Higher Education: Including Public, Nonprofit, and For-Profit
Institutions in a Single Definition Is Unlikely to Immediately
Affect Federal Spending, but Long-term Effects Are Unclear
(31-JUL-07, GAO-07-857).
The Higher Education Act (HEA) defines "institution of higher
education" to include public, nonprofit, and for-profit
institutions, allowing students at these institutions access to
$83.1 billion in aid. However, the act also includes a second,
narrower definition of institution of higher education
specifically excluding for-profits from access to nearly $1.96
billion in other funding. During the 109th Congress, legislation
proposed consolidating the two definitions. In response to a
congressional request, this report examines the extent to which a
single definition might affect federal spending, other aspects of
applicable federal programs, as well as state-level programs and
policies. To address these objectives, GAO searched the U.S. Code
to identify federal statutes and programs potentially affected by
a change in definition, conducted in-depth reviews of programs
and policies, and interviewed relevant officials.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-857
ACCNO: A73752
TITLE: Higher Education: Including Public, Nonprofit, and
For-Profit Institutions in a Single Definition Is Unlikely to
Immediately Affect Federal Spending, but Long-term Effects Are
Unclear
DATE: 07/31/2007
SUBJECT: Education
Entitlements
Federal funds
Federal grants
Federal regulations
Higher education
Nonprofit organizations
Program evaluation
Public schools
Requirements definition
Student financial aid
Students
Policies and procedures
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GAO-07-857
* [1]Results in Brief
* [2]Background
* [3]A Single Definition Is Unlikely to Immediately Increase Fede
* [4]Numerous Federal Statutes Reference the Federal Definition T
* [5]A Single Definition Would Not Likely Increase Federal Spendi
* [6]A Change to a Single Definition of an Institution of Higher
* [7]States We Reviewed Rely Mainly on Several Institutional Char
* [8]Officials and Representatives We Interviewed Predict Little
* [9]Increased Competition for Federal Grant Program Funds and
In
* [10]Increased Political Influence of For-Profit Institutions
* [11]Concluding Observations
* [12]Agency Comments
* [13]Search of U.S. Code
* [14]Review of Statutory References
* [15]In-depth Reviews of States
* [16]GAO Contacts
* [17]Staff Acknowledgments
* [18]GAO's Mission
* [19]Obtaining Copies of GAO Reports and Testimony
* [20]Order by Mail or Phone
* [21]To Report Fraud, Waste, and Abuse in Federal Programs
* [22]Congressional Relations
* [23]Public Affairs
Report to Congressional Requesters
United States Government Accountability Office
GAO
July 2007
HIGHER EDUCATION
Including Public, Nonprofit, and For-Profit Institutions in a Single
Definition Is Unlikely to Immediately Affect Federal Spending, but
Long-term Effects Are Unclear
GAO-07-857
Contents
Letter 1
Results in Brief 3
Background 5
A Single Definition Is Unlikely to Immediately Increase Federal Spending,
but May Expand For-Profits' Ability to Compete for Funding and to
Participate in Other Aspects of Certain Programs 6
A Change to a Single Definition of an Institution of Higher Education Is
Unlikely to Immediately Affect State Programs, but Could in the Future 12
Concluding Observations 16
Agency Comments 16
Appendix I Objectives, Scope, and Methodology 18
Search of U.S. Code 18
Review of Statutory References 20
In-depth Reviews of States 20
Appendix II U.S. Code References to Institution of Higher Education 22
Appendix III Comments from the Department of Education 40
Appendix IV GAO Contacts and Staff Acknowledgments 42
Table
Table 1: Results of U.S. Code Search for References to Section 101
Definition of an Institution of Higher Education, by Title 8
Abbreviations
HEA Higher Education Act
IPEDS Integrated Postsecondary Education Database System
SMART Science, Mathematics, and Research for Transformation
This is a work of the U.S. government and is not subject to copyright
protection in the United States. The published product may be reproduced
and distributed in its entirety without further permission from GAO.
However, because this work may contain copyrighted images or other
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wish to reproduce this material separately.
United States Government Accountability Office
Washington, DC 20548
July 31, 2007
The Honorable George Miller
Chairman
The Honorable Howard P. "Buck" McKeon
Ranking Member
Committee on Education and Labor
House of Representatives
The Honorable Dale E. Kildee
Chairman
The Honorable Michael N. Castle
Ranking Member
Subcommittee on Early Childhood, Elementary and Secondary Education
Committee on Education and Labor
House of Representatives
The Honorable John A. Boehner
House of Representatives
The Honorable Raul M. Grijalva
House of Representatives
The Honorable Betty McCollum
House of Representatives
In recent years, the scale and scope of for-profit higher education in the
United States has changed considerably, prompting a reconsideration of the
role of for-profits in the nation's higher education system. In 1998,
for-profits accounted for approximately 11 percent of all private higher
education enrollments. By 2004, that percentage had doubled and included
an industry of almost 2,600 for-profit institutions educating some 1.24
million students. Full-time enrollment in 4-year for-profits continues to
increase, and one for-profit university now boasts that it is the largest
private university in the United States. The Higher Education Act (HEA),
the primary legislation authorizing most federal student aid programs
(Title IV), already defines institution of higher education to include
public, nonprofit, and for-profit institutions, allowing all such
institutions to share in the $83.1 billion of federal grants and loans
distributed as financial aid. However, an institution of higher education
is defined more narrowly for purposes of non Title IV HEA programs--such
as grants for infrastructure or to support teacher training--to include
only public and nonprofit institutions. As a result, for-profit
institutions are currently unable to access the nearly $1.96 billion in
federal funding for these programs.
There has been an ongoing debate about creating a single definition of
institution of higher education that would give for-profit institutions
greater access to non Title IV HEA programs. Proponents of this approach
have sought to repeal the existing statutory definitions and replace them
with a single definition that would include public, nonprofit, and
for-profit institutions as part of an effort to increase college access
and remove barriers for nontraditional students.1 Proponents argued that
the dual definitions in the current law foster a tiered system where not
all institutions share the same standing in the nation's higher education
system. During deliberations to reauthorize the HEA, some members of
Congress expressed concerns that other federal statutes or state laws or
programs might explicitly or implicitly reference the existing narrower
federal definition and that a change to a single definition could have
unintended consequences, such as giving for-profit institutions access to
non HEA programs and increasing federal spending
To provide you with the information about the potential impact of adopting
a single definition we examined the ways in which a single definition of
an institution of higher education might affect: 1) federal spending and
other aspects of federal programs across the federal government and 2)
state programs and policies.
To address our objectives, we conducted searches of the U.S. Code to
identify federal statutes and the related programs that could be affected
by the adoption of a single definition of an institution of higher
education. Our search was confined to statutory provisions codified in or
classified to the U.S. Code and, as such, does not include appropriations
acts. We did not search the Code of Federal Regulations or other sources
of federal policy, such as agency guidance or other publications. In
addition to searching the U.S. Code, we analyzed data from the Department
of Education's Integrated Postsecondary Education Database System (IPEDS)
to review the volume of for-profit institutions' research expenditures and
the major fields of study of those enrolled. In addition, we conducted
in-depth reviews of applicable state higher education programs and
policies in six states--California, New York, Oregon, Pennsylvania, Texas,
and Wyoming--and conducted approximately 35 interviews with officials and
representatives from federal, state, and private sector organizations in
the higher education field. In some cases, the interviews involved
multiple attendees who represented various state agencies and public and
private organizations. The six states were selected on the basis of a
variety of criteria, including the intensity of the state's higher
education regulatory environment, expert recommendations, recent
legislative activity in areas of for-profit school regulation or
oversight, and the percentage of total state-funded financial aid going to
students at for-profit higher education institutions. Appendix I provides
a more detailed description of our study's scope and methodology. We
conducted our review between March 2006 and April 2007 in accordance with
generally accepted government auditing standards.
1Legislation to reauthorize the HEA passed by the House of Representatives
during the 109th Congress included a provision to consolidate the two
definitions into a single definition of an institution of higher
education. College Access and Opportunity Act of 2006, H.R. 609, 109th
Cong., S 101 (2006).
Results in Brief
Given that our review of references to the narrower HEA definition did not
identify any mandatory spending or entitlement programs, it is unlikely
that a single definition would immediately increase federal spending;
however, more institutions may become eligible to compete for federal
funds and participate in various aspects of certain federal programs.
Numerous federal statutes reference the definition limiting the
participation of for-profit institutions, but these references were to
programs involving discretionary spending. Under a single definition, more
institutions could become eligible to compete for these programs, but
given that most 4-year for-profits do not have the kinds of academic
programs that would qualify for grants, in the short run it is unlikely
that many federal programs would witness greater competition. For example,
many of the U.S. Code sections we reviewed involve making grant awards to
eligible institutions for research in the physical and life sciences,
fields in which few for-profits have academic programs. While federal
spending is not likely to increase, some of the provisions we identified
were funding-related and, as such, could also affect program
administration or increase competition for program resources. For example,
some of the provisions relate to the formation of partnerships to pursue
funding. Under a single definition, for-profit institutions could be a
potential partner. In a limited number of cases, the provisions we
identified were not connected to federal funding, but under a single
definition could expand the pool of eligible participants for some program
activities. For example, with a single definition, representatives of
for-profit institutions could become eligible to sit on some federal
advisory committees.
