End of an Era

We extend our deepest gratitude to the many courageous voices who have contributed to the Higher Education Inquirer over the years. Through research, reporting, whistleblowing, analysis, and public service, you have exposed inequities, challenged powerful interests, and helped the public understand the realities of higher education.

Special thanks to:
Bryan Alexander (Future Trends Forum), Lisa Bannon (Wall Street Journal), Joe Berry (Higher Education Labor United), Stephen Burd (New America), Ann Bowers (Debt Collective), James Michael Brodie (Black and Gold Project Foundation), Patrick Campbell (Vets Ed Brief), Kirk Carapezza (WGBH), Randall Collins (UPenn), G. William Domhoff (UC Santa Cruz), Ruxandra Dumitriu, Keil Dumsch, Garrett Fitzgerald (College Recon), Glen Ford (with the ancestors), Richard Fossey (Condemned to Debt), Erica Gallagher (2U Whistleblower), Cliff Gibson III (Gibson & Keith), Henry Giroux (McMaster University), Terri Givens (University of British Columbia), Luke Goldstein (The Lever),  Nathan Grawe (Carleton College), Michael Green (UNLV), Michael Hainline (Restore the GI Bill for Veterans), Debra Hale Shelton (Arkansas Times), David Halperin (Republic Report), Bill Harrington (Croatan Institute), Phil Hill (On EdTech), Robert Jensen (UT Austin), Seth Kahn (WCUP), Hank Kalet (Rutgers), Ben Kaufman (Protect Borrowers), Robert Kelchen (University of Tennessee), Neil Kraus (UWRF), LACCD Whistleblower, Michelle Lee (whistleblower), Wendy Lynne Lee (Bloomsburg University of PA), Emmanuel Legeard (whistleblower), Adam Looney (University of Utah), Alec MacGillis (ProPublica), Jon Marcus (Hechinger Report), Steven Mintz (University of Texas), John D. Murphy (Mission Forsaken), Annelise Orleck (Dartmouth), Margaret Kimberly (Black Agenda Report), Austin Longhorn (UT student loan debt whistleblower), Richard Pollock (journalist), Debbi Potts (whistleblower), Jack Metzger (Roosevelt University), Derek Newton (The Cheat Sheet), Chris Quintana (USA Today), Jennifer Reed (University of Akron), Kevin Richert (Idaho Education News), Gary Roth (Rutgers-Newark), Mark Salisbury (TuitionFit), Stephanie Saul (NY Times), Christopher Serbagi (Serbagi Law), Alex Shebanow  (Fail State),  Bill Skimmyhorn (William & Mary), Peter Simi (Chapman University), Gary Stocker (College Viability), Strelnikov, Taylor Swaak (Chronicle of Higher Education), Theresa Sweet (Sweet v Cardona), Harry Targ (Purdue University), Moe Tkacik (American Prospect),  Mark Twain Jr. (business insider), Michael Vasquez (The Tributary), Marina Vujnovic (Monmouth), Richard Wolff (Economic Update), Helena Worthen (Higher Ed Labor United), DW (South American Correspondent), Heidi Weber (Whistleblower Revolution), government officials who have supported transparency and accountability, and the countless other educators, researchers, whistleblowers, advocates, and public servants whose work strengthens our understanding of higher education.

Together, you form a resilient network of knowledge, courage, and public service, showing that collective insight can illuminate even the most entrenched systems. Your dedication has been, and continues to be, invaluable.

Dahn Shaulis and Glen McGhee

HEI Investigation: FAFSA (Financial Aid) Fraud

26-00780-F  

The Higher Education Inquirer (HEI) is requesting all emails, memos, and meeting notes between FSA leadership and ED leadership from January 2022–present referencing fraudulent FAFSA submissions, identity theft, synthetic identities, or the need for strengthened ID verification. (Date Range for Record Search: From 01/10/2022 To 12/02/2025)

26-00779-F  

The Higher Education Inquirer (HEI) is requesting from the FSA Office of the Chief Information Officer, all security assessments, vulnerability reports, or risk analyses referencing the FAFSA processing system (FPS), identity verification, or bot-driven application spikes from 2020–present. This includes reports about warnings about bots, concerns about insufficient authentication, and breaches or near-breaches that the public never hears about.  (Date Range for Record Search: From 01/10/2020 To 12/02/2025)

