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Our Vision and Mission
−Removed: Our vision is for education that transforms lives, advances careers, and improves communities.
−Removed: Our mission is to Power Potential and Prosperity for Those Who Serve.
+Added: Our vision is for education to transform lives, advance careers, and improve communities.
+Added: Our mission is to Power Purpose, Potential and Prosperity for Those in Service to Others.
Our institutions of advanced learning are purpose-built to prepare service-minded students for employment, careers, and leadership in a diverse and changing world.
−Removed: We are the number one educator of active-duty military and of veterans through American Public University System, a national leader in pre-licensure nursing education, focused on a Diploma in Practical Nursing, or PN degree, and an Associate Degree in Nursing, or ADN degree, through Rasmussen University and Hondros College of Nursing, and operate one of the largest providers of training to the federal government and public workforce through Graduate School USA.
+Added: Many of our students are from underserved populations for whom our institutions can transform their and their families’ lives.
+Added: We are the number one educator of active-duty military and of veterans through American Public University System.
+Added: We are a national leader in pre-licensure nursing education, focused on a Diploma in Practical Nursing, or PN degree, and an Associate Degree in Nursing, or ADN degree, through Rasmussen University and Hondros College of Nursing.
+Added: We operate one of the largest providers of training to the federal government and public workforce through Graduate School USA.
Our Institutions
We have four subsidiary institutions:
−Removed: American Public University System, Rasmussen University, Hondros College of Nursing, and Graduate School USA.
American Public University System;
−Removed: APUS provides online postsecondary education to approximately 89,800 adult learners.
+Added: Rasmussen University;
+Added: Hondros College of Nursing;
+Added: and Graduate School USA.
+Added: American Public University System
+Added: American Public University System, or APUS, provides online postsecondary education to approximately 88,400 adult learners.
APUS traces its roots to American Military University, or AMU, which was founded in 1991, as a distance-learning, graduate-level institution for military officers seeking an advanced degree in military studies.
−Removed: Since then, APUS has broadened its focus to include other military communities, veterans, and public service and public service-minded communities, with a focus on educating those who serve, and has two components:
+Added: Since then, APUS has broadened its focus to include veterans, extended military families, and other public service and service-minded communities, with a focus on educating those who serve, and has two brands:
AMU, which is focused on educating students from the military, national security, military-affiliated and service communities, like police, firefighters, emergency personnel, and government employees, and American Public University, or APU, which is focused on educating career-focused working adults with an emphasis on educating professionals working in service-related communities, including nursing, public health, public administration, and business administration.
−Removed: Today, a majority of APUS students are undergraduate-level students in addition to its graduate and certificate students.
+Added: Today, while the majority of APUS students are undergraduate-level, students are also enrolled in its certificate, graduate, and doctoral programs.
APUS is exclusively an online institution of higher learning, designed to meet the needs of the military, military-affiliated, public service, and working adult students.
−Removed: Many of these students serve in positions requiring extended and irregular work schedules, are on-call for rapid response missions, participate in extended deployments and exercises, travel or relocate frequently, and often must balance family and work demands.
+Added: Many of its students serve in positions requiring extended and irregular work schedules, are on-call for rapid response missions, participate in extended deployments and exercises, travel or relocate frequently, and often must balance family and work demands.
Although APUS’s focus has broadened since its founding, it continues to have an emphasis on its relationship with the military community.
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Most other higher education institutions accept APUS’s courses for transfer credit as a result of this accreditation.
−Removed: HLC will conduct a focused visit at APUS in March 2024 after raising concerns regarding compliance with standards related to program development oversight and program assessment processes as a result of course availability in one program.
−Removed: APUS has a Standard Pathway designation, having transitioned from the Open Pathway in 2023 because of HLC’s decision to conduct a focused visit.
−Removed: All institutions on the Standard Pathway, including APUS, must undergo a mid-cycle comprehensive evaluation.
−Removed: A reaffirmation of accreditation site visit date will take place 2030-2031.
+Added: For more details on APUS’s HLC accreditation, see “Our Institutions and Operations – Our Institutions – Accreditation” and “Regulatory Environment – Accreditation – Institutional Accreditation” below.
Rasmussen University
−Removed: RU provides nursing- and health sciences-focused postsecondary education to over 14,100 students at its 22 campuses in six states and online.
+Added: RU provides nursing- and health sciences-focused postsecondary education to approximately 14,600 students at its 20 campuses in six states and online.
At the beginning of its 124-year history, RU focused on educating business students to prepare them for practical careers in bookkeeping, secretarial services, and accounting.
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While RU continues to offer programs across a broad range of study including business, technology, and education, it expanded its breadth and embarked on providing healthcare education in 2006.
−Removed: Today, RU offers a comprehensive “ladder” of nursing degrees, including pre-licensure PN and ADN degrees, post-licensure Bachelor of Science in Nursing, or BSN, and RN to BSN degrees, Master of Science degrees in Nursing, Specialties and Nurse Practitioner, and a Doctorate of Nurse Practice.
+Added: Today, RU offers a comprehensive “ladder” of nursing degrees, including pre-licensure PN and ADN degrees, post-licensure Bachelor of Science in Nursing, or BSN, and Registered Nurse, or RN, to BSN degrees, Master of Science degrees in Nursing, Specialties and Nurse Practitioner, and a Doctorate of Nurse Practice.
RU is committed to innovation in program delivery.
−Removed: For example, RU offers competency-based education, or CBE, helping to advance this learning approach where students learn by doing, manage their pace, and stay connected with faculty and peers.
−Removed: Additionally, virtually every nursing program at RU incorporates online content alongside lab and clinical or classroom components.
−Removed: As of December 31, 2023, approximately 5,700 students are pursuing nursing degrees at RU, over 90% of whom are enrolled in RU’s pre-licensure nursing degree programs, and approximately 8,400 students are enrolled in non-nursing programs.
+Added: For example, virtually every nursing program at RU incorporates online content alongside lab and clinical or classroom components.
+Added: As of December 31, 2024, on-ground enrollment was approximately 6,300, of which approximately 5,500 students were pursuing nursing degrees at RU, approximately 90% of whom were enrolled in RU’s pre-licensure nursing degree programs.
+Added: At December 31, 2024, online enrollment was approximately 8,300 students.
RU is institutionally accredited by HLC with an Open Pathway designation, and all of RU’s Nursing programs are programmatically accredited by specialty nursing accrediting bodies.
As with APUS, most other higher education institutions accept RU’s courses for transfer credit as a result of RU’s HLC accreditation.
−Removed: APEI acquired RU on September 1, 2021, which we refer to as the Rasmussen Acquisition, adding what we believe is an attractive portfolio of programs to APEI, with a strong alignment around mission and culture.
Hondros College of Nursing
HCN provides nursing education to approximately 3,700 students across eight campuses in three states.
−Removed: HCN offers pre-licensure nursing programs that are designed to prepare individuals for productive careers through both a PN degree and an ADN degree, and two Direct Entry ADN degree options that offer an accelerated graduation pathway for students who meet certain transfer, academic, and entrance exam requirements.
+Added: HCN offers pre-licensure nursing programs that are designed to prepare individuals for productive careers through both a PN degree and an ADN degree, and two Direct Entry ADN degree options that offer an accelerated graduation pathway for students who meet certain transfer credit, academic, and entrance exam requirements.
HCN’s students principally receive on-campus instruction at one of HCN’s campuses and online for certain courses for those that prefer remote course learning.
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2024 Developments and Future Financial Objectives
−Removed: Campus Expansions and Relocations
−Removed: In 2023, HCN relocated its former Fairborn, Ohio campus, located in a suburb of Dayton, Ohio, to a new, larger and more convenient, location in Dayton to better serve its students.
−Removed: HCN also intends to relocate its Toledo and Columbus, Ohio campuses to new, larger locations nearby.
−Removed: These relocations are expected to be completed in the summer and fall of 2024, respectively.
−Removed: In April 2023, RU completed the relocation of its Topeka, Kansas, campus to a new, larger location to expand its campus footprint and offer larger classrooms with improved nursing skills and simulation labs.
−Removed: In addition, RU intends to combine two campuses located in Ocala, Florida, into a single, expanded campus to improve the student experience.
−Removed: Insourcing of Marketing and Information Technology
−Removed: RU has historically outsourced the vast majority of its marketing and information technology functions through two contracts, one for each of marketing and information technology, with Collegis, LLC, or Collegis.
−Removed: In October 2022, RU and Collegis mutually agreed to the termination of the marketing services contract, effective January 31, 2023, and completed the transition of RU marketing to our in-house centralized marketing team.
−Removed: Outsourced information technology services under the Collegis information technology contract will continue through September 2024, when we intend to allow the contract to expire, and transition all information technology functions currently outsourced to Collegis back to our operations and to one or more third-party vendors.
−Removed: In December 2023, we entered into an agreement to outsource certain of our information technology operations to a managed service provider, including service desk, end user support, and network support and operations.
−Removed: Executive Leadership Changes
−Removed: During 2023, we made strategic hires aimed at bolstering our ability to deliver improved student experience and outcomes, accelerating growth and transformation, including a new President of RU, a new President of GSUSA, and a new
−Removed: Chief Marketing Officer.
−Removed: Please refer to “Our Institutions and Our Operations – Information About our Executive Officers” below for additional information about our executive officers serving as of the date of this Annual Report.
+Added: The Planned Combination of APUS, RU, and HCN
+Added: On January 28, 2025, we announced our plan to combine APUS, RU, and HCN into one consolidated HLC-accredited institution that will be a university system encompassing all APUS, RU, and HCN programs, campuses, and operations, or the Combination.
+Added: The combined institution will be named American Public University System, or the Combined Institution.
+Added: As a result of the Combination, the Combined Institution will have two divisions, tentatively named (i) APUS Global, comprised of AMU and APU and (ii) Rasmussen, comprised of RU’s campus-based and online nursing programs, RU’s healthcare programs, HCN’s campus-based nursing and healthcare programs, and RU’s non-healthcare programs, with final division names to be determined closer to closing of the Combination.
+Added: The structure will allow each institution to continue to serve its particular student populations while benefiting from being part of a single university system.
+Added: The structure is designed to leverage each institution’s strengths to focus our efforts on supporting the military and veterans and expanding our nursing and healthcare platforms to better serve our students.
+Added: We believe combining our subsidiary institutions into a single university system will strengthen the financial position of our Company as a whole, enable us to operate with greater efficiency, and facilitate innovation across the Company through more direct collaboration among the educational divisions.
+Added: We anticipate completing the Combination in the third quarter of 2025, subject to obtaining required approvals and ED taking related actions.
+Added: For additional details regarding regulatory treatment of the Combination, see “Regulatory Environment – Accreditation – Institutional Accreditation” and “Regulatory Environment – Accreditation – The Planned Combination of APUS, RU, and HCN”, and for additional information regarding risks related to the Combination, see the Risk Factor with the caption beginning “The planned combination of APUS, RU, and HCN ….”
Rasmussen University Regulatory Metrics
−Removed: RU’s new leadership team focused in 2023 on improving various regulatory metrics at RU, particularly NCLEX pass rates.
−Removed: We increased our focus on these metrics in 2023 in light of RU’s ADN enrollment declines, as a result of both voluntary and imposed enrollment caps in large part due to NCLEX pass rates below requisite state thresholds, as discussed further in the Risk Factors captioned “RU is currently on provisional certification with ED, and the terms of that provisional certification could limit its potential for growth” and “Continued declines in enrollments at RU could materially adversely affect RU’s and our profitability, financial condition, results of operations, and cash flows.” We believe that initiatives put in place by RU’s leadership during 2023, together with changes to the NCLEX that were implemented in April 2023, resulted in improvements to RU NCLEX pass rates, including improvements in the ADN program pass rates at nearly every campus in the second half of 2023 as compared to the first half of 2023.
−Removed: We expect NCLEX pass rates and regulatory metrics more generally to be a continued area of focus and improvement in 2024.
−Removed: 90/10 Compliance Outlook
−Removed: We had a sustained focus in 2023 on the “90/10 Rule, which is described under “Student Financing Sources and Related Regulations/Requirements – Department of Education – Regulation of Title IV Financial Aid Programs – Financial Responsibility” below.
+Added: RU’s leadership team continued to focus throughout 2024 on improving various regulatory metrics at RU, particularly National Council Licensure Examination, or NCLEX, pass rates.
+Added: We increased our focus on these metrics in 2024, partially because RU’s ADN program enrollment had been adversely impacted by both voluntary and imposed enrollment caps imposed in large part due to NCLEX pass rates below requisite state thresholds, as discussed further in the Risk Factor captioned
+Added: “Declines in enrollments at RU could materially adversely affect RU’s and our profitability, financial condition, results of operations, and cash flows”.
+Added: In 2024, we saw improvements to RU NCLEX pass rates, including in the ADN program pass rates at nearly every campus, as compared to early 2023.
+Added: We believe these improvements were driven by initiatives put in place by RU’s leadership during the last two years as well as by changes to the NCLEX that were implemented in April 2023.
+Added: NCLEX pass rates and regulatory metrics more generally will continue to be an area of focus.
+Added: 90/10 Compliance
+Added: We continued to have a sustained focus in 2024 on the “90/10 Rule”, which is described under “Student Financing Sources and Related Regulations/Requirements – Department of Education – Regulation of Title IV Financial Aid Programs – Financial Responsibility” below.
While each of our institutions was in compliance with the 90/10 Rule for 2024, APUS’s relevant percentage for 2024 was 89%.
−Removed: In 2023, enrollments from students who use TA funds trended upward, while enrollments from students who use non-federal educational assistance funds continued to decline, causing APUS’s 90/10 percentage to increase and move closer to the threshold.
Compliance with the 90/10 Rule will continue to be an area of focus, and despite our efforts, there can be no assurance that we will continue to be able to comply in future years, particularly at APUS.
−Removed: See the Risk Factors captioned “If one or more of our institutions does not comply with the 90/10 Rule, it or they will lose eligibility to participate in federal student financial aid programs” and “Our student registrations, revenue, and cash flow have been adversely impacted and we could continue to experience adverse impacts as a result of the Army’s transition to new systems for soldiers to request TA” for more information.
−Removed: Cost and Expense Reductions
−Removed: During 2023, we initiated several cost and expense reduction efforts, including a reduction in force in the third quarter that resulted in the termination of 74 employees and the elimination of 57 open positions across a variety of roles and departments at APEI, RU, HCN and GSUSA.
−Removed: The headcount reductions reflect our ongoing efforts focused on realigning our organizational structure, eliminating redundancies, and optimizing certain functions.
−Removed: We incurred an aggregate of approximately $3.0 million of pretax cash expenses associated with employee severance costs as a result of this reduction in force, all of which were incurred in the third quarter of 2023.
−Removed: The reduction in force is expected to result in pre-tax labor and benefit savings of approximately $15.5 million on an annualized basis.
+Added: See the Risk Factors captioned “If one or more of our institutions does not comply with the 90/10 Rule, it or they will lose eligibility to participate in federal student financial aid programs” and “Our student registrations, revenue, and cash flow have been adversely impacted and we could experience additional adverse impacts as a result of the Armed Forces’ transition to new systems for soldiers to request TA” for more information.
+Added: Campus Consolidations and Closures
+Added: In 2024, RU combined two Florida campuses and two Minnesota campuses, each consolidation resulting in a single expanded campus in the respective state, with the intention to improve the student experience.
+Added: In May 2024, RU notified the Wisconsin Educational Approval Program, or EAP, that it intends to voluntarily close its two Wisconsin campuses, effective December 31, 2025, and 2026, respectively.
+Added: All students enrolled at the two Wisconsin campuses have expected graduation dates on or before the applicable campus closing date.
+Added: For additional information, see the Risk Factor captioned “RU’s actual and planned closure of campuses or termination of programs on certain campuses may adversely impact RU and us”.
+Added: Executive Leadership Changes
+Added: During 2024, we entered into a Transition and Release Agreement with our Chief Financial Officer and began an orderly search to fill this position.
+Added: In addition, we recently announced a new president for RU and the transition of the current RU president to service on the RU Board of Directors.
+Added: Please refer to “Our Institutions and Our Operations – Information About our Executive Officers” below for additional information about our executive officers serving as of the date of this Annual Report.
+Added: Information Technology
+Added: In April 2024, as part of our technology transformation program, we transitioned to a managed service provider for certain information technology services, including service desk, student support, end user support, and network management and operations.
+Added: In the third quarter of 2024, the information technology services previously outsourced under the Collegis LLC, or Collegis, information technology contract were transitioned in-house and to third-party vendors.
+Added: Tuition Increases
+Added: Providing affordable degree and certificate programs is an important element of our competitive strategy.
+Added: In April 2024, APUS implemented a modest tuition increase for master’s level students across all categories, including military, non-military, and veteran students, and in September 2024, APUS returned the military rate for master’s level students to the $250 per credit hour rate in effect prior to the April 2024 tuition increase.
+Added: We believe that APUS’s tuition and fees remain lower than the average in-state cost at public universities.
+Added: RU implemented modest tuition increases for all students for select programs in the first quarter of 2024, for new students for select programs in August 2024, and for returning students for select programs in October 2024.
+Added: The tuition and fee increases at RU are intended to reflect adjustments to be consistent with the local campus markets and competitive environment.
+Added: Even with these increases, we believe RU’s tuition and fees are designed to be affordable and competitive when compared to the tuition and fees at similar institutions offering the same level of flexibility, accessibility, and student experience.
Share Repurchase Program
−Removed: On March 16, 2023, our Board of Directors confirmed the availability under an existing share repurchase program to repurchase up to approximately $8.0 million of shares of our common stock.
−Removed: We fully expended this $8.0 million as of April 30, 2023, and repurchased a total of 1,335,357 shares of our common stock.
−Removed: On November 27, 2023, the Board of Directors authorized a new program to repurchase up to an additional $10.0 million of shares of our common stock.
−Removed: In the fourth quarter, we repurchased 180,409 shares of our common stock under this repurchase authorization for an aggregate purchase amount of $1.6 million.
−Removed: In the aggregate, in 2023 we repurchased 1,515,766 shares of our common stock for $9.7 million.
−Removed: In January 2024, we repurchased 251,146 shares of our common stock for an aggregate purchase amount of $2.8 million.
+Added: In January 2024, we repurchased 251,146 shares of our common stock under our November 2023 repurchase authorization for an aggregate purchase amount of $2.8 million.
Effective February 1, 2024, we ceased purchases under this purchase authorization.
Financial Objectives
−Removed: We strive to build on the momentum created by our actions and achievements in fiscal 2023 and to continue to execute on our strategic plan.
+Added: In 2025, we strive to build on the momentum created by our actions and achievements in 2024 and continue to execute on our strategic plan.
Specifically, we are focused broadly on (i) achieving public market scale by growing the revenue of our enterprise organically and inorganically and (ii) delivering improved enterprise-wide operating margins.
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• a continually changing regulatory environment;
−Removed: • fluctuations in enrollment as evidenced by industry-wide undergraduate enrollment growth of 2.1% in the fall 2023 as compared to an overall industry-wide enrollment decline of 0.7% in the fall 2022;
−Removed: • rapid technological transformation, including through increasing demand for online offerings and the utilization of technology to enhance student learning, and emerging artificial intelligence, or AI, technologies.
+Added: • fluctuations in enrollment, as evidenced by industry-wide undergraduate enrollment growth of 2.0% between the fall of 2012 and the fall of 2022 at four-year institutions;
+Added: • rapid technological transformation, including through increasing demand for online offerings and the utilization of technology to enhance student learning, and increasing use of artificial intelligence, or AI, technologies.
In addition to the characteristics outlined above, the U.S.
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We believe that APUS will continue to see competition in the military community from both not-for-profit and for-profit schools, as well as from the Armed Forces themselves, including through distance learning programs.
−Removed: For example, the Navy in 2019 launched the U.S.
−Removed: Naval Community College, or the USNCC, a community college supporting naval education for enlisted service members.
−Removed: The USNCC now provides education to approximately 2,600 service members, and it plans to eventually achieve the capability to accommodate up to 25,000 students.
−Removed: While a number of schools with which APUS competes are participating partners with the USNCC, as a for-profit institution, APUS is not an eligible partner.
−Removed: As traditional not-for-profit public and private schools advance online capabilities, we believe that they will also present increasing competition for APUS.
−Removed: military is demonstrating increased levels of support for credentials other than degrees, which we believe could lead to enhanced competition from institutions serving military students.
−Removed: For example, Credentialing Opportunities On-Line, or COOL, is a program for each of the military branches and DoD civilians that links military occupations and experiences to civilian credentials (e.g., occupational certifications, licenses, and apprenticeships).
