Looking in All the Wrong Places: College Oversight Source Documents

The analysis in “Looking in All the Wrong Places: How the Monitoring of Colleges Misses What Matters Most” is based upon a Freedom of Information Act, or FOIA, request filed by the Center for American Progress. To help readers better understand our findings and analysis, as well as conduct their own reviews, we are making the documents received through the request publicly available below.

We initiated our FOIA request with the U.S. Department of Education in May 2014.Specifically, we sought documents that higher education institutions periodically submit to the department in order to maintain eligibility for financial aid for students. We understood those documents to include: (1) an application signed by the head of an institution, which, among other things, declares intent to comply with various rules and regulations; (2) an annual audited financial statement; and (3) an annual compliance audit. We asked for an electronic file of these documents for “all institutions” that participate in student aid programs.

In response to the FOIA request, Department of Education staff informed us that the documents reside at regional offices and are not available in electronic form. Given the enormous volume of documents, they asked whether we could narrow our request. We agreed to revise it to the documents from the 100 largest nonpublic institutions handled by three of the agency’s regional offices: San Francisco; Kansas City, Missouri; and Philadelphia. In response, we ultimately received more than 6,000 pages of documents featuring information on 130 institutions and companies; this was the most recently available information at the time of our request.

To help the public understand the information received through our FOIA request, we have organized the documents by the entity that controls a college or group of colleges. In other words, the documents for the 17 campuses under the Everest College brand are all grouped under those schools’ owner at the time—Corinthian Colleges Inc.

Private, nonprofit institutions are labeled by the college name, and for-profit education companies are labeled by the owning company name, with a list of all the colleges included in the batch of documents. This index includes the following:

• Applications from 72 institutions to participate in federal financial aid programs. These are printouts of the electronic applications that college officials had completed at the time of the request. We also received the most recent—at the time of the request—Eligibility and Certification Approval Report, or ECAR, for 24 institutions. Department of Education staff generates this document, which details information about an institution’s leadership and accreditation, its programs, and the types of financial aid that students enrolled in those programs are eligible to receive.
• Compliance audits for 121 institutions. These documents determine if the entity is meeting specific rules or standards set in law. In some cases, these were included as part of audited financial statements; more often, they were stand-alone documents.
• Audited financial statements for 37 institutions or companies. These documents detail an institution’s financial condition at a particular point in time.

In general, compliance audits covered one college within a chain of colleges, while financial statements covered an enterprise as a whole. This distinction explains the large differences in the number of documents for each of the three types.

Elizabeth Baylor is the Director of Postsecondary Education at the Center for American Progress.