A single federal definition is unlikely to have an immediate impact on
state programs but could potentially affect state higher education
programs and policies in the future. There will likely be no immediate
impact on state financial aid programs because generally, state statutes
and regulations do not reference the federal definition of an institution
of higher education when establishing eligibility criteria. According to
officials in several states we reviewed, an institution's profit-making
status is less important than other factors in determining eligibility for
state programs. States generally rely more on factors such as regional
versus national accreditation and whether institutions offer degrees and
are based in that particular state. Even though there is unlikely to be
any immediate impact on state programs and policies, state officials and
representatives from other higher education organizations we spoke with
believe there could be future implications. Although opinions of officials
and representatives varied widely, increased competition for funding and
increased political influence of the for-profit higher education industry
were most often cited as potential long-term effects of changing the
federal definition.
In response to a draft of this report, the Department of Education
(Education) offered technical comments suggesting that a single definition
could have an effect on federal spending by giving for-profit institutions
access to special postage rates and extending certain tax benefits to
for-profit institutions. We do not believe that such consequences are
likely. With regard to the first issue, the Postal Service receives an
appropriation to cover the costs of revenues it foregoes as a result of
some reduced mailing rates, but this appropriation does not appear to
cover the costs of the reduced rate currently available to nonprofit and
public institutions for mailing course catalogs.2 However, according to
Postal officials, changing the definition of an institution of higher
education could result in some institutions seeking access to classes of
postage that they might not have had access to before. If they were to
prevail, this could affect Postal revenues. Regarding the second issue,
our review of the tax code, codified at Title 26, indicates that it does
not rely on the section 101 definition of "institution of higher
education" for purposes of determining the availability of tax benefits.
In the comments, Education also stated that the report should be explicit
regarding special eligibility requirements now contained in section 102
applicable to for-profit institutions. We have added language to clarify
this point.
239 U.S.C. S 2401.
Background
The Higher Education Act of 1965, as amended (HEA), is administered by the
U.S. Department of Education and authorizes a range of programs and
activities, including federal student financial aid (also known as the
Title IV programs), aid to institutions, and aid to improve K-12 teacher
training at postsecondary institutions. For the purpose of determining
postsecondary institutions' eligibility to participate in HEA's various
programs and activities, the HEA currently contains two definitions of
"institution of higher education." Section 101 defines the term
"institution of higher education" for the purposes of all programs and
activities of the HEA other than the Title IV student federal financial
aid programs.3 Under section 101, in order to meet the definition of
institution of higher education, the institution must be either a public
or nonprofit institution. For Title IV programs, however, section 102 of
the HEA4 defines "institution of higher education" more broadly to include
all institutions recognized under the section 101 definition, as well as
proprietary (for-profit) institutions that meet certain additional
eligibility requirements.5 Because of this broader definition, students at
some for-profit institutions have access to and may participate in Title
IV financial aid programs. Legislative proposals for a single definition
of institution of higher education for the HEA would repeal the existing
statutory definitions and replace them with a single definition that
includes public, nonprofit, and for-profit institutions, thereby giving
all institutions, regardless of their profit-making status, access to HEA
programs and potentially to other federal programs that use the section
101 definition.6
For-profit education has become an increasingly larger component of
American higher education. Between 1998 and 2004, the percentage of
students enrolled in for-profits compared to all enrollments doubled. In
1998, one in ten students enrolled in private institutions was at a
for-profit; by 2004, that ratio had dropped to one in five. For-profits'
offerings tend to be concentrated in a small number of applied fields and
range from non-degree-granting to doctoral programs, though the former is
more typical. In 2004, 2,186 of the 2,563 for-profit institutions only
offered programs leading to no more than a 2-year degree, and at 4-year
institutions, 98 percent of all enrollments were either in business (85
percent) or education (13 percent) programs. Demographically, such
institutions tend to enroll large percentages of women and minorities.
Indeed, between 2000 and 2004 the percentage of females at for-profits
increased from 50 percent to 57 percent.
320 U.S.C. S1001.
420 U.S.C. S1002.
5For example, in order to participate in Title IV programs, for-profit
institutions must have been in existence for two years and must obtain at
least 10 percent of their revenues from non Title IV sources. 20 U.S.C. S
1002(b).
6However, such proposals may retain the additional requirements, such as
those mentioned above, applicable to for-profit institutions.
Regulation and oversight of the nonprofit and for-profit higher education
sectors is largely decentralized. Individual states develop their own
public higher education systems, establish and implement rules governing
the establishment of private nonprofit and for-profit universities, and
specify the minimum requirements that all institutions operating in the
state must meet in order to grant academic degrees. Quality control is
maintained largely through a voluntary accreditation system, whereby
privately run accrediting agencies review the qualifications of member
institutions. Though it is possible to forego accreditation, the HEA
stipulates that an institution must be accredited by one of 61 nationally
recognized accrediting agencies designated by the U.S. Department of
Education to be eligible for Title IV federal financial aid programs.
A Single Definition Is Unlikely to Immediately Increase Federal Spending, but
May Expand For-Profits' Ability to Compete for Funding and to Participate in
Other Aspects of Certain Programs
Given that our review of references to the narrower HEA definition did not
identify any mandatory spending or entitlement programs, it is unlikely
that a single definition would immediately increase federal spending;
however, more institutions may become eligible to compete for federal
funds and participate in various aspects of certain federal programs.
Although numerous federal statutory provisions reference the section 101
definition that excludes for-profit institutions of higher education, none
of these provisions appears to implicate mandatory spending programs.
However, more institutions could become eligible to compete for programs
that are funded with discretionary spending. In addition, some of the
provisions we identified could affect program administration or increase
competition for program resources. For example, some of the provisions
relate to the formation of partnerships to apply for federal funding.
Under a single definition, for-profit institutions could become a
potential partner for some federal grant programs. A single definition
could also expand the pool of eligible applicants for some federal
activities. For example, faculty members of for-profit institutions could
become eligible to sit on some federal advisory committees.
Numerous Federal Statutes Reference the Federal Definition That Excludes
For-Profit Institutions of Higher Education
Section 101 of the Higher Education Act, which defines institutions of
higher education as public or nonprofit institutions, is frequently
referenced in federal laws, many of which pertain to subjects beyond
education. We identified references to the definition in more than 3507
statutes spread across 22 of the U.S. Code's 50 titles.8 Slightly more
than half of these references were located in Title 20, which pertains to
education, and about 20 percent were found in Title 42, which pertains to
public health and welfare. The remainder, scattered throughout the U.S.
Code, deal with subjects as varied as agriculture, national defense, and
immigration. What is more, the programs covered by statutes using this
definition are administered by a variety of federal agencies. Table 1
below lists the number of sections we identified in our search arranged by
applicable U.S. Code Title. A complete listing of the statutory references
to the section 101 definition we identified can be found in appendix II.
7There are also a significant number of provisions using the phrase
"institution of higher education," but not referring to the section 101
definition, that are not included in our analysis.
8The number of statutes is not indicative of the number of federal
programs that would be affected by a single definition. Numerous statutory
provisions together may form a single program. For example, at least seven
different U.S. Code sections are used to define and authorize the Teacher
Quality Enhancement program (20 U.S.C. S 1022).
Table 1: Results of U.S. Code Search for References to Section 101
Definition of an Institution of Higher Education, by Title
Title Subject matter Total number of sections
20 Education 192
42 The public health and welfare 77
10 Armed forces 12
29 Labor 12
30 Mineral lands and mining 11
15 Commerce and trade 10
22 Foreign relations and intercourse 9
7 Agriculture 8
25 Indians 4
33 Navigation and navigable waters 4
50 War and national defense 4
8 Aliens and nationality 2
5 Government organization and employees 1
11 Bankruptcy 1
14 Coast Guard 1
16 Conservation 1
18 Crimes and criminal procedure 1
23 Highways 1
37 Pay and allowances of the uniformed 1
services
39 Postal Service 1
40 Public buildings, property, and works 1
47 Telegraphs, telephones, and radiotelegraphs 1
Total 355
Source: GAO analysis of the United States Code.
A Single Definition Would Not Likely Increase Federal Spending Immediately, but
May Expand the Pool of Eligible Applicants for Some Program Funding and
Activities
A single definition of institution of higher education is unlikely to
increase federal spending in the short term. Approximately 44 percent of
the references we identified relate to the provision of federal program
funds directly to students or institutions.9
Our review of these provisions did not identify any mandatory or
entitlement programs that are not subject to spending caps. Accordingly,
the adoption of a single definition of an institution of higher education
will not immediately increase mandatory federal spending. The
funding-related references appear to be tied to discretionary programs
that are funded through the annual appropriations process. Spending for
these programs would increase only if Congress elected to appropriate
additional funds.
Although a single definition could affect federal programs by allowing
for-profit institutions to apply for discretionary funds, in the short
run, many federal programs may be unlikely to witness greater competition.