26-00777-F  

The Higher Education Inquirer (HEI) is asking for any and all FSA records, reports, data dashboards, spreadsheets, audits, or communications from January 2023–present that track or analyze fraudulent FAFSA submissions, including synthetic identities, ghost students, identity verification failures, or suspected fraud rings. This includes documents prepared for FSA leadership, ED leadership, OMB, or the OIG. (Date Range for Record Search: From 01/01/2023 To 12/02/2025)

26-00732-F  

The Higher Education Inquirer (HEI) is requesting all emails from the US Department of Education regarding selling off the student loan portfolio.   (Date Range for Record Search: From 01/10/2025 To 11/27/2025)

26-00023-F-IG  

The Higher Education Inquirer (HEI) is requesting any and all correspondence between the ED-OIG and the University of Phoenix regarding unusual or suspicious FAFSA applications from 1/1/2020 and 11/26/2025 (Date Range for Record Search: From 01/01/2020 To 11/26/2025)

26-00709-F  

The Higher Education Inquirer is requesting any and all email correspondence between the US Department of Education and the Thompson Coburn Law Firm from January 6, 2025 to November 24, 2025.  We are particularly interested in the following areas related to higher education:
Gainful Employment
Bare Minimum Rule
Borrower Defense to Repayment
Student Loan Forgiveness
Title IX
False Claims Act
Federal Funding Freeze Litigation
DEI Executive Orders Litigation, the Dear Colleague Letter Litigation, and DOJ’s July 2025 Guidance on Unlawful Discrimination
Executive Order 14242 Directing the Closure of ED
Grant Termination
Rate Cap Policy Litigation
Student and Exchange Visitor Program Litigation
Legality of Nationwide Injunctions
Program Participation Agreement Signatory Litigation (Date Range for Record Search: From 01/06/2025 To 11/24/2025)

26-00697-F

The Higher Education Inquirer (HEI) is requesting any and all correspondence pertaining to "unusual" or "suspicious" activity regarding FAFSA applications involving the University of Phoenix.  Phoenix Education Partners CEO Chris Lynne has recently acknowledged this issue.   (Date Range for Record Search: From 01/01/2024 To 11/23/2025)

26-00697-F

26-00697-F

PXED Throws US Department of Education Under the Bus Regarding Enrollment Fraud

[Editor's note: The Higher Education Inquirer has requested all Department of Education correspondence related to "unusual" or "suspicious" enrollment regarding the University of Phoenix.]   

Phoenix Education Partners (PXED), parent company of the University of Phoenix, used its latest earnings call to advance a familiar narrative: when things go wrong, blame the U.S. Department of Education. This time, CEO Chris Lynne positioned ED as the primary culprit behind the suspicious-enrollment surge that distorted PXED’s numbers over the past year.

The exchange began when Goldman Sachs analyst George Tong asked the question PXED tried to sidestep throughout its IPO process: How much of PXED’s slowing FY2026 enrollment growth is due to fraud controls, and how much of it is due to friction created for legitimate students? And, crucially, what prevents these distortions from resurfacing in the next cycle?

Lynne offered no numbers. Instead, he pivoted to a sweeping explanation of PXED’s “advanced algorithms” and internal control systems—systems so forceful that they immediately block applicants once certain thresholds are hit, even when PXED cannot determine whether they’ve flagged a real student or a bad actor.

But once the CEO finished describing these internal measures, he returned to the real point he wanted to deliver to Wall Street: this is the Department of Education’s fault, not PXED’s.

According to Lynne, the “root” cause was a breakdown in ED’s identity-verification controls tied to the troubled rollout of the new FAFSA. The Department “publicly acknowledged” the failure, Lynne said, and PXED executives met with ED in September to confirm that the government finally has “a good handle on this.” In Lynne’s telling, PXED is the responsible party cleaning up a federal mess.

What this framing ignores is everything that came before. PXED and its predecessor, the University of Phoenix, have long histories of enrollment-integrity problems that predate the FAFSA meltdown by more than a decade. When Lynne says his algorithms “cleaned up” the funnel after being moved to the top of the application process, what he really means is that PXED used its own filters—its own black-box controls—to decide which students were worth staff time and which were not.

