BILL ANALYSIS                                                                                                                                                                                                    �






                         SENATE COMMITTEE ON EDUCATION
                                Carol Liu, Chair
                           2013-2014 Regular Session
                                        

          BILL NO:       SB 1247
          AUTHOR:        Lieu
          INTRODUCED:    February 20, 2014
          FISCAL COMM:   Yes            HEARING DATE:  April 30, 2014
          URGENCY:       No             CONSULTANT:Kathleen Chavira

           SUBJECT  :  California Private Postsecondary Education Act.
          
           SUMMARY  

          This bill extends the California Private Postsecondary  
          Education Act of 2009, which governors the regulation of  
          private postsecondary educational institutions and the  
          operation of the Bureau for Private Postsecondary Education  
          (BPPE), until January 1, 2019.

           BACKGROUND  

          Current law, until January 1, 2015, establishes the  
          California Private Postsecondary Education Act (Act) of  
          2009, which provides for the approval, regulation, and  
          enforcement of private postsecondary educational  
          institutions by the Bureau for Private Postsecondary  
          Education (BPPE) within the Department of Consumer Affairs  
          (DCA).  (Education Code � 94800-94950) 

           ANALYSIS
           
           This bill  extends the California Private Postsecondary  
          Education Act (Act) of 2009 (currently set to expire on  
          January 1, 2015) until January 1, 2019. 

           STAFF COMMENTS  

           1)   Need for the bill  . According to the author, this bill  
               is necessary to extend the sunset date of the BPPE in  
               order to ensure continued oversight of private  
               postsecondary institutions that supports quality,  
               innovative programs which are approved in a timely  
               manner, while also making sure a robust government  
               structure prevents predatory practices and promotes  




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               student success.  The author plans to substantially  
               amend this bill to incorporate changes as outlined in  
               the Business, Professions and Economic Development  
               Committee (BPED Committee) background paper for the  
               recent BPPE Sunset Hearing.    

           2)   History  . The state's program for regulation of private  
               postsecondary and vocational education institutions  
               has historically been plagued by problems. During the  
               late 1980's, the state developed a reputation as the  
               "diploma mill capital of the world."  During this  
               period, the State Department of Education regulated  
               the private postsecondary education industry.  SB 190  
               (Morgan) created the Private Postsecondary and  
               Vocational Education Reform Act of 1989 (Reform Act)  
               to overhaul the state's regulatory program and  
               transferred oversight responsibility for the program  
               to the 20-member Private Postsecondary and Vocational  
               Council (Council).  Concurrently, the Maxine Waters  
               School Reform and Student Protection Act (Waters Act)  
               was enacted.  The provisions of the Reform Act and the  
               Waters Act were merged, but doing so created a  
               fragmented structural framework for regulation of  
               private postsecondary and vocational education  
               institutions with numerous duplicative and conflicting  
               statutory provisions.  In the years following  
               enactment of the Reform Act, concerns were expressed  
               about the Council's implementation of the Act.  In  
               1997, AB 71 (Wright) was enacted to create the former  
               Bureau for Private Postsecondary and Vocational  
               Education (BPPVE) within the Department of Consumer  
               Affairs (DCA), transferred responsibility for  
               administration of the Reform Act to the BPPVE and  
               extended the Reform Act's sunset date to January 1,  
               2005.  

               In 2004, the Joint Committee on Boards, Commissions  
               and Consumer Protection held a special hearing  
               regarding BPPVE and recommended that the Reform Act be  
               revised to make it intelligible and enforceable and  
               that the Administration and the DCA should consider  
               restoring, at least temporarily, the BPPVE 's staffing  
               resources to clear out existing backlogs.  The  
               Legislature enacted SB 1544 (Figueroa, Chapter 740,  
               Statutes of 2004), which required the appointment of  
               an Enforcement Monitor (Monitor) to provide an  




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               in-depth and impartial examination of the BPPVE's  
               operations.  The Monitor's report, presented to the  
               Joint Committee on December 7, 2005, outlined a  
               "twenty-year record of repeatedly identified,  
               fundamental problems in every one of the BPPVE 's key  
               operations."  The Report found that the BPPVE both  
               inadequately protected consumers and impeded the  
               expansion of quality postsecondary and vocational  
               educational opportunities.  The law and BPPVE were  
               allowed to Sunset on January 1, 2008.  

               After numerous legislative attempts to remedy the laws  
               and structure governing regulation of private  
               postsecondary institutions, Assembly Bill 48  
               (Portantino, Chapter 310, Statutes of 2009) was  
               enacted to establish the California Private  
               Postsecondary Education Act (Act) of 2009, which took  
               effect January 1, 2010.  The Act establishes the  
               current regulatory structure for oversight of private  
               postsecondary educational institutions operating with  
               a physical presence in California.  