Many of the U.S. Code sections related to federal funds were for research
in the physical and life sciences.10 However, academic programs at 4-year
for-profits are largely concentrated in the areas of business and
education, and the dollar volume of research such institutions do is
small, suggesting limited capacity for research in many of the areas where
federal funds for science research are available.11 We also identified a
number of U.S. Code sections addressing education-related training
programs that for-profit institutions could more readily qualify for, such
as the Teacher Institutes program or the Teacher Quality Enhancement
program.12 Additionally, for-profit institutions operating in large urban
areas and enrolling disproportionately more minority students than
nonprofit institutions may be more competitive than such institutions for
certain programs. One example is the Urban Community Service program,
which provides funds to urban academic institutions to address problems in
their communities.13 In general though, the number of federal
discretionary grant programs that would be affected by greater competition
appears to be limited.
9For purposes of this analysis, the term "institutions" includes
institutions of higher education but may also include state agencies and
local educational agencies.
10For example, 42 U.S.C. S 16721 offers grants to institutions of higher
education to conduct research in aeronautical sciences and technologies,
and 7 U.S.C. S 8103 awards grants to eligible entities, including
institutions of higher education, to help subsidize the development and
construction of biorefineries for carrying out projects demonstrating the
commercial viability of processes for converting biomass to fuels or
chemicals.
11Information based on the latest year available. More than 98 percent of
enrollments at 4-year proprietary institutions were either in
business-oriented (85.3 percent) or education (13 percent) programs. In
addition, of the 367 four-year for-profits reporting expenditures data
through IPEDS in 2004, only 13 reported expenditures related to research
and public service. One institution reported just more than $2 million
that year, and the mean expenditure was $10,715. Data was not reported on
the percentage of research expenditures related to science.
Many of the statutory provisions we identified were funding-related and
could also have an effect on various aspects of program administration or
increase opportunities for for-profits to partner with other entities for
purposes of applying for grant funds. With a single definition, for-profit
institutions could become eligible for some grants for which they could
not previously apply, but as recipients, for-profits may also be subjected
to additional reporting obligations. For example, some of these provisions
require that grant recipients report certain kinds of information to the
administering agency, or that institutions enrolling students who receive
federal funds file reports about those students.14 Other provisions in
this category state that only partnerships consisting of institutions of
higher education and other entities, such as school districts and state
education agencies, are eligible to apply.15 Accordingly, with a single
definition, entities desiring to apply for a grant could collaborate with
for-profit institutions as well as public and nonprofit institutions.
In a limited number of cases, the provisions we identified were not
connected to federal funding, but under a single definition could expand
the pool of eligible applicants for some program activities. For example,
some provisions specify the qualifications individuals must have to pursue
employment supported by federal funds, such as a provision related to the
No Child Left Behind Act that requires certain teachers' aides to complete
at least 2 years of study at an institution of higher education or meet
other qualification requirements.16 Under a single definition this would
include individuals who had completed their studies at for-profit
institutions as well. Other provisions authorize federal agencies to form
advisory committees for particular purposes and specify that committee
membership may include representatives of institutions of higher
education. For example, the provision establishing the Advisory Council on
Coal Research makes the council's membership open to representatives of
institutions of higher education who are knowledgeable in the fields of
coal research and mining.17 To the extent that a faculty member at a
for-profit was recognized as holding the necessary qualifications, a
single definition could allow such individuals to become members of some
federal advisory committees.
12The Teacher Quality Enhancement program under Title II of the HEA
provides grants to states for many purposes, including implementing
reforms that hold institutions of higher education with teacher
preparation programs accountable for preparing teachers who are highly
competent in the academic content areas in which the teachers plan to
teach. 20 U.S.C. SS 1021 - 1030. The Teacher Institutes program provides
for the National Science Foundation to make competitive grants to
institutions and other entities to support teacher education and training
in the areas of mathematics and science. 20 U.S.C. S 3913.
1320 U.S.C. SS 1139c, 1139d, 1139f, and 1139g.
14See 20 U.S.C. S 4706.
15See 20 U.S.C. S 1452.
For a small number of the provisions we analyzed, a single definition is
unlikely to have any effect on federal programs. These instances generally
involve statements related to program purposes or simply encourage policy
initiatives. For example, one provision18 encourages eligible institutions
to provide opportunities for students to develop their knowledge and
understanding of developing countries, and another provision19 expresses
Congress's sense that all institutions should take certain specific
measures to change the culture of alcohol consumption on college campuses.
With a single definition, these policy statements would apply to both
for-profit and nonprofit institutions.
1620 U.S.C. S 6319.
1730 U.S.C. S 1315.
1822 U.S.C. S 4709.
1920 U.S.C. S 1011h.
A Change to a Single Definition of an Institution of Higher Education Is
Unlikely to Immediately Affect State Programs, but Could in the Future
A single federal definition of an institution of higher education is
unlikely to have an immediate impact on state programs, but could
potentially affect state higher education programs and policies in the
future. There will likely be no immediate impact on state financial aid
programs because in general, state laws and regulations establishing
eligibility criteria for these programs do not directly reference the
federal definition. According to state officials, several institutional
characteristics, rather than the schools' profit-making status, are most
often employed to determine eligibility for state student aid programs,
including what agency accredits the institution, whether the institution
offers degrees, and where the institution is located. Even though there is
unlikely to be any immediate impact on state programs and policies, state
officials and representatives from other higher education organizations
with whom we spoke believe there could be future implications. While
perceptions varied widely, officials and representatives suggested that
the change in definition could eventually affect state programs and
policies by increasing competition for federal grant programs and possibly
giving the for-profit higher education industry more influence in shaping
relevant state policies.
States We Reviewed Rely Mainly on Several Institutional Characteristics, Not the
Federal Definition, to Determine Eligibility for State-Funded Student Financial
Aid Programs
Having a single definition is unlikely to result in an immediate or
substantial impact at the state level. Our search of state statutory and
regulatory codes identified only a small number of direct references to
the HEA section 101 definition of institution of higher education.
According to state officials in all the states we reviewed, state aid
directed to institutions is only provided to public and private nonprofit
higher education institutions. None of the states we reviewed provided
state aid, such as grants supporting an institution's core operations or
research activities, directly to for-profit institutions although in half
of the states, students attending for-profit institutions are eligible to
receive state financial aid. For state student financial aid, eligibility
requirements emphasize one or more factors like accreditation, types of
programs offered, and location, rather than institutions' profit-making
status.
Three of the six states we reviewed make state financial aid available to
students at for-profit institutions: California, New York, and
Pennsylvania. These states ensure the integrity of the programs they fund
by requiring that participating institutions have qualifications such as
accreditation and degree-granting status, and participation in federal
programs. State higher education officials in these states told us that
they were more focused on the quality and type of programs institutions
offered rather than their profit-making status. For example, officials in
New York told us they limit state Tuition Assistance Program funding to
students at degree-granting institutions only, regardless of their
profit-making status. Similarly, an institution of higher education in
Pennsylvania must be accredited and approved by the Pennsylvania
Department of Education in order to be eligible for the State Grant
Program.20 California also provides funding to students at for-profit
institutions with Cal Grant funds. For example, in California, any private
institution that participates in the Pell Grant program and any two of the
three major federal campus-based student aid programs may access student
financial aid funds,21 regardless of for-profit status.22
Wyoming, Texas, and Oregon currently exclude for-profit institutions from
state student financial aid programs. However, officials in each of these
states told us that for-profit institutions may have been excluded not
simply because of their for-profit status but also because of limited
public resources, relevant state laws being created before the growth in
degree-granting for-profit institutions, or because of state lawmakers'
preference to limit public funds to public institutions. For example, in
Wyoming, the Hathaway Scholarship Program funding is limited to students
attending the University of Wyoming or a Wyoming community college, even
though a Wyoming official told us there was some debate at the time of the
program's inception about opening it up to students attending other
accredited, degree-granting private institutions. Texas also limits state
student aid funding through the TEXAS Grant Program to the state's public
institutions and private nonprofit institutions accredited by Southern
Association of Colleges and Schools. One official indicated that these
funds may be limited to public and nonprofit institutions because of
limited state funding or because relevant state regulations were
established long before the rise in for-profit, degree-granting
institutions. Oregon also excludes for-profit institutions from its
student financial aid program, the Oregon Opportunity Grant, funding only
accredited nonprofit, Oregon-based schools, public institutions, and
community colleges.
20Out of state institutions are eligible only if they are accredited,
degree-granting, nonprofits.
21The three federal programs are the Supplemental Educational Opportunity
Grant, Work-Study, and the Perkins Loan.
22Any institution--public, nonprofit, or for-profit--are eligible to
participate as long as they are accredited by Western Association of
School and Colleges, the regional accrediting body responsible for
California, and meet certain requirements.
Officials and Representatives We Interviewed Predict Little or No Immediate
Impact on State Programs, but Views Vary on Long-Term Impact
While many officials and representatives we spoke with believed the single
definition would not have an immediate impact on state programs and
policies, they did raise a number of potential long-term consequences to
consider. Opinions on the exact nature of the long-term consequences,
however, varied among and within states, indicating that future impact is
difficult to predict. In general, we found that those representing the
for-profit higher education industry were more likely to note the
potential benefits of a single definition while representatives from
nonprofit and public institutions, along with state higher education
officials, were more likely to identify the possible problems. Of the
potential consequences mentioned most often by officials and
representatives with whom we spoke, two main issues emerged: (1) increased
competition for federal grant program funds and (2) increased political
influence of the for-profit higher education industry in state
policymaking.
