We are aware of the recent update from the Department of Education (DoE) initiating a review of the 2011 “Dear Colleague” letter that provides guidance for revenue-sharing agreements and third-party servicers (TPS). The DoE will hold public listening sessions beginning on March 8 and 9, 2023. EIM will participate in these sessions. While we don’t know what, if any, changes to the guidance may result from these or future sessions, we remain highly confident that the nature of our partnerships, services we provide, and value we create for our Partners should not be materially impacted.
- Our partnerships have always been and will always be a collaborative framework of shared goals. Our Partners ultimately have 100% control and ownership over establishing tuition, making admissions decisions, hiring faculty, approving curriculum, etc.
- Our partnerships are built around a robust set of services that easily meets today’s criteria for the bundled services exception.
- Our partnerships include a suite of comprehensive services necessary to help our Partners unlock the transformative potential of graduate health care programs in higher education.
We fully expect that this notice and upcoming hearings will trigger an increase in discussion and debate as to the impact and value businesses that partner with higher education institutions to develop and launch degree programs. Unfortunately, many of the concerns expressed by regulators and dissenting parties have not changed in the last 10+ years. Thankfully, leadership at our Partner institutions is helping to innovate in a meaningful and highly impactful manner.
- The DoE suggests that programs built through partnerships drive up tuition costs. Quite the opposite is true with our Partners and partnerships. For example, the Doctor of Physical Therapy program at our Partner institutions is two years in length compared to three years for the typical and traditional DPT program. Our Partner DPT programs help to reduce overall tuition by at least 33%.
- The DoE contends that programs built through partnerships do not support gainful employment of their graduates. EIM supports our Partners in delivering hybrid, accelerated graduate healthcare programs that get students licensed and into the workforce sooner at significantly lower costs than virtually all of their non-OPM-supported peers. For example, almost 100% of our Partner DPT program graduates are employed and/or have employment opportunities upon matriculation. Furthermore, our estimates suggest they gain an additional $150,000 in earnings over the first 15 years of their career when compared to their peers who graduated from traditional programs. This is due in part to the reduced student debt burden only possible because of the accelerated path to degree.
- The DoE doesn’t acknowledge the tremendous expansion in access to higher education created by our Partner programs. Today, affluent Caucasian individuals grossly overrepresent graduate healthcare education. The programs we partner to develop are hybrid graduate healthcare programs that allow students in every community to enroll in our Partner programs and pursue a healthcare career. As a result, our Partner programs attract significantly higher rates of candidates and students of racial and ethnic minority. For example, 15% of students enrolled in our Partner DPT programs are black, compared to 3% in traditional programs, equating to a 400% increase. Furthermore, 30% of students in our Partner programs identify as economically disadvantaged. This is helping to not just change higher education, but drive a positive shift in the makeup of the PT profession.
- The DoE doesn’t acknowledge the creation of critical services and support of underserved communities that our Partner programs underpin. We help our Partners extend a model to individuals that encourages them to become successful practitioners back in the communities where they reside. Because of our hybrid educational model, we can provide access to healthcare graduate programs to communities and individuals that are in ‘education deserts’. As an example, 82% of our Partner program out-of-state students come from underserved states where the local educational supply cannot and will not meet workforce demands, particularly in healthcare professions.
- The DoE doesn’t acknowledge the success of our Partner programs using measures they say are key for their typical and traditional programs. Our Partner programs result in stellar outcomes, including 95%+ graduation rates, 98%+ licensure rates, and 100% employment.
Despite the spotlight in our space, our partnerships represent the best in innovation, accessibility, and affordability. They have unfortunately become an easy target for political officials to score points with their constituents, who typically represent the largest institutions in the industry. While we agree that higher education needs radical reform, eliminating arrangements that include revenue share components will only hurt the smaller, innovation-minded institutions. In contrast, we believe it helps the most prominent brands become more entrenched, minimizing the type of reform needed in higher education. Only the most renowned institutions have the capital necessary to support the significant investment required to develop accessible graduate healthcare programs that serve our diverse population.
EIM will always comply with all guidelines that are deemed relevant and work to support our Partners to remain in good standing with their respective oversight bodies.