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Wednesday, July 12, 2023

University of Phoenix and the Ash Heap of Higher Ed History (Updated September 14, 2023)

[Editor's Note: The Higher Education Inquirer will continue to update this story as more information comes in.]

The University of Phoenix (or at least its name) may soon enter the ash heap of US higher education history--and rise again as a state-run robocollege. But it shouldn't--at least not yet. Once hailed as the leader in affordable adult education for workers entering middle management, it is a shell of its former self--in an economy less certain for workers and consumers.

With the school's wreckage are approximately one million people buried alive in an estimated $14B-$35B in student loan debt.

Pattern of Fraud

As of January 2023, more than 69,000 of these student loan debtors have filed Borrower Defense to Repayment fraud claims with the US Department of Education against the University of Phoenix (UoPX). Many more could file claims when they become aware of their rights to debt relief. In the partial FOIA response below, the US Department of Education reported that 69,180 Borrower Defense claims had been made against the school.

In a recent federal case, Sweet v Cardona, most if not all of the 19,860 "denied" cases were overturned in favor of the student loan debtors. We estimate the smaller number of fraud claims alone to amount to hundreds of millions of dollars.

Through a FOIA request, we also discovered 6,265 consumer complaints in the FTC database. In 2019, the FTC and the University of Phoenix settled a claim for $191M for deceptive employment claims. Based on the consumer complaints, we have no reason to believe that Phoenix has changed its behavior as a bad actor.

On May 3, 2023, six US Senators (Warren, Brown, Blumenthal, Durbin, Merkley, Hassan) called for the US Department of Education, Department of Veterans Affairs, and Department of Defense to investigate the University of Phoenix for launching a new program suggesting that it was a public university. The letter stated that the school "has long preyed on veterans, low-income students, and students of color."

Wolves in Sheep's Clothing

University of Phoenix's owners could potentially be liable for refunding the US government for the fraud. But as a state-related organization, it may be more politically difficult to claw back funds, no matter how predatory the school is.

Purdue University Global and University of Arizona Global set a precedence in state-related organizations acquiring subprime schools (Kaplan University and Ashford University) and rebranding them as something better. Whether they are better for consumers is questionable. Phoenix will have to cut costs, largely by reducing labor. Using Indian labor (like Purdue Global) and AI could be profitable strategies. It's likely that this deal, even if profitable, will add fuel to the growing skepticism of higher education in the US.

University of Phoenix's Finances

Apollo Global Management and Vistria Group currently own University of Phoenix but have been trying (unsuccessfully) to unload the subprime college for more than two years. Little is publicly known about the school's finances. What is known is that UoPX gets about $800M every year from the federal government, through federal student loans, Pell Grants, GI Bill funds, and DOD Tuition Assistance.

Despite this government funding, US Department of Education data show the school's equity value for the Arizona segment declined significantly, from $361M in FY 2018 to $187M in FY 2021.

$347M of the University of Phoenix's $518M in assets are intangible assets. Intangible assets typically include intellectual property and brand reputation. The school has $348M in liabilities.

The University of Phoenix has been reducing expenses by cutting instructional costs, from $70M in FY 2020 to $60M in FY 2021. UoPX spends about 8 percent of its revenues on instruction.

Marketing and advertising expenses are not available, but Phoenix has been visible on the Discovery Channel's Shark Week, CBS' Big Brother, and other television events. ISpot.tv reports that University of Phoenix spends millions of dollars each year on television ads. On one ad alone, the ad spend from February 2023 to July 2023 was an estimated $3.5M.

Attempts to Sell UoPX

There have been two known potential buyers for the University of Phoenix: the University of Arkansas System and the University of Idaho. In both cases, the owners required the potential buyers to keep the deal secret until the sale was imminent.

Fear of the impending higher education enrollment cliff appears to be an important pitch to potential buyers.

Arkansas, the first target, was in the process of making the deal, and it might have gone through if nit for the voice of one whistleblower and one outstanding investigative reporter, Debra Hale Shelton of the Arkansas Times.

In the case of Idaho, news of the potential deal was publicly noted just one day before the preliminary agreement was made with the Idaho Board of Education. Two other secret meetings were held before that.

