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Organic Food to Student Outcomes – a Conflict or Serving the Public Good?

The question: We’ve been asked if it is a conflict of interest for Skills Fund to facilitate efforts to create clear student outcomes reporting standards.

The answer: Is it a conflict of interest for Whole Foods to facilitate a standards setting process to define what organic and sustainable farming means for its supplier base? No.

It is Whole Foods doing well by doing good: helping an entire industry of farmers follow best practices so that consumers are protected (and benefiting Whole Foods' competitors in the process, as competitors source products from the same producers Whole Foods assisted in raising standards for).

Is it likely that by helping farmers follow best practices, and then sourcing enough product to meet those high standards, will attract more customers? Sure - they are making the pie bigger for everyone (including their competitors) while enabling informed, confident consumer decisions and improving agriculture and environmental policy – it's a win, win, win.

Similarly, Skills Fund facilitated the creation of an outcomes reporting standard because we are confident standards are in the best overall interest of students (many who are not our customers because they pay tuition in cash or finance it with one of our competitors) and the bootcamp industry as a whole (which includes bootcamps that our customers turn to in order to improve their lives).

If more students trust that the outcomes bootcamps tout are accurate and real, and not deceptive marketing gimmicks, will more people enroll in bootcamps (and a subset need a loan to facilitate access)? Sure. That's not creating a conflict of interest, but raising up an entire ecosystem that is a win for students, a win for bootcamps, and win for all entities facilitating student access.

CIRR is now up to 31 members, and we have major tech companies, nonprofits focused on employing under-represented populations in tech, and even four-year public universities seeking to join this effort. Why?

Prospective CIRR members clearly understand how important this is to the entire ecosystem, embrace high standards for outcomes reporting, and understand self-regulation is the only viable route to real industry regulation and reform.

These schools are subject to 50 different state regulatory requirements (many of which are ill suited to bootcamps as they were designed decades ago for proprietary schools) and it is inconceivable that all 50 states will ever agree to the same regulatory approach. State regulatory inconsistency is compounded by no federal jurisdiction to regulate this industry. Yes, the Federal Trade Commission (FTC) is actively investigating bootcamps for truth-in-advertising claims, but it has no authority to tell bootcamps to all use a particular outcomes reporting methodology.

Having been the chief consumer protection official in Colorado (with two-thirds of the state Attorney General's [AG] budget spent on cases my department decided to bring against bad actors), the former higher ed chief in Colorado that included oversight of schools like bootcamps, and now on the federal government's board that regulates college accrediting agencies, other than CIRR, I cannot think of any truly viable approach that will properly regulate this industry in the next three years (which is an eternity for the FTC and state AG's to go after bad actors in the space, generate lots of headlines, and potentially lead to the sullying of the entire industry and good schools in the process).

Additionally, we are thrilled that there are schools engaged with CIRR that have no student financing partnership with Skills Fund, as CIRR is another in a long line of successful standards setting initiatives (environmental, developing country factory labor, trade) that are designed to promote the public good.

We truly believe every post-secondary and workforce development program should report results using the CIRR standards. For example, someone considering attending law school deserves to know in a simple, apples-to-apples way which school will produce the outcome he/she seeks - how many students in this program graduate on time, how many get jobs quickly, and what type of jobs they secure.

In the near term, CIRR is focused on bootcamps, but the power in its standards is that it could easily apply to much of higher education and workforce development.

Learn more about CIRR here.