Statement regarding Department of Education comments by Miguel Cardona

In light of the disturbing and defamatory public comments made by U.S. Department of Education Secretary Miguel Cardona last week during a House Appropriations Committee hearing, Grand Canyon University is providing the following statement. 

This response is prefaced with the comment that our disagreements with the Department of Education (ED) are not politically motivated. We are not anti-government and have a record of cooperation and great relationships with 26 different regulatory and accrediting bodies, none of whom have corroborated what ED is claiming. We are an educational institution that is doing an exemplary job of addressing the many challenges that are plaguing higher education while also living out our Christian mission both on our campus and in the surrounding community. That is reflected in the growing demand from students and families who are seeking a higher education option at GCU that is affordable and taught from a Christian worldview perspective. That mission, not politics, is our motivation and it is our hope that we can again put our full attention to those efforts in the near future. 

Mr. Cardona’s inflammatory comments, which are legally and factually incorrect, are so reckless that GCU has no choice but to demand an immediate retraction. He is either confused, misinformed or does not understand the actions taken by his own agency. 

There are no factually supportable allegations that warrant an attempt to shut down GCU and, in fact, ED has already granted a three-year extension of GCU’s provisional program participation agreement that allows it to continue to receive Title IV financial aid dollars. Those Title IV funds go directly to students, who can use them at whatever institution they choose. More are choosing GCU than any other university in the U.S., which does not happen if you are deceiving a small number of students as ED claims. Further, GCU remains fully accredited by the Higher Learning Commission, which gave the university a maximum 10-year extension in its last review, and all of GCU’s academic programs, including those requiring state licensure, remain in good standing. 

Regarding Cardona’s misguided comments that GCU “lied” and “preyed” on students, we have asked ED repeatedly for evidence of intent and verified student complaints, and they have refused to provide us with that information. Rather, their accusations are based entirely on their own subjective opinion of GCU’s financial disclosures for doctoral programs. As Mr. Cardona’s comments confirm, those opinions reflect a deeply held bias against GCU, which has manifested itself in his Department’s selective and punitive enforcement actions against the university.  

Two points of fact directly refute ED’s claims against GCU that have resulted in a record $37.7 million fine that the university is appealing. 

  • First, ED’s claims are not corroborated by 1) the federal court system, which has refuted similar claims about GCU’s financial disclosures in Young v GCU, 2) GCU’s accrediting body, the Higher Learning Commission, which described GCU’s doctoral disclosures as “robust and thorough” in its 2021 comprehensive review of GCU’s enrollment practices, and 3) the Arizona State Approving Agency (SAA) of the Department of Veterans Affairs, which recently audited GCU specifically to investigate ED’s claims and confirmed that there were “no substantiated findings.” Unlike the ED bureaucrats in Washington, D.C., both the HLC and SAA actually took the time to visit GCU, conduct interviews and do a thorough first-hand review of GCU’s enrollment practices. 
  • Second, ED’s claims that GCU “lied to students” and “falsely advertised” the cost to complete a doctoral program are gross mischaracterizations of what GCU actually discloses. In higher education, doctoral programs that include dissertations rarely have a fixed cost because the number of continuation courses varies for each individual student. Most universities with similar continuous enrollment requirements do not disclose the cost or potential need for the additional coursework. GCU, on the other hand, uses the most prominent place that it provides financial estimates – its Degree Program Calculator (see attachment) – to highlight both the cost for the 60-credit doctoral programs and, in full-size red font, the average number and cost of continuation courses students take while completing their dissertation. GCU reiterates the need for continuation courses in six other places prior to the start of classes. In short, because it is trying to benefit students and provide full transparency, GCU provides more cost information than other universities regarding doctoral programs, yet GCU has been singled out by ED. 

Specific to Mr. Cardona’s broader comments about predatory for-profit schools’ marketing material “not being worth the paper it is printed on,” we actually agree with him – with two important caveats: GCU is not a predatory school and it is legally authorized to operate as a nonprofit, which Cardona does not distinguish. What’s more, GCU’s metrics on measurable academic metrics such as nursing NCLEX scores are well above the national average, even as GCU produces far more nurses than most universities; our Honors College has grown to nearly 3,000 students with an unweighted incoming GPA of 4.1; GCU’s National Society of Collegiate Scholars and Alpha Chi chapters are among the top performing chapters in the country; and GCU has over 100 teacher graduates who have been recognized as Superintendent, Administrator or Teacher off the Year award recipients.  

GCU has been asked repeatedly why it believes it is being targeted by federal agencies of the Biden Administration. Here’s what we can tell you: Mr. Cardona’s inflammatory comments make very clear the Department of Education’s intentions and their disdain for institutions that do not fit their ideological agenda. What’s also clear is that ED has no lawful grounds to carry out those intentions based on their disingenuous and factually unsupportable allegations. 