Increased Competition for Federal Grant Program Funds and Increased Oversight
Responsibility
Many officials and representatives of nonprofit and for-profit
institutions with whom we spoke believed that the single definition would
increase competition for federal funding. Some representatives and state
officials believe that increased competition could, in theory, provide
postsecondary students access to a broader range of programs and expand
overall educational choice. On the other hand, representatives from the
public and nonprofit sectors suggested that increased competition would
reduce already scarce public funding for nonprofit and public universities
in their states. However, as we stated earlier in this report, it may be
unlikely that most for-profits will be competitive for federal grant
programs in the short term. Some officials and representatives concurred
with this point, stating that they thought it unlikely that for-profit
institutions that do not already qualify for those funds for which they
would be most competitive--i.e., teacher training programs--would take the
necessary steps to meet the qualifications for federal grant programs in
other fields given the return on investment.
Some officials expressed concern that a single definition will cause a
strain on state agency resources. Assuming the single definition makes
more institutions eligible to apply for federal funds, several state
officials were worried about the administrative burden of monitoring the
increased number of institutions receiving federal funds. According to
officials, state agencies are already responsible for administering
federal grant programs in their respective states and providing oversight
for institutions that receive federal funds.23 Additionally, since states
rely heavily on institutions' accreditation status in their oversight,
some state officials we spoke with suggested that quality control in the
recognition of accrediting agencies would become more important.
Increased Political Influence of For-Profit Institutions
State officials and representatives from for-profit institutions we spoke
to believed that a single definition could potentially give the for-profit
sector added influence, allowing it to shape policy change in individual
states. For example, one official in Oregon, which currently excludes
for-profits from state financial aid funding, said that pressure to open
state programs to for-profit institutions already exists in this state and
believed that the single federal definition could potentially increase
that pressure on the state legislature. While officials in several states
we reviewed described their states' higher education policies as largely
independent of the federal government's, some officials and
representatives from other higher education organizations with whom we
spoke noted that states consider federal policy when setting state policy
and developing guidance. An official in Pennsylvania, for example, told us
that as a matter of practice, administration of state financial aid
generally parallels federal guidelines in order to ease the administrative
burden on the state's program administrators. Indeed, several officials
told us that they believed states could eventually follow the federal lead
on this issue.
Additionally, some state officials and representatives from for-profit
institutions believed that for-profit institutions could use successful
passage of the single definition at the federal level to push for policy
changes on other related issues, such as transfer of credit policy,
although many for-profit representatives with whom we spoke said they
wanted only the symbolic recognition provided by a single definition.24
Many traditional public and nonprofit institutions currently only accept
transfer credit from regionally accredited institutions, and since
for-profit institutions generally lack such accreditation, their students
face problems when trying to transfer to traditional nonprofit schools.
Representatives from several for-profit institutions believed that a
change in the federal definition could help remove these barriers. Other
representatives believed that transfer-of-credit policy would remain tied
to accreditation rather than profit-making status, regardless of the
outcome of the single definition debate. At the same time, some
representatives with whom we spoke from the for-profit sector maintained
that they were not seeking eligibility for specific federal and state
grant programs or other policies. Rather, they stated that the single
definition provides symbolic recognition of their institution's important
and fundamental role in the American postsecondary education system.
23Examples of federal programs administered by states include Teacher
Training under HEA and the Adult Education and Literacy Programs under the
Workforce Investment Act.
24GAO, Transfer Students: Postsecondary Institutions Could Promote More
Consistent Consideration of Coursework by Not Basing Determinations on
Accreditation, [24]GAO-06-22 (Washington, D.C.: October 2005).
Concluding Observations
A change in the federal definition of institution of higher education is
likely to have a limited impact in the short run. However, the effects of
a single definition on the American higher education system over a longer
time frame are difficult to predict yet important to keep in mind. While
states largely set their higher education policies independently, future
federal policy initiatives could provide states with incentives to more
closely align their own policies with those at the federal level. Newfound
eligibility to compete for federal resources may or may not encourage
for-profit institutions to invest in education and research programs
outside of their traditional domain, and greater competition may encourage
nonprofit institutions to expand their own commercial activities.
Furthermore, a larger pool of eligible institutions may, in the future,
increase pressure on the Congress to increase the funding levels for
existing discretionary programs. Overall, while a single definition would
grant for-profit institutions greater parity, additional federal
recognition would bring additional oversight. As policy makers address
questions about access, they will want to remain aware of these diverse
costs and benefits.
Agency Comments
We provided a draft of this report to Education for review and comment. In
response to a draft of this report, Education offered technical comments
about the effect that a single definition would have on federal spending.
Although Education suggests that giving for-profit institutions access to
special postage rates would result in immediate budgetary consequences for
the federal government, we do not believe that such consequences are
likely. This is, in part, because the Postal Service receives an
appropriation to cover the costs of revenues it foregoes as a result of
some reduced mailing rates, but this appropriation does not appear to
cover the costs of the reduced rate currently available to nonprofit and
public institutions for mailing course catalogs. However, according to
Postal officials, changing the definition of an institution of higher
education could result in some institutions seeking access to classes of
postage that they might not have had access to before. If they were to
prevail, this could affect Postal revenues. Similarly, Education suggested
that there could be increased federal costs for extending certain tax
benefits to for-profit institutions. However, our review of the tax code,
codified at Title 26, indicates that it does not rely on the section 101
definition of "institution of higher education" to determine the
availability of tax benefits, but rather relies on other criteria. As a
result, we do not anticipate that a single definition would, in itself,
result in any immediate tax consequences. Finally Education stated that
the report should be explicit regarding special eligibility requirements
now contained in section 102 and applicable to for-profit institutions. We
have added language to clarify this point and agree that Congress should
be aware of these additional eligibility rules as it considers future
legislative proposals for a single definition. Education's comments have
been reproduced in appendix III.
We will send copies of this report to the Secretary of Education, relevant
congressional committees, and other interested parties. In addition, the
report will be available at no charge on GAO's Web site at
[25]http://www.gao.gov . Please contact George Scott at (202) 512-5932 if
you or your staff have any questions about this report. Contact points for
our Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report are listed
in appendix IV.
George A. Scott
Director, Education, Workforce, and Income Security Issues
Dayna K. Shah
Managing Associate General Counsel, Office of General
Counsel
Appendix I: Objectives, Scope, and Methodology
Our objectives were to examine ways in which a single definition of an
institution of higher education might affect: 1) federal spending and
other aspects of applicable federal programs, and 2) state programs and
policies. To answer these questions, we searched the U.S. Code to identify
federal statutes and the related programs that could be affected by the
adoption of a single definition of an institution of higher education. We
also analyzed data from the Department of Education's Integrated
Postsecondary Education Database System (IPEDS) to review both the volume
of 4-year for-profit institutions' research expenditures and the major
fields of study of those enrolled. In addition, we conducted interviews
with federal, state, and private sector organizations in the higher
education field and contacted selected states to obtain more information
about the potential impact of the single definition within these states.
See below for more detailed information on each of these aspects of our
research. We performed our work from March 2006 through April 2007 in
accordance with generally accepted government auditing standards.
Search of U.S. Code
In order to determine the number of references to the section 101
definition of "institution of higher education" in the U.S. Code, we
performed multiple searches of the commercial legal databases Westlaw and
Lexis. First, we searched these databases for explicit references to
section 101's definition in statutory text, for example, by searching for
occurrences of the phrases "section 101" or "institution of higher
education" in close proximity to "the Higher Education Act," or for
references to the codified version of the section 101 definition, "20
U.S.C. S 1001." We reviewed these results carefully to ensure that they
referred to the section 101 definition of institution of higher education
and not to some other unrelated provision and in a small number of cases,
eliminated search results based upon this review.
In conducting this preliminary review, we observed that a significant
number of the statutory provisions we identified contained definitions
that applied for purposes of various subdivisions of the U.S. Code, such
as a particular chapter or subchapter. Therefore, we performed a second
set of searches designed to identify implicit references to the section
101 definition. For example, 10 U.S.C. S 2199 refers to the section 101
definition of institution of higher education and specifies that this
definition applies for purposes of the entire chapter in which the
reference occurs. Accordingly, in order to identify the implicit
references to the section 101 definition in the relevant chapter, we
searched that chapter only for additional uses of the term "institution of
higher education." In this particular case, our search revealed three
additional code sections (SS 2196 - 2198) that refer to institutions of
higher education, but incorporate the section 101 definition by reference,
rather than by identifying it explicitly. We repeated this process where
appropriate to expand our search results. Notably, this step generated
approximately three times more search results than the first, which
indicates that the majority of statutory provisions that rely on the
section 101 definition do not do so explicitly, but rather incorporate it
by reference. Both of these research steps were performed initially in
March 2006 and were repeated in January 2007 to ensure that our analysis
reflects any legislative changes that occurred in the course of our work.
The full list of search results is available in appendix II.
There are some limitations to our methodology that should be noted. First,
in some cases, we also observed that the term "institution of higher
education" is used to define another term (for example, "postsecondary
educational institution"), which is then used to establish grant
eligibility or other program requirements. However, we did not conduct
additional searches to identify statutory references to these other terms.
