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But I believe one of the criteria for a trade or technical school is the fact that its graduates are stably employed.

If you found that 50 percent of the graduates of a trade or technical school were not stably employed 1 year after they finish, I do think that would be grounds for withdrawing accreditation, would you not?

Mr. GODDARD. We have many types of institutions. I am not aware of any institution in our organization that has not been able to determine that 50 percent of the students or graduates available for placement are working in the field.

However, there are some types of schools where the risks are quite great for a student. I would list among these such programs as acting, and some of the other more artistic areas in which the student knows before he goes in that he may have very little opportunity to earn a living, a lifetime career in this field.

Therefore, we have never tried to say that a percentage-I think it would be very unrealistic, as a matter of fact, to say that a certain percentage in all types of occupations would have to go to work immediately in the field.

We have a school here on the East coast, for instance, that a substantial number of its students just happened because of the nature of the institution and its location, to be active military personnel. They are taking training for after military retirement in many cases, and are not even available for placement upon graduation.

So, the thought you have, I agree with completely, that in an occupational school, the people going to the school, seeking occupations and available for placement after graduation, should receive all the help and assistance available. I would not want even the teachers' colleges these days to be overly criticized for promises they made 6, 8, 10 years ago.

Senator PELL. I do not mean that the institution should act as a job placement agency.

All that I am saying is that I think there is a responsibility to the accrediting board to make sure that the graduates in the institution are available to fill a job opening, trained adequately to fill a job opening in the field for which they have been trained.

Mr. GODDARD. I agree with you completely.

Senator PELL. Going to this home study, and I do think that should be a criterion into accreditation, that they are adequately trained, I do believe we need more plumbers than we need more liberal arts graduates, and they will be happier and richer, too.

But going back for a moment to the home study council, in one of the series, either the Globe series, or Post series, I came across the references to cases where people were trained in television technology or Frigidaire technology. Then they were able to buy a television set or Frigidaire and charge it to the GI Bill, as a cost of tuition. Are there any instances of this sort?

Mr. FOWLER. I think what you are referring to is that some of the courses that are offered by some of the institutions do include certain kinds of tools and test equipment and, in some instances, actually

the process that is used to teach the student in the course, television and electronics, is the building of a television set. A television set, then, is an item that the student has to put together, assemble, as part of his learning experience.

When he completes his course, he does have the set which is his and available to him.

It is our policy and, therefore, schools do charge a tuition for the course, which of course includes the equipment necessary for the student to learn what he is to learn as a result of the course. So, yes, some of the courses do have kits and equipment, and some have tool sets, and, yes, these are included as part of the tuition charge.

So, there is no misunderstanding on the student's part as to what he owes and does not owe.

He should not get halfway through and be advised that he has to spend another $300 for this equipment. So that is how the equipment, the television set, or one school offers a refrigeration unit-I do not believe when it is finished it is Frigidaire, or window air conditioner, it is just a refrigeration unit-is part of the learning equipment given to the student.

Senator PELL. He is given a television set, being taught to assemble it.

Do you give it assembled or in little pieces?

Mr. FOWLER. This comes as a kit.

Senator PELL. That does mean little pieces?

Mr. FOWLER. Little pieces. Separate transistors, picture tube comes with an advanced part of the course, and as the student works through the course, he puts together the segments.

In some courses, in electronics courses particularly, some of the equipment given is test equipment.

As he first gets the kit to put together, it is test equipment, and he can learn such things as soldering techniques and basics with that. Then he begins to get parts for his television set.

Then he uses the test equipment to test the parts of the set he puts together as he goes along.

The school has, as part of the examination process, questions that are asked based on what test results he gets from testing parts of the equipment he has put together.

So no school that is accredited offers assembled television sets as part of the educational program. Many of them do offer kits that eventually, if the student progresses through the course and assembles them according to instructions, are assembled into a TV set when he completes the course.

Senator PELL. I came across a reference to a home-made helicopter. I would not like to fly in it. Is this used in any of your courses? Mr. FOWLER. No, not that. No.

Senator PELL. What would be the most expensive equipment that would be used in any of your courses? Would it be automobile or television set or Frigidaire or what would it be?

Mr. FOWLER. I think the most expensive piece, and there may be something else that I cannot think of at the moment, would be a color television set.

Senator PELL. How much is a color television set roughly?

Mr. FOWLER. In the kit form, the cost to the school might be $400, $500.

Senator PELL. What would be the cost of the course?

Mr. FOWLER. The course might cost $1.200 to $1,500 or $1,600. Senator PELL. So, in other words, the equipment, in your view, would never be more than half the cost of the course?

Mr. FOWLER. No, I would not say that arbitrarily, because some of those same schools that we are talking about include this test equipment that I mentioned. It is not just a television set.

It may be an oscilloscope, or some other piece of test equipment that the student assembles. In some cases it is an item that is needed for the testing, but the student could not assemble it at an early stage of the course, and he might receive an item like that already assembled. In the aggregate, it is possible that the cost of all of that equipment might exceed half the cost of the course.

Senator PELL. Do you provide any courses on how we go metric for machinists?

Mr. FOWLER. I believe there are one or two schools that do offer a course on this subject.

Senator PELL. Would you submit for the record those schools that have courses in helping people to be prepared for conversion to the metric system, metric measurement?

Mr. FOWLER. Be glad to. Some of the names we submit may be schools that are not members of our organization that have this kind of course.

Senator PELL. Just put an asterisk against those that are members of your organization. Could you do the same, Mr. Goddard?