−Removed: The Army also offers an
−Removed: expanded credentialing program called the Army Credentialing Assistance Program, or Army CA, which is designed to support soldiers who wish to pursue civilian credentials, licenses, and certifications that may lead directly to a specific job.
−Removed: We believe other service branches may follow the Army’s example or pursue other approaches to enhancing support for credentialing, including, for example, the Coast Guard’s CA Program.
−Removed: APUS was previously an approved training provider for Army CA programs but ceased offering courses under the Army CA program in November 2022.
+Added: For example, the U.S.
+Added: Naval Community College, or the USNCC, a community college supporting naval education for enlisted service members, reached initial operating capability in the fall of 2023 and now provides education to approximately 5,000 service members.
+Added: By fiscal year 2026, it plans to achieve the capability to accommodate more than 10,000 students.
+Added: While a number of schools with which APUS competes are participating partners with the USNCC, APUS is not an eligible partner because of its status as a for-profit institution.
+Added: As traditional not-for-profit public and private schools continue to advance online capabilities, we believe that they will continue to present increasing competition for APUS.
Nursing Programs
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Non-Traditional Competition
−Removed: We also face competition from competing schools and others providing non-traditional education programs, often without charge or at low costs, including:
−Removed: • institutions offering competency-based education, or CBE, programs and single course or course packages aimed at credentialing outcomes rather than degree outcomes;
+Added: We also face competition, particularly at APUS and for RU’s online programs, from competing schools and others providing non-traditional education programs, often without charge or at low costs, including:
+Added: • institutions offering CBE programs and single course or course packages aimed at credentialing outcomes rather than degree outcomes;
• corporate training and other companies partnering with universities or the federal government to offer alternative educational paths for students and the federal government workforce, respectively;
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Our Opportunities
−Removed: Active-Duty Military and Veterans
+Added: Active-Duty Military, Veterans, and their Families
military community will continue to be an important market segment for online education.
−Removed: We believe service members will continue to seek respected universities that provide military-focused support services coupled with an
−Removed: online curriculum and flexible scheduling.
+Added: We believe service members will continue to seek respected universities that provide military-focused support services coupled with an online curriculum and flexible scheduling.
We believe service members are particularly interested in postsecondary credentials that offer both career advancement within the military and preparation for employment outside of the military.
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We believe that our military heritage, affordability, and online offerings are attractive to veterans.
−Removed: New policies and campaigns to facilitate the hiring of veterans may lower barriers to non-military jobs and facilitate veteran-owned businesses.
−Removed: As these policies and campaigns lower barriers to non-military jobs and facilitate veteran-owned businesses, we believe online universities offer valuable educational opportunities for veterans regardless of where they live, work, or learn.
+Added: In addition, policies and campaigns to facilitate the hiring of veterans may reduce barriers to non-military jobs and facilitate veteran-owned businesses.
+Added: As these policies and campaigns reduce barriers to non-military jobs and facilitate veteran-owned businesses, we believe online universities offer valuable educational opportunities for veterans regardless of where they live, work, or learn.
+Added: We also believe that family members of both active-duty military and veterans represent an opportunity given our prominence and reputation in the military and veterans communities.
The expanding need for healthcare coupled with a nursing shortage continues to drive significant demand for nursing education.
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When factoring in the need to replace workers who transfer to different occupations or exit the labor force, such as to retire, the U.S.
−Removed: Bureau of Labor Statistics projects openings each year for registered nurses of approximately 193,100, and approximately 54,400 for practical nurses, through 2032.
+Added: Bureau of Labor Statistics projects openings each year for registered nurses of approximately 194,500, and approximately 54,000 for practical nurses, through 2033, though the amount of demand varies by geography.
There is significant unmet demand from qualified students for nursing educational programs.
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The combined tuition and fees at APUS are generally less than the average in-state cost at a public university.
−Removed: APUS’s low tuition and fees, in combination with APUS-funded tuition grants and book grants provided to all undergraduate students result in significant savings and mean that APUS students are not required to take on as much debt as they might at another institution.
+Added: APUS’s low tuition
+Added: and fees, in combination with APUS-funded tuition grants and book grants provided to all undergraduate students result in significant savings and mean that APUS students are not required to take on as much debt as they might at another institution.
APUS’s generous transfer credit policy, and use of open educational resources, further reduce a student’s out-of-pocket costs.
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RU students may also lower their total cost of attendance through self-directed assessments, which provide savings by permitting students who demonstrate proficiency in a subject to test out of courses.
−Removed: Similarly, HCN students may apply performance-based grants and needs-based grants toward the balance of their tuition.
+Added: Similarly, HCN students may apply performance-based grants toward the balance of their tuition.
Please refer to “Our Institutions and Operations – Our Institutions – Affordability and Cost of Attendance” below.
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Our institutions are also committed to continually assessing and enhancing our academic programs and student services to offer a high-quality education and facilitate successful outcomes for our students and graduates that align with employer needs.
−Removed: The depth and breadth of APUS’s and RU’s non-nursing program offerings are designed to effectively address the diverse needs of students who enter into education programs with vastly different educational and career backgrounds and goals.
+Added: The depth and breadth of APUS’s and RU’s non-nursing program offerings are designed to effectively address the needs of students who enter into education programs with vastly different educational and career backgrounds and goals.
For example, APUS utilizes Industry Advisory Councils to evaluate its current curriculum and determine the career relevance of programs and degrees, which facilitate efforts to connect APUS’s curriculum to the industries and the students it serves and to deliver a high-quality academic product.
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Our institutions offer flexible learning modalities to meet the needs of busy working adults.
−Removed: APUS offers online delivery with monthly starts and academic support offerings are individualized to students’ needs, while RU offers CBE programs, a blend of online and in person courses for their nursing and other healthcare-related programs, and flexible start dates and online courses for other programs.
+Added: APUS offers online delivery with monthly starts and academic support offerings that are individualized to students’ needs, while RU offers a blend of online and in person courses for their nursing and other healthcare-related programs, and flexible start dates and online courses for other programs.
HCN offers PN and ADN programs that accommodate working adults by offering on-campus instruction, online instruction for certain courses, as well as daytime and evening/weekend options.
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APUS is the number one educator of active-duty military and of veterans.
−Removed: Since its founding, APUS has broadened its focus to include other military communities, veterans, and public service and service-minded communities, with a focus on a broad purpose of “educating those who serve.” As of December 31, 2023, approximately 66% of APUS’s students self-reported that they served in the military on active duty at the time of initial enrollment, and approximately 11% of APUS’s students self-reported that they are a military veteran.
+Added: Since its founding, APUS has broadened its focus to include veterans, extended military families, and other public service and service-minded communities, with a focus on a broad purpose of “educating those who serve.” As of December 31, 2024, approximately 65% of APUS’s students self-reported that they served in the military on active duty at the time of initial enrollment, and approximately 12% of APUS’s students self-reported that they are a military veteran.
We are also a national leader in pre-licensure nursing education.
−Removed: RU has more than 5,700 nursing students at its 22 campuses across six states and online with over 90% of those students pursuing a pre-licensure PN degree, ADN degree, or post-licensure BSN degree.
+Added: RU and HCN have more than 9,200 nursing students at their 28 campuses across nine states and online with over 90% of those students pursuing a pre-licensure PN degree, ADN degree, or post-licensure BSN degree.
Finally, we are one of the largest providers of training to the federal and public employee workforces through GSUSA with its extensive portfolio of government agency customers and directly enrolled federal government employees.
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We believe that our institutions provide us with a foundation from which we can build a career learning platform.
−Removed: We intend to expand GSUSA into new domains and models.
−Removed: We seek to enter into new, and expand existing nursing provider partnerships such as those at HCN.
−Removed: For example, during the fourth quarter of 2022, HCN entered into a tuition scholarship program with a national healthcare provider to provide scholarships to ADN students at its Toledo, Ohio campus in exchange for a work commitment following graduation.
−Removed: In the fall of 2023, HCN partnered with another national healthcare organization to provide similar scholarships to ADN students at its Columbus, Ohio campus.
−Removed: Additionally, among our institutions’ offerings are certificate programs, credentialing, and CBE programs.
+Added: We seek to enter into new nursing provider partnerships and expand existing nursing provider partnerships, such as those at HCN.
+Added: For example, in the fall of 2022, HCN entered into a tuition scholarship program with a national healthcare provider to provide scholarships to ADN students at its Toledo, Ohio, campus in exchange for a work commitment following graduation, and, in 2023, partnered with another national healthcare organization to provide similar scholarships to ADN students at its Columbus, Ohio, campus.
+Added: We continue to add new partnerships with healthcare partners at HCN to provide scholarships to ADN and LPN students at our Ohio campuses.
+Added: During the fourth quarter of 2024, we began exploring similar opportunities for RU.
+Added: Additionally, among our institutions’ offerings are certificate and credentialing programs.
Transform the Company to Achieve Sustainable Growth
We aim to increase our public market scale by growing the revenue of our enterprise organically and inorganically and delivering improved enterprise-wide operating margins.
−Removed: We intend to develop capabilities to drive organic growth and plan to continue to assess and pursue strategic investments and acquisitions and integrate and grow them for inorganic growth.
+Added: We intend to develop capabilities to drive organic growth and plan to continue to assess and pursue strategic acquisitions and integrate and grow them for inorganic growth.
Our strategy is organized around areas where we believe we have “the right to win.” For example, we will continue to focus on being the top educator for active-duty military and veterans and pre-licensure nurses.
−Removed: We also aim to deliver improved enterprise-wide operating margins by continuing to exercise financial discipline and taking steps such as our efforts focused on realigning our organizational structure, eliminating redundancies, and optimizing certain functions.
+Added: We also aim to deliver improved enterprise-wide operating margins by continuing to exercise financial discipline and taking steps such as our efforts focused on realigning our operating model, including the Combination, eliminating redundancies, and optimizing certain functions.
Focus on Regulatory Metrics
13 unchanged sentences
Programs and Areas of Study
−Removed: We offer a total of 184 degree programs, 134 certificate programs, and four diploma programs, through our institutions.
+Added: We offer a total of 182 degree programs, 136 certificate programs, and five diploma programs, through our institutions.
We offer programs across a broad range of fields of study, including public service-focused fields such as nursing, national security, military studies, intelligence, and homeland security, as well as traditional academic fields such as business, health science, information technology, justice studies, education, and liberal arts.
17 unchanged sentences
More than 1,700 distinct courses are available in either eight- or sixteen-week formats.
−Removed: Most APUS academic terms begin on the first Monday of each
+Added: Most APUS academic terms begin on the first Monday of each month.
APUS’ certificate programs generally require a minimum of 18 credit hours and focus on a particular component of a broader degree program.
−Removed: Among those programs are 19 undergraduate and 18 graduate NanoCerts TM programs, focused programs comprised of three academic courses in a related area of interest that provide skills necessary for career or professional development and result in a micro credential.
+Added: Among those programs are 13 undergraduate and 13 graduate NanoCerts TM programs, which are focused programs comprised of three academic courses in a related area of interest that provide skills necessary for career or professional development and result in a micro credential.
RU offers over 60 programs across seven schools of study in addition to nursing.
2 unchanged sentences
In addition, RU also offers a post-graduate nursing certificate.
−Removed: HCN offers on-campus instruction leading to a Diploma in PN and an ADN degree, as well as a Direct Entry ADN degree option that offers an accelerated graduation pathway for students who meet certain transfer, academic and entrance exam requirements.
+Added: HCN offers on-campus instruction leading to a PN or ADN degree and, beginning in the fourth quarter of 2024, a Medical Assisting Diploma, as well as a Direct Entry ADN degree option that offers an accelerated graduation pathway for students who meet certain transfer credit, academic, and entrance exam requirements.
Portions of these programs are taught online.
Academic terms for HCN’s PN and ADN programs begin four times each year, with courses starting in January, April, July, and October.
−Removed: Graduates of RU and HCN’s PN and ADN programs are eligible to seek licensure after passing the applicable National Council Licensure Examination, or NCLEX, exams.
+Added: Graduates of RU and HCN’s PN and ADN programs are eligible to seek licensure after passing the applicable NCLEX exams.
Government Training
10 unchanged sentences
APUS is designed to serve those adult learners with tailored offerings to support them in successfully reaching their individual goals.
−Removed: RU provides education to approximately 14,100 enrolled students.
+Added: RU provides education to approximately 14,600 enrolled students at 20 campuses in six states.
Student enrollment is defined as the number of unique active students, including those who take an approved leave of absence.
4 unchanged sentences
The average HCN student is approximately 33 years old and 93% of HCN students are female.
+Added: As of December 31, 2024, approximately 65% of HCN students were enrolled in a PN program and 35% were enrolled in an ADN program.
Accreditation
3 unchanged sentences
Students and sponsors of tuition reimbursement programs look to accreditation for quality assurance, and employers rely on institutions’ accredited status when evaluating a candidate’s credentials.
−Removed: In 2023, APUS transitioned from the Open Pathway designation to the Standard Pathway designation.
−Removed: As a result of this transition, APUS will be subject to a focused site-visit in March 2024 and will be subject to a
−Removed: comprehensive site-visit for the year four mid-cycle review under the Standard Pathway, to take place in 2025.
−Removed: The reaffirmation of accreditation site visit date remains unchanged and will take place 2030-2031.
+Added: APUS is institutionally accredited by HLC with a Standard Pathway designation, with the next reaffirmation of accreditation site visit date to take place in 2030-2031.
RU has institutional accreditation from HLC with an Open Pathway designation, with the next comprehensive evaluation for reaffirmation of accreditation scheduled for May 2026.
−Removed: HCN is institutionally accredited by ABHES, and in February 2021, ABHES granted HCN continued accreditation through February 2027 for all programs at all campuses.
+Added: HCN is institutionally accredited by ABHES and has been granted continued accreditation through February 2027 for all programs at all campuses.
GSUSA is accredited by ACCET.
3 unchanged sentences
Certain programs offered by RU have received specialized accreditation as well.
−Removed: For example, RU’s ADN and Licensed Practical Nursing programs are accredited by the Accrediting Commission for Education in Nursing.
+Added: For example, RU’s PN and ADN programs are accredited by the Accrediting Commission for Education in Nursing.
HCN’s PN program is accredited by NLN CNEA.
4 unchanged sentences
We work to attract students who are more likely to persist and succeed in our programs and continue to work to identify and implement changes and initiatives in an effort to attract and enroll more college-ready students more effectively.
−Removed: We welcome students to apply for admission at any time through online application processes at APUS, HCN, and RU.
+Added: We welcome students to apply for admission at any time through online application processes at APUS, RU, and HCN.
The current qualification for most undergraduate programs is a high school diploma or General Education Development certificate.
7 unchanged sentences
APUS tuition remains among the lowest in the four-year for-profit sector.
−Removed: The combined tuition and fees at APUS are generally less than the average in-state cost at a public university.
APUS costs are more than 25% less than the average in-state full-time undergraduate tuition, fees, and books at four-year public universities, based on the final 2023-2024 institutional data reported to ED through the Integrated Postsecondary Education Data System.
4 unchanged sentences
APUS implemented tuition and fee increases for its non-military and veteran students in the second and third quarters of 2023.
−Removed: At APUS, following the tuition increases, tuition for undergraduate courses is $350 per credit hour, while tuition for master’s level classes is $425 per credit hour.
+Added: In April 2024, APUS implemented an additional modest tuition increase to master’s level students across all categories, including military, non-military, and veteran students, and in September 2024, APUS returned the military rate for master’s level students to the $250 per credit hour rate in effect prior to the April 2024 tuition increase.
+Added: Following these increases, tuition for undergraduate courses is $350 per credit hour, while tuition for master’s level classes is $455 per credit hour.
In general, a bachelor’s degree may be earned for $42,000 in tuition costs at current tuition rates, and APUS master’s degrees may be earned for $16,380 in tuition at current tuition rates.
1 unchanged sentence
Because APUS is an exclusively online institution, there are no required resident fees, such as for parking, food service, student union, and recreation.
−Removed: Students taking graduate courses at APUS are charged a technology fee of $85 per course.
+Added: Most students taking graduate courses at APUS are charged a technology fee of $85 per course.
When applicable, APUS students are charged certain additional fees, such as graduation, late registration, transcript request, and comprehensive examination fees.
−Removed: In the second quarter of 2024, as part of the continuous improvement initiatives in education quality, APUS plans to implement a modest tuition increase to master’s students across all categories, including military, non-military, and veteran students.
RU’s costs vary among its programs and between part-time and full-time attendance.
−Removed: In January 2023, RU implemented tuition increases for select programs to help offset the increased cost of delivering a quality education.
+Added: RU implemented modest tuition increases in the first quarters of 2023 and 2024 for all students for select programs, for new students for select programs in August 2024, and for returning students for select programs in October 2024, to help offset the increased cost of delivering a quality education.
RU’s ADN program typically costs $400 per credit hour in addition to course fees.
−Removed: Credit hour costs range from $199 per credit hour to
−Removed: $419 per credit hour for other undergraduate programs.
+Added: Credit hour costs range from $210 per credit hour to $449 per credit hour for other undergraduate programs.
At the graduate level, RU offers six different master’s programs for $218 per credit hour or less.
3 unchanged sentences
In the second quarter of 2023, HCN implemented a 5% increase in tuition and fees across all programs to offset the increased cost of delivering a quality, competitive education.
−Removed: HCN’s PN program may be completed for approximately $19,600 in tuition and fees and the ADN program may be completed for approximately $27,800 in tuition and fees, depending on the campus location.
+Added: HCN’s PN program may be completed for approximately $19,600 in tuition and fees, the ADN program may be completed for approximately $27,800 in tuition and fees, and the new Medical Assisting program may be completed for approximately $13,000 in tuition and fees, each of which is dependent on the campus location.
Fees include the cost of examination review materials, lab fees, and test review fees, among others.
4 unchanged sentences
At RU and HCN, tuition increases are adjusted to be consistent with the local campus markets.
−Removed: Even inclusive of recent increases, RU and HCN’s tuition and fees are designed to be affordable and competitive when compared to the tuition and fees at similar institutions.
+Added: Even with these increases, RU and HCN’s tuition and fees are designed to be affordable and competitive when compared to the tuition and fees at similar institutions.
Grants and Other Fee Reduction Opportunities
4 unchanged sentences
In the second quarter of 2023, coinciding with the tuition increases described above, APUS added a 10% Veteran Grant for veterans and veteran’s family members, on standard undergraduate and master’s level courses.
+Added: In April 2024, APUS increased the Veteran Grant on master’s level courses to 15% and added a 10% Opportunity Grant for undergraduate and master’s level courses.
In addition, veterans who qualify for 100% of their Post-9/11 Veterans Educational Assistance Act of 2008, or Post-9/11 GI Bill, benefits are expected to generally have no out-of-pocket expenses either.
3 unchanged sentences
Self-directed assessments, when available, may be attempted for a prepaid fee, which is generally $149 per attempt.
−Removed: HCN students may apply performance-based grants and needs-based grants toward the balance of their tuition after all other funding sources.
−Removed: HCN offers an institutional affordability grant to students demonstrating financial need to cover the difference between the total cost of tuition and fees less the amount of all eligible financial aid resources.
+Added: HCN students may apply performance-based grants toward the balance of their tuition after the application of all other funding sources.
+Added: HCN also offers an institutional affordability grant to students demonstrating financial need to cover the difference between the total cost of tuition and fees less the amount of all eligible financial aid resources.
The grant is designed to limit a student’s monthly payment to $200 through an award of up to $200 per month, or $600 per term after consideration of financial aid, employer tuition reimbursement, and other financial resources.
−Removed: HCN offers its students an extended payment plan option.
−Removed: The extended payment plan is designed to assist students with educational costs including tuition and fees.
−Removed: Payment plans require ongoing payments while the student is enrolled in a program and extend after the last day of attendance or graduation.
+Added: HCN offers its students extended payment plan options.
+Added: The extended payment plans are designed to assist students with educational costs including tuition and fees.
+Added: HCN’s payment plans require ongoing payments while the student is enrolled in a program and extend after the last day of attendance or graduation.
To the extent interest is applied, it is generally fixed and does not accrue until the student departs the program or graduates.
3 unchanged sentences
Most students rely on some form of financial aid in addition to their individual resources.
−Removed: At APUS, students utilizing DoD’s TA programs as their primary source of payment accounted for 48%, those utilizing VA education benefits 22%, those utilizing ED’s Title IV programs 17%, and those utilizing cash and other sources 13%, of
−Removed: revenue in 2023.
−Removed: At RU, students utilizing ED’s Title IV programs as their primary source of payment accounted for 75%, those utilizing cash and other sources 23%, and those utilizing VA education benefits 2%, of revenue in 2023.
