The U.S. Department of Education is preparing to set new policy by releasing its gainful employment rule.  Its purported intent is to reduce the number of students who graduate from private sector and proprietary colleges with starting salaries that are below a set threshold for repaying their student loans.

Explaining why students choose an education that does not “pay off” (by certain standards) is a challenge. The assumptions behind the rule-setting appear to be ones like these: that private sectors schools are providing poor preparation for some graduates despite their hard work, thereby leaving them ill-prepared for the job market; that private sector schools are admitting students who are poor candidates for the job market; and that private sector schools are encouraging students to take out loans that they cannot repay.

For most students and graduates of private sector schools, such assumptions appear to be patently wrong.  They are satisfied with their education and happy with the jobs they now have.  Nevertheless, the gainful employment rule, if issued, would still apply to these satisfied students, thereby limiting access to job-related education and training when it is most needed in a tough economy.

Explaining student behavior is often harder than simple assumptions would suggest.  In April, the National Bureau of Economic Research issued a report, Increasing Time to Baccalaureate Degree in the U.S., which attempts to unravel student behavior associated with time-to-degree. The assumptions about longer time-to-degree include declining student preparedness, rising costs of a college education, and increasing numbers of students from lower income families.  In fact, what the research found was that students take more time to obtain a degree today as a result of public schools’ declining institutional resources and the increased working behavior of today’s students.

Student behavior – like most human behavior – is complicated to explain but, subjected to rigorous research, it can be better understood.  And better understanding of student behavior is essential for sound policy.  The U.S. Department of Education should undertake thorough research before implementing rules like the potential gainful employment rule, based on unproven assumptions, that decreases access to needed career-related education.