A number of journalists including Kevin Richert (Idaho EdNews), Laura Guido (The Idaho Press), Troy Oppie (Boise State Public Radio), and Noble Brigham (Idaho Statesman) have exposed some of the problems and potential problems with the deal. In June, Idaho legislators began questioning the acquisition.

More recently, the opinion editor at the Idaho Statesman argued that the deal may actually be worthwhile.

Particulars about the finances are sketchy at best and misleading at worst. The University of Phoenix is said to include $200M in cash in the deal, but they have not said how much of that sum is required by law as "restricted cash"--money the school needs if the Department of Education needs to claw back funds. Phoenix also claims to be highly profitable, but without showing any evidence.

What is known about the deal is that the University of Idaho will have to borrow $685M and put its (bond) credit rating at risk. The school has not identified important information how the bonds would be sold (underwriters, bond raters, date to maturity, interest rate).

The University of Idaho has created an FAQ to answer questions about the sale, but HEI has identified a number of misleading statements about University of Phoenix's present finances (failure to report the school's equity), potential liability (cost of tens of thousands of Borrower Defense claims), and leadership (lack of background information about Chris Lynne, the President of the University of Phoenix). These deficiencies have been reported to the University of Idaho and to the Representative Horman.

On June 20, Idaho Attorney General Raul Labrador filed a lawsuit to halt, or at least slow down the deal.

The University of Idaho submitted a Pre-Acquisition Review from the US Department of Education, and it may take up to three months before the application is completed.

As of September 2023, the deal is far from done. Since this article was first published there have been a number of developments:

On September 11, US Senators Elizabeth Warren, Dick Durbin, and Richard Blumenthal called on University of Idaho President Green to abandon the sale. The Senators also asked Green if he had a plan to pay for the Borrower Defense claims, noting that University of Arizona may be on the hook for thousands of claims against Ashford University (aka University of Arizona Global campus).

In November, the Joint Finance-Appropriations Committee of the Idaho Legislature is expected to discuss the issue again.

*The Higher Education Inquirer has made a FOIA request for more up-to-date numbers from the US Department of Education. We have also filed FOIA requests with the FTC.

Sunday, January 30, 2022

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

The failure of University of Phoenix (UoPX) is more than a dark moment in higher education history. It should act as a lesson learned in the higher ed business. Executives at 2U, Guild Education, Coursera, Liberty University, Purdue University Global, University of Arizona Global, Chegg, Academic Partnerships, Pearson PLC, Navient, Maximus and other for-profit and non-profit entities must take heed of the mistakes and the hubris of Phoenix, the wisdom of its cofounder John D. Murphy, and the silencing of important worker voices.

For several decades of the 20th century, hundreds of University of Phoenix campuses dotted the American landscape, conveniently located in cities and growing suburbs, off major highways. Founded in 1973, America's largest university became a for-profit darling of Wall Street in the 1980s and 1990s, and the provider of career education for mid-level managers in corporate America and public service. A Phoenix degree was the ticket to promotions and salary increases.

During its zenith, the school was backed by dozens of lawyers and DC lobbyists and a number of politicians and celebrities--including Nancy Pelosi, John McCain, Shaquille O'Neil, Al Sharpton, and Suze Orman. UoPX bought the naming rights to the Arizona Cardinals' pro football stadium in 2006. And in 2010, enrollment at the University of Phoenix stood at nearly a half million students. The school even had an enormous presence at US military installations across the globe. University of Phoenix's presence was everywhere.*

Phoenix's stock rose for many reasons. It was a leader in educational innovation. It was convenient and affordable for upwardly social mobile workers. Its profits were large, and its labor costs were relatively low because UoPX hired business leaders and experts in the field, not tenured scholars, to teach part-time.

But something went horribly wrong along the way.

In the 2010s, University faced government and media scrutiny for its questionable business practices, its declining graduation rates, and its part in creating billions in student loan debt. And when workers voiced their concerns, they were silenced in a variety of ways, from threats and intimidation to firings.

This enrollment collapse has now lasted a dozen years and counting.

Today, as a miniscule portion of Apollo Global Management's portfolio, UoPX's enrollment numbers are less than 100,000--and few of its physical campuses remain open during the Covid pandemic. It's not known how many campuses, if any, are financially viable.

University of Phoenix enrollment, 2009-2016 (Source: US Department of Education)

There are a several reasons why University of Phoenix is just a shadow of what it was. Businesspeople and lobbyists blame government regulation and oversight; others blame the relentless pursuit of quarterly profits and corrupt Apollo Group CEOs, including Todd Nelson.

