the  
           institution then submits to BPPE as payment into the fund.  The Act  
           leaves the bulk of STRF rules and administration to the regulatory  
           process via regulations promulgated by the Bureau, but clearly  
           states that the balance of the STRF may not be in excess of $25  
           million at any time.  Students seeking reimbursement from STRF must  
           submit a claim and supporting documents to BPPE at which point  
           Bureau staff review the claim application to determine whether  
           adequate supporting materials were provided, among other items, and  
           determine whether to approve or deny the claim.  Approved STRF  
           claims result in payment from the STRF to the student.  BPPE is  
           currently authorized in its regulations to negotiate with a lender,  
           holder, guarantee agency, or USDE for the full compromise or  
           write-off of student loan obligations to relieve students of  
           economic loss and, if possible, to reduce the liability of the STRF  
           for the payment of claims.  The Bureau is also authorized to pay a  
           student's claim directly to the lender, holder, guarantee agency or  
           USDE.  

           Current law authorizes the Cal Grant Program, administered by the  
           California Student Aid Commission, to provide grants to financially  
           needy students to attend college.  The program consists of the Cal  
           Grant A, Cal Grant B, and Cal Grant C programs and eligibility is  
           based upon financial need, grade point average, California  
           residency, and other eligibility criteria, as specified.  BPPE's  
           current STRF regulations do not specifically address options for  
           tuition repayment for a student who used a portion of their Cal  
           Grant eligibility at a now ineligible institution.  While an  
           institution like CCA, which lost its accreditation and was no  
           longer eligible to accept Cal Grant monies, would also not be  
           eligible to receive future Cal Grant payments, no mechanism  
           currently exists for the student or the State, to recoup the award  
           payments previously paid to the institution. 

           At its December 2013 Advisory Committee meeting, regulations were  
           considered to define "third-party payers" as a person, business or  
           agency who pays any portion of an institutional charge on behalf of  
           a student.  The proposal further would provide that for a student  
           whose total or partial charges are paid by a third-party payer who  
           suffers a loss of an educational opportunity, the portion paid by  
           the third party payer up to the amount of the economic losses may  
           be paid to a subsequent institution upon evidence that a student is  





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           enrolled in a different institution.  These regulations are  
           currently being reviewed and prepared for public comment.  While  
           the regulations appear to begin to address the issue this bill  
           intends to address, the proposed regulations make no provision for  
           how, or to whom the funds would be paid.     

           Currently, STRF has a large balance and over one year ago met the  
           statutory cap of $25 million established in the Act.  BPPE recently  
           proposed regulations to significantly decrease the amount of money  
           paid into the fund, as well as completely stop collecting STRF for  
           a period of four years to avoid being in violation of the Act and  
           the established maximum for the fund.  There is some concern that  
           prohibiting the collection of STRF as a means of avoiding conflict  
           with the law does not take the same consumer oriented approach as  
           enhancing efforts to properly utilize the funds in a timely manner  
           or determining whether there are other appropriate uses for the  
           fund.  A recent background paper for the April BPPE Sunset Review  
           Hearing found that there are currently very narrow options for the  
           use of STRF when an institution closes that could be expanded  
           beyond tuition repayment, for example, to assist in the repayment  
           of student loans for students who have been subject to a school  
           closure.  Committee staff noted that STRF could also be used to  
           repay student loans for students attending institutions found to be  
           in violation of the Act; for example, if the school is cited for  
           failing to provide required disclosures, or for providing false or  
           misleading information on the School Performance Fact Sheet.

        3. Related Legislation This Session.   SB 1247  (Lieu) of 2014 extends  
           until January 1, 2019 the term of the California Private  
           Postsecondary Education Act of 2009, which provides for the  
           regulation of private postsecondary educational institutions by the  
           Bureau for Private Postsecondary Education in the Department of  
           Consumer Affairs.  The bill also extends the term of the Student  
           Tuition Recovery Fund under the administration of the Bureau, and  
           subjects the Bureau to review by the appropriate policy committees  
           of the Legislature.  (  Status  : This bill will also be heard before  
           the BP&ED Committee during today's hearing.)

            AB 330  (Chau) of 2013 would require postsecondary educational  
           institutions to provide their net price calculators and average  
           student debt per graduate to the California Student Aid Commission  
           (CSAC) as a condition of eligibility for the Cal Grant Program,  
           requires CSAC to provide this information on its website in a  
           searchable database, and requires a for-profit institution to  
           include this information in its School Performance Fact Sheet.   
           (  Status:   This bill is pending in the Senate Committee on  





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           Education.) 

            AB 534  (Wieckowski) of 2013 would have required public and private  
           postsecondary educational institutions to provide entrance and exit  
           counseling, as specified, for students enrolled at their  
           institutions regarding student loans offered by the institution or  
           a private lender, and prohibits a lender from accepting an  
           application for a private student loan without first receiving  
           certification that the counseling was conducted by the appropriate  
           postsecondary institution, which may charge a fee to the lender for  
           this service.  
           (  Status:   This bill was held in the Assembly Committee on  
           Appropriations.)

        4. Prior Related Legislation.   AB 48  (Portantino, Chapter 310,  
           Statutes of 2009) established the Private Postsecondary Act of  
           2009. 

        5. Arguments in Support.   Legal Aid Foundation of Los Angeles  (LAFLA)  
           supports this bill, writing that it will help to ensure that  
           students impacted by sudden for-profit school closures will have  
           future educational opportunities to pursue their dreams.  LAFLA  
           believes that this is an important bill and has been involved with  
           helping students affected by the CCA closure.  According to LAFLA,  
           most of the students would like to continue their education  
           elsewhere and believes that this bill "is crucial to ensuring that  
           students harmed by school closures have a full opportunity to  
           pursue a higher education at a different college."

        6. Author's Amendments.  The Author agreed to take amendments in  
           response to issues raised by staff in the Senate Committee on  
           Education.  Staff noted that in its current form, "it is unclear  
           who would receive the funds if a Cal Grant recipient successfully  
           claimed reimbursement from the STRF.  Would a student receive the  
           funds directly?  As the funds were initially paid by the state, and  
           not the student, would such action be considered a gift of public  
           funds?  Would the BPPE retain the funds on a student's behalf and  
           pay them directly to an alternate institution of the student's  
           choice?  Only institutions that meet specified criteria, as  
           determined by the CSAC, are eligible to participate in the Cal  
           Grant program.  Should an agency other than the CSAC be authorized  
           to re-distribute Cal Grant funds? "  

           The Author has agreed to take amendments to also require the  
           payment of a student's claim directly to the California Student Aid  
           Commission, if the STRF claimant's educational costs were paid with  





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           a Cal Grant. 
        

        SUPPORT AND OPPOSITION:
        
         Support:   

        Legal Aid Foundation of Los Angeles 

         Opposition:  

        None on file as of April 23, 2014.



        Consultant:Sarah Mason