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To the Editor:

The argument made by some people in your March 2 article ("Tightening the 90/10 Rule") that closing the 90/10 rule is unfair because it is not a direct measure of quality and penalizes schools that enroll low income students is disingenuous.  The 90/10 rule, just like many other outcome based metrics is not intended to be a direct measure of quality, but serves as a necessary proxy for systemic taxpayer risk in the absence of a universally agreed upon measure.   Whether you are talking about loan repayment rates, graduation rates, job placement rates, or even licensure test pass rates, these are all proxies for quality, which are valid in their own right if used correctly and in tandem. 

Would those who say closing the 90/10 rule loophole is unfair also say that a holding a school accountable when less than a third of their students make any progress paying down their loan principal is unfair? This is a bit like saying we should have no speed limit on the highway because speeding is not a direct measure of an individual cars’ safety.

The question is not how many proprietary schools would close by closing this loophole, but how many with good outcomes would close.   I suspect we could probably count on one hand the number of proprietary colleges reliant 90 plus percent on federal dollars, that teach more than one subject, and are not located directly on a military base that actually have good outcomes in multiple areas.

--Ben Reppe
Assistant Director of Financial Aid
Kennesaw State University

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