GCU Statement Regarding the Arizona SAA Audit

GCU has issued the following statement regarding the Arizona State Approving Agency (SAA) for the U.S. Department of Veterans Affairs closing their audit on the University. Contrary to what the Department of Education (ED) and the FTC have alleged, the SAA found no wrongdoing in their audit. 
 

Arizona VA Agency finds no wrongdoing in audit of
Grand Canyon University ​​​​​

(March 12, 2024) – The Arizona State Approving Agency (SAA) for the U.S. Department of Veterans Affairs has closed its most recent risk-based audit of Grand Canyon University with no findings. The audit, which was triggered by a recent Federal Trade Commission lawsuit against the university, was the second such audit in less than a year and looked at, among other things, GCU’s doctoral disclosures and processes that are the subject of both the FTC lawsuit and a Department of Education (ED) investigation that resulted in the announcement of a record $37.7 million fine currently being disputed and appealed by GCU. In a letter to GCU dated Feb. 21, the Arizona SAA stated it “did not have any substantiated findings based on our review of Grand Canyon University." Further, the SAA stated, "There are no findings impacting the continued approval of Grand Canyon University at this time."

GCU has a longstanding positive relationship with the SAA and greatly appreciates the agency’s willingness to visit the campus and meet with GCU’s Dean of the College of Doctoral Studies and members of the Office of the Provost, among others, to understand how students progress through the doctoral program, what it takes to complete a dissertation, how the university measures quality and student success, and the many support services that are available to students. The SAA site visit also included reviews of specific areas relating to finances, enrollment, recruiting, student outcomes and other success measures.

GCU continues to categorically deny the FTC’s and ED’s unwarranted allegations related to the doctoral program, which are part of coordinated and targeted actions the federal government is taking against the largest Christian university in the country.

A multitude of entities have found no wrongdoing in GCU’s disclosures and/or praised the university’s transparency, including:

• Federal judges at both the district and appellate court level who ruled in GCU’s favor in Young v. GCU, rejecting similar claims that the university misrepresented the time and cost it would take a student to complete a doctoral program.
• GCU’s accrediting body, the Higher Learning Commission, which in its 2021 comprehensive review called the university’s doctoral disclosures “robust and thorough, providing prospective students a clear picture of their academic and financial path toward a degree at GCU.”
• Programmatic accrediting bodies and state agencies that consistently approve GCU’s many academic programs through their robust review processes.
• The higher education industry as a whole, which has asked GCU representatives to speak at seven major conferences as a leader and expert in transparency and processes in higher education.
• More than 5,000 public and private GCU partners, none of whom have expressed concern about a perceived “misrepresentation” or “deception” based on their interactions with the university. In fact, many have become partners because of GCU’s exemplary levels of transparency and compliance.

Further, GCU’s own preliminary study of publicly available information at 100 other university doctoral programs found that only 2% of universities show total program cost for doctoral programs, 51% either failed to disclose anything about the need for additional courses needed to complete a dissertation or were unclear about them, and 45% made statements that a doctoral degree could be earned in a set number of years (varying from 2-8) despite the varying length of time needed to complete a dissertation. The sample of 100 public and private universities includes 52 Tier 1 Research institutions (including five Ivy League schools) and 19 Tier 2 Research institutions.

Such evidence is in direct contrast to the U.S. Department of Education, which characterized GCU’s doctoral disclosures as “substantial misrepresentations,” and the FTC, which based most of its lawsuit vs. GCU on ED’s claims and its refusal to acknowledge the university’s lawful nonprofit status. ED’s claims are not based on student complaints but rather its subjective opinion of GCU’s disclosures.

ED portrays GCU’s financial disclosures as “false advertising” and in “fine print” because the vast majority of students take continuation courses in addition to the required 60 credits of coursework in order to complete a dissertation, which is common among higher education programs and the reason there is rarely a fixed cost for doctoral programs. ED issued no prior guidance related to these specific disclosures yet fined GCU despite the fact that it provides more cost information than is legally required or that other universities provide.

GCU makes clear in the most prominent place it provides financial disclosures for academic programs – its Degree Program Calculator (DPC) – the cost for the 60-credit doctoral program requirement and further points out that the average doctoral student takes several continuation courses with the associated costs in order to complete the dissertation process. GCU’s disclosure is in full-size red type and placed above the DPC calculation in order to bring attention to it (see screenshot in this GCU statement). GCU reiterates the need for continuation courses in six other areas prior to the start of classes. The net impression of these disclosures is the reason federal courts have already sided with GCU on this matter.

In other developments related to GCU’s ongoing battle with the federal government:

• The university has added Paul Clement as a co-counsel to its outside legal team. The former Solicitor General of the United States has argued over 100 cases before the U.S. Supreme Court, including Hobby Lobby v. Burwell, Kennedy v. Bremerton, and Loper Bright Enterprises v. Raimondo which protect the rights of individuals and organizations against government overreach. Clement has argued more Supreme Court cases since 2000 than any lawyer in or out of government. Clement, who holds degrees from Georgetown University, Cambridge University and Harvard Law School, has also argued many important cases in the lower courts, including Walker v. Cheney, United States v. Moussaoui and NFL v. Brady.
• The Arizona-based Goldwater Institute is independently suing the U.S. Department of Education for its refusal to provide transparency in that agency’s dealings with other federal government entities related to their fine and other actions taken against GCU.