As a result, our analysis may overlook some peripheral references to
"institution of higher educations." Second, we did not verify whether
Congress has provided recent funding for particular programs or
provisions. Additionally, our search was confined to statutory provisions
codified in or classified to the U.S. Code and as such does not include
appropriations acts. We did not search the Code of Federal Regulations or
sources of federal policy, such as agency guidance or other publications.
To the extent that these sources rely on the section 101 definition, there
may also be implications for a change to a single definition.
Although this approach enabled us to identify the number of provisions
that potentially would be affected by a single definition of institution
of higher education, we did not attempt to identify the number of federal
programs that would be affected. Our decision was affected by multiple
factors. First, given that numerous statutory provisions together may form
a single program, the number of statutes is not indicative of the number
of federal programs that would be affected by a single definition.1
Second, some statutes are free standing and cannot be identified as part
of a larger program. Additionally, in some cases, the statutes forming a
particular program are codified in places scattered throughout the U.S.
code. However, in some cases, the structure of the U.S. Code lends itself
more easily to identifying statutes that together form a program.2 As a
result, our analysis refers to both federal programs and particular
provisions.
1For example, at least seven different U.S. Code sections identified in
our search are used to define and authorize the Teacher Quality
Enhancement Grant Program (20 U.S.C. S 1022).
Review of Statutory References
In order to determine whether a change in the definition of an institution
of higher education will have a federal budgetary impact or result in
higher federal spending, our approach was to determine if any of the
identified references involved mandatory funding--programs whose budget
authority is provided in laws other than appropriations acts, such as
entitlement programs. To determine the budgetary impact, we identified
references that are related to programs that provide funds directly to
students or institutions and traced these direct-funding references to
readily available descriptive information. Such readily available
information included published program data, the President's budget,
agencies' budget justification documents, and/or other information made
publicly available by agencies administering the programs. We also
reviewed a list of mandatory accounts to determine if these direct-funding
references involved mandatory funding. To determine the likely impact of a
single definition on other aspects of federal programs, we reviewed the
statutory text of provisions not directly related to federal funding to
determine if the adoption of a single definition would have any impact on
these program activities.
In-depth Reviews of States
To determine how a single definition might affect state programs and
policies, we conducted in-depth reviews of six states. We visited three
states: California, New York, and Oregon, and interviewed officials by
phone in Pennsylvania, Texas, and Wyoming.3 These states were selected on
the basis of a variety of criteria, including the intensity of the state's
regulatory environment, expert recommendations, recent legislative
activity in areas of private school regulation or oversight, and the
percentage of total state financial aid going to students at for-profit
higher education institutions. During our interviews, we discussed each
state's higher education system with various state officials. These
discussions included how it is structured and regulated, the extent of
state oversight, and the eligibility criteria for states' higher education
grant programs, such as institutional aid and student financial aid. We
also reviewed documents obtained from higher education officials during
these meetings, including state laws or regulations outlining eligibility
criteria for states' student financial aid programs. To determine
perspectives on how the creation of a single definition of institution of
higher education may affect federal and state programs and policies, we
also spoke with representatives from nonprofit and for-profit higher
education institutions, and several higher education associations
representing the interests of the for-profit and nonprofit, private higher
education sectors nationwide. In total, we conducted approximately 35
interviews that, in some cases, included multiple attendees who
represented various state agencies and public and private institutions and
organizations.
2See appendix II for examples of how the structure of the U.S. Code can be
used in some cases to identify programs. Title 10, for example, deals
generally with topics related to the armed forces. It is further divided
into subtitles, which are divided into parts, which are divided into
chapters. In this case, Chapter 112 pertains to the Information Security
Scholarship Program. For purposes of our work, the sections within this
program that are relevant are S 2200, S 2200a, S 2200b, and S 2200e.
3These officials, in general, included officials from the state department
of education, state student aid administrations, and state legislative
staff.
As part of our review of the six selected states, we conducted a limited
search of state statutory and administrative codes to help determine if a
single federal definition would have an immediate impact on state policies
or programs. We requested that state officials in our six interview states
provide us with relevant statutory language defining institutional
eligibility criteria for state student financial aid programs. Based on
the information they provided, we searched state statutes and regulations
to identify the appropriate institutional eligibility requirements. In
addition, we searched each of these states' statutory codes and program
regulations using key terms to assess whether the federal definition of an
institution of higher education was used to determine institutional
eligibility for other higher-education-funding programs in our interview
states.
Appendix II: U.S. Code References to Institution of Higher Education
References in the U.S. Code to "Institution of Higher Education" as
defined by Section 101 of the Higher Education Act
Title 5. Government Organization and Employees
Part III. Employees
Subpart I. Miscellaneous
Chapter 98. National Aeronautics and Space Administration
S 9809. Science and technology scholarship program
Title 7. Agriculture
Chapter 55. Department of Agriculture
S 2279. Outreach and assistance for socially disadvantaged farmers and
ranchers
S 2279c. student internship programs
Chapter 64. Agricultural Research, Extension, and Teaching
Subchapter III. Agricultural Research and Education Grants and Fellowships
S 3152. Grants and fellowships for food and agricultural sciences
education
Subchapter XIV. Institutions of Higher Education in Insular Areas
S 3361. Definition
Chapter 103. Agricultural Research, Extension, and Education Reform
Subchapter III. Miscellaneous Provisions
Part B. General
S 7657. Senior Scientific Research Service
Chapter 107. Renewable Energy Research and Development
S 8103. Biorefinery development grants
S 8104. Biodiesel fuel education program
S 8105. Energy audit and renewable energy development program
Title 8. Aliens and Nationality
Chapter 12. Immigration and Nationality
Subchapter II. Immigration
Part II. Admission Qualifications for Aliens; Travel Control of Aliens and
Citizens
S 1182. Inadmissible Aliens
S 1184. Admission of nonimmigrants
Title 10. Armed Forces
Subtitle A. General Military Law
Part II. Personnel
Chapter 31. Enlistments
S 510. Enlistment incentives for pursuit of skills to facilitate national
service
Part III. Training and Education
Chapter 111. Support of Science, Mathematics, and Engineering Education
S 2192a. Science, Mathematics, and Research for Transformation (SMART)
Defense Education Program
S 2193. Improvement of education in technical fields: grants for higher
education in science and mathematics
S 2196. Manufacturing engineering education: grant program
S 2197. Manufacturing experts in the classroom
S 2198. Management training program in Japanese language and culture
S 2199. Definitions
Chapter 112. Information Security Scholarship Program
S 2200. Programs; purpose
S 2200a. Scholarship program
S 2200b. Grant program
S 2200e. Definitions
Subtitle E. Reserve Components
Part IV. Training for reserve components and Educational assistance
programs
Chapter 1611. Other Educational assistance programs
S 16401. Marine Corps platoon leaders class: college tuition assistance
program
Title 11. Bankruptcy
Chapter 5. Creditors, The debtor, and the estate
Subchapter II. Debtor's duties and benefits
S 522. Exemptions
Title 14. Coast Guard
Part II. Coast Guard Reserve and Auxiliary
Chapter 21. Coast Guard Reserve
Subchapter A. General
S 709a. Reserve student precommissioning assistance program
Title 15. Commerce and Trade
Chapter 7. National Institute of Standards and Technology
S 278h. Research program on security of computer systems
Chapter 40. Department of Commerce
S 1542. Establishment of the Ernest F. Hollings Scholarship Program
Chapter 81. High-performance computing
Subchapter III. Department of Energy high-end Computing Revitalization
S 5541. Definitions
S 5542. Department of Energy high-end computing research and development
program
Chapter 92. Year 2000 Computer Date Change
S6604. Punitive damages limitations
Chapter 100. Cyber Security Research and Development
S 7402. Definitions
S 7403. National Science Foundation research
S 7404. National Science Foundation computer and network security programs
S 7410. Grant eligibility requirements and compliance with immigration
laws
S 7411. Report on grant and fellowship programs
Title 16. Conservation
Chapter 6. Game and Bird Preserves; Protection
S 698u-5. Advisory committee
Title 18. Crimes and Criminal Procedure
Part I. Crimes
Chapter 11. Bribery, Graft, and Conflicts of Interest
S 207. Restrictions on former officers, employees, and elected officials
of the executive and legislative branches
Title 20. Education