+Added: At APUS, students utilizing DoD’s TA programs as their primary source of payment accounted for 46% of revenue in 2024, those utilizing VA education benefits 24%, those utilizing ED’s Title IV programs 17%, and those utilizing cash and other sources 13%.
+Added: At RU, students utilizing ED’s Title IV programs as their primary source of payment accounted for 76% of revenue in 2024, those utilizing cash and other sources 22%, and those utilizing VA education benefits 2%.
In addition, most HCN students rely on some form of financial aid in addition to their individual resources.
8 unchanged sentences
For example, RU’s Council for Nursing Excellence is dedicated to helping students pass the NCLEX exam the first time by identifying student-specific challenge areas and providing customized tutoring resources and faculty training.
−Removed: We believe these initiatives contributed to improved NCLEX scores at certain campuses in 2023.
−Removed: RU also plans to integrate NCLEX testing simulation and preparation tools throughout the curriculum and to conduct a curriculum assessment to identify areas where RU can better enable student mastery and success.
+Added: We believe these initiatives contributed to improved NCLEX pass rates, including improvements in the ADN program pass rates at nearly every campus in 2024 compared to early 2023.
+Added: In July 2024, RU entered into a contract with a third-party to provide nursing program curriculum upgrades and course materials and testing services to nursing students.
+Added: These services included integrated NCLEX testing simulation and preparation tools throughout the curriculum and curriculum assessments to identify areas where RU can better enable student mastery and success, which were implemented in January 2025.
Career Development
6 unchanged sentences
In the fall of 2023, HCN partnered with another national healthcare organization to provide similar scholarships to ADN students at its Columbus, Ohio campus.
+Added: During the fourth quarter of 2024, we began exploring similar opportunities at RU.
Marketing and Branding
14 unchanged sentences
We also have programs at APUS that aim to assist members of the military as they transition into private sector jobs.
−Removed: RU and HCN nursing program marketing includes leveraging relationships with and marketing to the healthcare community, and in late 2022 we increased our non-nursing marketing for RU in response to demand, which continued throughout 2023 and which we expect will continue as part of our 2024 marketing strategy.
−Removed: In 2022, we began efforts to centralize our marketing organization.
−Removed: Our centralized team is currently providing all marketing and branding services through a shared service model to APUS and GSUSA, and providing many of these services for HCN.
−Removed: RU historically relied on Collegis for a variety of outsourced marketing services.
−Removed: In October 2022, RU and Collegis mutually agreed to the termination of the marketing services contract effective January 31, 2023, and we have completed the transition of RU marketing to our in-house centralized marketing team.
−Removed: We are also developing marketing expertise that spans a variety of functional areas and to extend our use of marketing technology and analytics.
−Removed: We currently use technology and analytics to improve marketing mix, audience targeting, new initiatives, messaging, and creative decisions, as well as advertising development, delivery, and testing.
−Removed: In 2023, to support all of our institutions, we also hired subject matter experts in all key marketing functional areas.
+Added: RU and HCN nursing program marketing includes leveraging relationships with and marketing to the healthcare
+Added: community, and we continue to focus our marketing efforts on non-nursing in markets with increases in demand for those programs.
+Added: In April 2024, APU announced its plan to expand its reach to become a global digital university that integrates emerging technology and enhanced teaching and learning opportunities for faculty and students.
+Added: APU aims to provide students with collaborative learning experiences, classroom support powered by AI, and personalized digital services.
+Added: Already, students can access personalized career coaches, and 24/7 mental health support, both in multiple languages;
+Added: AI-based career services;
+Added: and numerous online practical work experience opportunities.
+Added: RU historically outsourced the vast majority of its marketing functions.
+Added: In October 2022, RU and Collegis mutually agreed to the termination of the marketing services contract, effective January 31, 2023, and completed the transition of RU marketing to our in-house centralized marketing team.
+Added: We continue to develop our marketing team with subject matter expertise and optimize our initiatives utilizing marketing technology and analytics.
+Added: This in turn allows us to improve our marketing/media mix, audience targeting, creative messaging and user experience for all of our educational institutions.
Information Technology
1 unchanged sentence
APEI provides information technology services to our institutions through a shared services model.
−Removed: In addition, RU is party to a service agreement with Collegis to provide information technology services through September 2024.
−Removed: RU currently relies on Collegis for a variety of outsourced information technology functions, including data center, learning management system, user support, and network and voice services, and its technology infrastructure is currently hosted, managed, and supported by Collegis.
−Removed: Our Ongoing Technology Transition
−Removed: We are in the midst of a multi-year technology transformation program to enable us to enhance the learning experience for students, better accommodate new flexible learning modalities, and improve the operational effectiveness of our enterprise.
−Removed: In April 2022, we notified Collegis that we intend to permit RU’s contract with Collegis to expire by its terms in September 2024.
−Removed: We plan to insource all the technology and services currently provided by Collegis to cloud services or third-party vendors over which we will have management oversight.
−Removed: As part of the transition from Collegis, we plan to continue looking more broadly for opportunities to further improve operational effectiveness across our information technology operations and rationalize our technology portfolio.
−Removed: For example, in December 2023, we entered into an agreement to outsource a number of our information technology operations, including some that were previously being handled by Collegis, to a managed service provider, including service desk, end user support, network support and operations.
+Added: Prior to September 2024, RU outsourced a variety of information technology functions under a service agreement with Collegis, including its data center, support and maintenance of its learning management, student information, and customer relationship management systems, student support, end user support, voice services, and network management and operations, and its technology infrastructure was hosted, managed, and supported by Collegis.
+Added: Our Ongoing Technology Transformation
+Added: We are in the midst of a multi-year technology transformation program that we expect will enable us to enhance the learning experience for students, better accommodate new flexible learning modalities, and improve the operational effectiveness of our enterprise.
+Added: In April 2022, we notified Collegis that we intended to permit RU’s information technology services contract to expire by its terms in September 2024.
+Added: In December 2023, we entered into an agreement with a managed service provider to outsource a number of our information technology operations, including some that were previously being handled by Collegis, including service desk, student support, end user support, and network management and operations.
+Added: In April 2024, this transition was completed, and in the third quarter of 2024, we substantially completed the insourcing of information technology services and the outsourcing of certain of those same services to a managed service provider.
Student Information and Instructional Delivery
2 unchanged sentences
RU uses Anthology Campus Nexus as its SIS.
−Removed: The RU SIS environment is currently hosted with Collegis, which maintains all systems, support, and hosting for RU.
+Added: The RU SIS environment is currently hosted with Anthology in a cloud environment.
APUS and RU admissions functions are managed inside of Salesforce and connected to PAD for APUS and Anthology for RU to ensure all pertinent information is synchronized appropriately.
HCN and GSUSA have their own SIS platforms.
−Removed: In 2024, we plan to replace the existing SIS
−Removed: platform used by GSUSA and will also begin moving HCN to a new SIS platform.
+Added: In 2025, we plan to replace the existing SIS platform used by GSUSA and will also begin moving HCN to a new SIS platform.
More broadly, we continue to review and assess our student information and services platforms and their capabilities, including whether to consolidate to a standard platform across more or all our institutions.
−Removed: PAD is designed to enable APUS to provide each student with individualized support at appropriate times from pre-enrollment through and beyond graduation, including student advising, administrative support, and community networking.
+Added: PAD is designed to enable APUS to provide each student with individualized support at appropriate times from pre-enrollment through graduation and beyond, including student advising, administrative support, and community networking.
We continually evaluate PAD for changes and upgrades and anticipate that we will eventually make significant changes to or replace this system.
−Removed: In 2021, we consolidated APUS and HCN onto a single, cloud based LMS platform, Brightspace by D2L.
−Removed: RU uses Blackboard Ultra as its LMS platform.
−Removed: This environment is hosted with Blackboard, which is now owned by Anthology.
−Removed: All RU support for Blackboard Ultra is currently provided by Collegis.
−Removed: We are continuing to consolidate APUS’s customer relationship management systems onto a single platform, the first phases of which were completed in 2022.
+Added: APUS and HCN use a cloud based LMS platform, Brightspace by D2L.
+Added: RU uses Blackboard Ultra as its LMS platform, in an environment hosted by Blackboard, which is now owned by Anthology.
+Added: All RU support for Blackboard Ultra is currently provided by APEI’s information technology shared services.
In early 2023, at APUS we launched a new native mobile application to improve the student experience.
−Removed: The APUS mobile application provides current and future students with university information and access to academic tools via mobile and tablet, 24/7.
+Added: The APUS mobile application provides current and prospective students with university information and access to academic tools via mobile and tablet, 24/7.
Key features include registration, academic dashboard, task manager, program tracker, and real-time notifications.
−Removed: In addition to our student information and services systems, LMS platforms, and CRM systems, we also have several other systems that support the student experience, financial aid processing, fiscal management, human resources processes, marketing, and decision support.
+Added: In 2024, we completed the consolidation of APUS’s CRM systems onto a single platform.
+Added: In addition to our SIS, LMS, and CRM platforms, we also have several other systems that support the student experience, financial aid processing, fiscal management, human resources processes, marketing, and decision support.
Our Information Technology Infrastructure
2 unchanged sentences
Student access to our systems is provided through redundant data carriers.
−Removed: RU’s network is fully redundant through a software-defined wide area network infrastructure.
We intend to continue to migrate much of our infrastructure and core applications to a cloud computing model with the goal of improving the reliability, scalability, agility, and security of our core infrastructure and applications.
2 unchanged sentences
Our ability to deliver on our mission and to continue to transform our enterprise to focus on quality student outcomes and on sustainable growth is tightly aligned with our human capital strategy.
−Removed: Our performance depends on the talents, experience, and efforts of our employees, and on our ability to foster a culture and practice of high performance, innovation, cooperation, integrity, and respect.
+Added: Our performance depends on the talents, experience, and efforts of our staff employees and faculty, and on our ability to foster a culture and practice of high performance, innovation, cooperation, integrity, and respect.
We seek to be a destination for high-potential employees and desire to build a bench of future leaders by developing best-in-class human capital capabilities.
−Removed: During 2023, our key human capital efforts focused on centralizing certain components of our human capital strategy, including implementing a common talent acquisition methodology and common talent management and talent review process, as well as centralizing and improving responses to human capital inquiries through our HR Operations AskHR team.
+Added: During 2024, our key human capital efforts focused on continuing to centralize certain components of our human capital strategy, including our talent acquisition methodology and common talent management and talent review process, as well as implementing a centralized learning management and training platform.
+Added: We continue to provide centralized responses and support through our HR operations and AskHR team.
We also continue to implement a streamlined and proactive approach to employee communication to drive connectivity, engagement, and efficiencies.
7 unchanged sentences
Total 722 1,771 2,493 3,271 353 6,117
−Removed: Our employees have diverse backgrounds, influenced in part by the geography in which our headquarters, administrative facilities, and campuses are located, and by the communities we serve, in particular military, military-affiliated, veteran, and nursing communities.
−Removed: As of December 31, 2023, our employee diversity was as follows:
−Removed: People of Color (2)
−Removed: APUS 53 % 23 %
−Removed: HCN 78 % 28 %
−Removed: GSUSA 55 % 44 %
−Removed: Corporate 57 % 26 %
−Removed: (1) Consists of employees self-identifying as female.
−Removed: (2) Consists of employees self-identifying as Black or African American, Hispanic, Asian American, Native American, or more than one race or ethnicity.
−Removed: Diversity and inclusion is a business imperative at the core of our values, and we believe that diversity and inclusion reflects the expectations of students we serve.
−Removed: In the first quarter of 2023, we launched an enterprise-wide, cross-functional Inclusion and Impact Council that includes members of executive leadership, as well as inclusion champions from across all of our education units, and focuses on driving awareness and harmonization around diversity, equity, inclusion, and belonging initiatives.
−Removed: To support our diversity and inclusion efforts, we also have diversity and inclusion task forces and committees at our institutions.
+Added: The different backgrounds of our employees are influenced in part by the geography in which our headquarters, administrative facilities, and campuses are located and by the communities we serve, in particular military, military-affiliated, veteran, and nursing communities.
Talent Development and Retention
2 unchanged sentences
RU and HCN also compete with both nursing schools and traditional employers of healthcare professionals to fill open faculty positions.
−Removed: A nursing faculty shortage continues, adversely affecting our ability to recruit and retain qualified nursing faculty at RU and HCN.
+Added: A nursing faculty shortage continues, in certain markets, adversely affecting our
+Added: ability to recruit and retain qualified nursing faculty at RU and HCN.
We believe that current job market dynamics, including low unemployment, have further increased the challenge of hiring and employee retention.
We strive to retain our talent and closely track retention among our employees, both faculty and staff.
−Removed: In 2023, we had full-time employee turnover of approximately 19%, of which 73% was voluntary and 27% was involuntary.
−Removed: In 2022, we had full-time employee turnover of approximately 28%, of which, 70% was voluntary and 30% was involuntary.
−Removed: Although we have taken additional steps to retain our current faculty and source and recruit talent, there can be no assurance that our efforts will be successful.
+Added: In 2023 and 2024, we had full-time employee turnover of approximately 19% and 14%, respectively, of which 73% was voluntary and 27% was involuntary for both years.
+Added: Although we continue to take steps to retain our current faculty and source and recruit talent, there can be no assurance that our efforts will be successful.
Our strategic initiatives require our personnel to perform at a high level and to adapt and learn new skills and capabilities.
3 unchanged sentences
We have implemented a centralized talent and transformation team to focus on improving internal learning and development practices and succession planning to ensure that we cultivate skills needed to deliver high quality student outcomes and help grow our operations.
−Removed: In 2023, we executed an enterprise-wide talent review for all vice-president and above employees to ensure a consistent review of talent and more meaningful development plans for those leaders, as well as enhanced succession planning.
−Removed: We also invested in both change management and integration talent at the Company level to assist in further integrating our institutions, and we continued our centralized and consistent compliance training approach across the organization.
−Removed: We are committed to working to ensure that new hires and employees are fully trained on key compliance issues at hire and also on an annual basis during the duration of employment.
+Added: In 2024, we again executed an enterprise-wide talent review for all vice-president and above employees to ensure a consistent review of talent and more meaningful development plans for those leaders, as well as enhanced succession planning.
+Added: We also continued our centralized and consistent compliance training approach across the organization.
+Added: We implemented a new learning management and training platform and remain committed to working to ensure that new hires and employees are fully trained on key compliance issues both at hire and also on an annual basis during the duration of employment.
We also review all required compliance trainings annually to ensure the training is comprehensive.
Staffing our Institutions
−Removed: We believe that hiring and retaining well-educated and qualified faculty members is important to our success.
−Removed: We continue to centralize more of our talent acquisition function in an effort to improve talent search efficiency, increase the consistency of our sourcing practices, and strengthen hiring processes.
+Added: We believe that hiring and retaining well-educated and qualified faculty and non-faculty members is important to our success.
+Added: In 2024, we continued to centralize more of our talent acquisition function to improve talent search efficiency, increase the consistency of our sourcing practices, and strengthen hiring processes.
This centralization has significantly reduced our time to fill metrics and improved our ability to assess talent needs company-wide.
4 unchanged sentences
Employee Engagement and Relations
−Removed: We measure employee engagement, including faculty, on an ongoing basis by soliciting feedback, including a company-wide annual employee engagement survey for all employees, in order to understand the views of our employees.
+Added: We measure employee engagement, including faculty, on an ongoing basis by soliciting feedback, including a company-wide annual employee engagement survey for all employees, to understand the views of our employees.
The results from engagement surveys are used to implement programs and processes designed to enhance employee engagement and improve the employee and faculty experience.
+Added: In 2024, we implemented certain enhancements around employee service awards to recognize the tenure and commitment of our employees.
None of our employees are parties to a collective bargaining agreement, and management considers employee relations to be good.
1 unchanged sentence
We are committed to the health and well-being of our employees and assess our well-being initiatives and marketplace trends on an ongoing basis.
−Removed: Beginning in 2022, and continuing in 2023, we have increased our focus on employee well-being and have enhanced our Total Rewards Team, which is focused on benefits and well-being.
−Removed: In 2023, we added paid parental leave to support our employees and their families and additional paid time off, including time for volunteerism, as additional retention tools.
−Removed: Since the abatement of the COVID-19 pandemic, we have allowed employees to return to a hybrid work setting.
−Removed: Employees are continuing to follow a blended model of working onsite and remotely, and we have committed to determining the optimal mix of site-based, flexible, and fully remote work models on a department and role basis.
+Added: We have increased our focus on employee well-being and have enhanced our Total Rewards Team, which is focused on benefits and well-being.
+Added: We offer paid parental leave to support our employees and their families and additional paid time off, including time for volunteerism, as additional retention tools.
+Added: In 2024, we added an employee discount program and developed communications and guides focusing on total rewards to educate our employees on benefits and resources available to them.
Community Impact
−Removed: We intend for our Inclusion and Impact Council to lead efforts to ensure that we positively impact the communities in which our employees work and live, including by organizing volunteer opportunities.
−Removed: Beginning in 2023, we provided full-time employees, faculty, and staff with eight hours of additional paid time off for volunteering and giving back to society.
+Added: We have a variety of engagement and community impact councils at APEI and in our education units.
+Added: These teams lead our efforts to ensure that we positively impact the communities in which our employees work and live, including by organizing volunteer opportunities.
+Added: We provide full-time employees, faculty, and staff with eight hours of additional paid time off for volunteering and giving back to our communities.
Information About our Executive Officers
8 unchanged sentences
Fernandes 48 President, APUS
−Removed: Singer 69 President and Chief Academic Officer, RU
+Added: Arnold 51 President, RU
Wilkins 68 Chief Executive Officer, HCN
7 unchanged sentences
Prior to her role at Baird, Ms.
−Removed: Selden served as Chief Executive Officer and Executive Co-Chairman of Arise Virtual Solutions, Inc., a virtual workforce solutions outsourcer from January 2005 until
+Added: Selden served as Chief Executive Officer and Executive Co-Chairman of Arise Virtual Solutions, Inc., a virtual workforce solutions outsourcer from January 2005 until August 2011.
Earlier in her career, Ms.
40 unchanged sentences
Gaffney also previously held various leadership roles at Best Western Hotels & Resorts.
−Removed: Fernandes joined APUS as President in August 2022.
+Added: Fernandes joined us in August 2022 as President of APUS.
Prior to joining APUS, Mr.
1 unchanged sentence
Fernandes has also held various leadership roles at Overseas Leisure Group and Bosch.
−Removed: Singer joined us in April 2023 as President and Chief Academic Officer of RU and as a non-voting member of our RU Board of Directors.
−Removed: Prior to joining RU, Paula spent 27 years at Laureate Education, Inc.
−Removed: where she retired in January 2022 as the CEO of Laureate Online and Walden University.
−Removed: During her tenure with Laureate Education, Inc.
−Removed: Singer served as chairman of Walden University for 19 years.
−Removed: Singer is the co-founder and principal owner of Nurture Nest Montessori School and serves as a board director at the University of Connecticut Foundation.
+Added: Arnold joined us in January 2025 as President of RU.
+Added: Prior to joining RU, Mr.
+Added: Arnold served as the Chief Executive Officer of Nystrom & Associates, an outpatient mental health provider, from 2020 to 2023.
+Added: Prior to this, Mr.
+Added: Arnold was Chief Operating Officer at Rayus Radiology (formerly, Center for Diagnostic Imaging) from 2017 to 2020 and held other various roles, including Chief Development & Strategy Officer, Senior Vice President & General Manager, Regional Vice President, Minnesota, and Vice President, Strategy and Business Development from 2011 to 2017.
+Added: Arnold previously served as a senior healthcare research analyst at Piper Sandler from 2005 to 2011, held leadership roles at 3M Company, and was a healthcare management consultant.
Wilkins rejoined us in May 2019 as the Chief Executive Officer of HCN, a position he previously held from December 2013 until his retirement in December 2015.
12 unchanged sentences
Our institutions own the copyright for a work by a faculty member where there has been express agreement on such ownership, if the institutions compensated the faculty member for the particular product, or if the institutions funded the research in whole or in part.
−Removed: We or our institutions have secured or claim rights to trademarks for various names and terms used in our and their respective businesses, including rights in “American Public Education, Inc.,” “American Public University System,” “American Military University,” “American Public University,” “Graduate School USA”, “Rasmussen University”, and others.
+Added: We or our institutions have secured or claim rights to trademarks for various names and terms used in our and their respective businesses, including rights in “American Public Education, Inc.,” “American Public University System,” “American Military University,” “American Public University”, “Rasmussen University”, “Graduate School USA”, and others.
In connection with our acquisition of HCN, we received a royalty-free, irrevocable, exclusive, transferable, sublicensable license to use the name “Hondros College of Nursing” and, instead of “Nursing,” any other qualifier directly related to nursing, medicine, or healthcare in connection with the business and operations of HCN.
