312-page report by Mary Lyn Hammer,
indexed, glossary, 96 data and image tables, Independent Accountants’ Report Verification conducted by Kaiser and Carolin, P.C.
Publisher: Champion Empowerment Institute
ISBN: 978-0-9970978-0-1 (paperback)
ISBN: 978-0-9970978-1-8 (ebook)
CONTACT: CHAMPION COLEDGE SOLUTIONS
Email: [email protected]
Injustice for All Reader’s Notes for Executives, Journalists and Bloggers
Ms. Hammer is an expert resource for journalists who need reliable answers to tough questions about how the U.S. government handles student loans, cohort default rates, higher education loan regulations, and financial literacy, and about education legislation.
For more information, to obtain a review copy, schedule an interview, and/or to book Ms. Hammer to speak to your group, please contact John White by email at Joh[email protected] or by phone at 480.222.4314.
Click here to order the report in printed or ebook formats.
From the desk of education advocate, CEO, and entrepreneur, Mary Lyn Hammer, comes a book to provide us with solid independently-verified evidence on the corruption in higher education reporting.
Protect the future of our country by examining all of the evidence—our current belief system about education may or may not be based upon accurate data facts.
Injustice for All is a 312-page indexed report with 96 data and image tables that takes you on a journey through well-documented evidence of the U.S. Department of Education’s (DOE) consistent pattern of data manipulation, misreporting, and a strategic lack of reporting that drive the agendas that threaten to annihilate American education ideals.
Ms. Hammer has diligently prepared this audited evidence of the truth—that the DOE’s publicly available reports and press releases include manipulated data and reporting that seems to be designed to sway public opinion about sector-level performance in higher education and to hide the truth about the DOE’s own failures and substandard performance. In publishing the report, Ms. Hammer also accepted the risks to her businesses and personal reputation in bravely revealing the level of outright deception she had uncovered. Ms. Hammer was drawn to reveal the interesting consistencies of inaccurate reporting throughout multiple databases (including some that have mysteriously disappeared) which have led her to identify consistent patterns that support an anti-for-profit twofold agenda:
AGENDA ITEM #1 Eliminate the private-sector Federal Family Education Loan Program (FFELP) for federal student loans
AGENDA ITEM #2 Eliminate for-profit institutions of higher education
Agenda Item #1 was accomplished with disastrous results, ruining the financial reputations of approximately 403,000* student borrowers with defaults that never should have occurred and were the result of the DOE’s mismanagement of the transition to 100% direct lending. When Ms. Hammer personally went to DC for face-to-face meetings and made DOE officials aware of the tragedy unfolding for students who had CORRECTLY filed and been approved for deferments, forbearances, and alternate payment options, and whose status was NOT correctly transferred to the new federal conduit loan servicers, the DOE officials chose to do nothing to correct the situation and allowed innocent students to go into, and remain in, default status.
Agenda Item #2 is well on its way because the DOE has manipulated reporting to hide substandard performance at public institutions and purposefully defamed the reputations of many high-performing for-profit institutions, jeopardizing our freedom of educational choice.
Even after Ms. Hammer published her report, the DOE has continued the assault, most recently with Defense to Repayment (Docket ID ED-2015-OPE-0103), which comes in the guise of protecting student borrowers by offering loan forgiveness but goes beyond the intended mission of the DOE and the U.S. Constitution. The following excerpt is from Ms. Hammer’s July 2016 personal comments on Defense to Repayment:
I am alarmed by the Department’s departure from its mission which is blatantly evident in this proposed rule. Nowhere in the Department’s mission is any definition that could remotely be construed as authoritarian where the Department has been awarded the discretion to choose cases to bring forward (federal attorney), then decide who the hearing officer is (choose their own judge), then argue the cases (prosecutor) in front of their hearing officer of choice, and then decide the punishment (jury). Not only are the contents of this proposed rule a departure from the Department’s defined mission, it is also an alarming departure from the legal structure in America that assumes innocence until proven guilty; ensures that the accused is allowed to have a hearing in front of an unbiased selection of peers; and ensures that the terms and provisions of the Constitution are upheld.