And PXED quietly admitted the cost. The verification loops and algorithmic filters caught many real students, blocking or delaying their enrollment and layering additional obstacles onto people who already face the steepest barriers in higher education. Lynne dismissed this as mere “friction”—a small price to pay for cleaner numbers.

But the larger problem is structural. For-profit systems built on volume rely on conversions, throughput, and funnel efficiency. When that model is threatened, the instinct is not to repair student-facing systems—it's to blame the government, tighten internal controls, and preserve the revenue pipeline. PXED’s decision to throw ED under the bus fits that pattern exactly.

The real story isn’t that the Department of Education made serious mistakes in rolling out the new FAFSA—mistakes it has acknowledged. The real story is how quickly companies like PXED use those failures as a shield, deflecting accountability for their own long-standing recruitment practices and quietly punishing the very students they claim to serve.

Phoenix Education Partners, FAFSA Fraud, and the Familiar Dance of Blame

When Phoenix Education Partners (PXED) CEO Chris Lynne publicly blamed the U.S. Department of Education for missing fraud in FAFSA applications—fraud that allowed the University of Phoenix to enroll individuals engaged in financial-aid misconduct—he likely hoped to redirect scrutiny away from his own shop. Instead, the maneuver sent up a flare. For many observers of the for-profit college sector, it felt like the return of a well-worn tactic: deflect, distract, and deny responsibility until the heat dies down.

The pivot toward blaming the Department of Education does not merely look defensive; it echoes a pattern that helped bring down an entire generation of predatory schools. And it raises a simple question: why is PXED responding like institutions that have something to hide?


The Old Script, Updated

The University of Phoenix, under PXED’s ownership, carries not just a long memory of investigations and settlements but a structural DNA shaped by years of aggressive enrollment management, marketing overreach, and high-pressure tactics. When the industry was confronted with evidence of systemic abuses—lying about job placement, enrolling ineligible students, manipulating financial-aid rules—the typical industry defense was to claim that problems were caused by bad actors, by misinterpreted regulations, or by a sluggish and incompetent Department of Education.

Those excuses were not convincing then, and they ring even more hollow now.

If individuals involved in financial-aid fraud managed to slip into the system, an institution with PXED’s history should be the first to strengthen internal controls, not pass the buck. Schools are required under federal law to verify eligibility, prevent fraud, and monitor suspicious patterns. Pretending that ED is solely responsible ignores the compliance structure PXED is obligated—by statute—to maintain.

Why Blame-Shifting Looks So Suspicious

Instead of demonstrating transparency or releasing information about internal controls that failed, PXED’s leadership has opted for a public relations gambit: blame the regulator. This raises several concerns.

First, shifting responsibility before releasing evidence suggests that PXED may be more focused on reputational management than on institutional accountability. If the organization’s processes were sound, those facts would speak louder—and more credibly—than an accusatory press statement.

Second, the posture is déjà vu for people who have tracked the sector for decades. Corinthian Colleges, ITT Tech, Education Management Corp., and Career Education Corporation all blamed ED at various stages of their collapses. In each case, deflection became part of the pattern that preceded deeper revelations of systemic abuse.

When PXED’s CEO adopts similar rhetoric, observers reasonably wonder whether history is repeating itself—again.

Finally, PXED’s argument undermines trust at a moment when the University of Phoenix is already under skepticism from accreditors, policymakers, student-borrower advocates, and the public. Instead of strengthening compliance, PXED’s messaging signals defensiveness. Institutions with nothing to hide usually take a different approach.

The Structural Issues PXED Doesn’t Want to Discuss

PXED acquired the University of Phoenix with promises of modernization, stabilization, and responsible stewardship. But beneath the marketing, core challenges remain:

A business model dependent on federal aid. The more a school relies on federal dollars, the stronger its responsibility to prevent fraud—not the weaker.

A compliance culture shaped by profit pressure. For-profit education has repeatedly shown how financial incentives can distort admissions and oversight.

A credibility deficit. PXED took over an institution known internationally for deceptive advertising and financial-aid abuses. Blaming ED only magnifies the perception that nothing has fundamentally changed.

A fragile regulatory environment. With oversight tightening and student-protection rules returning, PXED cannot afford to gesture toward the old for-profit playbook. Doing so suggests they are trying to manage optics instead of outcomes.