Chapter 28. Higher Education Resources and Student Assistance
Subchapter I. General provisions
Part A. Definitions
S 1001. General definition of institution of higher education
S 1003. Additional definitions
Part B. Additional General Provisions
S 1011. Antidiscrimination
S 1011a. Protection of student speech and association rights
S 1011b. Treatment of territories and territorial student assistance
S 1011d. Student representation
S 1011e. Financial responsibility of foreign students
S 1011h. Binge drinking on college campuses
S 1011i. Drug and alcohol abuse prevention
Part C. Cost of Higher Education
S 1015. Improvements in market information and public accountability in
higher education
Part D. Administrative Provisions for Delivery of Student Financial
Assistance
S 1018. Performance-Based Organization for delivery of federal student
financial assistance
Subchapter II. Teacher Quality Enhancement
Part A. Teacher Quality Enhancement Grants for States and Partnerships
S 1021. Purposes; definitions
S 1022. State grants
S 1023. Partnership grants
S 1025. Administrative provisions
S 1027. Accountability for programs that prepare teachers
S 1028. State functions
S 1029. General provisions
Part B. Preparing Tomorrow's Teachers to Use Technology
S 1041. Purpose and program authority
S 1042. Eligibility
S 1043. Use of funds
Subchapter III. Institutional Aid
S 1051. Findings and Purpose
Part A. Strengthening Institutions
S 1058. Definitions; eligibility
S 1059c. American Indian tribally controlled colleges and universities
S 1059d. Alaska Native and Native Hawaiian-serving institutions
Part B. Strengthening Historically Black Colleges and Universities
S 1060. Findings and purposes
S 1061. Definitions
S 1063. Allotments to institutions
S 1063b. Professional or graduate institutions
Part C. Endowment Challenge Grants for Institutions Eligible for
Assistance under Part A or Part B
S 1065. Endowment Challenge Grants
Part D. Historically Black College and University Capital Financing
S 1066c. Limitations on Federal insurance for bonds issued by designated
bonding authority
Part E. Minority Science and Engineering Improvement Program
Subpart 1. Minority Science and Engineering Improvement Program
S 1067. Findings
S 1067a. Purpose; authority
Subpart 2. Administrative and General Provisions
S 1067g. Eligibility for grants
S 1067k. Definitions
Part F. General Provisions
S 1068b. Application review process
Subchapter IV. Student Assistance
Part B. Federal Family Education Loan Program
S 1078-11. Loan forgiveness for child care providers
Subchapter V. Developing Institutions
Part A. Hispanic-Serving Institutions
S 1101. Findings; purpose; and program authority
S 1101a. Definitions; eligibility
S 1101b. Authorized activities
Subchapter VI. International Education Programs
Part A. International and Foreign Language Studies
S 1121. Findings and purposes
S 1122. Graduate and undergraduate language and area centers and programs
S 1123. Language resource centers
S 1124. Undergraduate international studies and foreign language programs
S 1125. Research; studies; annual report
S 1126. Technological innovation and cooperation for foreign information
access
S 1128a. American overseas research centers
Part B. Business and International Education Programs
S 1130. Findings and purpose
S 1130-1. Centers for international business education
S 1130a. Education and training programs
Part C. Institute for International Public Policy
S 1131. Minority foreign service professional development program
S 1131a. Study abroad program
S 1131c. Internships
Part D. General Provisions
S 1132. Definitions
Subchapter VII. Graduate and Post-Secondary Improvement Programs
Part A. Graduate Education Programs
Subpart 1. Jacob K. Javits Fellowship Program
S 1134. Award of Jacob K. Javits Fellowships
S 1134a. Allocation of fellowships
S 1134b. Stipends
S 1134c. Fellowship conditions
Subpart 2. Graduate Assistance in Areas of National Need
S 1135. Grants to academic departments and programs of institutions
S 1135a. Institutional eligibility
S 1135b. Criteria for applications
S 1135c. Awards to graduate students
S 1135d. Additional assistance for cost of education
Subpart 3. Thurgood Marshall Legal Educational Opportunity Program
S 1136. Legal Educational Opportunity Program
Part B. Fund for the Improvement of Postsecondary Education
S 1138. Fund for the improvement of postsecondary education
S 1138c. Special projects
Part C. Urban Community Service
S 1139c. Allowable activities
S 1139d. Peer review
S 1139f. Designation of urban grant institutions
S 1139g. Definitions
Part D. Demonstration Projects to Ensure Students with Disabilities
Receive a Quality Higher Education
S 1140. Purposes
S 1140a. Grants authorized
S 1140b. Applications
S 1140c. Rule of construction
Subchapter VIII. Miscellaneous
S 1153. Underground Railroad Educational and Cultural Program
Chapter 31. General Provisions Concerning Education
Subchapter II. Appropriations and Evaluations
Part 2. Planning and Evaluation of Federal Education Activities
S 1228c. Disclosure requirements
Chapter 33. Education of Individuals with Disabilities
Subchapter I. General Provisions
S 1401. Definitions
Subchapter II. Assistance for Education of All Children with Disabilities
S 1412. State eligibility
S 1416. Monitoring, technical assistance, and enforcement
Subchapter IV. National Activities to Improve Education of Children with
Disabilities
Part A. State Personnel Development Grants
S 1452. Eligibility and collaborative process
S 1454. Use of funds
Part B. Personnel Preparation, Technical Assistance, Model Demonstration
Projects, and Dissemination of Information
S 1461. Purpose; definition of eligible entity
S 1462. Personnel development to improve services and results for children
with disabilities
S 1465. Interim alternative educational settings, behavioral supports, and
systemic school interventions
Part C. Supports to Improve Results for Children with Disabilities
S 1471. Parent training and information centers
Part D. General Provisions
S 1481. Comprehensive plan for parts B and C
S 1482. Administrative provisions
Chapter 42. Harry S Truman Memorial Scholarships
S 2002. Definitions
S 2005. Truman scholars
S 2008. Scholarship conditions
Chapter 44. Vocational Education
S 2302. Definitions
Subchapter I. Career and Technical Education Assistance to the States
Part A. Allotment and Allocation
S 2324. National activities
S 2325. Assistance for the outlying areas
S 2327. Tribally controlled postsecondary career and technical
institutions
Part B. State Provisions
S 2342. State plan
S 2344. State leadership activities
Subchapter II. Tech Prep Education
S 2373. Tech prep education
S 2374. Consortium applications
Chapter 52. Education for Economic Security
S 3902. Definitions
Subchapter I. National Science Foundation Science and Engineering
Education
S 3913. Teacher institutes
S 3914. Materials development and methods research for mathematics,
science, and engineering
S 3916. Other functional activities
Subchapter III. Partnerships in Education for Mathematics, Science, and
Engineering
Part A. Higher Education Partnerships
S 3981. Statement of purpose
S 3982. Definitions
S 3984. Authorized activities
S 3985. Application
S 3986. Submission of applications
Chapter 57. James Madison Memorial Fellowship Program
S 4505. Recipient's choice of institution
S 4506. Recipient's eligibility
S 4509. Fellowship conditions
S 4514. Definitions
Chapter 59. Barry Goldwater Scholarship and Excellence in Education
Program
S 4702. Definitions
S 4706. Scholarship conditions
Chapter 66. Morris K. Udall Scholarship and Excellence in National
Environmental Policy Foundation
S 5602. Definitions
S 5605. Authority of Foundation
Chapter 70. Strengthening and Improvement of Elementary and Secondary
Schools
Subchapter I. Improving The Academic Achievement of the Disadvantaged
Part A. Improving Basic Programs Operated by Local Educational Agencies
Subpart 1. Basic Program Requirements
S 6316. Academic assessment and local educational agency and school
improvement
S 6317. School support and recognition
S 6319. Qualifications for teachers and paraprofessionals
Part B. Student Reading Skills Improvement Grants
Subpart 1. Reading First
S 6362. Formula grants to State educational agencies
S 6363. State formula grant applications
Subpart 3. William F. Goodling Even Start Family Literacy Programs
S 6381a. Program authorized
S 6381f. Applications
Part C. Education of Migratory Children
S 6398. Coordination of migrant education activities
Part D. Prevention and Intervention Programs for Children and Youth Who
Are Neglected, Delinquent, or At-Risk
Subpart 1. State Agency Programs
S 6438. Transition services
Part F. Comprehensive School Reform
S 6516. Local use of funds
Subchapter II. Preparing, Training, and Recruiting High Quality Teachers
and Principals
Part A. Teacher and Principal Training and Recruiting Fund
S 6602. Definitions
Subpart 2. Subgrants to Local Educational Agencies
S 6623. Local use of funds
Subpart 3. Subgrants to Eligible Partnerships
S 6631. Definitions
S 6634. Use of funds
Subpart 5. National Activities
S 6651. National activities of demonstrated effectiveness
Part B. Mathematics and Science Partnerships
S 6661. Purpose; definitions
Part C. Innovation for Teacher Quality
Subpart 1. Transitions to Teaching
Division A. Troops-To-Teachers Program
S 6673. Recruitment and selection of program participants
S 6674. Participation agreement and financial assistance
S 6676. Support of innovative preretirement teacher certification programs
Division B. Transition to Teaching Program
S 6681. Purposes
S 6682. Definitions
S 6683. Grant program
Subpart 2. National Writing Project
S 6702. National Writing Project
Subpart 3. Civic Education
S 6715. Cooperative civic education and economic education exchange
programs
Subpart 4. Teaching of Traditional American History
S 6721. Establishment of program
Part D. Enhancing Education through Technology
S 6753. Definitions
Subpart 1. State and Local Technology Grants
S 6764. Local applications
Subchapter III. Language Instruction for Limited English Proficient and
Immigrant Students
Part A. English Language Acquisition, Language Enhancement, and Academic
Achievement Act
Subpart 1. Grants and Subgrants for English Language Acquisition and
Language Enhancement