5 unchanged sentences
Operating results fluctuate as a result of seasonal or other variations in enrollments.
−Removed: For example, historically, across our institutions, our enrollments are higher in the fall term when students traditionally start their education.
+Added: For example, historically, across our institutions, our enrollments are higher in the fall when students traditionally start their education.
Our student population also varies as a result of new enrollments, graduations, student attrition, the success of our marketing programs, and other reasons that we cannot always anticipate.
8 unchanged sentences
APUS, RU, and HCN are approved to participate in TA programs administered by DoD, and veterans education benefits programs administered by the VA and are therefore also subject to oversight by those agencies.
−Removed: standards, and policies of these agencies address the vast majority of our operations, including our educational programs, facilities, instructional and administrative staff, administrative procedures, marketing, recruiting, and financial operations and condition.
+Added: Regulations, standards, and policies of these agencies address the vast majority of our operations, including our educational programs, facilities, instructional and administrative staff, administrative procedures, marketing, recruiting, and financial operations and condition.
We are also regulated in some cases by other federal agencies including the Consumer Financial Protection Bureau, or CFPB, and Federal Trade Commission, or FTC.
6 unchanged sentences
Institutional Accreditation
−Removed: Accreditation is a voluntary, non-governmental process through which an institution submits to review its institution or programs based on the standards of the accrediting agency and the stated aims and purposes of the institution or program.
+Added: Accreditation is a voluntary, non-governmental process through which an institution submits to review of its institution or programs based on the standards of the accrediting agency and the stated aims and purposes of the institution or program.
Accrediting agencies establish criteria for accreditation, conduct peer-review evaluations, and publicly recognize those institutions or programs that meet the stated criteria and are considered accredited institutions or accredited programs.
3 unchanged sentences
To be recognized by ED, accrediting agencies must adopt specific standards and procedures.
−Removed: If one of our institutions’ institutional accreditors was to lose its recognition as an accrediting agency and the institution was unable to obtain recognition from another recognized accrediting agency, the institution could lose its eligibility to participate in Title IV programs and TA.
+Added: If one of our institutions’ institutional accreditors was to lose its recognition as an accrediting agency and the institution was unable to obtain recognition from another recognized accrediting agency, the institution could lose its eligibility to participate in Title IV
+Added: programs and TA.
The loss of ability of one of our institutions to participate in either Title IV programs or TA could have a material adverse effect on our business and financial condition.
2 unchanged sentences
APUS’s next reaffirmation of accreditation is scheduled for 2030-2031.
−Removed: HLC will conduct a focused visit at APUS in March 2024 after raising concerns regarding compliance with standards related to program development oversight and program assessment processes as a result of issues with course availability in one program.
−Removed: HLC’s focused visit will result in a written report addressing the topics of concern identified in the letter calling for the focused visit.
−Removed: The focused visit team report will include a recommendation to accept the report or may call for additional monitoring, sanction, show-cause order, or withdrawal of accreditation.
−Removed: Although APUS would have the opportunity to respond prior to any HLC action on the report, we cannot be sure that the HLC team will not identify deficiencies at APUS during the focused visit or call for negative accreditation-related action against APUS as a result.
+Added: HLC conducted a focused visit at APUS in March 2024, after raising concerns regarding compliance with standards related to program development oversight and program assessment processes as a result of issues with course availability in one program.
+Added: Following the focused visit, the team found that the concerns were appropriately addressed, and that no additional monitoring was required.
+Added: Their recommendations were sent to HLC’s Institutional Action Council, or IAC, for review and action.
+Added: At the June 2024 meeting, the IAC concurred with the team’s findings and affirmed that APUS addressed all concerns regarding compliance with HLC standards.
APUS has a Standard Pathway designation, having transitioned from the Open Pathway in 2023 because of HLC’s decision to conduct a focused visit.
−Removed: All institutions on the Standard Pathway must undergo a mid-cycle comprehensive evaluation.
−Removed: APUS is currently scheduled for its mid-cycle comprehensive evaluation site visit in 2025.
+Added: All institutions on the Standard Pathway must undergo a mid-cycle comprehensive evaluation, which entails, among other things, HLC conducting a mid-cycle assurance review and site visit.
+Added: As a result of the Combination, APUS’s assurance review and site visit will now be conducted in March 2026 which will entail a review of APUS in its post-Combination form.
+Added: As noted below, HLC is scheduled to conduct a site visit in March 2025 in connection with the Combination.
• RU is institutionally accredited by HLC.
−Removed: RU’s next comprehensive evaluation for reaffirmation of accreditation is scheduled for May 2026.
−Removed: RU is accredited with the Open Pathway designation.
+Added: RU’s reaffirmation of accreditation had been scheduled for 2025-2026, and the associated comprehensive evaluation site visit is scheduled for May 2026.
+Added: RU’s assurance review and site visit will now be conducted in March 2026 which will entail a review of RU in its post-Combination form.
+Added: RU has an Open Pathway designation.
• HCN is institutionally accredited by ABHES.
3 unchanged sentences
Alternatively, ABHES may in its discretion provide an opportunity for a program that is not meeting ABHES’ outcomes thresholds to come into compliance within a period of time specified by ABHES, and ABHES may extend the period for achieving compliance if a program demonstrates improvement over time or for other good cause.
−Removed: In prior years, several HCN programs at certain HCN campuses have failed to satisfy ABHES’s student achievement measures, and as a result ABHES has placed specific programs at certain campus locations on program-specific warning or outcomes reporting status and required action plans.
+Added: In prior years, select HCN programs at certain HCN campuses have failed to satisfy ABHES’s student achievement measures, and as a result ABHES has placed specific programs at certain campus locations on program-specific warning or outcomes reporting status and required action plans.
As a result of retention rates being below the 70% benchmark for 2021-2022 reporting year, which was the second consecutive full reporting year, ABHES placed the PN programs at the Cincinnati, Cleveland, Columbus, and Dayton campuses on program-specific warning status in January 2023.
2 unchanged sentences
The reports submitted in response to this requirement demonstrated that the PN program at the Cincinnati, Cleveland, Columbus, and Dayton campuses and the ADN program at the Akron campus were above the 70% retention benchmark through the first three quarters of the 2022-2023 reporting year.
−Removed: As a result, the Cincinnati, Cleveland, Columbus, and Dayton PN programs were removed from program-specific warning status, and ABHES informed HCN that no additional information was required for the ADN program at the Akron campus.
+Added: As a result, the Cincinnati, Cleveland, Columbus, and Dayton PN programs were removed from program-specific warning status, and ABHES informed HCN that no additional reporting was required for the ADN program at the Akron campus.
However, HCN reported that the retention rate for the PN program at the Toledo campus was below the 70% benchmark through the first three quarters of the 2022-2023 reporting year.
1 unchanged sentence
For the reporting year ended June 30, 2023, the PN program at the Cleveland, Columbus, Dayton, and Toledo campuses, as well as the ADN program at the Akron and Dayton campuses, were below the 70% benchmark for retention.
−Removed: As a result, ABHES has continued the Toledo PN program on outcomes reporting status, due to its retention rate falling below the 70% benchmark.
−Removed: ABHES is also requiring additional reporting for the Cleveland PN, Columbus PN, Dayton PN, Dayton ADN, and Akron ADN programs.
−Removed: In conjunction with these actions, ABHES is requiring HCN to submit reports for each of these programs demonstrating their retention rate through the first three quarters of the 2023-2024 reporting year by May 2024.
−Removed: If the Cleveland PN, Columbus PN, Dayton PN, Dayton ADN, and Akron ADN programs do not meet the 70% retention benchmark by the third quarter of the 2023-2024 reporting year, ABHES will likely place these programs on outcomes reporting status.
−Removed: If the Toledo PN program does not meet the 70% retention benchmark by the third quarter of the 2023-2024 reporting year, ABHES will likely place the program on program-specific warning status.
−Removed: For more information on the risks associated with these rates, refer to the risk factor in “Risk Factors” with the caption beginning “A failure of HCN to satisfy ABHES accreditation standards...”.
−Removed: • GSUSA is institutionally accredited by ACCET.
+Added: As a result, ABHES continued the Toledo PN program on outcomes reporting status and required HCN to submit reports for each of these programs demonstrating their retention rate through the first three quarters of the 2023-2024 reporting year by May 2024.
+Added: In May 2024, HCN submitted the required mid-year retention reports for the programs that fell below the 70% benchmark in the 2022-2023 reporting year (Cleveland PN, Columbus PN, Dayton PN and ADN, Toledo PN, and Akron ADN).
+Added: These reports demonstrated compliance with the 70% benchmark through the first three quarters of the 2023-2024 reporting year.
+Added: As a result, the ABHES Commission voted to remove retention reporting requirements for all affected HCN programs at its July 2024 meeting.
+Added: For the reporting year ended June 30, 2024, the Cleveland and Dayton PN programs, and the Akron ADN program were below the 70% benchmark for retention.
+Added: As a result, ABHES placed the Cleveland and Dayton PN programs and Akron ADN program on outcomes reporting status and required HCN to submit reports for each of these programs demonstrating their retention rate through the first three quarters of the 2024-2025 reporting year by May 2025.
+Added: At its July 2024 meeting, ABHES voted to affirm its July 2022 grant of accreditation of the Detroit, Michigan campus following a team visit to the campus from February 29, 2024, to March 1, 2024.
+Added: For more information on the risks associated with these rates, refer to the risk factor in “Risk Factors – Risks Related to the Regulation of Our Industry” with the caption beginning “A failure of HCN to satisfy ABHES accreditation standards...”.
+Added: • GSUSA is institutionally accredited by ACCET through December 15, 2027.
GSUSA does not participate in the Title IV, TA, or VA education benefits programs.
4 unchanged sentences
Failure to maintain our institutional accreditations would result in the loss of eligibility to participate in Title IV programs and TA.
+Added: The Planned Combination of APUS, RU, and HCN
+Added: On January 28, 2025, we announced the Combination, as discussed in more detail above under “2024 Developments and Future Financial Objectives – The Planned Combination of APUS, RU, and HCN”, which will result in a combined institution named American Public University System comprised of two divisions tentatively named (i) APUS Global, comprised of AMU and APU and (ii) Rasmussen, comprised of RU’s campus-based and online nursing programs, RU’s healthcare programs, HCN’s campus-based nursing and healthcare programs, and RU’s non-healthcare programs, with final division names to be determined closer to closing of the Combination.
+Added: W e anticipate completing the Combination in the third quarter of 2025 subject to obtaining required approvals and ED taking related actions.
+Added: The Combination constitutes a Change of Control, Structure or Organization pursuant to HLC policy and, accordingly, we must receive HLC approval prior to effectuating the Combination.
+Added: APUS and RU have jointly submitted an application for Change of Control, Structure or Organization .
+Added: For HLC purposes, APUS will be the surviving institution, and the application seeks approval for the Combination and the expansion of APUS’s HLC accreditation to include the RU and HCN programs and locations.
+Added: HLC will conduct a site visit in March 2025 related to the joint application and is expected to complete its review of the joint application in June 2025.
+Added: ED has conveyed that it does not treat the combination of institutions with the same parent as a change in ownership and control for the purposes of Title IV.
+Added: As such, we do not expect the proposed transaction to trigger ED’s change in ownership and control requirements.
+Added: Rather, we expect ED will require APUS, as the surviving institution, to seek and obtain approval to expand its Title IV certification to cover the RU and HCN programs and locations.
+Added: In order for ED to expand APUS’s Title IV certification, we will be required to submit evidence that APUS’s HLC accreditation has been expanded to include the RU and HCN programs and locations, and that APUS is approved to operate in the states where RU and HCN have campuses.
+Added: Accordingly, in addition to the HLC approval process described above, APUS will need to obtain required approvals from state agencies, including state boards of nursing, in order to operate in the states where HCN and RU currently operate.
+Added: We anticipate completing the Combination in the third quarter of 2025, subject to obtaining required approvals and ED taking related actions.
+Added: See the Risk Factor captioned “The planned combination of APUS, RU, and HCN may not be completed, or
+Added: may not be completed on the terms currently contemplated, and if it is, the expected benefits may not be realized, both of which would have a material adverse impact on our business, financial condition, and results of operations” for more information.
Programmatic Accreditation and Professional Recognition
In addition to institutional accreditation, our institutions have obtained programmatic accreditation or professional recognition for certain programs, as described more fully above in “Our Institutions and Operations – Our Institutions – Academics – Accreditation”.
−Removed: Among other standards and requirements, programmatic accreditors may utilize benchmarks for
−Removed: student outcomes in the programs they accredit and may require the institution to address outcomes that fail to satisfy those benchmarks or may take other action based on such matters.
−Removed: If one of our institutions fails to satisfy the standards of these programmatic accrediting agencies or professional organizations for the relevant programs, the institutions could be subject to restrictions or could lose the programmatic accreditation or professional recognition for those programs, which could result in materially reduced student enrollments, prevent the institution from offering the programs in certain states where programmatic accreditation is required, or prevent our students from seeking and obtaining licensure or employment.
+Added: Among other standards and requirements, programmatic accreditors may utilize benchmarks for student outcomes in the programs they accredit and may require the institution to address outcomes that fail to satisfy those benchmarks or may take other action based on such matters.
+Added: If our institutions fail to satisfy the standards of these programmatic accrediting agencies or professional organizations for the relevant programs, they could be subject to restrictions or could lose the programmatic accreditation or professional recognition for those programs, which could result in materially reduced student enrollments, prevent the institution from offering the programs in certain states where programmatic accreditation is required, or prevent our students from seeking and obtaining licensure or employment.
The Accreditation Commission for Education in Nursing, or ACEN, accredits certain RU PN and ADN programs at certain RU locations.
−Removed: RU’s Illinois ADN program has been in candidacy status for initial accreditation with ACEN since July 2020.
−Removed: ACEN will not grant accreditation to a program on probationary status with the Illinois Department of Financial and Professional Regulation, or IDFPR, as RU’s Illinois ADN program is.
−Removed: The current candidacy is set to expire in July 2024.
−Removed: As further discussed in “State Authorization/Licensure – State Authorization/Licensure of Our Institutions” below, recently enacted legislation has resulted in the removal of all Illinois nursing programs, including RU’s Illinois ADN program, from probationary status for a period of three years.
−Removed: However, there were several bills introduced in the Illinois legislature in February 2024 seeking to modify this change in legislation.
−Removed: Furthermore, there can be no assurance that the removal from probationary status of RU’s Illinois ADN program will be viewed favorably by ACEN or another nursing program accreditor or would result in RU’s Illinois ADN program obtaining ACEN accreditation following the February 2024 site visit.
−Removed: RU’s Bloomington, Minnesota ADN program has been subject to adverse action and heightened scrutiny from ACEN, which is its programmatic accreditor, and other regulators as a result of continued failure to meet applicable accreditor and regulatory requirements.
−Removed: As more fully discussed in the Risk Factor with the caption beginning “RU’s planned closure of its Bloomington, Minnesota ADN program…” in December 2023, RU informed the Minnesota Board of Nursing, or MBN, that it intends to voluntarily close the Bloomington, Minnesota ADN program on June 15, 2024.
−Removed: The MBN voted to approve the voluntary closure of the Bloomington, Minnesota ADN program at its February 1, 2024 meeting.
−Removed: Due to previous self-imposed enrollment caps and the pause on new enrollments, enrollment in this program currently represents less than 2% of RU’s current total enrollment.
−Removed: For all students enrolled in the Bloomington, Minnesota ADN program graduating after June 2024, their enrollment record will be transferred to RU’s St.
−Removed: Cloud, Minnesota ADN program.
−Removed: However, there can be no assurance that any or all remaining students in the program will transfer to the St.
−Removed: Cloud campus.
+Added: RU’s Illinois ADN program was in candidacy status for initial accreditation with ACEN since July 2020, but following a February 2024 site visit, ACEN granted initial accreditation to the Illinois ADN program at its September 2024 Board of Commissioners meeting, which is retroactive to July 2020.
+Added: ACEN’s next site visit is scheduled for Spring 2029.
+Added: RU’s Bloomington, Minnesota ADN program had been subject to adverse action and heightened scrutiny from regulators as a result of continued failure to meet applicable accreditor and regulatory requirements.
+Added: As more fully discussed in the Risk Factor with the caption beginning “RU’s actual and planned closure of campuses …” in December 2023, RU informed the Minnesota Board of Nursing, or MBN, that it intended to voluntarily close the program, which it did effective June 15, 2024.
In September 2022, ACEN granted RU’s ADN and PN programs in Moorhead, Minnesota and RU’s ADN program in Overland Park, Kansas continued accreditation with conditions, in each case because the program experienced first-time NCLEX pass rates below ACEN’s required threshold.
For the two Moorhead, Minnesota programs, ACEN also identified evidence of noncompliance with respect to analysis and use of assessment data in program decision-making.
−Removed: The ADN programs have two years, and the PN program has 18 months, from the date the conditions were imposed, to demonstrate compliance with all criteria related to the standard for which the programs were found to be in noncompliance, though ACEN does not necessarily have to take action on any particular timetable.
−Removed: If compliance is not achieved by the end of the monitoring period, ACEN may deny continuing accreditation absent good cause.
+Added: The ADN programs were given two years, and the PN program 18 months, from the date the conditions were imposed, to demonstrate compliance with all criteria related to the standard for which the programs were found to be in noncompliance.
+Added: Although ACEN does not necessarily have to take action on any particular timetable, if compliance is not achieved by the end of the articulated monitoring period, ACEN may deny continuing accreditation absent good cause.
In February 2024, RU’s Moorhead, Minnesota PN program submitted to ACEN a follow-up report and an application for continuing accreditation for good cause.
−Removed: If ACEN determines areas of non-compliance remain, ACEN could withdraw the PN program’s accreditation or grant it continuing accreditation for good cause.
−Removed: RU’s Moorhead, Minnesota PN program is currently approved with the MBN, but first-time NCLEX pass rates have been below the standard for three consecutive years.
−Removed: RU expects that the MBN will place RU’s Moorhead, Minnesota PN program on conditional approval status and issue a corrective action order following the MBN’s April 2024 Board meeting.
+Added: In April 2024, after review of the follow-up report, ACEN removed the conditions for RU’s Moorhead, Minnesota PN program, granting continuing accreditation with the next evaluation in Spring 2030.
+Added: In July 2024, RU’s Moorhead, Minnesota ADN program and the Overland Park, Kansas ADN program submitted to ACEN their follow-up reports and applications for continuing accreditation for good cause.
+Added: In September 2024, after review of the follow-up reports, ACEN removed the conditions for RU’s Moorhead, Minnesota ADN program and Overland Park, Kansas ADN program, granting continuing accreditation with the next evaluation in Spring 2030.
State Authorization/Licensure
7 unchanged sentences
The growth of online education has led and may further lead to new laws and regulations and new interpretations of existing laws and regulations.
−Removed: New laws, regulations, or
−Removed: interpretations, including with respect to whether our institutions’ activities constitute a physical presence or otherwise may require authorization or licensure, could increase our cost of doing business and affect our ability to recruit students in particular states, which could negatively affect enrollments and revenue and have a material adverse effect on our business.
+Added: New laws, regulations, or interpretations, including with respect to whether our institutions’ activities constitute a physical presence or otherwise may require authorization or licensure, could increase our cost of doing business and affect our ability to recruit students in
+Added: particular states, which could negatively affect enrollments and revenue and have a material adverse effect on our business.
Changes in our business activities could lead states that do not currently require our institutions to be authorized to require such authorization.
5 unchanged sentences
SARA does not cover, or limits its coverage related to, certain activities.
−Removed: As a result, an institution may still be required to obtain state authorization from, for example, agencies, or boards responsible for professional licensure.
+Added: As a result, an institution may still be required to obtain state authorization from, for example, state education agencies or boards responsible for professional licensure.
For information on our institutions’ status under SARA, please refer to “State Authorization/Licensure of Our Institutions” in this Annual Report.
+Added: In January 2024, SARA’s coordinating entity, the National Council for State Authorization Reciprocity Agreements, or NC-SARA, initiated its policy modification process, soliciting proposals for changes to SARA policy.
+Added: Such proposals included, among other things, potential denial of an institution’s participation in SARA if it violates any requirement related to state authorization, accreditation, or participation in Title IV programs and potential denial of an institution’s participation, or limiting participation, in SARA as a result of adverse actions against an institution related to its academic quality, its financial stability, or student consumer protection issues.
+Added: In October 2024, the NC-SARA board of directors approved ten proposals, which included changes related to when an institution may be placed on provisional status and when a state must deny or may exercise its discretion to deny an institution’s participation in SARA, which concluded the policy modification process.