Having talked to co-founder John D. Murphy and read his book Mission Forsaken, what I found out was that University of Phoenix began failing three decades earlier, during the Ronald Reagan era, when US companies chose to invest less in their workforces. When this post-Fordist shift happened, US companies reduced benefits for workers, and divested in the education and training of mid-level executives.

In order to keep the company growing in the face of this retrenchment, UoPX shifted its mission, from educating America's upwardly mobile workers to enrolling anyone--at any cost. The company could only decline as it preyed upon consumers and silenced its workers. After 2010, enrollment counselors were signing up people who were woefully unprepared academically and financially for college work.

By 2014, about 1 million University of Phoenix's alumni were saddled with more than $35 billion in student loan debt.

US Student Loan Debt by Institution (Source: Brookings, Looney and Yannelis, 2015)

In 2017, Apollo Group sold the company to Apollo Global Management, an investment behemoth, along with Vistria Group and the Najafi Companies. As part of its holdings, the school was a tiny portion of its portfolio. Barak Obama's close friend, Anthony Miller, was paid to be Board president.

Among national universities, UoPX is now ranked near the bottom in social mobility according to the Washington Monthly.

In January 2022, as a sign of its continued unraveling, Apollo Education appointed George Burnett, a former executive of three failed or predatory companies, including Alta College and Academic Partnerships, to be Phoenix's newest President.

UoPX's problems are a symptom of an economic system that despite the hype cares little about workers: a system that today looks at labor costs as something to be reduced--rather than an investment. With few exceptions, America's most powerful corporations: Amazon, Walmart, Target, Yum Brands, McDonalds--rely on low-wage labor and automation to make a huge profit. Companies in medicine, finance, and tech have smaller labor numbers--and while work may be lucrative at the moment, it's becoming more precarious.

*In the early 2010s, Apollo Group, Phoenix's former parent company, spent between $376 million and $655 million a year on ads and marketing.

Related link: Robocolleges and Robostudents

Tuesday, August 21, 2018

The Slow-Motion Collapse of America’s Largest University

[While most of my higher education analysis has been statistical in nature, it’s important to look at qualitative and historical aspects of higher education. The collapse of University of Phoenix is one of those important stories.]

From 1976 to the early 2000s, the University of Phoenix established itself as a leader in educational innovation for working adults.

Hundreds of the school’s campuses and learning sites dotted the American landscape, conveniently located near interstate off ramps. Phoenix turned hotel meeting rooms and retail spaces into learning centers for busy strivers. For those who could not attend those schools, University of Phoenix created an online presence that was unsurpassed, with small class sizes and working professionals with real world experience as instructors.

Phoenix’s founder John Sperling was considered a genius for bringing education to adult professionals and other nontraditional students. A former university professor and self-described enemy of the academic elite, Sperling became friends with the political and business elite. Higher education’s billionaire was a notable friend of California Congresswoman Nancy Pelosi--and he appeared on Oprah.

Like the prosperity preachers who filled American television, Sperling offered the keys to success to anyone who would listen. Instead of Jesus, though, he was selling higher education.

In 2007, the limitations of online education, the adjunctification of labor, and the University of Phoenix became more evident in a New York Times article that revealed the school’s subprime graduation rate.

Rather than improving educational quality, Phoenix and its parent company, Apollo Group, became all about the numbers. At the highest level, Apollo was shooting for a half million students, which sounded laudable. Apollo Group branched out into associate degrees, and it reached out to students outside North America.

But the truth is that the company had to cut corners to meet these numbers.

In a scheme called “The Matrix”, enrollment representatives were rewarded for meeting enrollment numbers. And with that, enrollment representatives would do almost anything to get asses in classes. Apollo Group’s CEO Todd Nelson took the school to its highest numbers. But these numbers would come at a cost. The school faced enormous pressure from federal and state agencies.

The 2010 Harkin Commission and Aaron Glantz’s investigations with the Center for Investigative Reporting a few years later showed Phoenix to be a school that would use any means necessary to make a profit. Phoenix became a joke in popular culture, skewered by comedians John Stewart and John Oliver.

[In recent years, University of Phoenix's Wikipedia page looked more like a criminal rap sheet than an institution of higher education.]

