Consortium of ABA-accredited Propriety Law Schools
Prior to the release of the Department of Education’s Notice of Proposed Rulemaking (NPRM) on Gainful Employment, Cornerstone was engaged by a consortium of three bricks-and-mortar, ABA-accredited proprietary law schools, who was concerned about the rule and its possible effect on its schools. Cornerstone was asked to develop and carry out a strategic plan to impact the NPRM and any and all future regulation and legislation.
Prior to its engagement of Cornerstone, our client had little to no interaction with Washington and therefore had few relationships on the Hill or in the Administration. Knowing they had to crawl before they could run, we designed a targeted outreach campaign in order to raise their profile.
Because we began our campaign so late in the game, there was little opportunity for direct interaction with the Department. Additionally, compared with the industry writ large, the proprietary law school sector is so small that we were unlikely to impact the rule on a broad level (or have any effect on the Department). Therefore, it was imperative that we impacted members and staff from the schools’ districts who regularly worked and communicated with those crafting the rule. By working with Senate HELP Committee staff and educating House and Senate members as to what it means to be an ABA-accredited law school, we were able to bring attention to our small sector. Throughout the process we remained in close contact with HELP staff, if at times only to gather information. We worked with Members of the Senate who, although perhaps outwardly unwilling to help, weighed in on our behalf and discussed our concerns.
Although ABA-accredited law schools were not exempted from the final rule, the Department did include a number of favorable graduate school-specific provisions (loan debt is program and school specific; borrowers with consolidation loans need only pay down interest; amortization schedule now 20 years for doctoral and first-professional degree programs—not 10 for all programs, as originally proposed). In post-rule discussions with HELP staff it was clear the Department heard our argument and made changes on our client’s behalf.