Under these proposed rules, which also appear to be aimed primarily at proprietary schools, the following is evident:
- The Department has made itself the single authority for reviewing, organizing and bringing forth claims against schools giving itself broad discretion and complete control over every aspect of these cases. This includes organizing “classes” of litigants to bring claims even if those students themselves have not made a claim against the school. The students can be put into litigation classes without their knowledge or approval and the Department can use a students’ personal information in the claim without their knowledge or consent.
- The Department has redefined the meaning of “fraud”. Fraud is traditionally defined as “A false representation of a matter of fact—whether by words or by conduct, by false or misleading allegations, or by concealment of what should have been disclosed—that deceives and is intended to deceive another so that the individual will act upon it to her or his legal injury.”
“Fraud must be proved by showing that the defendant’s actions involved five separate elements: (1) a false statement of a material fact, (2) knowledge on the part of the defendant that the statement is untrue, (3) intent on the part of the defendant to deceive the alleged victim, (4) justifiable reliance by the alleged victim on the statement, and (5) injury to the alleged victim as a result.” (Source: http://legal-dictionary.thefreedictionary.com/fraud)
In these rules, the Department does not require “injury” or “damage” as a mandatory component of the claims. A student could have graduated, be working in the field of study, and earn within range of the earnings disclosed by the school yet still be allowed to file a claim or be included by the Department in a “class” of litigants for discharge of his or her student loan debt without his or her knowledge or consent.
- Schools have little if any options for appealing or offsetting the costs of frivolous claims, which are definitely expected to be filed. Schools have no way of reversing the damage to their reputations resulting from the “presumed guilty” nature of these regulations—once the schools have endured negative publicity from a frivolous claim, the damage has been done.
- The proposed regulations subject schools to “double jeopardy” which is strictly prohibited by the Constitution because individuals who lose a claim under a “class” have been given the right to file another claim as an individual, thus giving them two chances to file claims.
The egregious departure from the Department’s mission has also been identified by elected officials and media outlets alike.
Ms. Hammer challenges us to examine the audited information in her report to ensure the future of an American higher education system that benefits ALL citizens rather than serving political agendas.
She offers facts, evidence, AND logical solutions to reverse the defaults for innocent student borrowers, ideas to improve accountability, as well as implementable standards that protect students, schools, and the federal fiscal interest.
*After publication of Injustice for All, the estimate of 403,000 affected borrowers was updated based on methodology agreed upon in Congressional meetings.
Chapter by Chapter Executive-Level
Highlights & Points
The following highlights and points come from the Injustice for All report (©2016 Mary Lyn Hammer) and have been compiled to condense the full 312-page report into a digest format in order to give executives, journalists, and bloggers the ability to preview the book by reading summaries of the report. If you have limited time to read the entire report but want to gain a quick understanding, we suggest reading the following chapters:
1. Manifesto on pages 14–47 (click here to read the Manifesto chapter online)
2. Injustice for All Summaries and Conclusions on pages 253–281
If you are not sure…please read the following sample from the Reader’s Notes for the Manifesto chapter.
Injustice for All: The Truth about the Annihilation of American Education Ideals (page 14)
The Manifesto chapter creates the foundation for the key points Ms. Hammer brings to light in the Injustice for All report, including:
- The expert findings from a pioneer in student loan default management. Ms. Hammer was a negotiated rulemaker who aided the DOE in drafting regulatory language for default management that was mandatory for high-default-rate schools from 1989 until 1996.
- Details about the events that motivated Ms. Hammer to logically conclude that the data the DOE had reported was terribly wrong.
- Questioning DOE data integrity—Ms. Hammer personally invested thousands of dollars in having her analysis of DOE data reporting independently verified.