S 6822. Native American and Alaska Native children in school
S 6825. Subgrants to eligible entities
S 6826. Local plans
Subpart 3. National Activities
S 6861. National professional development project
Subpart 4. Definitions
S 6871. Eligible entity
Part B. Improving Language Instruction Educational Programs
Subpart 1. Program Development and Enhancement
S 6911. Financial assistance for language instruction educational programs
S 6912. Program enhancement activities
S 6913. Comprehensive school and systemwide improvement activities
S 6914. Applications
Subpart 2. Research, Evaluation, and Dissemination
S 6931. Authority
Subpart 3. Professional Development
S 6951. Professional development grants
Subpart 4. Emergency Immigrant Education Program
S 6967. Uses of funds
Part C. General Provisions
S 7011. Definitions
Subchapter V. Promoting Informed Parental Choice and Innovative Programs
Part A. Innovative Programs
Subpart 3. Local Innovative Education Programs
S 7215a. Administrative authority
Part D. Fund for the Improvement of Education
Subpart 1. Fund for the Improvement of Education
S 7243. Programs authorized
Subpart 2. Elementary and Secondary School Counseling Programs
S 7245. Elementary and secondary school counseling programs
Subpart 3. Partnerships in Character Education
S 7247. Partnerships in character education program
Subpart 4. Smaller Learning Communities
S 7249. Smaller learning communities
Subpart 6. Gifted and Talented Students
S 7253c. Authorized programs
Subpart 7. Star Schools Program
S 7255c. Applications
S 7255f. Definitions
Subpart 8. Ready to Teach
S 7257. Grants
Subpart 11. Community Technology Centers
S 7263a. Eligibility and application requirements
Subpart 13. Excellence in Economic Education
S 7267b. Grant program authorized
Subpart 15. Arts in Education
S 7271. Assistance for arts education
Subpart 16. Parental Assistance and Local Family Information Centers
S 7273e. Local family information centers
Subpart 21. Women's Educational Equity Act
S 7283b. Programs authorized
S 7283c. Applications
S 7283d. Criteria and priorities
Subchapter VI. Flexibility and Accountability
Part A. Improving Academic Achievement
Subpart 1. Accountability
S 7301a. Grants for enhanced assessment instruments
Subchapter VII. Indian, Native Hawaiian, and Alaska Native Education
Part A. Indian Education
Subpart 2. Special Programs and Projects to Improve Educational
Opportunities for Indian Children
S 7441. Improvement of educational opportunities for Indian children
S 7442. Professional development for teachers and education professionals
Subchapter VII. Indian, Native Hawaiian, and Alaska Native Education
Part A. Indian Education
Subpart 3. National Activities
S 7451. National research activities
S 7452. In-service training for teachers of Indian children
S 7453. Fellowships for Indian students
Subpart 4. Federal Administration
S 7473. Preference for Indian applicants
Part B. Native Hawaiian Education
S 7512. Findings
S 7515. Program authorized
Subchapter IX. General Provisions
Part A. Definitions
S 7801. Definitions
S 7803. Applicability to Bureau of Indian Affairs operated schools
Part E. Uniform Provisions
Subpart 2. Other Provisions
S 7908. Armed Forces recruiter access to students and student recruiting
information
Chapter 73. Adult Education and Literacy
Subchapter I. Adult Education and Family Literacy
S 9202. Definitions
Chapter 76. Education Research, Statistics, Evaluation, Information, and
Dissemination
Subchapter I. Education Sciences Reform
S 9501. Definitions
Part A. Institute of Education Sciences
S 9514. Office of the Director
S 9516. National Board for Education Sciences
Part C. National Center for Education Statistics
S 9544. Performance of duties
S 9546. Dissemination
Part D. National Center for Education Evaluation and Regional Assistance
S 9562. Commissioner for education evaluation and regional assistance
S 9564. Regional educational laboratories for research, development,
dissemination, and technical assistance
Part F. General Provisions
S 9579. Fellowships
Title 22. Foreign Relations and Intercourse
Chapter 33. Mutual Educational and Cultural Exchange Program
S 2460. Bureau of Educational and Cultural Affairs
S 2462. Establishment of grant program for foreign study by American
college students of limited financial means
Chapter 55. Research and Training for Eastern Europe and the Independent
States of the Former Soviet Union
S 4502. "Institution of higher education" and "Advisory Committee" defined
S 4504. Authority to make payments; purposes
Chapter 57. United States Scholarship Program for Developing Countries
S 4701. Statement of purpose
S 4703. Scholarship program authority
S 4706. Policy regarding other international educational programs
S 4707. Establishment and maintenance of counseling services
S 4709. General authorities
Title 23. Highways
Chapter 5. Research, Technology, and Education
S 504. Training and education
Title 25. Indians
Chapter 1. Bureau of Indian Affairs
S 13. Expenditure of appropriations by Bureau
Chapter 20. Tribally Controlled College or University Assistance
S 1801. Definitions
Subchapter I. Tribally Controlled Colleges or Universities Grant Program
S 1809. Effect on other programs
Subchapter II. Tribally Controlled College or University Endowment Program
S 1832. Establishment of program; program agreements
Title 29. Labor
Chapter 14. Age Discrimination in Employment
S 623. Prohibition of age discrimination
Chapter 16. Vocational Rehabilitation and Other Rehabilitation Services
S 705. Definitions
S 718. Traditionally underserved populations
Subchapter I. Vocational Rehabilitation Services
Part A. General Provisions
S 721. State plans
S 723. Vocational rehabilitation services
Subchapter II. Research and Training
S 762. National Institute on Disability and Rehabilitation Research
S 764. Research and other covered activities
Subchapter III. Professional Development and Special Projects and
Demonstrations
S 772. Training
S 773. Demonstration and training programs
Chapter 31. Assistive Technology for Individuals with Disabilities
S 3002. Definitions
S 3003. State grants for assistive technology
S 3005. National activities
Title 30. Mineral Lands and Mining
Chapter 25. Surface Mining Control and Reclamation
Subchapter VII. Administrative and Miscellaneous Provisions
S 1291. Definitions
Subchapter VIII. University Coal Research Laboratories
S 1311. Establishment of university coal research laboratories
S 1312. Financial assistance
S 1313. Limitation on payments
S 1314. Payments; Federal share of operating expenses
S 1315. Advisory council on coal research
Subchapter IX. Energy Resource Graduate Fellowships
S 1321. Fellowship awards
S 1322. Fellowship recipients
S 1323. Distribution of fellowships
S 1324. Stipends and allowances
S 1326. Fellowship conditions
Title 33. Navigation and Navigable Waters
Chapter 26. Water Pollution Prevention and Control
Subchapter I. Research and Related Programs
S 1259. Training grants and contracts
S 1260. Applications; allocation
S 1261. Scholarships
S 1262. Definitions and authorizations
Title 37. Pay and Allowances of the Uniformed Services
Chapter 7. Allowances
S 430. Travel and transportation: dependent children of members stationed
overseas
Title 39. Postal Service
Part IV. Mail Matter
Chapter 36. Postal Rates, Classes, and Services
Subchapter I. Provisions Relating to Market-Dominant Products
S 3626. Reduced rates
Title 40. Public Buildings, Property, and Works
Subtitle I. Federal Property and Administrative Services
Chapter 5. Property Management
Subchapter I. Procurement and Warehousing
S 502. Services for other entities
Title 42. The Public Health and Welfare
Chapter 6A. Public Health Service
Subchapter III-A. Substance Abuse and Mental Health Services
Administration
Part B. Centers and Programs
Subpart 2. Center for Substance Abuse Prevention
S 290bb-25b. Programs to reduce underage drinking
Subpart 3. Center for Mental Health Services
S 290bb-36. Youth suicide early intervention and prevention strategies
S 290bb-36b. Mental and behavioral health services on campus
Chapter 16. National Science Foundation
S 1862i. Scientific and technical education
S 1869c. Low-income scholarship program
Chapter 35. Programs for Older Americans
Subchapter I. Declaration of Objectives and Definitions
S 3002. Definitions
Subchapter II. Administration on Aging
S 3011. Establishment of Administration on Aging
S 3012. Functions of Assistant Secretary
Subchapter IV. Activities for Health, Independence, and Longevity
Part A. Grant Programs
S 3032. Program authorized
S 3032a. Career preparation for the field of aging
S 3032c. Health care service demonstration projects in rural areas
S 3032d. Computer training
S 3032g. Native American programs
Subchapter XI. Allotments for Vulnerable Elder Rights Protection
Activities
Part C. General Provisions
S 3058cc. Administration
Chapter 46. Justice System Improvement
Subchapter II. National Institute of Justice
S 3722. National Institute of Justice
Subchapter III. Bureau of Justice Statistics
S 3732. Bureau of Justice Statistics
Subchapter IX. Definitions
S 3791. General provisions
Chapter 77. Energy Conservation
Subchapter III. Improving Energy Efficiency
Part B. State Energy Conservation Plans
S 6322. State energy conservation plans
Chapter 84. Department of Energy
Subchapter VI. Administrative Provisions
Part C. General Administrative Provisions
S 7274e. Scholarship and fellowship program for environmental restoration
and waste management
Chapter 85. Air Pollution Prevention and Control
Subchapter II. Emission Standards for Moving Sources
Part A. Motor Vehicle Emission and Fuel Standards
S 7545. Regulation of fuels
Chapter 105. Community Services Programs
Subchapter II. Head Start Programs
S 9844. Research, demonstrations, and evaluation
Subchapter IV. Grants to States for Planning and Development of Dependent
Care Programs and for Other Purposes
S 9874. Use of allotments
S 9877. Definitions
Chapter 123. Drug Abuse Education and Prevention
Subchapter IV. Miscellaneous
S 11851. Definitions
Chapter 129. National and Community Service
Subchapter I. National and Community Service State Grant Program
Division A. General Provisions
S 12511. Definitions
Division B. School-Based and Community-Based Service-Learning Programs
Part II. Higher Education Innovative Programs for Community Service