With the doubling of class sizes, that motivation has been stripped away. I can barely keep up with the minimal requirements of my job, to say nothing of the additional effort I used to put in. There is no time for extras; the students are a blur. I find myself hoping they drop out and doing little to nothing to keep them in class, because each drop equals a bit of relief for me.--University of Phoenix instructor, 2018

In 2016, Apollo Education Group was taken over by Apollo Global Management, a corporate behemoth known to buy failing companies and stripping them of assets, and then selling them at a profit. Along with the sale, friends of President Obama--Tony Miller and Marty Nesbitt--were brought in to make the deal seem to be an act of educational reform.

[Image below: Apollo Education still has more than two dozen lobbyists in DC, but the money to Washington may be dwindling. Source: Open Secrets]

In 2018, the school’s marketing strategy has been to look backward, at the deceased founder John Sperling, and the adult night classrooms that are all but gone.

In a Trumpian world where history doesn't matter, the University of Phoenix is an unexamined relic of the 20th century. Enrollment is down an estimated 80 percent from its peak and more than 450 campuses and learning sites have closed. At least half of the campuses that have remained open are no longer taking new students, suggesting that they will close in the next 18 months.

Friday, September 15, 2023

Fraud Claims Against University of Phoenix Continue to Mount

The Higher Education Inquirer received a FOIA response today from the US Department of Education stating that 73,740 consumer fraud claims have been filed against the University of Phoenix. These claims have been made through the Department of Education's Borrower Defense to Repayment program.

The Sweet v Cardona lawsuit, concluded earlier in 2023, allowed for about 19,000 claims to be settled immediately--in favor of student debtors and against the University of Phoenix. Another 15,000 or so cases are supposed to be expedited as a result of the federal ruling.

23-02373-F Final Response

We estimate that the potential liability of these immediate claims to be $200M-$600M with another $500M-$1.5B for the remaining cases. The higher estimates are based on the median federal loan debt among borrowers who completed their undergraduate degree ($32,421) and a study by Adam Looney and Constantine Yannelis that indicated University of Phoenix debtors, on average, paid off almost nothing of their principal. The authors also estimated that total student loan debt from more than a million University of Phoenix debtors was $35B.

The Department of Education has not presented any estimates on the total debt by University of Phoenix students or its costs to the US government.

Thousands of new cases continue to be filed. From January 2015 through January 1, 2022, there were 32,040 Borrower Defense claims made against the University of Phoenix. An additional 41,700 claims were filed between 2022 and August 2023.

Idaho Sale

University of Phoenix's current owners are Apollo Global Management and Vistria Group, who have been trying to unload the online robocollege for years. The University of Idaho has been the most recent target, but the sale is far from being consummated. The entire deal is expected to cost $685M. Idaho Attorney General Raul Labrador has filed a lawsuit to stop or at least slow down the acquisition. And members of the Idaho Legislature continue to have questions.

In order to shield itself from liability the University of Idaho created a non-profit organization called 43 Education. But the state university may be responsible if the non-profit fails to make enough money to repay the bondholders of the new non-profit.

The liability of these Borrower Defense claims to the current or future owners of the University of Phoenix seems possible in light of a recent statement by Department of Education Undersecretary James Kvaal. Kvaal said the University of Arizona Global Campus may be liable for the misdeeds of Ashford University (UAGC's former name). The University of Arizona purchased Ashford in 2020 for one dollar.

Feds Cancel Loans for 2,300 Students Scammed by Ashford U. So Why Does the School Still Get Tax Dollars? (David Halperin)

University of Phoenix and the Ash Heap of Higher Ed History

Borrower Defense Claims Surpass 750,000. Consumers Empowered. Subprime Colleges and Programs Threatened.

The Growth of "RoboColleges" and "Robostudents"

More Transparency About the Student Debt Portfolio Is Needed: Student Debt By Institution

Monday, May 27, 2019

Can Apollo Global Management stem the bleeding at University of Phoenix?

Related Link: University of Phoenix Collapse Kept From Public Scrutiny, As Ads Continue (2019)
Related Link: The Slow-Motion Collapse of America’s Largest University (2018)
Related Link: University of Phoenix: "Where Dreams Die" (2016)
Related Link: Faux Phoenix or Vulture? (2015, 2018)

The collapse of University of Phoenix has been off the mainstream media radar for years. Only the conservative Daily Caller has bothered to investigate the demise of America's largest university. Since University of Phoenix is subsumed under a hedge fund behemoth, Apollo Global Management, it's very difficult to track the collapse. But the old information that we do have does not look good.

