November 25, 2015

Ms. Teri Stanfill
Executive Director
Arizona State Board for Private Postsecondary Education
1400 W. Washington Street, Room 260
Phoenix, AZ 85007

RE:

Federal Express
Tracking Number
806073837520

Request for Information

Dear Ms. Stanfill:
The U.S. Department of Education (Department) is conducting an assessment of placement rate
and graduation rate claims made by certain post-secondary educational institutions. This
assessment is designed to evaluate whether those institutions are complying with the Student
Right-to-Know Act (P.L. 101-542) requirements and other relevant criteria in calculating and
disclosing on-time graduation rates and placement rates, including calculations and disclosures
made to institutional accreditors, programmatic accreditors, and state agencies. To that end, the
Department hereby requests the following information related to job placement requirements for
institutions licensed by the Arizona State Board for Private Postsecondary Education (the State
Board). Please respond to each of the following requests separately and in writing.
Placement Rate Calculation Requirements
A. Please describe any requirements that the State Board has for institutions to provide
placement information for students completing an institution’s programs. Examples
could include, but are not limited to, the calculation and submission of a placement rate
to the State Board, or the reporting of student-level outcomes without calculating a rate.
Please describe each such circumstance as specifically as possible.
Placement Rate Calculation Exceptions
B. Please describe any circumstances in which an institution is not required to provide
placement information for students completing its programs. Examples could include,
but are not limited to, institutions that are in teach out or programs with small cohorts of
completers. Please describe each such circumstance as specifically as possible (e.g., how
many students must a cohort contain before the institution is required to provide
placement information).

830 First Street, NE, Washington, DC 20202
StudentAid.gov

 Arizona State Board for Private Postsecondary Education
Page 2 of 3

Placement Rate Calculation Backup Documentation
C. Please describe the backup documentation requirements for institutions with respect to
data submitted to the State Board and used to calculate placement rates for member
campuses and program cohorts. Please respond to this inquiry generally, and also
provide specific answers to the following questions:
1. Please indicate whether any institutions are required to submit backup data to the
State Board;
a. If so, under what circumstances?
b. Please fully describe the documentation requirements.
2. Please indicate whether any institutions are required to have an independent thirdparty verify placement data prior to, or concurrent with its submission to the State
Board;
a. If so, under what circumstances?
b. Please fully describe the documentation requirements.
3. Please discuss the requirements for maintaining backup data on site at member
institutions with respect to placement data:
a. Please fully describe the requirements, including how long such data
must be maintained and whether student-by-student data must be
maintained (as opposed to summaries of cohorts).
b. Are written attestations acceptable without additional documentation?
Verbal attestations?
c. Is there any difference between the documentation required for
placements versus the documentation required to count a student as an
“exception” and unavailable for placement?
4. Does the State Board require that any institution have an internal audit procedure
with respect to placement rate data?
a. If so, under what circumstances?

 Arizona State Board for Private Postsecondary Education
Page 3 of 3

Request for Documents
D. Please provide a copy of all documents which reasonably tend to support the existence of
the policies and procedures you have described above, including without limitation the
State Board standards of licensure (and, if those standards have changed in the last three
years, copies of the prior standards), minutes of meetings wherein the policies and
procedures were adopted, and similar documents. For documents which are responsive to
this request that are available online, the State Board may provide a working hyperlink to
the document in lieu of providing a copy. For the purposes of this request, please
construe the term “documents” in a broad sense.
The Department’s assessment is time sensitive. Therefore, please submit this information within
seven calendar days from the date of this letter. You may submit your response electronically to
Michael Powers of my staff, at michael.e.powers@ed.gov.

Thank you for your assistance in this matter.
Sincerely,

Michael Frola
Division Director
Multi-Regional and Foreign School Participation Division