What Accountability Would Look Like

If PXED wanted to demonstrate leadership rather than defensiveness, a different response was available:

• Conduct and publish a full internal review of financial-aid intake processes
• Outline steps to prevent enrollment of fraudulent actors
• Acknowledge institutional lapses—and explain how they occurred
• Invite independent audits rather than blaming federal partners
• Demonstrate an understanding of fiduciary obligations to students and taxpayers

This is the standard expected of Title IV institutions. It is also the standard PXED insists they meet.

A Familiar Pattern at a Familiar Institution

Every moment of pressure reveals something about institutional culture. PXED’s choice to immediately fault the Department of Education—without presenting evidence of its own vigilance—suggests that the company may still be operating according to the old Phoenix playbook: when in doubt, blame someone else.

But in 2025, the public, regulators, and students have seen this movie before. And they know how it ends.

Sources
U.S. Department of Education, Federal Student Aid Handbook
Senate HELP Committee, For-Profit Higher Education: The Failure to Safeguard the Federal Investment and Ensure Student Success
Federal Trade Commission, University of Phoenix Settlement Documents
U.S. Department of Education, Program Review and Compliance Requirements
Higher Education Inquirer archives

Same Predators, New Logo: PXED — A $22 Billion Student‑Debt Gamble Investors Should Beware

Warning to Investors: Phoenix Education Partners (PXED) may present itself as a cutting‑edge solution in career-focused higher education, but it’s built on the same extractive infrastructure that powered the University of Phoenix. With nearly a million students still owing an estimated $22 billion in federal loans, backing PXED isn’t just a financial bet — it’s a moral and reputational risk.

PXED’s leadership includes powerful private-equity players: Martin H. Nesbitt (Co‑CEO of Vistria, PXED trustee, and friend of Barak Obama), Adnan Nisar (Vistria), and Theodore Kwon and Itai Wallach (Apollo Global Management). Also in the mix is Chris Lynne, PXED’s president and a former Phoenix CFO intimately familiar with UOP’s controversial enrollment and marketing strategies. These are not educational reformers — they are dealmakers aiming to extract value from a student-debt pipeline.

[Image: Power Player Marty Nesbitt]

Higher Education Inquirer’s College Meltdown Index highlights how PXED fits into a broader financialization of higher education. Rather than reforming the University of Phoenix, its backers have resurrected it under a new brand — one that continues to enroll vulnerable adult learners, harvest federal aid, and operate with considerably less public oversight. 

Whistleblowers previously documented that Phoenix pressured recruitment staff to falsify student credentials, enrolling people who wouldn’t otherwise qualify for federal aid. Courses were allegedly kept deliberately easy — not to teach, but to keep students “active” enough to trigger aid disbursements. Internal marketing also exaggerated job prospects and corporate partnerships (e.g., with Microsoft and AT&T) to entice students. 

PXED may lean on a three‑year default rate (often cited around 12–13%), but that number is deeply misleading. Many UOP students stay stuck in deferment, forbearance, or income-driven repayment, masking the real long-term risk of non-payment. This is not just a short-term liability — it’s a potentially massive, multiyear financial exposure for PXED’s backers.

There was a significant FTC settlement that canceled $141 million in student debt and refunded $50 million to some students. But the scale of harm far exceeds that payout. Untold numbers of borrowers still have unresolved Borrower Defense claims, and the reputational risk remains profound.

Beyond financial concerns, there’s a major ethical dimension. HEI’s Divestment from Predatory Education argument makes a compelling case that investing in companies like PXED — or in loan servicers that profit from student debt — is not just risky, but morally indefensible. According to HEI, institutional investors (including university endowments, pension funds, and foundations) are complicit in a system that monetizes students’ aspirations and perpetuates financial harm. 

For investors, the message is clear: Phoenix is not merely an education play — it’s a high-stakes, ethically fraught extraction machine built on a legacy of indebtedness and regulatory vulnerability.

Unless PXED commits to real transparency, independent reporting on student outcomes, and accountability mechanisms — including reparations or debt relief — it should be approached not as a social-growth story, but as a dangerous gamble.