Mr. GODDARD. Yes, sir. That is, to give you a list of names of the schools that offer metric, yes.

I believe that most all of our schools that offer mechanical trades already include some sort of metrication training, and especially automotive where equipment has been coming over to this country for many years requiring the use of the metric equipment.

Senator PELL. I believe we will be in the metric system before we are through.

I had a bill pass the Senate last Congress. In this Congress because of the election pressures, and I think mistaken assumptions on the part of many people, it has passed neither body, but I would not be surprised if it passed both pretty soon. I think we have probably covered the ground.

Is there any other point that any of you would like to make? Do not forget your ideas on legislation.

Mr. EHRLICH. Yes, we will do that because we have made note of it. I would like to point out that in terms of the courses of instruction, unlike other types of accrediting agencies, courses are evaluated by outside experts, called subject specialists.

These are people who are not either home study or trade or technical school people necesarily. These are people from industry, people who have knowledge of training programs and how it is done.

I would like to clarify because, at one time in one series in the Post, there were some questions raised about how we evaluated the medical system program. And a claim was made that we never used a physician of any kind, which is not true.

Our programs are all evaluated by outside area specialists who file reports and they determine whether the course, in fact, including kits and materials and everything else, can achieve the objectives that the school advertises to the public.

Senator PELL. One other thing. As I understood Mr. Fowler, he said there were about 500 correspondence institutions in the country, and 80 were members of your group?

Mr. FOWLER. That is correct.

Senator PELL. Could Mr. Goddard give me a rough horseback figure along the same line, how many in the country, and how many are members of your group?

Mr. GODDARD. I do not think anyone knows for sure how many schools there are of our type in the country. Perhaps over 5,000, and we have accredited between 400 and 500.

Senator PELL. What are the dues paid by an institution to each of your groups?

Mr. GODDARD. The minimum dues would be $250. The scale would range as high as $2,000, conceivably. There would be a few schools that could pay as much as $2,000.

Senator PELL. What would be the answer from you, Mr. Fowler? Mr. FOWLER. We have two schedules. One is the cost for accreditation, an annual sustaining fee for accreditation. The application fee is $100, and the visitation fee is $150 a day for each examiner, and the annual fee ranges from $50 to $500, depending on the income to the school from tuition home study courses.

The National Home Study Council, the national association, has dues. I believe minimum dues are $250. Dues are on a sliding scale, based on the income of the school, up to about $12,000 to $15,000, depending on the school's income based on amount of home study involvement.

Senator PELL. How often are institutions required to be visited? Mr. FOWLER. At least every 5 years. The institution has to undergo full evaluation at least every 5 years. We have discovered in the past 2 or 3 years that for various reasons, either new courses being added, or changes in management, or for other reasons, complaints, questions of financial stability-we get an annual report that includes information on all of these there was some kind of review that seems to be going on about every 2 or 3 years. Senator PELL. For a serious complaint?

Mr. FOWLER. Yes.

Senator PELL. How often for your schools?

Mr. GODDARD. About the same thing, 5 years would be the maximum between full-scale reevaluations. I would assume most accrediting agencies would operate in a similar manner, since we are all recognized by the U.S. Office of Education under special criteria.

Senator PELL. What would you consider a complaint that would justify a special look?

Mr. GODDARD. Well there are areas, other than complaints, that could cause early reevaluations. I would say that most evaluations, as a matter of fact, are caused by something other than complaints. A type of complaint that could be in areas of business practices, or in areas of education.

However, our industry is very rarely criticized in its educational quality. We do have more significant criticism of business practices. I suppose that if a school were not providing the required equipment, or a sufficient number of instructors, or something, we would look into that.

Senator PELL. The series mentioned in the press, would you consider that cause for a fresh look?

Mr. GODDARD. For total reevaluation? I would say the series in the press certainly led to investigations, which of course in some instances could lead to total reevaluation.

Senator PELL. Someone asked this question already, and I want to repeat it there were a series of articles in the Post and Globe, and Mr. Fulton mentioned that only one of the institutions mentioned belonged to his group.

How many of those institutions belonged to either of your groups? Mr. GODDARD. Four belonged to the National Association of Trade and Technical Schools.

Senator PELL. How many belonged to your group?

Mr. FOWLER. I cannot give you an exact number, but almost all of the correspondence schools mentioned in the Globe article were members of our group.

Senator PELL. What have you done, having read those articles, to jack up or expel those groups, those schools?

Mr. FOWLER. Well, the first thing we did was to write to each of the schools, sending them a copy of the article, and asking them to provide us with an answer regarding each of these.

In some cases, there were not any allegations or charges made. It was more of a narrative, explaining something that had been said or that had occurred without any charging of anything being wrong. In each case we wrote to the schools mentioned and asked them to give the accrediting commission a full response, with the facts. If the article said that a student was enrolled who had not had the basic educational qualifications that the school said he should have, a copy of the enrollment agreement that that student had sent was provided, and so on.

Each of these items, each of these responses each of the schools has responded each of the responses, has been evaluated, and in some cases the resulting input has been part of an accrediting review that has taken place for the school.

Usually, though, I would have to say that if there are evidences of one kind of problem, a school has other kinds of problems also, so that no accrediting review really-I should say rarely, goes to one problem.

There are other things that are involved also. So it is a more general kind of review of the school.

Senator PELL. I would like to ask you to submit for the record, if you do not recall the number, of how many of the institutions that

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