- Raising important questions: Why did the DOE change the CDR calculations without congressional approval and what else are they up to that we have yet to uncover?
Readers will begin to understand the two agendas Hammer identifies, which have been unfolding in a strategic, long-term plan to brainwash the public into FALSELY assuming that:
- Nonprofit schools are honest, while for-profit educators rip off students.
- Community colleges perform better and are more affordable than proprietary options.
- The U.S. government is standing up to and punishing the greedy schools that swindle students.
- The rate at which borrowers default on student loans is a reliable and accurate measure of quality higher education.
What Ms. Hammer reports in the Manifesto chapter should lead the reader to start to question the Machiavellian-style plot by President Obama’s administration to systematically release false reports, from what should be a trustworthy government source, the DOE, reports that put schools out of business and limit educational opportunities for Americans.
Manifesto Extract from Pages 17–18
Comprehensive data available in the College Navigator [1. https://nces.ed.gov/collegenavigator/] in 2014–2015 when this research and analysis was completed contains pertinent information about each sector that had to be manually collected, most likely so that people wouldn’t easily see the truth.
The College Navigator data shows that community colleges are the lowest performing group in terms of graduation rates (26.6%) and are the most costly for students per graduation percent ($195). It also shows that the proprietary colleges are the highest performing of all groups in terms of graduation rates (60.4%) and are the least costly for students per graduation percent ($117).
Traditionally, the loan balance has always been used to drive the opinion that community colleges are the least expensive of all schools, while the truth is that the loan balances are high when considering the extremely low graduation rates.
In contrast, the proprietary colleges have slightly higher loan balances ($7,088) than community colleges ($5,182), while the proprietary sector graduates more than twice the students (60.4%) than community colleges graduate (26.6%)—and these schools are both serving students with similar socioeconomic backgrounds.
The cost for borrowers is higher at community colleges ($195) while the costs are the lowest ($117) at proprietary colleges. When you consider that proprietary schools do not get all of the state and federal grants that public colleges get, the cost of education at proprietary colleges is lower for taxpayers as well.
When we add cohort default rate data (CDRs are defined later in this chapter) to the mix, the data proves that misinformation about sector default rates has also been pushed upon the public.
I. Manifesto Chapter Table of Contents and Numbered Table Listings
Table 1: DOE Loan Program Reporting vs Data Reality 16
Table 2: Cost of Student Loans by School Sector 17
Table 3: Sector Cohort Default Rate (iCDR) Good and Bad Quality Indicators 19
Table 4: YOY iCDR Manipulation of # Borrowers in Default 21
Table 5: YOY iCDR % of Manipulation by Sector 22
Table 6: YOY Total % of Difference in iCDR Manipulation 22
The Motivation Behind These Agendas 23
Table 7: YOY Comparison of DOE iCDR Briefings to iCDR PEPS300 Data 23
Student Loan Default Rates Are Used as a Measure of Quality Education 26
Table 8: DOE-Controlled Loan Portfolio Performance 33
Table 9: YOY Comparison of DOE Loan Portfolio Reporting vs Available Data 34
The Gainful Employment Agenda 35
Table 10: Gainful Employment Debt-to-Earnings (D/E) Definitions for Original and GE 2.0 Regulations 37
FY 2011 GE Informational Rates Were Incomplete, Inaccurate, and Misled Public Opinion about Results 38
Table 11: GE Programs Included in Final vs Streamlined Data by Sector 38
Does There Appear to Be Another Agenda
with GE? 40
Equal Application of Quality Metrics 41
Is Tax-Filing Status Really an Indicator of Good or Bad Quality in Education? 41
Table 12: Comparison of Performance Metrics for Public (PCC) and Proprietary (PMI) 42
Table 13: March 18, 2015 College Scorecard Search Results (whitehouse.gov screenshot) 44
Table 14: September 17, 2015 College Scorecard Search Results (DOE screenshot) 45
Freedom of Education Is Important 46
Education Is One of Many Freedoms Being Compromised 47