college, inc.

FEATURED LESSON PLAN: Policy Analysis: The ‘Gainful Employment’ Rule



In this lesson, students will watch a video clip that shows a single mother struggling to repay her student loans, discuss the cause of her debt load, and work on a mock policy committee to evaluate a proposed rule designed to help others avoid this situation. For background information on the “gainful employment” rule discussed in the main activity, please see Related Resources.


Subject Area:

Social Studies, Language Arts, Government/Civics, Economics


Grade Level:

Grades 9-12



    The student will:
  • Examine why many students of for-profit colleges and universities carry a heavy debt load
  • Explore the positions of various stakeholders regarding the gainful employment rule proposed by the U.S. Department of Education
  • Analyze the costs and benefits of the Department of Education’s proposal
  • Recommend whether or not the gainful employment rule should be enacted


Estimated Time Needed:

Two 50-minute class periods, plus homework time


Materials Needed:




  • For homework the night before this lesson, ask students to read the handout, The “Gainful Employment” Rule.
  • Begin the lesson by showing the class Chapter Three of College, Inc., “The Sales and Marketing Story.” Ask students to take notes on the situation faced by Anne Cobb, a single mother who is having trouble repaying her college loans.
  • Ask the class who or what is responsible for Ms. Cobb’s heavy debt load. (Herself? High tuition that requires substantial borrowing? Easy access to federal student loans? Low income post graduation?, etc.) Discuss student ideas.
  • Explain that the U.S. Department of Education regulates higher education and has proposed a rule it hopes will help people like Anne Cobb. Students are going to simulate a process used by policy-makers to analyze a proposed rule and provide feedback on whether it is an appropriate solution to a given problem. In this case, they will examine the gainful employment rule proposed by the U.S. Department of Education and recommend whether or not it should be enacted. Distribute the remaining handouts and review the steps for the activity.
  • Assign each student one of these seven stakeholder roles:
    • Representative from the U.S. Department of Education (ED)
    • Former student of a for-profit college who had a positive experience
    • Former student of a for-profit college who had a negative experience
    • For-profit higher-education industry lobbyist
    • Congressional representative who is critical of for-profit education institutions and concerned about low-income and minority students
    • Congressional representative who is critical of the ED proposal
    • Congressional representative who is concerned that the ED is overstepping its authority
  • Organize groups that include at least one of each type of stakeholder.
  • Have each group proceed through the activity to develop its recommendation. If time permits, have each group present its recommendation to the entire class.
  • Ask students to complete the agreement form individually.



This teacher’s guide was developed by Cari Ladd. It was written by Greg Timmons. Advisers were Satinder Hawkins of Millikan High School in Long Beach, Calif., and Mark Pearcy of Braden River High School in Bradenton, Fla.


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