Data from fiscal year 2017 show that University lost money in all of its segments, except for Arizona. And that segment, which included the online division, showed only a slim profit. The total annual loss was about $52 million.

University of Phoenix has created cost cutting measures by closing most of its campuses, but that alone may not be enough to gain profitability. When campuses are closed, enrollment and reputation decline. It's notable that Federal Trade Commission has not publicly stated that they are finished with their investigation either.

The UoPX brand is badly tarnished and perhaps beyond repair. Expensive fantasy land media campaigns like "Discover Your Wings" cannot make up for a declining product or service that depends more on word of mouth and the success of those who attend. Apollo Education and University of Phoenix could declare bankruptcy, as other Apollo Global Management companies have done or threatened to do, but that would bring even more bad attention.

I have attempted multiple times to communicate with University of Phoenix, but they refuse to respond. While stonewalling can prevent misquotes and distortions, "playing dead" is not a good sign for any business.

Saturday, March 4, 2023

An Email of Concern to the People of Arkansas about the University of Phoenix (Tarah Gramza)

February 26, 2023.

Hi! My name is Tarah Gramza. Dahn Shaulis has been talking with me about the University of Phoenix/University of Arkansas situation. I offered to share my knowledge as I have quite a bit with years of experience in this mess of subprime colleges and student loan debt.

I am the creator/administrator of a quite popular Facebook group with approximately 14,000 members. Theresa Sweet and I came together by sheer accident and became close friends. We have managed this group together for a few years now.

Theresa started her battle with the US Department of Education (aka ED) nearly a decade ago trying to get anyone’s attention to hear her story and draw attention to the fraud being committed by these schools right under everyone’s noses. Our stories are all similar: we attended schools who promised a future full of butterflies and roses, misled quality of education, pressured enrollment, false advertised job placement, lied about costs...the list goes on.

Following the bread crumbs

Our lawsuit started as a mission to hold the Department of Education accountable for delaying the processing of Borrower Defense to Repayment applications. These delaying actions broke ED's own rules and regulations. The last several administrations tried to change rules for their own agendas and to satisfy their paid cronies. We know for a fact many congressional leaders have been deeply invested and made millions from this for-profit schools fraud. This includes the Secretary of Education at the time, Betsy DeVos.

The first settlement forced ED to process applications fairly within a period of time. The department made a big mistake, they decided to deny 90% of class members applications and used illegal denial letters, which ultimately stopped the settlement and sent us back to litigation/discovery. During the discovery it was uncovered that ED had internal emails showing they were intentionally not reviewing applications per the law requirement (a policy of mass denial), withheld evidence by the department on many of the main culprit schools, and knew about the fraud being committed at the highest levels. This led to additional claims by the class and now opened the department up for direct financial liability and undue harm. This led to the final settlement that sits today.

Between the first settlement and the illegal denials and the present one, the administrations changed and Betsy DeVos quit her job. During the discovery (testimony) it was found that upper leadership under Betsy DeVos pointed their fingers directly at Betsy herself and that she directed these policies, an attempt was made to make her testify. As government always does, they protected her and their own tails in the process and she was allowed to skate by unscathed. The new administration decided it was time to start doing the right thing; the sheet was pulled back enough for everyone to see they well knew about the fraud for over a decade.

This lawsuit also brought forward the fact that ED had not used its own rules to go after schools for recoupment costs on the taxpayers behalf and recoup funds from these executives, schools, leaders. This includes some of the leaders of major school collapses such as Corinthian Colleges and ITT Tech. Sadly, the executives just jumped from one school to the next bringing their fraud with them along the way, leaving a wake of schools with damaged students.

Putting it together

The final settlement (Sweet v Cardona) was signed and all of a sudden four schools from the list of 151 known offender schools decided to intervene on the lawsuit. They used every excuse they could to conjure up to stop this case and hold up the settlement--even though the settlement didn’t hold them accountable for the class discharged claims. The judge ultimately denied their requests leading a final settlement approval. Three of those four schools then appealed the judge for a stay,which was officially denied Friday evening.