+Added: See the Risk Factor captioned “Our institutions’ failure to comply with the requirements of SARA or regulations of ED or various states related to state authorization could result in actions that would have a material adverse effect on our enrollments, revenue, and results of operations” for more information.
Many states also have specific requirements that an individual must satisfy in order to be licensed as a professional in a specified field.
13 unchanged sentences
State Authorization and Professional Licensure
−Removed: Beginning July 1, 2024, new ED regulations will require institutions that offer postsecondary education programs leading to employment in an occupation that requires licensure or certification to meet certain additional requirements in order for those programs to maintain eligibility to participate in Title IV programs.
+Added: Effective July 1, 2024, new ED regulations require institutions that offer postsecondary education programs leading to employment in an occupation that requires licensure or certification to meet certain additional requirements in order for those programs to maintain eligibility to participate in Title IV programs.
In each state in which the institution is located, in which students enrolled in distance education are located, or where a student enrolled after July 1, 2024 attests that they intend to seek employment, the program must:
−Removed: (1) meet all applicable federal or state agency accreditation or pre-accreditation requirements, including as a condition of employment in the occupation for which the program prepares the students;
−Removed: (2) satisfy the applicable state education requirements for professional licensure or certification so that a student seeking employment may qualify to take any licensure or certification exam needed to practice or find employment in the state;
−Removed: and (3) comply with all applicable state laws related to closure.
+Added: (i) meet all applicable federal or state agency accreditation or pre-accreditation requirements, including as a condition of employment in the occupation for which the program prepares the students;
+Added: (ii) satisfy the applicable state education requirements for professional licensure or certification so that a student seeking employment may qualify to take any licensure or certification exam needed to practice or find employment in the state;
+Added: and (iii) comply with all applicable state laws related to closure.
State Authorization/Licensure of Our Institutions
3 unchanged sentences
Failure to comply with WVHEPC requirements could result in APUS losing its authorization from WVHEPC, its accreditation by HLC, its eligibility to participate in Title IV programs and TA, or its ability to offer certain programs, any of which could force APUS to cease operations.
−Removed: APUS participates in SARA.
+Added: As explained further in “Student Financing Sources and Related Regulations/Requirements – Department of Education – Regulation of Title IV Financial Aid Programs – Financial Responsibility”, APUS participates in SARA on provisional status due to its composite score for fiscal year 2022 being in the zone.
APUS also has obtained authorization to operate in California, which is the only state that is a non-SARA jurisdiction.
−Removed: RU is headquartered in Bloomington, Minnesota, and has 22 campuses across Florida, Illinois, Kansas, Minnesota, North Dakota, and Wisconsin.
−Removed: HCN is headquartered in Westerville, Ohio, and has six campuses in Ohio, one in Indiana, and one in Michigan.
−Removed: RU and HCN have obtained from the relevant state postsecondary education agencies the requisite authorizations, approvals, or registrations for the states in which they have campuses.
+Added: RU is headquartered in Bloomington, Minnesota and is authorized to offer its programs by the Minnesota Office of Higher Education, or MOHE.
+Added: RU has a total of 20 campuses across Florida, Illinois, Kansas, Minnesota, North Dakota, and Wisconsin, and is also authorized to offer its programs by the relevant education agencies in these states.
+Added: In December 2024, the North Dakota State Board of Higher Education approved RU to operate under a provisional license effective January 1, 2025, due to APEI’s composite score for fiscal year 2022, which is the most recent composite score that ED has calculated.
+Added: In July 2024, RU closed its Lake Elmo, Minnesota campus and moved all enrolled students at the campus to RU’s Eagan, Minnesota campus, which is located less than 10 miles from the Lake Elmo campus.
+Added: In addition, in May 2024, RU notified the Wisconsin Educational Approval Program that it intends to voluntarily close RU’s two Wisconsin campuses, Green Bay and Wausau, effective December 31, 2025, and 2026, respectively.
+Added: These actions are expected to directly impact approximately 90 students, or less than 1% of RU’s current total enrollment.
+Added: HCN is headquartered in Westerville, Ohio and is authorized to offer its programs by the Ohio State Board of Career Colleges and Schools.
+Added: HCN has six campuses in Ohio, one campus in Indiana and one campus in Michigan, and is also authorized to offer its programs by the relevant education agencies in these states.
+Added: For details about “home” state authorization generally, see the “State Authorization/Licensure – Federal Requirements for State Authorization/Licensure – ‘Home’ State Authorization” above.
In addition, the nursing education programs offered by RU and HCN are approved by the relevant state boards of nursing.
1 unchanged sentence
HCN does not offer online programs in California.
+Added: Effective as of July 2024, a new Minnesota statute prohibits private educational institutions from using agreements that restrict students from disclosing information in connection with many types of student complaints.
+Added: In October 2024, MOHE notified RU that it had determined that RU had used an impermissible nondisclosure agreement with one student.
+Added: For more information on the risks related to this determination, see the Risk Factor with the caption beginning “If we or our institutions fail to comply with the extensive regulatory requirements for the operation of postsecondary education institutions...”
To maintain regulatory approval from the state board of nursing or equivalent body in the states that we operate, an educational program must maintain a certain pass rate on the relevant licensure exam, as defined by the state.
If a program does not attain this pass rate, the program may face various consequences, including development and implementation of a plan of corrective action, issuance of a corrective order, or revocation of approval pursuant to an adjudication proceeding.
−Removed: In Indiana, a program that is under initial accreditation may not be granted full accreditation if the program’s pass rate is lower than one standard deviation below the average national pass rate.
+Added: For example, in Indiana, a program that is under initial accreditation may not be granted full accreditation if the program’s pass rate is lower than one standard deviation below the average national pass rate.
In addition, if the program’s pass rate is lower than one standard deviation below the average national pass rate for three consecutive years, the program may be subject to additional oversight or a change in accreditation status.
−Removed: A number of programs at certain RU campuses and in certain states, including its Bloomington and Moorhead, Minnesota, Fort Myers, Florida, Ocala, Florida, Tampa/Brandon, Florida, and Illinois and Kansas ADN programs and its Moorhead, Minnesota PN program, as well as HCN’s Ohio ADN program, have not met state-established first-time NCLEX benchmarks for consecutive years.
+Added: A number of programs at certain RU campuses and in certain states, including its Moorhead, Minnesota, Fort Myers, Tampa and Ocala, Florida, and Illinois and Kansas ADN programs and its Moorhead, Minnesota PN program, as well as HCN’s Ohio ADN program, have not met state-established first-time NCLEX benchmarks for consecutive years.
We believe that low pass rates may be the result of a number of factors, including, without limitation, the academic preparedness of our students, curriculum gaps, changes in the mode of course delivery including the use of virtual courses, testing failures and inconsistencies, imbalances in enrollment and resources, and changes in admission standards.
For more information, please refer to the Risk Factor that begins with the caption “Failure to improve certain of our programs’ NCLEX pass rates...”.
−Removed: A stipulation and consent order with the MBN required RU’s Bloomington, Minnesota ADN program to, among other things, reach applicable NCLEX pass rate standards by the end of 2023 and maintain a specified student to faculty ratio in 2023, with a potential penalty up to and including withdrawal of program approval.
+Added: RU’s Moorhead, Minnesota PN program is currently approved by MBN, but first-time NCLEX pass rates have been below the standard for three consecutive years.
+Added: In August 2024, MBN placed RU’s Moorhead, Minnesota PN program on conditional approval status and issued a corrective action order.
+Added: MBN conducted a survey visit in February 2025, regarding the third consecutive year of below-standard NCLEX pass rates.
+Added: The findings of the visit will be presented to MBN’s Board in mid-2025, and we believe the findings are likely to result in a corrective action order for the ADN program.
+Added: The program’s NCLEX pass rate must meet the state standard by the end of June 2025, measured using cumulative pass rates from the preceding four quarters (i.e., July 2024 to June 2025).
+Added: A stipulation and consent order with MBN required RU’s Bloomington, Minnesota ADN program to, among other things, reach applicable NCLEX pass rate standards by the end of 2023 and maintain a specified student to faculty ratio in 2023, with a potential penalty up to and including withdrawal of program approval.
The Bloomington, Minnesota ADN program did not reach the applicable NCLEX pass rates by the end of 2023.
−Removed: As a result, on December 29, 2023, RU informed the MBN that it intended to voluntarily close the Bloomington, Minnesota ADN program on June 15, 2024.
−Removed: The MBN approved the voluntary closure of the Bloomington, Minnesota ADN program at its February 1, 2024 meeting.
−Removed: For all students enrolled in the Bloomington, Minnesota ADN program graduating after June 2024, their enrollment record will be transferred to RU’s St.
−Removed: Cloud, Minnesota ADN.
−Removed: However, there can be no assurance that any or all remaining students in the program will transfer to the St.
−Removed: Cloud campus.
−Removed: In February 2022, RU’s Illinois ADN program was placed on probationary status by the IDFPR.
−Removed: Therefore, RU is required to temporarily reduce admitted students in the program by 25% and has two years to demonstrate evidence of implementing strategies to correct deficiencies and satisfy the required NCLEX pass rate.
−Removed: The requirement provided that after two years if the pass rate does not satisfy the required standard, the program will be reevaluated by the IDFPR for a determination as to whether the program will be allowed to continue on probation or whether it should be disapproved.
−Removed: An Illinois statute also required nursing programs to have achieved accreditation by the end of 2022 in order to meet state approval requirements.
−Removed: RU’s Illinois ADN program is currently in candidacy status with ACEN and was deemed by IDFPR to meet the state’s accreditation requirement based on such candidacy status, but actual accreditation has not yet been granted.
−Removed: The current candidacy status is set to expire in July 2024.
−Removed: Although the IDFPR has indicated that candidacy status satisfies this requirement, the IDFPR could change its position.
−Removed: The State of Illinois enacted legislation in August 2023, which took effect on January 1, 2024, that we believe could positively impact RU’s Illinois ADN program by providing the program with additional time to improve NCLEX pass rates.
−Removed: The legislation changed the Illinois NCLEX pass rate requirements from a one-year measurement based on first attempts only to a three-year average that includes all test attempts and temporarily removed all nursing programs, including RU’s Illinois ADN program, from probationary status for a period of three years.
−Removed: The IDFPR’s Board of Nursing now publicly lists RU as approved with no reference to probation.
−Removed: However, there can be no assurance that the IDFPR’s Board of Nursing will not seek to impose different or additional requirements in connection with this change in legislation or that additional legislation will not be enacted that imposes new requirements that are more restrictive than what is currently in place.
−Removed: Furthermore, there can be no assurance that the resulting removal from probationary status of RU’s Illinois ADN program may be viewed favorably by ACEN or another nursing program accreditor and may result in RU’s Illinois ADN program obtaining ACEN accreditation following a site visit in February 2024.
+Added: As a result, on December 29, 2023, RU informed MBN that it intended to voluntarily close the Bloomington, Minnesota ADN program on June 15, 2024.
+Added: MBN approved the voluntary closure of the Bloomington, Minnesota ADN program at its February 1, 2024, meeting.
+Added: In February 2022, RU’s Illinois ADN program was placed on probationary status by the Illinois Department of Financial and Professional Regulation, or IDFPR.
+Added: RU was required to temporarily reduce admitted students in the program by 25% and was given two years to demonstrate evidence of implementing strategies to correct deficiencies and satisfy the required NCLEX pass rate.
+Added: The State of Illinois enacted legislation in August 2023, which took effect on January 1, 2024, that changed the Illinois NCLEX pass rate requirements from a one-year measurement based on first attempts only to a three-year average that includes all test attempts, and temporarily removed all nursing programs, including for RU’s Illinois ADN program, from probationary status until September 2026.
+Added: In October 2024, RU’s Illinois ADN program was included in IDFPR’s published list of approved nursing programs with no reference to probation;
+Added: however, its low pass rate for two consecutive years was acknowledged.
Kansas regulations were amended, effective January 2022, to increase the threshold first-time pass rate to 80% and change corrective actions for noncompliance.
In April 2022, RU’s Kansas ADN program was issued a notice of concern by the Kansas Board of Nursing, or KBN, requiring RU to submit to the KBN a plan of action to improve its NCLEX pass rates.
−Removed: The Kansas ADN program has until April 2024 to increase its NCLEX pass rate to the regulatory standard.
−Removed: RU’s Kansas ADN program’s first-time pass rate exceeded the threshold pass rate for 2023.
−Removed: In February 2023, the Florida Board of Nursing, or FBN, placed RU’s Fort Myers, Florida ADN program on probation until its pass rate reaches the applicable threshold for a calendar year.
+Added: The Kansas ADN program had until April 2024 to increase its NCLEX pass rate to the regulatory standard.
+Added: RU’s Kansas ADN program’s first-time pass rate exceeded the threshold pass rate for 2023 in advance of the April 2024 deadline.
+Added: In February 2023, the Florida Board of Nursing, or FBN, placed RU’s Fort Myers, Florida ADN program on probation due to two consecutive years of its NCLEX pass rates not meeting the state standard.
+Added: In February 2024, FBN notified RU that the program will be allowed to continue on probation for one additional year.
+Added: If the program fails to achieve the required NCLEX pass rate at the end of this additional one-year period, but the program continues to show adequate progress toward the required pass rate, FBN may allow the program to continue on probation for one additional year.
+Added: If the program fails to show adequate progress toward the required pass rate, FBN may choose to disapprove the program.
RU is required to disclose this status to active and prospective students.
−Removed: If the program fails to achieve the required NCLEX pass rate within two years following placement on probation, FBN may extend the program’s status for a year if the program is demonstrating progress toward achievement.
−Removed: However, absent further extension or achievement of the required rate by the end of the extension, Florida law provides that FBN shall terminate the program.
−Removed: In February 2024, FBN also placed RU’s Ocala, Florida and Tampa/Brandon, Florida ADN programs on probation – a status that must be disclosed to active and prospective students – until the programs’ pass rates reach the applicable threshold for a calendar year.
−Removed: RU was required to present an action plan to FBN on February 7, 2024, detailing benchmarks to measure progress toward achieving the required NCLEX pass rate.
−Removed: In January 2024, legislation that would significantly overhaul the regulation of Florida nursing programs in ways that could materially adversely impact RU’s Florida ADN and PN programs was introduced in the Florida senate, but at this time there can be no assurance that the legislation will be enacted as drafted or at all.
−Removed: Rasmussen University had its annual review in January 2024, with the Florida Commission for Independent Education, or FCIE, where it waived a decision.
−Removed: Rasmussen is expected to appear on the May 2024, agenda where FCIE will review Florida campus NCLEX scores and campus income statements.
−Removed: Based on FCIE review, the FCIE may place Rasmussen on a provisional license due to recent NCLEX pass rates and campus income statements.
−Removed: If placed on provisional status, the Florida program would have one year to increase its NCLEX scores as well as improve its financials.
−Removed: If Rasmussen is unable to improve NCLEX scores and financials over time, this situation could have an adverse impact on their ability to enroll students and eventually our ability to continue offering our programs in Florida.
+Added: In March 2024, FBN placed RU’s ADN programs at its Tampa, and Ocala, Florida, campuses, along with the Ocala campus satellite program at North Orlando, Florida, on probationary status due to two consecutive years of NCLEX pass rates not meeting the state standard.
+Added: In January 2025, RU’s ADN programs at its Fort Myers, Tampa, and Ocala, Florida campuses received notification from FBN that the programs met NCLEX pass rate requirements, and they were removed from probationary status at FBN’s February 2025 Board meeting.
+Added: At its May 2024 meeting, the Florida Commission for Independent Education, or FCIE, reviewed RU for a substantive change due to financial stability concerns and, at the time, the Fort Myers, Tampa and Ocala, Florida ADN programs being placed on probation by FBN.
+Added: FCIE subsequently placed RU on a provisional license until November 30, 2024.
+Added: To fulfill a condition of licensure, RU submitted an interim report on its financial condition and NCLEX pass rates for the Fort Myers,
+Added: Ocala and Tampa, Florida ADN programs to FCIE in July 2024.
+Added: RU’s annual renewal was reviewed by FCIE in November 2024, and RU was granted a provisional license for 2025.
HCN’s ADN program has been on provisional approval status in Ohio since March 2017 due to not meeting the first-time pass rate standard for five consecutive years.
1 unchanged sentence
In January 2023, OBN placed HCN’s PN program on provisional approval for a period of 18 months due to two self-reported instances of noncompliance with faculty credential and program records requirements.
−Removed: As a result, HCN must submit to OBN progress reports evidencing that it meets and maintains nursing program requirements.
−Removed: Additionally, HCN will host a site visit from OBN in 2024 after which OBN may reconsider the provisional approval status.
−Removed: If a program on provisional approval fails to meet OBN requirements at the end of the time period established for provisional approval, in this case as of June 2024, OBN may propose to continue provisional approval for a set time period or may propose to withdraw approval.
−Removed: RU and HCN have been implementing changes to their ADN programs, including programmatic certification improvement plans at RU, and curriculum, academic achievement, and course retake policy changes at HCN, in order to help prepare students and graduates for successful performance on the NCLEX exam.
−Removed: However, there is no assurance that these changes will be successful in the required time periods or will not have negative effects on RU’s or HCN’s enrollment.
−Removed: If RU and HCN are unable to improve NCLEX scores over time, and in some cases by the deadlines imposed on their programs at certain campuses and in certain states as discussed above, this situation could have an adverse impact on their ability to enroll students and eventually our ability to continue offering the ADN programs at the applicable campuses.
+Added: As a result, HCN was required to submit to OBN progress reports evidencing that it meets and maintains nursing program requirements.
+Added: In July 2024, OBN restored the PN program to full approval status for a five-year period after HCN hosted a site visit from OBN.
Failure to comply with state authorization or licensure requirements has impacted and could in the future restrict our institutions’ ability to recruit or enroll students or result in other sanctions, including fines and penalties.
−Removed: New laws, regulations, interpretations, or changed circumstances related to our institutions’ educational programs could increase our cost of doing business and affect our ability to recruit students and offer programs in particular states, which could, in turn, adversely affect
−Removed: our institutions’ enrollments and revenue and have a material effect on our business.
+Added: New laws, regulations, interpretations, or changed circumstances related to our institutions’ educational programs could increase our cost of doing business and affect our ability to recruit students and offer programs in particular states, which could, in turn, adversely affect our institutions’ enrollments and revenue and have a material effect on our business.
Additional information regarding the current impacts and potential risks associated with our NCLEX pass rates is provided in the “Risk Factors” section of this Annual Report.
Student Financing Sources and Related Regulations/Requirements
−Removed: Our students finance their education through a combination of Title IV programs, TA, education benefits administered by the VA, private loans, corporate reimbursement programs, individual resources, and institutional grants, and in the case of HCN, an extended payment plan option.
−Removed: Participation in federal student aid programs, including those administered by the DoD and VA, and the extended payment plan option at HCN, adds to the regulation of our operations.
+Added: Our students finance their education through a combination of Title IV programs, TA, education benefits administered by the VA, private loans, corporate reimbursement programs, individual resources, and institutional grants, and in the case of HCN, extended payment plan options.
+Added: Participation in federal student aid programs, including those administered by the DoD and VA, and the extended payment plan options at HCN, adds to the regulation of our operations.
Department of Education
2 unchanged sentences
An institution will be certified to participate in the Title IV programs only if, among other things, it enters into a written program participation agreement, or PPA, with ED, which conditions participation in Title IV programs upon compliance with ED regulations and any additional conditions specified in the PPA.
−Removed: ED recently released a final rule modifying and expanding the current financial responsibility, administrative capability, and certification regulations, which takes effect July 1, 2024.
−Removed: Under the modified regulations, institutions will be required to meet additional financial responsibility criteria and must report certain “financial responsibility” events to ED.
+Added: ED regulations effective July 1, 2024, modify and expand requirements related to financial responsibility, administrative capability, and certification procedures.
+Added: Under the modified regulations, institutions are required to meet additional financial responsibility criteria and must report certain “financial responsibility” events to ED.
Such events include certain mandatory and discretionary triggers that capture financial circumstances that may not be reflected in an institution’s financial statements, including instances where an institution faces a potential loss of Title IV funding.
−Removed: Under the new rule, if ED determines that an institution has 90/10 Rule violations, high borrower default rates, or certain pending legal and administrative actions, it will require the institution to post “financial protection”, such as a letter of credit.
+Added: If ED determines that an institution has 90/10 Rule violations, high borrower default rates, or certain pending legal and administrative actions, it will require the institution to post “financial protection”, such as a letter of credit.
ED may also require the institution to post financial protection if it determines that certain discretionary triggers may have an adverse effect on the financial condition of the institution, such as pending accrediting agency or government agency actions, high annual dropout rates, or pending borrower defense claims.