---

Sources

• HEI. “Divestment from Predatory Education Stocks: A Moral Imperative.” Higher Education Inquirer

• HEI. “The College Meltdown Index: Profiting from the Wreckage of American Higher Education.” Higher Education Inquirer

• HEI. “What Do the University of Phoenix and Risepoint Have in Common? The Answer Is a Compelling Story of Greed and Politics.” Higher Education Inquirer

• HEI. “University of Phoenix Uses ‘Sandwich Moms’ to Sell a Debt Trap.” Higher Education Inquirer

• HEI. “New Data Show Nearly a Million University of Phoenix Debtors Owe $21.6 Billion.” Higher Education

ED Completes Pre-Acquisition Review for University of Phoenix Deal. University of Idaho Continues Hiding Details of Transaction Fees, 43 Education "High-Risk" Bonds.

[Editor's note: This article will be updated as we receive more information.]

US Department of Education (ED) sources have told the Higher Education Inquirer that the Pre-Acquisition Review for the Idaho-University of Phoenix deal was completed in November 2023 in response to a request from the University of Phoenix in June of the same year.  

The University of Phoenix is currently owned by two powerful investment firms: Apollo Global Management and Vistria Partners. But those companies have been attempting to unload the for-profit college for more than two years. The latest potential owner is the University of Idaho's affiliate organization, Four Three Education--at an initial cost of $685 million.    

ED will not require anyone to post a Letter of Credit--despite the fact that Four Three Education currently has no financial assets and will likely have to issue high-risk bonds to acquire the University of Phoenix. 

Four Three Education, and the University of Idaho, may be responsible for compensating the Department of Education for successful Borrower Defense to Repayment (fraud) claims made by tens of thousands of consumers.  While that could amount to more than a billion dollars, the University of Idaho affiliate expects to spend much less by using aggressive legal means. 

Financing for the Phoenix project has been deliberately opaque. The University of Idaho, however, has acknowledged that it may be liable for some future losses, but only up to $10 million annually. And Idaho officials, including University of Idaho President C. Scott Green, seem undeterred by these potential problems.  

The Most Recent Court Case

A court case to determine whether the University of Idaho violated open meeting laws was completed last week.  Idaho District Judge Jason Scott ruled that the University of Idaho was not in violation for holding three secret meetings followed by a quick vote on May 18, 2023. The University of Idaho claimed that secrecy was essential for the deal to occur.

The State asserted that the Idaho Board of Education did not perform due diligence for the sale, relying on President Green and his word that this was a worthwhile deal for the University of Idaho. In turn, Green admitted he did not ask important questions about competition, for fear that he would be considered naive, and that he outbid the competition.  

As Judge Scott remarked, the wisdom of the deal was not on trial. If it had, perhaps the ruling would have been different. 

Information about the competition to buy the University of Phoenix continues to be sketchy. The University of Arkansas System rejected a deal from the University of Phoenix in April 2023, weeks before the last closed door meeting. UMass Global was mentioned in the court case, but with no evidence that they were ever a serious suitor. 

The Idaho-Phoenix Scheme

The University of Idaho spent a reported seven million dollars on consultants over two months to determine whether the deal would be profitable to the University of Idaho. But little is publicly known about how the funds were spent. Hogan Lovells, President Green's former employer, was one of the organizations involved in consulting the University of Idaho. A local law firm, Hawley Troxell was also involved.  

Idaho also created a non-profit organization, Four Three Education, to act as a firewall in the event the school loses money. The current President of the University of Phoenix, Chris Lynne, will remain in place and be a member of the Four Three Education Board. 

The University of Idaho claims that the University of Phoenix will make a $150 million annual profit but they have not produced evidence. Information about Phoenix's assets are also limited, but Idaho claims the for-profit college holds $200 million in cash. How liquid (or how restricted) the cash is has not been mentioned.

Funding for the sale will be through an initial debt of $685 million, which includes more than $100 million in transaction fees. When bond interest is included, the deal is likely to cost billions of dollars according to an industry source. In an opinion piece in the Idaho Statesman, Rod Lewis, a former attorney for Micron Technology and former president of the Idaho State Board of Education stated:

Phoenix will issue $685 million in corporate bonds anticipated to be “bb” rated (known as “high risk” or “speculative” bonds). Phoenix’s estimated debt service will be $60 million to $70 million per year. It sounds risky, and it is.