Why would four schools appeal a lawsuit that doesn’t involve them of which ultimately has no recoupment against them for the class?

Well- here’s why, the post class group AND any following applications will have recoupment. The department, right around the time of the announcement, had recently announced the recoupment efforts against Devry University and this terrified the schools. They knew full well they were next and that it would put them out of business and these shareholders would be left holding the bag. Now a plan needed to be put into place to try to find a way out.

The plan

University of Phoenix is one the biggest offenders and probably one the largest schools to profit from this business model of fraud. We’ve seen evidence that much of the fraudulent activity came directly out of the University of Phoenix training manuals. They also had some of biggest lawsuits, so intervening as University of Phoenix was a bad idea.

The well-known school lobbying group Career Education Colleges and Universities (CECU) led by Jason Altmire banded together to not only bundle money from these subprime schools to stop this lawsuit, by using these four smaller less widely known, less lawsuits, as pawns in a bigger game. Jason has been known and deeply ingrained in this scandal for over 20 years, even before he was lobbying. He was an elected official voting for this for profit game. Holding up the lawsuit benefited every single school named on Exhibit C and you will see why below.

The new rules and regulations were published a few months back with hard targeted rules that establish a line in the sand starting July 2023. These regs held harsh consequences for all schools not only into the future but also for past bad deeds. The rules also clarified and hardened the rules for information sharing (evidence) and group discharges.

It became apparent that the shareholders and owners of University of Phoenix needed out and now. This is because the recoupment efforts follow owners. If they can sell the school, they can cash out what is left of their $1 Billion investment and run intact. Which leads to the point of this email, if Arkansas, or any other buyer decides to buy University of Phoenix they will be the target for the recoupment efforts which I estimate to be approximately $600M dollars as it stands today with the number pending recoupable borrower defense applications. If things go as expected this number could exceed $1B. The rules call for recoupment of funds and also steep consequences such as loss of title IV funds.

Jason Altmire and his lobbying group are so desperate to prevent these rules, they are suing in Texas to prevent them from being implemented.

Why would the Governor of Arkansas pursue this deal?

The Governor of Arkansas knows full well the risks. The political side of this story is administrations. Republican administrations have been very friendly to these schools and have in the past created and changed ED rules in the schools favor and turned a blind eye to the fraud. Democrats have also been guilty of this but in today’s climate we have to think of the present state of the Republican position in student debt relief. The state of Arkansas is offered a sweet deal of a percent of profits on a private deal which they claim doesn’t cost tax payers.

The hidden agenda by the governor is she is gambling against a change in administration that is friendlier and will either not pursue recoupment against a state owned (affiliated) school OR she is thinking the Biden administration will lose the next election in which they will push to change the rules again! This is a steep gamble as I suspect the secrets in this deal don’t offer protections to the state as presented in press briefings. If the state is signing a contract for profits, what happens if the school goes under? As you may be aware, much of these warnings have been shared with the leadership of Arkansas by many student advocate groups including our lawyers for the Sweet case, the Project on Predatory Student Lending-PPSL.

Recent announcements made by the Department of Education have added an additional layer of risk for anyone purchasing University of Phoenix as ED recently announced it “may require certain individuals to assume personal liability as a condition of allowing the schools they own or operate to participate in the federal financial aid programs and likely to require an individual to assume personal liability on behalf of the institutions or groups of affiliated institutions that pose the largest financial risk to the United States. This is determined based on institutions with the most serious and significant sets of concerns.” The question becomes, who will be putting their personal assets as collateral? University of Phoenix is not only a risk, it is one the primary reasons for the need for additional protections to the tax payers.

What value would the purchase of University of Phoenix have to the state of Arkansas if it can’t have its Title IV renewed? This fact alone combined with the University of Phoenix history, should scare away even the most riskiest investor!

Now you know the big picture. I hope it helps guide your actions and I hope you are willing to write and share with the public how this dangerous gamble is being wagered against the people of the state of Arkansas. For the records, I am a Republican and my focus is to point to facts of the situation and the truth of the climate in politics leads toward the assessment I’ve given. Let me know if you have any questions. I’m happy to help where I can. I also hold a large document that provides significant evidence against all the schools but the University of Phoenix file speaks volumes and will likely expand on the depth of the fraud, if you are interested.

Sincerely,

Tarah Gramza