2 unchanged sentences
ED may also impose additional requirements on the institution’s participation in Title IV programs, such as restrictions on enrollment, addition of new programs, or acquisitions.
+Added: In August 2024, ED announced that it would publish certain information related to PPAs, some of which ED already makes publicly available online or upon request.
+Added: Specifically, ED will now make publicly available on its website the Title IV participation statuses of the institutions currently participating in one or more Title IV programs, an example of a typical full certification PPA, copies of all provisional PPAs executed on or after January 1, 2024 and June 26, 2024, which will be updated on a rolling basis to include provisional PPAs issued after June 26, 2024, and a list of adverse administrative actions initiated between October 1, 2021, and July 31, 2024 against institutions participating in Title IV programs, which will be updated on a quarterly basis.
Higher Education Act
10 unchanged sentences
The Title IV programs are subject to Congressional action in terms of appropriations and other legislation that may affect funding levels, student eligibility, and other requirements.
−Removed: For example, the Pell Grant program could be subject to cuts or
−Removed: changes in the future, and cuts in ED’s administrative budget could lead to delays in student eligibility determinations and delays in origination and processing of federal student loans.
+Added: For example, the Pell Grant program could be subject to cuts or changes in the future, and cuts in ED’s administrative budget could lead to delays in student eligibility determinations and delays in origination and processing of federal student loans.
Regulation of Title IV Financial Aid Programs
8 unchanged sentences
An institution may come under review when it expands its activities in certain ways, such as opening an additional location, adding a new program, or, in certain cases, when it modifies academic credentials that it offers.
−Removed: New ED regulations, effective July 1, 2024, will implement supplementary performance measures that ED will consider when determining whether to certify or condition an institution’s participation in Title IV programs.
+Added: ED regulations effective July 1, 2024, implement supplementary performance measures that ED will consider when determining whether to certify or condition an institution’s participation in Title IV programs.
Among other requirements, ED may consider amounts spent on instruction and instructional activities, academic support, and support services, compared to the amounts spent on recruiting activities, advertising, and other pre-enrollment expenditures.
3 unchanged sentences
In addition, ED may more closely review a provisionally certified institution if it applies for approval to open a new location, add an educational program, acquire another school, or make any other significant change.
−Removed: If ED determines that a provisionally certified institution is unable to meet its responsibilities, it may seek to revoke the institution’s certification to participate in Title IV programs with fewer due process protections than if it were fully certified.
+Added: If ED determines that
+Added: a provisionally certified institution is unable to meet its responsibilities, it may seek to revoke the institution’s certification to participate in Title IV programs with fewer due process protections than if it were fully certified.
In June 2020, APUS timely applied for recertification to participate in Title IV programs.
2 unchanged sentences
APUS applied for recertification in March 2023.
−Removed: APUS’s recertification application is still pending, and APUS remains on provisional certification with ED .
−Removed: In July 2023, ED began a program review of APUS’s administration of Title IV programs during the 2021-2022 and 2022-2023 award years, which includes, among other things, a review of compliance with the 90/10 Rule.
−Removed: APUS has not yet received a program review report from ED.
−Removed: Accordingly, at this time, we cannot predict the outcome of the APUS program review, when it will be completed, whether there will be any adverse findings in the resulting program review report, what findings there may be related to 90/10 Rule compliance, if any, or whether ED will place any liability or other limitations on APUS as a result of the review.
+Added: In July 2024, ED notified APUS that it had approved APUS’s continued participation in the Title IV programs under a Provisional Program Participation Agreement, or PPPA, that is effective July 15, 2024, and expires June 30, 2026.
+Added: ED granted approval on a provisional basis because APUS was subject to an open program review (described below) at the time of recertification.
+Added: The PPPA imposes new reporting requirements on APUS related to accrediting agency actions, governmental actions, and class actions.
+Added: Additionally, APEI co-signed the PPPA pursuant to new regulations effective July 1, 2024, which require an entity with a direct or indirect ownership interest and the power to exercise control over the institution to co-sign the PPPA and assume joint and several liability for the participating institution’s Title IV liabilities.
In July 2021, in connection with RU’s March 2019 change in ownership that preceded our acquisition of RU, ED imposed certain temporary growth restrictions on RU, including limitations on new programs and locations and a cap on enrollments of students who participate in Title IV programs.
Additionally, ED required RU to submit periodic financial and enrollment reports and a financial responsibility letter of credit.
−Removed: In connection with the Rasmussen Acquisition, RU timely submitted a change in ownership and control application to ED seeking approval to participate in the Title IV programs under our ownership and, effective October 2021, ED and RU entered into a Temporary Provisional Program Participation Agreement, or TPPPA, that allowed RU to continue disbursing Title IV funds while ED reviewed the change in ownership application.
+Added: RU was initially required to fund this letter of credit using a restricted deposit account that required a deposit of 105%, or $24.2 million, to secure the RU letter of credit.
+Added: In connection with the acquisition of RU, or the Rasmussen Acquisition, RU timely submitted a change in ownership and control application to ED seeking approval to participate in the Title IV programs under our ownership and, effective October 2021, ED and RU entered into a Temporary Provisional Program Participation Agreement, or TPPPA, that allowed RU to continue disbursing Title IV funds while ED reviewed the change in ownership application.
The TPPPA continued the restrictions that ED imposed as a result of the March 2019 change in ownership.
−Removed: August 2023, ED notified RU that it had approved RU’s continued participation in the Title IV programs under APEI ownership under a Provisional Program Participation Agreement, or PPPA.
+Added: In August 2023, ED notified RU that it had approved RU’s continued participation in the Title IV programs under APEI ownership under a PPPA.
The PPPA continues to impose certain growth restrictions on RU that were included in the TPPPA, including limitations on new programs and locations and the enrollment of students that participate in Title IV programs.
2 unchanged sentences
The PPPA specifies that after ED reviews and accepts financial statements and compliance audits for one complete fiscal year of RU’s Title IV participation under APEI’s ownership, RU may seek approval for new programs that replace current programs.
−Removed: Although one complete fiscal year of RU’s Title IV participation under APEI’s ownership has passed, and we believe that we may now seek approval for new programs that replace current programs, we have not yet confirmed with ED that it has accepted the financial statements and compliance audits for such purpose.
+Added: Because one complete fiscal year of RU’s Title IV participation under APEI’s ownership has passed and ED has accepted the financial statements and compliance audits for that year, we believe that we may now seek approval for new programs that replace current programs.
The PPPA also specifies that after ED reviews and accepts financial statements and compliance audits that cover the second complete fiscal year of RU’s Title IV participation under our ownership, RU must seek pre-approval for new locations, new programs that are not replacing current programs, and other changes.
−Removed: For the second and third fiscal years, RU is also subject to enrollment growth limitations, after which RU can request ED that release RU from further enrollment restrictions.
+Added: For the second and third fiscal years, RU is also subject to enrollment growth limitations, after which RU can request that ED release RU from further enrollment restrictions.
The PPPA no longer requires RU to post the financial responsibility letter of credit that ED had imposed based on the 2019 change in ownership and control of RU, although this letter of credit has not yet been released.
5 unchanged sentences
In June 2023, HCN again timely applied for recertification.
−Removed: ED subsequently notified HCN that it had been granted non-provisional participation in all Title IV programs effective August 15, 2023 and expiring June 30, 2026.
+Added: ED subsequently notified HCN that it had recertified HCN’s participation in all Title IV programs effective August 15, 2023, and expiring June 30, 2026.
Co-Signature Requirements.
−Removed: A participating institution must sign a Program Participation Agreement with ED as a condition to participation in Title IV programs.
−Removed: New regulations, effective July 1, 2024, codify a current ED policy requiring signatures from corporations or other legal entities that have, or could have, a direct or indirect effect on the institution’s financial responsibility.
−Removed: Under the new regulations, entities with a direct or indirect ownership interest and the power to exercise control over the institution must co-sign the Program Participation Agreement.
+Added: A participating institution must sign a PPA with ED as a condition to participation in Title IV programs.
+Added: Regulations effective July 1, 2024, codify a current ED policy requiring signatures from corporations or other legal entities that have, or could have, a direct or indirect effect on the institution’s financial responsibility.
+Added: Under the new regulations, entities with a direct or indirect ownership interest and the power to exercise control over the institution must co-sign the PPA.
Co-signers agree that they are jointly and severally liable for the participating institution’s Title IV liabilities.
1 unchanged sentence
ED regulations specify extensive criteria that an institution must satisfy to establish that it has the requisite administrative capability to participate in Title IV programs.
−Removed: These criteria relate to, among other things, institutional staffing, operational standards such as procedures for disbursing and safeguarding Title IV program funds, timely submission of accurate reports to ED, referring to ED’s Office of Inspector General, or ED OIG, credible information that a student or employees with Title IV responsibilities may have engaged in fraud or illegal conduct in connection with Title IV program administration, and various other procedural matters.
−Removed: As described above, due to new regulations, effective July 1, 2024, ED may find that an institution has failed the administrative capability requirements if the institution does not provide adequate financial aid counseling or career services, has been subject to a negative action by a state or federal agency, court, or accreditor, fails to verify high school diplomas, or does not timely place students in geographically accessible clinical or externship opportunities.
−Removed: If an institution fails to satisfy any of the administrative capability requirements, ED may require the repayment of Title IV program funds, transfer the institution from the “advance” system of payment of Title IV program funds to heightened cash monitoring status, or to the “reimbursement” method of payment, place the institution on provisional certification status, or commence a proceeding to impose a fine or to limit, suspend, or terminate the participation of the institution in Title IV programs.
+Added: These criteria relate to, among other things, institutional staffing, operational standards such as procedures for disbursing and safeguarding Title IV program funds, timely
+Added: submission of accurate reports to ED, referring to ED’s Office of Inspector General, or ED OIG, credible information that a student or employees with Title IV responsibilities may have engaged in fraud or illegal conduct in connection with Title IV program administration, and various other procedural matters.
+Added: As further explained above under “Student Financing Sources and Related Regulations/Requirements – Department of Education,” due to ED regulations effective July 1, 2024, ED may find that an institution has failed the administrative capability requirements if the institution does not provide adequate financial aid counseling or career services, has been subject to a negative action by a state or federal agency, court, or accreditor, fails to verify high school diplomas, or does not timely place students in geographically accessible clinical or externship opportunities.
+Added: If an institution fails to satisfy any of the administrative capability requirements, ED may require the repayment of Title IV program funds, transfer the institution from the “advance” method of payment of Title IV program funds to heightened cash monitoring status, or to the “reimbursement” method of payment, place the institution on provisional certification status, or commence a proceeding to impose a fine or to limit, suspend, or terminate the participation of the institution in Title IV programs.
Financial Responsibility.
3 unchanged sentences
The formula focuses on three financial ratios:
−Removed: (1) equity ratio (which measures the institution’s capital resources, financial viability, and ability to borrow);
−Removed: (2) primary reserve ratio (which measures the institution’s viability and liquidity);
−Removed: and (3) net income ratio (which measures the institution’s profitability or ability to operate within its means).
−Removed: Generally, an institution’s financial ratios must yield a
−Removed: composite score of at least 1.5 for the institution to be deemed financially responsible.
+Added: (i) equity ratio (which measures the institution’s capital resources, financial viability, and ability to borrow);
+Added: (ii) primary reserve ratio (which measures the institution’s viability and liquidity);
+Added: and (iii) net income ratio (which measures the institution’s profitability or ability to operate within its means).
+Added: Generally, an institution’s financial ratios must yield a composite score of at least 1.5 for the institution to be deemed financially responsible.
A composite score between 1.0 and 1.4 is considered by ED to be in the “zone.” An institution in the “zone” may still participate in the Title IV programs as a financially responsible institution through the “zone alternative” or the “financial protection alternative” as set forth in ED regulations.
8 unchanged sentences
Because ED does not review each of our institution’s financial statements separately, a determination by ED that our consolidated financial statements do not satisfy the “financial responsibility” requirements could cause all of our institutions to lose access to Title IV program funding or result in other penalties or conditions on continued participation.
−Removed: Although our consolidated composite score is expected to be above 1.5 at our next financial responsibility test, there is no assurance that it will remain at 1.5 or above in the future or that if it falls in the “zone” in the future that we will be able to demonstrate financial responsibility.
−Removed: On March 4, 2024, ED notified us that in calculating our composite score for the fiscal year-ended December 31, 2022, it excluded our deferred tax assets from its calculation of our assets.
−Removed: As a result, ED calculated that we had a 2022 consolidated composite score of 1.1 and our institutions were therefore in the “zone.” We disagree with ED’s calculation and conclusion and intend to submit a timely response to ED supporting our position that our deferred tax assets should not be excluded from the calculation and that our composite score was above 1.5 for the year-ended December 31, 2022.
−Removed: However, there can be no assurance that ED will agree with our position.
−Removed: If ED does not accept our position, we intend to comply with the zone alternative requirements.
−Removed: Under the zone alternative requirements, we would be required to:
+Added: See risk factor captioned “Our subsidiary institutions’ failure to meet financial responsibility..” for more information.
+Added: In March 2024, ED notified us that in calculating our composite score for the fiscal year-ended December 31, 2022, it excluded our deferred tax assets from its calculation of our assets.
+Added: As a result, ED calculated that we had a 2022 consolidated composite score of 1.1 and our institutions were therefore in the “zone.” We disagree with ED’s calculation and conclusion and submitted a timely response to ED also in March 2024.
+Added: In April 2024, ED issued a response to our rebuttal and disagreed with our position, reiterating that our institutions must establish financial responsibility on an alternative basis.
+Added: We timely informed ED in April 2024 that although we continue to disagree with its composite score methodology with respect to deferred tax assets, we select the “zone alternative” as the alternative basis on which we establish financial responsibility.
+Added: Under the zone alternative, we are required to:
(i) make Title IV disbursements to eligible students and parents under the heightened cash monitoring payment method, or HCM1, pursuant to which we would be required to first make disbursements to eligible students and parents and pay any credit balances before we request or receive funds from ED for the amount of those disbursements;
2 unchanged sentences
and (iv) require our auditors to express an opinion on our compliance with the requirements under the zone alternative.
+Added: In addition, our institutions will be required to seek ED’s approval prior to adding educational programs or a new location at which the institution offers or will offer 50% or more of an educational program.
Institutions with composite scores below 1.5 do not qualify for approval from SARA unless, in the case of scores above 1.0, the home state exercises its discretion to consider additional financial information.
3 unchanged sentences
And, because composite scores are viewed as a measure of financial responsibility, other regulators or accreditors could consider a composite score that is in “zone” negatively, which could have an impact on their interactions with us and what they permit us to do.
−Removed: As of September 30, 2020, prior to the Rasmussen Acquisition, RU had a composite score equal to 1.4.
−Removed: RU elected to post a letter of credit with ED totaling $23.1 million, which represented 10% of the Title IV program funds received by RU during its then most recently completed fiscal year.
−Removed: Upon the closing of the Rasmussen Acquisition, RU was required to fund this letter of credit using a restricted deposit account that required a deposit of 105%, or $24.2 million, to secure the RU letter of credit.
−Removed: Under the TPPPA for RU described above, ED continued to require a letter of credit at least until ED reviews and accepts financial statements and compliance audits that cover one complete fiscal year of RU’s Title IV participation under APEI’s ownership.
−Removed: The PPPA no longer requires RU to post the financial responsibility letter of credit that ED had imposed based on the 2019 change in ownership and control of RU, although this letter of credit has not yet been released.
−Removed: We believe we have met all obligations for the release of the letter of credit, but we understand from communications with ED that financial statements for the year ended December 31, 2022 remain under review by ED.
−Removed: Additionally, RU continues to be required to make Title IV disbursements to eligible students and parents under HCM1.
In September 2019, ED published modifications to its financial responsibility standards that took effect July 1, 2020.
We refer to these regulations as the 2019 Borrower Defense Regulations.
−Removed: The 2019 Borrower Defense Regulations identify
−Removed: certain conditions or other triggering events that have or may have an adverse material effect on the institution’s financial condition, in response to which ED would or could require that the institution submit some form of financial protection, such as a letter of credit, to ED.
+Added: The 2019 Borrower Defense Regulations identify certain conditions or other triggering events that have or may have an adverse material effect on the institution’s financial condition, in response to which ED would or could require that the institution submit some form of financial protection, such as a letter of credit, to ED.
Triggering events are characterized as either mandatory or discretionary.
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If ED determines that one of our institutions is not financially responsible because of one or more triggering events, the institution would be required to provide an irrevocable letter of credit equal to at least 10% of the amount of federal student financial aid funds received by the institution for the past year.
−Removed: In October 2023, ED published modifications to its financial responsibility standards that take effect on July 1, 2024.
+Added: In October 2023, ED published modifications to its financial responsibility standards effective July 1, 2024.
These revised standards include, among other requirements, an expanded list of conditions or other triggering events for which ED could require financial protection, such as a letter of credit.
In addition, if ED requires financial protection as a result of more than one mandatory or discretionary trigger, it will require separate financial protection for each individual trigger.
−Removed: The American Rescue Plan Act, or ARPA, which was enacted in March 2021, modifies the HEA’s 90/10 Rule to require that a for-profit institution derive not less than 10 percent of its revenue from sources other than “federal education assistance funds”.
−Removed: ED published final regulations in October 2022 that address ARPA’s modifications to the 90/10 Rule.
−Removed: The new regulations provide that for fiscal years beginning on or after January 1, 2023, and therefore for our institutions the year ended December 31, 2023, federal funds used to calculate the “90%” side of the ratio include Title IV funds and any other educational assistance funds provided by a federal agency directly to an institution or a student, including the federal portion of any grant funds provided by or administered by a non-federal agency, except for non-Title IV federal funds provided directly to a student to cover expenses other than tuition, fees, and other institutional charges.
−Removed: ED confirmed that the 90/10 Rule would no longer permit institutions to count federal aid for veterans and service members as part of the “10%” side of the ratio.
−Removed: As a result, effective January 1, 2023, TA and VA benefits are included in the “90%” side of the ratio, and our institutions’ 90/10 Rule percentages increased, particularly at APUS.
−Removed: In March 2021, the Army launched ArmyIgnitED, to replace GoArmyED as its system for processing the Army’s TA funds for participating institutions.
−Removed: Issues related to the launch of ArmyIgnitED resulted in cash payments from the Army to APUS that were expected in 2021 and 2022 to be received in 2023, which, together with the change to the 90/10 Rule, enrollment growth among service members as compared to declines in students who use non-federal educational assistance funds and the delayed receipt of funds have caused and may continue to cause, APUS’s 90/10 Rule percentage to increase, making it more difficult to satisfy the 90/10 Rule.
−Removed: While each of our institutions was in compliance with the 90/10 Rule for 2023, with APUS’s relevant percentage for 2023 being 89%, there can be no assurance that we will continue to be able to comply in future years, particularly at APUS.
+Added: The “90/10 Rule.” Under the so-called “90/10 Rule”, a for-profit institution is prohibited from deriving more than 90% of its revenue (as computed by ED) on a cash accounting basis (except for certain institutional loans) from Title IV programs for any fiscal year.
+Added: If an institution fails to satisfy the 90/10 Rule for any fiscal year, the institution is placed on provisional status for two fiscal years.
+Added: An institution that fails to satisfy the rule for two consecutive fiscal years becomes ineligible to participate in Title IV programs for at least two fiscal years and is required to demonstrate compliance with Title IV eligibility and certification requirements for at least two additional fiscal years prior to resuming Title IV program participation.
+Added: Such institution would also lose the ability to participate in TA because DoD requires institutions to participate in the Title IV programs in order to participate in TA.
+Added: Ineligibility of any one or more of our institutions to participate in Title IV programs and TA would have a material adverse effect on our enrollments, revenue, results of operations, and cash flows.
+Added: The American Rescue Plan Act, or ARPA, which was enacted in March 2021, modified the HEA’s 90/10 Rule to require that a for-profit institution derive not less than 10% of its revenue from sources other than “federal education assistance funds”.
+Added: ED published final regulations in October 2022 that address ARPA’s modifications to the 90/10 Rule and provide that for fiscal years beginning on or after January 1, 2023, federal educational assistance funds used to calculate the “90%” side of the ratio include Title IV funds and any other educational assistance funds provided by a federal agency directly to an institution or a student, including the federal portion of any grant funds provided by or administered by a non-federal agency, except for non-Title IV federal funds provided directly to a student to cover expenses other than tuition, fees, and other institutional charges.
+Added: The 90/10 Rule no longer permits institutions to count federal aid for veterans and service members as part of the “10%” side of the ratio.
+Added: As a result, effective January 1, 2023, TA and VA benefits are included in the “90%” side of the ratio.