We will know more when the University of Idaho produces the bond contracts and names the bond underwriters.    

Poisoning the Public Higher Ed Well

The University of Phoenix relies heavily on obfuscation, intimidation, political lobbying, and lawsuits to reduce expenses related to fraud. Given recent data on consumer complaints about the University of Phoenix, University of Idaho officials say they are prepared for contingencies related to the tens of thousands of Borrower Defense to Repayment claims. But the school or its affiliated organizations could also be liable for claims related to questionable business practices in the present and future. 

It's too early to tell whether Idaho will profit from its acquisition. But if the sale is consummated, the University of Phoenix will join a growing list of state-affiliated and non-profit robocolleges, one that includes Purdue University Global (formerly Kaplan University) and University of Arizona Global Campus (formerly Ashford University), two schools that have not lived up to their parent company names.

Related links:

Predatory Colleges, Converted To Non-Profit, Are Failing (David Halperin, Republic Report)

University of Phoenix's Sinking Ship: Who is Chris Lynne?

University of Phoenix and the Ash Heap of Higher Ed History

Fraud Claims Against University of Phoenix Continue to Mount

How University of Phoenix Failed. It's a Long Story. But It's Important for the Future of Higher Education.

The Slow-Motion Collapse of America’s Largest University

The Growth of "RoboColleges" and "Robostudents"

University of Phoenix's Sinking Ship: Who is Chris Lynne?

Who is Chris Lynne, the latest President of the University of Phoenix?  The school has posted a short, glowing biography that provides some information: four years as the CFO of University of Phoenix, former President of HotChalk and former CFO of Northcentral University.  A Wikipedia article was created for him earlier this year but was recently deleted.

People in the edtech industry say they know little about Chris Lynne, at least not publicly. Of three experts who did respond off the record, no one said anything positive. One mentioned problems at HotChalk and another, problems at Northcentral. The third expert claimed to know nothing, despite decades in the business.

Lynne has worked for a number of companies with issues: accounting firm Arthur Andersen (corruption scandal with Enron led to its closing in 2002), Vice-President at Education Management Corporation (predatory enrollment, financial failure) from 2003-2010, CFO at Northcentral University (financial troubles/US Department of Education Heightened Cash Monitoring) from 2010-2014, President at HotChalk (federal violations with Concordia contract), and CFO at the University of Phoenix from 2018-2022. While no one should be found guilty by their associations, this string of questionable employers does not look good.

Information about Chris Lynne from the WayBack machine.

In June 2022, the University of Phoenix made Chris Lynne the interim President of the school, replacing George Burnett. At the helm for less than six months, Burnett resigned amid an inquiry by the US Department of Education about his work at the now defunct Westwood College. Burnett and Lynne worked together several years at Northcentral University, another subprime college. 

Work at the University of Phoenix 

Chris Lynne was Phoenix's CFO beginning in November 2018. Despite almost a billion dollars government funding per year, US Department of Education data show the school's equity for the Arizona segment declined significantly, from $361M in FY 2018 to $187M in FY 2021. No other data after that are available.

In June 2022, Lynne was named the interim President of the University of Phoenix.  Six months later, he was appointed to that position permanently. Little if anything is known about the hiring process that occurred, and who else was considered for the position.

The truth is, without looking at all the books and matching them with expert observations, we have no idea what Chris Lynne has done as the CFO and now President of the University of Phoenix. The numbers we have from the US Department of Education show a school in decline in terms of enrollment and revenues, shored up by closing campuses and reducing instruction costs.  We do not know what the University of Phoenix has done to maintain its infrastructure, including its computer hardware and software. 

If we could take a close look at all the financial records, examine the school's infrastructure, and interview workers, we would know better how Lynne has handled his work at the school and what shape the University of Phoenix is in for the long run as it is sold to the folks in Idaho.

Related articles:

University of Phoenix and the Ash Heap of Higher Ed History

Fraud Claims Against University of Phoenix Continue to Mount

How University of Phoenix Failed. It's a Long Story. But It's Important for the Future of Higher Education. 

New University of Phoenix Head Ran College That Closed After Fraud Suit (David Halperin)

The 17 Questions The Education Dept. Asked A University President Before He Resigned