               The Act requires all unaccredited colleges in  
               California to be approved by the Bureau for Private  
               Postsecondary Education (BPPE), and all nationally  
               accredited colleges to comply with numerous student  
               protections.  It also establishes prohibitions on  
               false advertising and inappropriate recruiting.  The  
               Act requires disclosure of critical information to  
               students such as program outlines, graduation and job  
               placement rates, and license examination information,  
               and ensures colleges justify those figures.  The Act  
               also guarantees students can complete their  
               educational objectives if their institution closes its  
               doors while providing BPPE with enforcement powers  
               necessary to protect consumers.  

           3)   The sector  .  According to the BPPE, as of June 30,  
               2013, it had approved 1,960 institutional locations  
               throughout California, including 1107 main campus  
               locations, 340 branch locations, and 513 satellite  
               locations. Based upon self-reported data from 2011  
               annual reports, these institutions serve a combined  
               total of almost 316,000 students, with the vast  
               majority (over 255,000) enrolled in diploma and/or  
               certificate programs.  The range of offerings includes  




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               programs in cosmetology, vocational nursing, truck  
               driving and computer training.  In 2011, three percent  
               of students were enrolled in bachelor' programs and a  
               combined three percent were enrolled in graduate level  
               degree programs. According to the information reported  
               to the BPPE, 324 of these institutions participated in  
               federal Title IV financial aid programs, 318  
               participated in federal veteran's financial aid  
               programs, and 66 participated in California aid  
               programs.

           4)   Report results . Among other things, the Act included  
               two reporting requirements. The recommendations from  
               each of these reports appear to be somewhat  
               inconsistent. 

                a)        Legislative Analyst Report (LAO)  . The LAO  
                    was required to report to the Legislature and the  
                    Governor on the appropriateness of the exemptions  
                    provided in this chapter, with particular  
                    attention to the exemptions provided by Article 4  
                    (commencing with Section 94874) that are based on  
                    accreditation. In its December 2013 report,  
                     Oversight of Private Colleges in California  , the  
                    LAO recommended that the BPPE consumer protection  
                    activity focus on the highest risk institutions  
                    and that regionally accredited colleges continue  
                    to be exempt from vast majority of Bureau  
                    oversight, and that nationally accredited  
                    institutions undergo reduced period inspection  
                    for low-risk colleges. The LAO also recommended  
                    that the Legislature require online colleges to  
                    be state-approved and provide statutory authority  
                    for the BPPE to grant reciprocal approval to  
                    institutions licensed in other states. 

                b)        Bureau of State Audits Report (BSA)  . The  
                    overriding finding of the BSA was that the BPPE  
                    has consistently failed to meet its  
                    responsibility to protect the public's interests,  
                    as summarized below:

                    i)             The BPPE has not met its statutory  
                         responsibility to regulate and oversee  
                         private postsecondary educational  
                         institutions.




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                    ii)            As of June 30, 2013, it had more  
                         than 1,100 licensing applications  
                         outstanding, some for more than three years.
                    iii)           During fiscal years 2009-10  
                         through 2012-13, it took an average of 185  
                         days to process 3,200 licensing applications  
                         that it had received and closed.

                    iv)            It failed to identify proactively  
                         and sanction effectively unlicensed  
                         institutions.

                    v)             It conducted only a fraction of  
                         the inspections of institutions required by  
                         law and failed to identify violations during  
                         these inspections.

                    vi)            The BPPE has not protected  
                         students' interests as state law requires.

                    vii)           It failed to respond appropriately  
                         to complaints against institutions, even  
                         when students' safety was allegedly at risk.

                    viii)          It did not ensure that  
                         institutions provided students with accurate  
                         disclosures about their operations.

                    ix)            It can improve its management of  
                         the Student Tuition Recovery Fund (STRF).

           5)   Joint Oversight Hearing  . On April 21 2014, the BPED  
               Committee convened a joint hearing that included the  
               relevant committees in both houses (Senate Education,  
               Assembly Committees on Higher Education and Business,  
               Professions and Consumer Protection).  The background  
               paper for the hearing identified 26 different issues  
               for consideration at the hearing, including  
               administrative, budget, licensing and exemption,  
               enforcement, and accountability issues.  
               Recommendations for consideration relevant to this  
               committee's purview include the following:

               a)        Grant the BPPE additional spending authority  
                    to improve operations, ability to hire  




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                    appropriate staff, conduct trainings, purchase an  
                    enhanced data tracking system, and other tools  
                    necessary to meet its consumer protection  
                    mandate.

               b)        Require institutions that offer a degree to  
                    be accredited in order to obtain approval to  
                    operate.