See the Risk Factor captioned “If one or more of our institutions does not comply with the 90/10 Rule, it or they will lose eligibility to participate in federal student financial aid programs” for more information.
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and institutions must notify ED and students in a timely manner if they fail the 90/10 Rule.
−Removed: The “90/10 Rule.” Under the so-called “90/10 Rule”, a for-profit institution is prohibited from deriving more than 90% of its revenue (as computed by ED) on a cash accounting basis (except for certain institutional loans) from Title IV programs for any fiscal year.
−Removed: If an institution fails to satisfy the 90/10 Rule for any fiscal year, the institution is placed on provisional status for two fiscal years.
−Removed: An institution that fails to satisfy the rule for two consecutive fiscal years becomes ineligible to participate in Title IV programs for at least two fiscal years and is required to demonstrate compliance with Title IV eligibility and certification requirements for at least two additional fiscal years prior to resuming Title IV program participation.
−Removed: Such institution would also lose the ability to participate in TA because DoD requires institutions to participate in the Title IV programs in order to participate in TA.
−Removed: Ineligibility of any one or more of our institutions to participate in Title IV programs and TA would have a material adverse effect on our enrollments, revenue, results of operations, and cash flows.
−Removed: See the Risk Factor with the caption beginning “If one or more of our institutions does not comply…” for more information.
Using the applicable 90/10 formula, the following table contains the percentage of cash-basis revenue earned from Title IV program funds:
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To remain eligible to participate in Title IV programs, an educational institution’s student loan cohort default rates must remain below certain levels.
−Removed: Pursuant to requirements of the HEA, if the cohort default rate for any year exceeds 40% in any single year, or exceeds 30% for three consecutive years, an institution loses eligibility to participate in Title IV programs.
+Added: Pursuant to HEA requirements, if the cohort default rate for any year exceeds 40% in any single year, or exceeds 30% for three consecutive years, an institution loses eligibility to participate in Title IV programs.
If an institution’s cohort default rate is equal to or greater than 30% in any year, it must establish a default prevention task force and develop a default prevention plan with measurable objectives for improving the cohort default rate.
In September 2024, ED released final official cohort default rates for institutions for federal fiscal year 2021 with ED reporting a zero percent cohort default rate for APUS, RU, and HCN.
−Removed: These cohort default rates were favorably impacted by regulatory relief provided in connection with the COVID-19 pandemic pursuant to which borrowers with Title IV program student loans were not required to make payments on their federal loans.
−Removed: As explained further in “Student Loan Defaults” below, interest accrual on federal student loans resumed on September 1, 2023, and payments became due beginning October 1, 2023, which may lead to higher default rates in the future.
+Added: These rates were favorably impacted by regulatory relief provided in connection with the COVID-19 pandemic pursuant to which borrowers with Title IV program student loans were not required to make payments on their federal loans, which, as explained further in “Student Loan Defaults” below, may lead to higher default rates in the future.
The final official ED cohort default rates for APUS, RU, and HCN for the federal fiscal years 2019, 2020 and 2021 are as follows:
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Government policies to minimize the adverse economic impact of the COVID-19 pandemic have artificially lowered our institutions’ cohort default rates, which nevertheless may be higher than otherwise expected as a result of the pandemic.
−Removed: Congress and ED implemented a temporary freeze on student loan payments and interest accruals, which means borrowers are less likely to default on their loans and our institutions’ cohort default rates are lower not because borrowers are making timely repayments but because the government is allowing them not to make payments.
+Added: Congress and ED implemented a temporary freeze on student loan payments and interest accruals, which means borrowers were less likely to default on their loans and our institutions’ cohort default rates are lower not because borrowers are making timely repayments but because the government was allowing them not to make payments.
In June 2023, the Fiscal Responsibility Act was enacted, ending the freeze on payments and interest accruals.
−Removed: Accordingly, interest accrual on federal student loans resumed on September 1, 2023, and payments became due beginning October 1, 2023, which may lead to an increase in defaults and therefore an increase in our institutions’ cohort default rates.
−Removed: ED has announced a 12-month “on-ramp” to repayment, running from October 1, 2023 to September 30, 2024, so that financially vulnerable borrowers who miss monthly payments during this period will not be considered delinquent, reported to
−Removed: credit bureaus, placed in default, or referred to debt collection agencies.
−Removed: ED has also announced other actions intended to provide debt relief and support for student loan borrowers, such as instituting a new income-driven repayment plan.
−Removed: However, there can be no assurance that our institutions’ cohort default rates will benefit from these efforts, and the eventual end of the “on-ramp” period may also lead to an increase in defaults.
−Removed: If one of our institutions loses its eligibility to participate in Title IV programs because of high student loan default rates, students would no longer be eligible to use Title IV program funds at that institution, which would significantly reduce that institution’s enrollments and revenue and cash flows and have a material adverse effect on our results of operations.
−Removed: In addition, if Congress or ED restricts permitted types of default prevention assistance, the default rates of our former students may be negatively impacted.
−Removed: Congress could also increase the measuring period, which could also negatively impact student default rates.
+Added: Accordingly, interest accrual on federal student loans resumed on September 1, 2023, and payments became due beginning October 1, 2023.
+Added: As a result, ED implemented a 12-month “on-ramp” to repayment, running from October 1, 2023, to September 30, 2024, during which borrowers were not considered delinquent, reported to credit bureaus, placed in default, or referred to debt collection agencies
+Added: for missed payments, which may lead to an increase in defaults and therefore an increase in our institutions’ cohort default rates in the future.
+Added: See the Risk Factor captioned “Our institutions may lose eligibility to participate in Title IV programs if their student loan default rates are too high, and our future growth could be impaired as a result” for more information.
Gainful Employment Regulations .
−Removed: Pursuant to new gainful employment, or GE, regulations, that will take effect July 1, 2024, ED will determine the Title IV eligibility of GE programs based in part on satisfaction of specified performance levels of two measures defined by GE regulations:
+Added: Pursuant to new gainful employment, or GE, regulations that took effect July 1, 2024, ED will determine the Title IV eligibility of GE programs based in part on satisfaction of specified performance levels of two measures defined by GE regulations:
the debt-to-earnings rates (which include two rates, the discretionary debt-to-earnings rate and the annual debt-to-earnings rate) and the earnings premium measure.
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The three APUS programs failing in the PPD represent 2.2% of total net course registrations for the three months ended December 31, 2024.
−Removed: Programs that fail to achieve the specified performance levels of the GE measures in two of any three successive years for which the debt-to-earnings rates or the earnings premium measure are calculated would lose access to Title IV funding.
−Removed: Under the GE regulations, the failure of any of our institutions’ programs to satisfy the required specified performance levels could adversely impact those institutions and programs.
−Removed: We expect that the earliest a program could lose eligibility is July 1, 2026.
−Removed: In addition, programs that fail any of the metrics in a year will be required to warn enrolled and prospective students that the program risks losing access to Title IV funding.
−Removed: At this time, it is difficult to predict whether our institutions’ programs will satisfy the performance levels of future GE metrics, including whether the programs identified as failing in the PPD will in fact fail or whether other programs will fail or pass.
+Added: Programs that fail to achieve the specified performance levels of the GE measures in two of any three successive years for which the debt-to-earnings rates or the earnings premium measure are calculated will lose access to Title IV funding.
+Added: Institutions will generally be required to report certain information used to calculate these measures to ED by July 31 of each year, provided that for 2024, ED has extended the deadline numerous times.
+Added: Most recently, in February 2025, ED announced that all reporting will be due September 30, 2025, and that it does not anticipate any further extensions.
+Added: In addition, ED stated that it does not plan to produce any GE data prior to the September 30, 2025, deadline and confirmed that it will not take enforcement or other punitive actions against institutions that have not yet completed their required reporting.
+Added: See the Risk Factor captioned “ED’s new gainful employment requirements could materially and adversely affect our business” for more information.
Third-Party Servicers.
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If any third-party servicer engaged by one of our institutions does not comply with applicable statutes and regulations, our institution may be liable for its actions, and our institution could lose its eligibility to participate in Title IV programs.
−Removed: ED recently issued and subsequently retracted guidance that would have significantly expanded the types of activities and functions that constitute third-party servicer activities for Title IV purposes and stated ED’s position that an institution may not contract with a third-party servicer for Title IV purposes if the servicer (or its subcontractors) is located outside the U.S.
−Removed: or is owned or operated by an individual who is not a U.S.
−Removed: citizen or national or a lawful U.S.
−Removed: permanent resident.
−Removed: In a November 2023 press release, ED indicated that it intends to issue updated guidance in early 2024 with an effective date at least six months after its publication.
−Removed: Once final guidance is published, our institutions must assess their arrangements with third parties to determine whether a vendor must now be treated as a third-party servicer based on the guidance, and such assessment may lead to a need to modify or end existing contracts and establish new contracts.
Title IV Return of Funds.
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If the student withdraws after the 60% threshold, then the student has earned 100% of the Title IV program funds.
−Removed: The institution must return to the appropriate Title IV programs, in a specified order, the lesser of (i) the unearned Title IV program funds or (ii) the institutional charges incurred by the student for the period multiplied by the percentage of unearned Title IV program
+Added: The institution must return to the appropriate Title IV programs, in a specified order, the lesser of (i) the unearned Title IV program funds or (ii) the institutional charges incurred by the student for the period multiplied by the percentage of unearned Title IV program funds.
An institution must return the funds no later than 45 days after the date of the institution’s determination that a student withdrew.
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In connection with that finding, HCN was required to conduct a full file review and have the review tested by an independent auditor.
−Removed: In July 2022, HCN issued a final program review determination with respect to all findings, resulting in total liabilities of approximately $12,000.
−Removed: On August 15, 2023 the U.S.
−Removed: Department of Education recertified HCN's Title IV Program Participation Agreement with no restrictions and removed the prior provisional classification.
+Added: In July 2022, ED issued a final program review determination with respect to all findings, resulting in total liabilities of approximately $12,000.
Substantial Misrepresentation.
−Removed: Under the HEA and its implementing regulations, ED may take action against an institution in the event of substantial misrepresentation by the institution concerning the nature of its educational programs, its financial charges, or the employability of its graduates.
+Added: Under the HEA and its implementing regulations, ED may take action against an institution in the event of substantial misrepresentation by the institution concerning the nature of its educational programs, its
+Added: financial charges, or the employability of its graduates.
As part of the 2022 Borrower Defense Regulations, ED modified the substantial misrepresentation rule to explicitly include certain “omissions of fact” as a basis for a misrepresentation claim or borrower defense to repayment, or BDTR, claim.
If ED determines that an institution has engaged in substantial misrepresentation regarding the nature of its education program, its financial charges, or the employability of its graduates, ED may:
−Removed: (i) if the institution is provisionally certified, as our institutions currently are, revoke an institution’s program participation agreement or impose limitations on its participation in Title IV programs;
+Added: (i) if the institution is provisionally certified, as some of our institutions currently are, revoke an institution’s program participation agreement or impose limitations on its participation in Title IV programs;
(ii) deny participation applications made on behalf of the institution;
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For Direct Loans first disbursed on or after July 1, 2017, the 2016 Borrower Defense Regulations created a new federal standard for BDTR of Direct Loans, new limitation periods for such claims, and new processes for resolution of such claims.
−Removed: The 2016 Borrower Defense Regulations were in effect from July 1, 2017 until July 1, 2020 when ED published new BDTR regulations.
+Added: The 2016 Borrower Defense Regulations were in effect from July 1, 2017, until July 1, 2020, when new BDTR regulations became effective.
In September 2019, ED published the 2019 Borrower Defense Regulations, which, among other things, modify the standard for BDTR of Direct Loans made on or after July 1, 2020, the limitation periods for such claims, and the processes for resolution of such claims.
The 2016 Borrower Defense Regulations continue to apply to all Direct Loans made on or after July 1, 2017, and before July 1, 2020, with certain exceptions pursuant to the 2019 Borrower Defense Regulations.
−Removed: The 2019 Borrower Defense Regulations apply to all Direct Loans made on or after July 1, 2020 and before July 1, 2023, when ED again published new BDTR regulations.
+Added: The 2019 Borrower Defense Regulations apply to all Direct Loans made on or after July 1, 2020, and before July 1, 2023, when new BDTR regulations became effective.
In March 2021, ED announced a revised approach for determining relief for borrowers who successfully assert borrower relief claims.
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The 2022 Borrower Defense Regulations will create a single standard and streamlined process for relief that will:
−Removed: apply to all future and pending BDTR claims as of July 1, 2023 instead of standards varying based on the date of the borrower’s first loan disbursement;
−Removed: allow students to assert borrower defenses related to Direct Consolidation Loans;
−Removed: define what kinds of misconduct could lead to borrower defense discharges (substantial misrepresentation, substantial omission of fact, breach of contract, aggressive and deceptive recruitment, and certain judgments or final ED actions);
−Removed: establish a reconsideration process for borrowers whose claims are not approved for a full discharge;
−Removed: create a process for forming groups of borrowers and adjudicating claims based on the common facts of those group claims;
−Removed: and provide a clear timeline for adjudication of group and individual claims.
+Added: (i) apply to all future and pending BDTR claims as of July 1, 2023 instead of standards varying based on the date of the borrower’s first loan disbursement;
+Added: (ii) allow students to assert borrower defenses related to Direct Consolidation Loans;
+Added: (iii) define what kinds of misconduct could lead to borrower defense discharges (substantial misrepresentation, substantial omission of fact, breach of contract, aggressive and deceptive recruitment, and certain judgments or final ED actions);
+Added: (iv) establish a reconsideration process for borrowers whose claims are not approved for a full discharge;
+Added: (v) create a process for forming groups of borrowers and adjudicating claims based on the common facts of those group claims;
+Added: and (vi) provide a clear timeline for adjudication of group and individual claims.
The 2022 Borrower Defense Regulations indicate that ED will hold colleges accountable for the cost of discharges, including by establishing a recoupment process separate from the approval of BDTR claims and making a recoupment determination based on the standards in place at the time the loan was first disbursed.
2 unchanged sentences
In 2022, ED joined a class settlement agreement that would result in a blanket grant of automatic, presumptive relief for all BDTR applications filed by students at certain institutions through June 22, 2022, but our institutions were not included in the blanket grant of relief.
−Removed: The class settlement agreement would also provide certain expedited review of borrower defense claims related to institutions excluded from the automatic relief list, as well as for borrowers who applied during the period after execution of the settlement and before final approval.
−Removed: Borrowers had to have submitted an application by November 15, 2022 in order to receive expedited review.
+Added: The class settlement agreement provided certain expedited review of borrower defense claims related to institutions excluded from the automatic relief list, as well as for borrowers who applied during the period after execution of the settlement and before final approval.
+Added: Borrowers had to have submitted an application by November 15, 2022, in order to receive expedited review, and ED confirmed it would adjudicate all such applications under the 2016 Borrower Defense Regulations.
In December 2023, RU received from ED 338 BDTR claims, all of which had submission dates between June 23, 2022, and November 15, 2022, for students attending RU between 2000 and 2022, seeking in the aggregate a discharge of approximately $6.1 million in loans.
−Removed: In December 2023, HCN received from ED 77 BDTR claims, all of which were dated between June 23, 2022 and November 15, 2022 for students attending HCN between 2007 and 2022, seeking in the aggregate a discharge of approximately $1.4 million in loans.
−Removed: RU and HCN dispute the validity of these claims and have filed responses to them with ED.
−Removed: We are unable to predict whether ED will grant BDTR relief for the claims, or if so, whether it will seek recoupment from RU and/or HCN.
−Removed: While we have not received any claims with respect to APUS at this time, we believe is it reasonably likely that we will receive claims in the future.
+Added: In December 2023, HCN received from ED 77 BDTR claims, all of which had submission dates between June 23, 2022, and November 15, 2022, for students attending HCN between 2007 and 2022, seeking in the aggregate a discharge of approximately $1.4 million in loans.
+Added: In September 2024, APUS received from ED 408 BDTR claims, all of which had submission dates between June 23, 2022, and November 15, 2022, for students attending APUS between 2006 and 2021, seeking in the aggregate a discharge of approximately $6.6 million in loans.
+Added: Each of RU, HCN, and APUS disputes the validity of these claims and has filed responses to them with ED.
+Added: We are unable to predict whether ED will grant BDTR relief for the claims, or if so, whether it will seek recoupment from RU, HCN and/or APUS.
Refer to the Risk Factor captioned “ED rules related to BDTR claims may create significant liability that could have an adverse effect on our business” for additional information.
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the liability was reduced on appeal to $77,569.
−Removed: RU may also face closed school discharge liabilities as a result of the 2021 consolidation of two Florida campuses and the 2022 consolidation of two Minnesota campuses.
−Removed: The 2022 Borrower Defense Regulations will provide for automatic discharges to any borrower who was enrolled within 180 days prior to a school’s closure and who did not complete their education at the school or through an approved teach-out agreement at another school within one year after the closure of their original school.
−Removed: The final regulations shorten the previous period for automatic discharge so borrowers do not default on their loans after a closure of their school.
+Added: RU may also face closed school discharge liabilities as a result of the 2021 consolidation of two Florida campuses, the 2022 consolidation of two Minnesota campuses, and the planned closure of two Wisconsin campuses.
+Added: The 2022 Borrower Defense Regulations included closed school loan discharge provisions that would provide for automatic discharges to any borrower who was enrolled within 180 days prior to a school’s closure and who did not complete their education at the school or through an approved teach-out agreement at another school within one year after the closure of their original school.
+Added: The regulations would shorten the previous period for automatic discharge so borrowers do not default on their loans after a closure of their school.
+Added: The closed school loan discharge provisions of the 2022 Borrower Defense Regulations are currently enjoined nationwide by court order, which means ED currently cannot apply the closed school loan discharge provisions of the 2022 Borrower Defense Regulations to any institution.
Dispute Resolution .
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The 2019 Borrower Defense Regulations, which apply to all Direct Loans made on or after July 1, 2020, and before July 1, 2023, generally remove these prohibitions but require institutions whose students must enter into pre-dispute arbitration agreements or class action waivers to disclose publicly those requirements, and prohibit requiring a student to participate in arbitration or any internal dispute resolution process prior to filing a BDTR application with ED.
−Removed: The 2022 Borrower Defense Regulations, which apply to all Direct Loans made on or after July 1, 2023 and to all BDTR claims pending as of that date, prohibit institutions from requiring borrowers to sign mandatory pre-dispute arbitration agreements or class action waivers for claims related to the making of a Federal Direct Loan or the provision of
−Removed: educational services for which the loan was obtained.
−Removed: However, the effective date of the 2022 Borrower Defense Regulations is currently enjoined nationwide by court order, which means ED currently cannot apply the 2022 Borrower Defense Regulations to any institution, including the new dispute resolution rules.
+Added: The 2022 Borrower Defense Regulations, which apply to all Direct Loans made on or after July 1, 2023, and to all BDTR claims pending as of that date, prohibit institutions from requiring borrowers to sign mandatory pre-dispute arbitration agreements or class action waivers for claims related to the making of a Federal Direct Loan or the provision of educational services for which the loan was obtained.
+Added: However, the effective date of the 2022 Borrower Defense Regulations is currently enjoined nationwide by court order, which means ED currently cannot apply the 2022 Borrower Defense Regulations to any institution.
Other Department of Education Regulation
1 unchanged sentence
The Family Educational Rights and Privacy Act of 1974, or FERPA, and ED’s regulations implementing FERPA require education institutions to protect the privacy of students’ education records by, among other things, limiting disclosure of a student’s personally identifiable information without prior written consent.
−Removed: If an institution fails to comply with FERPA, ED may require corrective actions or terminate eligibility to participate in Title IV programs.
+Added: If an institution fails to comply with FERPA, ED may require corrective actions or terminate eligibility to participate in
+Added: Title IV programs.
In addition, education institutions engaged in financial activities such as the granting of student loans are obligated to safeguard student information pursuant to the Gramm-Leach-Bliley Act, or GLBA, and implementing regulations, which among other things, requires reasonable security practices to protect personally identifiable financial information of students, parents, or other individuals in a customer relationship with the institution.
2 unchanged sentences
FTC enforcement focuses primarily on:
−Removed: (1) collecting, using, sharing, or retaining personal information inconsistent with representations, commitments, and promises in privacy policies and other public statements;
−Removed: (2) privacy policies that do not adequately inform consumers about actual practices;
−Removed: and (3) failing to reasonably protect the security, privacy, and confidentiality of personal information.
+Added: (i) collecting, using, sharing, or retaining personal information inconsistent with representations, commitments, and promises in privacy policies and other public statements;
+Added: (ii) privacy policies that do not adequately inform consumers about actual practices;
+Added: and (iii) failing to reasonably protect the security, privacy, and confidentiality of personal information.