S 12561. Higher education innovative programs for community service
Division C. National Service Trust Program
Part I. Investment in National Service
S 12571. Authority to provide assistance and approved national service
positions
S 12572. Types of national service programs eligible for program
assistance
S 12573. Types of national service positions eligible for approval for
national service educational awards
Part II. Application and Approval Process
S 12581. Provision of assistance and approved national service positions
by competitive and other means
S 12582. Application for assistance and approved national service
positions
Part III. National Service Participants
S 12591. Description of participants
S 12592. Selection of national service participants
Division D. National Service Trust and Provision of National Service
Educational Awards
S 12602. Individuals eligible to receive a national service educational
award from the Trust
S 12604. Disbursement of national service educational awards
Division E. Civilian Community Corps
S 12626. Definitions
Division G. Corporation for National and Community Service
S 12651f. Employees, consultants, and other personnel
Division H. Investment for Quality and Innovation
S 12653. Additional Corporation activities to support national service
Chapter 136. Violent Crime Control and Law Enforcement
Subchapter VIII. Police Corps and Law Enforcement Officers Training and
Education
Part A. Police Corps
S 14092. Definitions
S 14095. Scholarship assistance
S 14096. Selection of participants
Part B. Law Enforcement Scholarship Program
S 14111. Definitions
S 14113. Establishment of program
S 14114. Scholarships
S 14116. State application
Chapter 149. Energy Policy, 2005
S 15801. Definitions
Subchapter IV. Coal
Part A. Clean Coal Power Initiative
S 15964. Clean coal centers of excellence
Part B. Clean Power Projects
S 15977. Department of Energy transportation fuels from Illinois basin
coal
Subchapter VI. Nuclear Matters
Part B. Next Generation Nuclear Plant Project
S 16022. Project management
Subchapter VII. Vehicles and Fuels
Part A. Existing Programs
S 16051. Joint flexible fuel/hybrid vehicle commercialization initiative
Subchapter VIII. Hydrogen
S 16151. Purposes
S 16154. Programs
S 16161. Solar and wind technologies
Subchapter IX. Research and Development
S 16181. Goals
S 16182. Definitions
Part A. Energy Efficiency
S 16192. Next Generation Lighting Initiative
Part B. Distributed Energy and Electric Energy Systems
S 16215. Electric transmission and distribution programs
Part C. Renewable Energy
S 16232. Bioenergy program
Part E. Nuclear Energy
S 16272. Nuclear Energy Research Programs
Part F. Fossil Energy
S 16291. Fossil energy
S 16294. Research and development for coal mining technologies
S 16296. Low-volume oil and gas reservoir research program
Part G. Science
S 16320. Spallation Neutron Source
S 16324. Energy research fellowships
Part H. International Cooperation
S 16341. Western Hemisphere energy cooperation
Part I. Research Administration and Operations
S 16353. Merit review of proposals
Part J. Ultra-Deepwater and Unconventional Natural Gas and Other Petroleum
Resources
S 16372. Ultra-deepwater and unconventional onshore natural gas and other
petroleum research and development program
Subchapter X. Department of Energy Management
S 16392. Technology Infrastructure Program
S 16394. Outreach
Subchapter XI. Personnel and Training
S 16414. National Power Plant Operations Technology and Educational Center
Subchapter XVI. Studies
S 16522. Low-volume gas reservoir study
Chapter 150. National Aeronautics and Space Programs
Subchapter III. Science
Part B. Remote Sensing
S 16671. Definitions
S 16676. Education
Subchapter IV. Aeronautics
S 16701. Definition
Part B. High Priority Aeronautics Research and Development Programs
S 16721. Fundamental research program
S 16727. University-based Centers for Research on Aviation Training
Part C. Scholarships
S 16741. NASA aeronautics scholarships
Title 47. Telegraphs, Telephones, and Radiotelegraphs
Chapter 5. Wire or Radio Communication
Subchapter II. Common Carriers
Part I. Common Carrier Regulation
S 223. Obscene or harassing telephone calls in the District of Columbia or
in interstate or foreign communications
Title 50. War and National Defense
Chapter 15. National Security
Subchapter VII-A. Education in Support of National Intelligence
Part A. Science and Technology
S 441g-2. Intelligence Community Scholarship Program
Chapter 37. National Security Scholarships, Fellowships, and Grants
S 1902. Scholarship, fellowship, and grant program
S 1903. National Security Education Board
S 1908. Definitions
Source: GAO Analysis of the United States Code.
Appendix III: Comments from the Department of Education
Appendix IV: GAO Contacts and Staff Acknowledgments
GAO Contacts
George Scott, (202) 512-5932 or [26][email protected] Dayna Shah, (202)
512-8208 or [27][email protected]
Staff Acknowledgments
Jeff Appel and Patrick DiBattista, Assistant Directors; and Susan Chin,
Analyst-in-Charge; managed this assignment. Nora Boretti, Sheila McCoy,
and Carlo Salerno made significant contributions to this report. In
addition, Yumiko Jolly and Kathy Leavitt provided assistance in data
collection and analysis; Susannah Compton provided writing assistance; and
Richard Burkard provided legal assistance.
(130551)
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Highlights of [35]GAO-07-857 , a report to congressional requesters
July 2007
HIGHER EDUCATION
Including Public, Nonprofit, and For-Profit Institutions in a Single
Definition Is Unlikely to Immediately Affect Federal Spending, but
Long-term Effects Are Unclear
The Higher Education Act (HEA) defines "institution of higher education"
to include public, nonprofit, and for-profit institutions, allowing
students at these institutions access to $83.1 billion in aid. However,
the act also includes a second, narrower definition of institution of
higher education specifically excluding for-profits from access to nearly
$1.96 billion in other funding.
During the 109th Congress, legislation proposed consolidating the two
definitions. In response to a congressional request, this report examines
the extent to which a single definition might affect federal spending,
other aspects of applicable federal programs, as well as state-level
programs and policies.
To address these objectives, GAO searched the U.S. Code to identify
federal statutes and programs potentially affected by a change in
definition, conducted in-depth reviews of programs and policies, and
interviewed relevant officials.
[36]What GAO Recommends
GAO does not make recommendations in this report. The Department of
Education stated that a single definition could increase federal spending
by increasing access to some special postal rates and tax benefits. GAO
does not believe that the former is likely; the tax code does not rely on
the HEA definitions of institution of higher education.
Given that GAO's review of references to the narrower HEA definition did
not identify any mandatory spending or entitlement programs, it is
unlikely that a single definition would immediately increase federal
spending; however, more for-profit institutions may become eligible to
compete for federal funds and participate in various aspects of certain
federal programs. GAO's searches of the U.S. Code to identify federal
statutes and related programs that could be affected by the adoption of a
single definition yielded numerous federal statutes referring to the HEA
definition that limits participation to public and nonprofit institutions.
However, these references appear to be tied to discretionary programs
funded through annual appropriations, not mandatory spending or
entitlement programs. Accordingly, adopting a single definition will not
immediately increase federal spending.
Although a single definition could affect federal programs by allowing
some for-profit institutions to apply for discretionary funds, many
federal programs may be unlikely to witness greater competition because
for-profit institutions generally lack the kinds of academic programs that
would qualify for such grants. While federal spending is not likely to
increase, some of the provisions GAO identified were funding-related and,
as such, could also affect program administration or increase competition
for program resources. For example, some of the provisions relate to
forming partnerships to pursue funding, and under a single definition,
for-profit institutions could become a potential partner. In a limited
number of cases, the provisions GAO identified were not connected to
federal funding, but under a single definition could expand the pool of
eligible participants for some program activities.
A single federal definition is unlikely to immediately affect state
programs but could potentially affect state higher education programs and
policies in the future. State statutes and regulations generally do not
reference the federal definition when establishing eligibility criteria
for state higher education programs, and officials in several states told
GAO that an institution's for-profit status is less important than other
factors when determining state program eligibility. State officials told
GAO that the likely effects of a single definition were greater
competition for funding and greater political influence for for-profit
higher education institutions.
The effects of a single definition on the American higher education system
over a longer time frame are difficult to predict. For example, states
might align their own policies to match the definition; for-profit
institutions might expand their research programs; and Congress might
decide to increase funding for existing discretionary programs. As policy
makers address questions about access, they will want to remain aware of
these diverse costs and benefits.
References
Visible links
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25. http://www.gao.gov/
26. mailto:[email protected]
27. mailto:[email protected]
28. http://www.gao.gov/
29. http://www.gao.gov/
30. http://www.gao.gov/fraudnet/fraudnet.htm
31. mailto:[email protected]
32. mailto:[email protected]
33. mailto:[email protected]
34. http://www.gao.gov/cgi-bin/getrpt?GAO-07-857
35. http://www.gao.gov/cgi-bin/getrpt?GAO-07-857
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