               c)        Examine reciprocity agreements for distance  
                    learning regulation and establish standards to  
                    require that basic protections be in place prior  
                    to entering into any agreement.

               d)        Maintain a single system for regulation,  
                    maintain the ability of an exempt institution to  
                    voluntarily come under jurisdiction, and further  
                    examine those efforts and consider potential  
                    challenge prior to any further relaxing of  
                    regulation.

               e)        Require an update on efforts related to  
                    third-party payers and the STRF.

               f)        Authorize the use of Integrated  
                    Postsecondary Education Data System (IPEDS) for  
                    reporting, and require a memorandum of  
                    understanding (MOU) with the Employment  
                    Development Department to gain access to wage  
                    data.

               g)        Authorize a law school to satisfy  
                    Performance Fact Sheet disclosure requirements  
                    with alternate reporting requirements.

               h)        Reconstitute the BPPE as an independent  
                    board comprised of specified stakeholders.
           
            6)   Related legislation  .

                a)        SB 1069 (Torres)  requires the BPPE to adopt  
                    regulations to make students who utilize a Cal  
                    Grant, a Pell Grant, or both, eligible to apply  
                    for payment from the STRF.  SB 1069 was heard and  
                    passed by this committee on consent on April 24,  
                    2014, with an understanding that amendments would  




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                    be adopted to ensure that payment of a STRF claim  
                    for a student who was a Cal Grant recipient was  
                    paid to the California Student Aid Commission.     
                       SB 1069 is currently awaiting action in the  
                    Assembly Appropriations Committee. 

                b)        AB 330 (Chau)  requires 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.  AB 330 is awaiting  
                    action in the in this committee. 

                c)        AB 634 (Gomez)  requires the BPPE to clarify  
                    the definition of "avocational education" through  
                    regulations.  AB 634 is awaiting action in the  
                    Senate Business Professions and Economic  
                    Development Committee.

                d)        AB 834 (Williams)  authorizes a law school  
                    accredited by the American Bar Association, and  
                    owned by an institution operating under BPPE to  
                    satisfy the current disclosure requirements of  
                    the School Performance Fact Sheet by complying  
                    with ABA disclosure requirements, reporting to  
                    the National Association for Law Placement, and  
                    making completion, Bar passage, placement, and  
                    salary and wage data available to prospective  
                    students prior to enrollment through the  
                    application process administered by the Law  
                    School Admission Council.  AB 834 is also on the  
                    committee's agenda today. 

           7)   Prior Legislation  .  

                a)        AB 2296 (Block, Chapter 585, Statutes of  
                    2012)  expanded the disclosure requirements for  
                    institutions under the Bureau related to  
                    unaccredited programs; expanded disclosure  
                    requirements for all regulated institutions,  
                    established more stringent criteria for  




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                    determining gainful employment and calculating  
                    job placement rates and increased institutional  
                    documentation and reporting requirements around  
                    completion rates, job placement/license exam  
                    passage rates, and salary/wage information for  
                    graduates.

                b)        SB 498 (Liu, 2011)  would have abolished the  
                    Bureau and transferred the Bureau's powers and  
                    duties under the Act to the California  
                    Postsecondary Education Commission.  SB 498 was  
                    held by the Senate Committee on Business,  
                    Professions and Economic Development.)
                
                 c)        SB 619 (Fuller, Chapter 309, Statutes of  
                    2011)  exempted 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.
                
                 d)        SB 675 (Wright, 2011  ) would have required  
                    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.  SB 675  
                    failed passage in the Senate Committee on  
                    Business, Professions and Economic Development by  
                    a vote of 3-3.
                
                 e)        AB 611 (Gordon, Chapter 103, Statutes of  
                    2011)  set forth certain disclosure requirements  
                    pertaining to accreditation status, licensure,  
                    and related limitations for unaccredited doctoral  
                    programs.
                
                 f)        AB 773 (Block, 2011)  would have allowed the  
                    Bureau to revoke an exemption of an institution  
                    which was exempt based on accreditation but still  
                    required to comply with the Student Tuition  
                    Recovery Fund requirements, if it determined that  
                    the institution had not in fact complied with  
                    those requirements.  AB 773 was referred to the  
                    Assembly Higher Education Committee but the  
                    hearing was cancelled at the request of the  




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                    author.   

               g)        AB 797 (Conway, 2011)  would have exempted  
                    schools of cosmetology, as defined, from the Act.  
                     AB 797 was held in Assembly Committee on Higher  
                    Education.
                
                 h)        AB 1013 (Assembly Committee on Higher  
                    Education, Chapter 167, Statutes of 2011  ) made  
                    clarifying changes to the Act and related Bureau  
                    oversight.

           SUPPORT  

          None received.

           OPPOSITION

           None received.