Yesterday after the close, the Department of Education (DOE) delivered a draft of the Negotiated Rulemaking (NegReg) regulations that align with a negative scenario:

1) Tying Title IV eligibility to a “gainful employment” metrics including cost of program , loan debt, and income after graduation. (apparantly to be applied to vocational programs only)

2) Getting rid of all 12 incentive compensation safe harbors . 

ED’s proposals for gainful employment standard will determine the appropriate levels of debt allowable for each vocational program/degree offering and thus may effectively result in tuition caps 

Eliminating all 12 safe harbors could restrict a school’s ability to utilize 3rd party call centers for qualification & hot transfer and potentially diminish internet generated starts, thus stalling enrollment growth. 

Still much speculation and uncertainty…