Here’s what else we can tell you: Simply look for yourself at GCU’s actual disclosures and the conclusions of a court of law, two impartial agencies (HLC and SAA) and 26 regulatory/accrediting bodies that consistently grant GCU full approval. Look at the 700 industry leaders on our 20 advisory boards who want access to GCU’s graduates. Look at the 5,000+ partnerships GCU has with schools, hospitals and other organizations across the country who have not expressed concerns about GCU’s transparency. Look at GCU’s efforts to help disadvantaged populations in its surrounding community through a groundbreaking five-point plan that no other institution is doing. If GCU’s intent was really to deceive students, why would we choose the smallest degree program we offer (doctoral) which is less than 5% of our student body and includes our most experienced students? If our goal was to generate more revenue, rather than allegedly deceive students we could simply increase tuition 3-4% a year for a few years – as most universities have done – and no one would bat an eye. We haven’t done that. In fact, we have frozen tuition on our ground campus for 16 straight years because our innovative approach to managing this university, which ED objects to, has allowed us to do that for the benefit of our students. 

Your other option is to look for yourself at the one outlier in this issue: a federal government agency that has done the following: 

  • Openly stated its disdain of for-profit institutions and, in order to label GCU a for-profit, intentionally disregarded the conclusions of the IRS, State of Arizona, Arizona Private Postsecondary Board, HLC, NCAA Athletics and two major independent accounting/finance firms that acknowledged and/or supported GCU’s nonprofit transaction. 
  • Coordinated actions with the Federal Trade Commission and U.S. Department of Veterans Affairs to launch five inquiries into GCU in retaliation for the lawsuit the university filed vs. the Department in 2021 over its lawful nonprofit status. 
  • Recently initiated unprecedented fine actions against the two largest Christian universities in the country (GCU and Liberty). In GCU’s case, ED has confirmed the proposed $37.7 million fine is not based on student complaints and has not identified a single corroborated account of a student actually being misled by the university’s disclosures. That is a shocking admission from an agency trying to impose the largest fine in its history. 
  • Focused much of its efforts under the Biden Administration granting itself significantly broader regulatory authority through the negotiated rulemaking process and circumventing both Congress and the Supreme Court in an attempt to grant broad student loan debt relief (which was recently refuted by a 5th Circuit Court of Appeals decision that severely questioned ED’s authority). 
  • Has drawn the ire of the House Education and Workforce Committee after ED “failed an audit two years in a row, been derelict in its duties and continues to make up estimates it cannot defend to its auditor.” Further, the committee stated, “We are deeply disturbed by this administration’s bungling, general ineptness and deliberate wasteful spending of taxpayer dollars.” 
  • Has been universally rebuked for the delays, glitches and inaccurate data that have accompanied its rollout of a new FAFSA form. Overseen by ED Office of Federal Student Aid COO Richard Cordray and ultimately Secretary Cardona, the rollout has been an abject failure that has broken the trust of higher education institutions across the country and left many students wondering if they will even be able to attend college due to the uncertainty of their financial aid situation. 
  • Been sued by the Goldwater Institute in its efforts to uncover documents about ED’s coordinated actions against GCU with other agencies. 

ED’s conduct related to GCU goes well beyond normal regulatory activity. It epitomizes the weaponization of federal agencies’ power against a private Christian university. To borrow a term ED uses liberally to describe every for-profit institution it is trying to harm, the comments by Mr. Cardona and actions taken by his Department are predatory in nature and designed to achieve their own ideological agenda. 

GCU is confident that, in time, an impartial court of law will refute ED’s extraordinarily thin allegations. GCU’s intent is to fight these accusations all the way to the Supreme Court if necessary. The Department of Education’s intent, based on the frivolous nature of its accusations and defamatory statements from ED officials, seems to be to damage the university’s reputation, use its “findings” as a rationale to seek loan forgiveness for students under the borrower’s defense to repayment program and impose unprecedented fines and legal fees. In other words, regardless of the inevitable legal outcomes in GCU’s favor, the process becomes the punishment. 

With 118,000 students and growing, GCU is thriving and will continue to thrive. In an industry that is struggling and slow to change, GCU has created a model that has allowed it to freeze tuition on its ground campus for 16 straight years, increase diversity and social mobility by ensuring that higher education is affordable to all socioeconomic classes (over 40% of GCU’s ground campus student body are students of color), maintain lower student loan default rates than the national average and lower student debt levels than other private universities, and produce nearly 30,000 graduates in each of the past three years. 

If a government-run institution produced those kinds of outcomes, it would be applauded. At the largest private Christian university in the country, it draws unwarranted threats from the Secretary of Education and the ire of the federal government. 

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