Institutions must also comply with the FTC Red Flags Rule, a requirement designed to identify and mitigate identity theft for certain student accounts.
States can also bring similar enforcement actions under so called “mini-FTC Acts” as well as other applicable privacy and security laws.
−Removed: For example, the California Consumer Privacy Act, or the CCPA, and implementing regulations impose disclosure and notice obligations on institutions and provides a broad array of consumer rights relating to California residents and their personal information, including among others, the right to access personal information, the right to opt out of sales of personal information, and the right to delete personal information.
+Added: For example, the California Consumer Privacy Act, or the CCPA, as amended by the California Privacy Rights Act, or CPRA, and implementing regulations impose disclosure and notice obligations on institutions and provides a broad array of consumer rights relating to California residents and their personal information, including among others, the right to access personal information, the right to opt out of sales of personal information, the right to correct or delete personal information, and the right to limit certain disclosures of personal information.
The CCPA has the potential for significant civil penalties for failing to comply as well as a private right of action and statutory damages for data breaches that are the result of unreasonable security.
−Removed: The California Privacy Rights Act, or CPRA, expands the CCPA’s requirements and provides certain rights to consumers to correct personal information and limit its disclosure.
Other comprehensive state privacy laws that our institutions may be subject to with varying requirements also came into effect in 2023.
3 unchanged sentences
Section 504 of the Rehabilitation Act of 1973, or Section 504, prohibits discrimination against a person with a disability by any organization that receives federal financial assistance, which includes us.
−Removed: ED’s Office for Civil Rights, which enforces Section 504, together with the Department of Justice, has asserted that requiring the use of technology in a classroom environment when such technology is inaccessible to individuals with disabilities violates Section 504, unless those individuals are provided accommodations or modifications that permit them to receive all the educational benefits provided by the technology in an equally effective and integrated manner.
−Removed: In recent years, ED’s Office for Civil Rights has taken enforcement action against several institutions of higher education, including primarily online institutions, after determining that their websites and online learning management platforms were not accessible to persons with a disability.
−Removed: If one of our institutions is found to have violated Section 504, it may be required to modify existing content and functionality of its online classroom or other uses of technology, including through adoption of specific technical standards.
+Added: ED’s Office for Civil Rights, or OCR, which enforces Section 504, together with the Department of Justice, has asserted that requiring the use of technology in a classroom environment when such technology is inaccessible to individuals with disabilities violates Section 504, unless those individuals are provided accommodations or modifications that permit them to receive all the educational benefits provided by the technology in an equally effective and integrated manner.
+Added: In recent years, OCR has taken enforcement action against several institutions of higher education, including primarily online institutions, after determining that their websites and online learning management platforms were not accessible to persons with a disability.
+Added: In 2022, OCR initiated a compliance review of APUS’s learning management system and courses.
+Added: In August 2024, OCR identified we were out of compliance with certain accessibility requirements for people with disabilities for ten courses.
+Added: Currently, APUS is cooperating with OCR on a resolution to bring APUS into compliance.
+Added: At this time, we cannot predict when the compliance review will be completed, additional costs associated with compliance, whether there will be any further findings, or whether OCR will place any liability or other limitations on APUS as a result of the compliance review.
An institution that does not come into compliance with Section 504 could lose access to federal funding, including the ability to participate in the Title IV programs and TA.
+Added: See the Risk Factor captioned “Enforcement of laws related to the accessibility of technology continues to evolve, which could result in increased information technology development costs and compliance risks” for more information.
Title IX of the Education Amendments of 1972, or Title IX, prohibits discrimination on the basis of sex in education programs that receive funding from the federal government.
−Removed: ED regulations effective as of August 2020 define what constitutes sexual harassment for purposes of Title IX in the administrative enforcement context, describe what actions trigger an institution’s obligation to respond to incidents of alleged sexual harassment, and specify how an institution must respond to allegations of sexual harassment.
−Removed: In June 2022, ED released proposed regulations that would significantly revise how schools, including higher education institutions, must address cases involving sex-based discrimination, including cases of sexual harassment, sex-based harassment, and assault.
−Removed: The proposed regulations also would explicitly include protections against discrimination based on sexual orientation, gender identity, and sex characteristics.
−Removed: In addition, the proposed regulations would update protections against discrimination because of pregnancy, related conditions, or terminations of pregnancy.
+Added: ED regulations effective August 2020, or the 2020 Rule, define what constitutes sexual harassment for purposes of Title IX in the administrative enforcement context, describe what actions trigger an institution’s obligation to respond to incidents of alleged sexual harassment, and specify how an institution must respond to allegations of sexual harassment.
+Added: In April 2024, ED released new regulations that significantly revise how schools, including higher education institutions, must address cases involving sex-based discrimination, including cases of sexual harassment, sex-based harassment, and assault occurring on or after the August 1, 2024, effective date.
+Added: The new regulations also explicitly include protections against discrimination based on sexual orientation, gender identity, and sex characteristics.
+Added: In addition, the new regulations update protections against discrimination because of pregnancy, related conditions, or terminations of pregnancy.
+Added: Multiple states challenged the new regulations, and federal district courts granted preliminary injunctions in 26 states:
+Added: Alabama, Alaska, Arkansas, Florida, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Tennessee, Texas, Utah, Virginia, West Virginia, and Wyoming.
+Added: In some instances, courts expanded the injunction to named schools, regardless of where the schools are located;
+Added: APUS was named among nearly 700 such schools in a July 2024 list.
+Added: Dep’t of Educ.
+Added: 5:24-cv-4041 (D.
+Added: Except where enjoined, the new regulations otherwise became effective on August 1, 2024.
+Added: In January 2025, a federal district court granted summary judgment against ED, concluding that the new regulations were unlawful and permanently vacating the rule nationwide.
+Added: Cardona , No.
+Added: 2:24-cv-072 (E.D.
+Added: In February 2025, OCR issued a Dear Colleague Letter confirming both that it will enforce Title IX under the 2020
+Added: Rule and that institutions with open investigations initiated under the new regulations should reevaluate such investigations for consistency with the 2020 Rule.
Distance Education.
Regulations that were effective July 2021 provide institutions additional flexibility in offering distance education and competency-based education programs.
−Removed: Definitions in the rule clarify the instructional requirements that
−Removed: distance education programs must abide in order to remain eligible for Title IV disbursements.
+Added: Definitions in the rule clarify the instructional requirements that distance education programs must abide in order to remain eligible for Title IV disbursements.
Failure to comply with these standards could lead to adverse actions by ED.
+Added: In addition, in January 2025, ED published new regulations related to distance education and Return to Title IV, or R2T4, rules, which govern an institution’s obligations to return Title IV funds to ED when a student withdraws.
+Added: These changes related to distance education, when effective, will require institutions to report student enrollment in distance education in accordance with procedures established by ED, and changes related to R2T4 rules address circumstances constituting a withdrawal, codify longstanding policies, and modify certain types of R2T4 calculations.
+Added: The new regulations become effective July 1, 2026.
Department of Defense
3 unchanged sentences
Service members may use TA to pursue postsecondary degrees at institutions that are accredited by accrediting agencies recognized by ED.
−Removed: APUS participates in TA, and for students in APUS undergraduate, and beginning January 2020, for students in APUS master’s programs, APUS provided grants so that APUS tuition rates per credit hour can be 100% covered by TA provided that the student does not exceed their annual funding limits per student.
+Added: APUS participates in TA, and for students in APUS undergraduate, and beginning January 2020, for students in APUS master’s programs.
RU and HCN also participate in TA.
−Removed: RU’s active-duty military students in most undergraduate programs and master’s level graduate programs receive per credit tuition pricing at a tuition rate that is commensurate with available TA funding to allow tuition charges to be 100% covered by TA.
−Removed: HCN offers an alumni achievement grant of up to $1,200 to assist qualifying PN program alumni as they progress into the ADN program, as well as an institutional affordability grant to students demonstrating financial need to cover the difference between the total cost of tuition and fees less the amount of all eligible financial aid resources.
+Added: RU’s active-duty military students in most undergraduate programs and master’s level graduate programs receive per credit hour tuition pricing at a tuition rate that is commensurate with available TA funding to allow tuition charges to be 100% covered by TA.
In March 2013, DoD restricted the ability of service members who have not previously taken a postsecondary education course and who are in certain duty locations outside the continental United States, or overseas locations, to receive TA for courses offered by institutions of higher education that are not parties to contracts with the DoD to provide DoD voluntary education programs at those locations.
6 unchanged sentences
Pursuant to the DoD MOUs, among other requirements, institutions must:
−Removed: explain certain tools to service members, such as ED’s “College Navigator” website and the “Paying for College” website of the CFPB;
+Added: (i) explain certain tools to service members, such as ED’s “College Navigator” website and the “Paying for College” website of the CFPB;
comply with requirements related to readmission policies for service members;
−Removed: abide by limitations on the use of funds derived from TA;
+Added: (ii) abide by limitations on the use of funds derived from TA;
provide certain academic and student support services;
−Removed: disclose information about transfer of credit;
+Added: (iii) disclose information about transfer of credit;
in certain circumstances, return TA funds to DoD (such as when a student ceases to attend or an institution cancels a course);
−Removed: offer to service members loan counseling before private student loans are offered or recommended;
−Removed: and comply with ED’s Title IV “program integrity” rules, including rules related to incentive payments and misrepresentation.
+Added: (iv) offer to service members loan counseling before private student loans are offered or recommended;
+Added: and (v) comply with ED’s Title IV “program integrity” rules, including rules related to incentive payments and misrepresentation.
The DoD MOUs also provide that an institution may only participate in TA if it is accredited by an accrediting agency recognized by ED, approved for VA funding, and a participant in Title IV programs.
+Added: In February 2025, the DoD Voluntary Education Institutional Compliance Program, or ICP, notified APUS that it will conduct a review of APUS compliance with the DoD MOU.
Additional information regarding the potential risks associated with the DoD MOUs is provided in the “Risk Factors” section of this Annual Report.
Several federal government agencies have established an online student complaint system for service members, veterans, and their families to report negative experiences at education institutions and training programs administering the Post-9/11 GI Bill, TA, and other military-related education benefit programs.
−Removed: An institution having recurring substantive complaints, or demonstrating an unwillingness to resolve complaints, may face a range of penalties, including revocation of its MOU and removal from participation in TA.
+Added: An institution having recurring substantive
+Added: complaints, or demonstrating an unwillingness to resolve complaints, may face a range of penalties, including revocation of its MOU and removal from participation in TA.
Department of Defense Funding
A series of automatic federal budget cuts, known as sequestration, have impacted certain federal student aid programs since fiscal year 2013 and have been extended through fiscal year 2030.
−Removed: As a result of uncertainty about the availability of
−Removed: funding, several military branches initially suspended and later announced changes to their TA programs.
+Added: As a result of uncertainty about the availability of funding, several military branches initially suspended and later announced changes to their TA programs.
For example, the Army now requires service members to complete one year of service after graduation from Advanced Individual Training in order to be eligible for TA, and the Army and the Coast Guard have both reduced the total per service member annual benefits.
−Removed: Congressional inaction on budgetary matters has led to lapses in funding, resulting in government shutdowns, and subsequent policy changes that have affected federal student aid programs at DoD.
+Added: Congressional inaction on budgetary matters has led to lapses in federal funding, resulting in government shutdowns, and subsequent policy changes that have affected TA programs at DoD.
A future government shutdown, particularly one that includes DoD or suspension or resulting modification of TA programs, including in connection with the failure to increase or a delay in increasing the federal debt ceiling, could have a material adverse effect on APUS’s enrollments and on our cash flows, results of operations, and financial condition.
−Removed: Funding shortfalls have also affected DoD federal student aid programs.
+Added: Funding shortfalls have also affected DoD TA programs.
For example, as a result of the expected exhaustion of annual TA benefits available to sailors, in May 2019, the Navy ceased approving TA funds for eligible sailors until the start of the government’s fiscal year 2020.
1 unchanged sentence
In addition, eligible sailors can only use TA to fund two courses each quarter of the fiscal year, and reservists on one-year orders are ineligible for TA.
−Removed: In 2024, Congress approved an approximately 5.9% increase in the funds appropriated for DoD federal student aid programs;
−Removed: however, it is unclear whether the increased funding will encourage the military branches to expand service member eligibility for TA programs, or the amount of the service member annual benefit.
+Added: In 2024, Congress approved an approximately 5.9% increase in the funds appropriated for DoD federal off-duty and volunteer education aid programs across all military branches.
+Added: On December 11, 2024, the U.S.
+Added: Department of the Army announced increases to the annual cap on the dollar amount of tuition assistance benefits and to the hours cap for each semester.
+Added: It is unclear whether the increased funding will encourage other military branches to expand service member eligibility for TA programs, or the amount of the service member annual benefit.
We expect each military branch and the DoD to continually evaluate their approach to education funding, and the resulting changes could have an impact on the funds available to service members to pursue their education at our institutions.
1 unchanged sentence
The VA administers education benefits provided by federal law, including the Montgomery GI Bill, or GI Bill, and the Post-9/11 GI Bill.
−Removed: APUS, RU and HCN are approved to provide education to veterans and members of the selective reserve and their dependents in West Virginia for APUS, and by the state approving agencies in states where RU and HCN campuses are located.
+Added: APUS, RU, and HCN are approved to provide education to veterans and members of the selective reserve and their dependents by the state approving agencies where RU and HCN campuses are located for RU and HCN, and in West Virginia for APUS.
In order for an institution to participate in VA education benefits, it must be a participant in the Title IV programs.
9 unchanged sentences
Section 1018 of the Isakson Roe Act mandates that schools that receive veterans education benefits:
−Removed: (i) provide VA students with information on total cost of an education program, an estimate of debt the student will have upon graduation, graduation rates, requirements to obtain any license, certification, or approval for which the course of education is designed to provide preparation, and certain other information;
+Added: (i) provide VA students with information on total cost of an education program, an estimate of debt the student will have upon graduation, graduation rates, requirements to obtain any
+Added: license, certification, or approval for which the course of education is designed to provide preparation, and certain other information;
(ii) inform VA students of the availability and potential eligibility of federal financial aid before packaging or arranging private student loans or alternative financing programs;
16 unchanged sentences
The legislation also requires the VA to take disciplinary action if a person with whom an institution has an agreement to provide educational or recruiting services violates the VA’s incentive compensation prohibitions.
−Removed: On August 26, 2022, the President signed into law the Ensuring the Best Schools for Veterans Act of 2022, which modifies how the VA implements the rule generally forbidding use of VA benefits for students enrolling in a program in which more than 85% of students enrolled in the program have any portion of their tuition, fees, or other charges paid to or for them by the institution or by the VA, or the 85/15 Requirement.
+Added: On August 26, 2022, former President Biden signed into law the Ensuring the Best Schools for Veterans Act of 2022, which modifies how the VA implements the rule generally forbidding use of VA benefits for students enrolling in a program in which more than 85% of students enrolled in the program have any portion of their tuition, fees, or other charges paid to or for them by the institution or by the VA, or the 85/15 Requirement.
Among other things, the law clarifies that reporting associated with the 85/15 Requirement generally does not apply to institutions at which 35% or fewer students receive GI bill benefits, computed separately for the main campus and any branch or extension of the institution.
8 unchanged sentences
As a condition to an institution’s participation in the Title IV programs, the institution must adopt a code of conduct pertaining to student loans, including alternative loans.
−Removed: HCN offers its students an extended payment plan option.
+Added: HCN offers its students extended payment plan options.
The extended payment plan is designed to assist students with educational costs including tuition and fees.
The extended payment plan is subject to various federal and state laws and regulations, such as the Truth in Lending Act as implemented in Regulation Z, the Equal Credit Opportunity Act as implemented in Regulation B and the Unfair, Deceptive or Abusive Acts or Practices provisions of Title X of the Dodd-Frank Act.
−Removed: Beginning January 1, 2020, HCN began offering an institutional affordability grant to students demonstrating financial need to cover the difference between the total cost of tuition and fees less the amount of all eligible financial aid resources.
+Added: In addition, HCN offers an institutional affordability grant to students demonstrating financial need to cover the difference between the total cost of tuition and fees less the amount of all eligible financial aid resources.
The grant is designed to limit a student’s monthly payment to $200 through an award of up to $200 per month, or $600 per term after consideration of financial aid, employer tuition reimbursement, and other financial resources.
2 unchanged sentences
The CFPB has pursued enforcement actions against certain for-profit institutions of higher education and has released several reports that directly address issues related to institutions of higher education.
−Removed: In October 2023, the CFPB Education Loan Ombudsman released its annual report analyzed approximately 2,350 private student loan complaints (a decrease of approximately 21% compared to prior-year data) and approximately 6,934 federal student loan complaints (an increase of approximately 27% compared to prior-year data).
−Removed: The CFPB indicated that almost nine in ten complaints involved problems consumers had dealing with their loan servicer.
+Added: In November 2024, the CFPB Education Loan Ombudsman released its annual report which analyzed a sample set of 1,301 private student loan complaints (out of 4,107 received complaints) and 2,977 federal student loan complaints (out of 14,170 received complaints) received during the 2023-2024 award year.
+Added: The CFPB indicated that with respect to the private student loan complaints, almost one in three of the sample set were submitted by borrowers seeking loan cancellation;
+Added: and with respect to the federal student loan complaints, many complaints involved problems consumers had dealing with their loan servicer.
We do not know what enforcement actions the CFPB may pursue, or what steps Congress or federal agencies may take, in response to these reports and whether such actions, if any, will have an adverse effect on our business or results of operations.
6 unchanged sentences
The FTC also announced that it would be enhancing its enforcement cooperation with other agencies with oversight of educational institutions, including ED’s Office of Federal Student Aid and the VA.
−Removed: We do not know what enforcement actions the FTC may pursue in light of its recent informational notices and whether such actions, if any, will have an adverse effect on our business or results of operations.
+Added: We do not know what enforcement actions the FTC may pursue in light of its informational notices and whether such actions, if any, will have an adverse effect on our business or results of operations.
Other Issues Related to Consumer Protection and Complaints
4 unchanged sentences
However, even if such complaints are resolved or are otherwise unfounded, they may still harm the reputation of our institutions.
−Removed: On October 8, 2021, ED announced that it had restored an Office of Enforcement within ED’s Office of Federal Student Aid to strengthen oversight of and enforcement actions against postsecondary institutions that participate in federal student loan, grant, and work-study programs.
+Added: In October 2021, ED announced that it had restored an Office of Enforcement within ED’s Office of Federal Student Aid to strengthen oversight of and enforcement actions against postsecondary institutions that participate in federal student loan, grant, and work-study programs.
+Added: In September 2024, the Office of Enforcement issued a Federal Student Aid Enforcement Bulletin describing conduct that creates a risk of engaging in substantial misrepresentations, which may prompt administrative action by ED against an institution.
Compliance with Regulatory Standards and the Effect of Regulatory Violations
7 unchanged sentences
In September 2022, RU received a program review report from ED that asserted 14 findings of noncompliance with Title IV rules, including rules related to Title IV administration, policies, and consumer information and reporting requirements, and the federal work study, Pell Grant, and Federal Supplemental Educational Opportunity Grant programs.
−Removed: The program review required RU to do a review in connection with the federal work study finding, prepare policies
−Removed: and procedures, return small amounts of funds to two students, provide training, and take other actions in connection with the findings, and to provide a response, which RU timely provided.
+Added: The program review required RU to do a review in connection with the federal work study finding, prepare policies and procedures, return small amounts of funds to two students, provide training, and take other actions in connection with the findings, and to provide a response, which RU timely provided.
In July 2023, ED officially closed the program review by issuing a final program review determination and indicating that 12 of the findings were considered resolved with no liabilities.
1 unchanged sentence
ED determined that the total liability was minimal as it was under the $1,000 threshold so no recoupment was required;
−Removed: however, RU was responsible for, and has taken all steps necessary in ensuring that adequate corrective procedures had been implemented.
+Added: however, RU was responsible for, and has taken all steps necessary, to ensure that adequate corrective procedures had been implemented.
In July 2022, HCN received from ED the final program review determination from a review that had been pending since June 2017, and in September 2022 ED notified HCN that it had closed the program review, and no further action was required.
1 unchanged sentence
HCN was required to do a full file review in connection with the return of Title IV funds finding, to have the review tested by an independent auditor, and to prepare policies and procedures and take other actions in connection with the findings.
−Removed: The total liability for this finding was $11,714.10, consisting of $11,538.00 principal owed to ED and $176.10 for the cost of funds associated with the unreturned funds.
−Removed: In order to participate in TA, institutions must agree to participate in DoD’s Voluntary Education Institutional Compliance Program, or ICP.
+Added: The total liability for this finding was approximately $12,000.
+Added: In July 2023, ED began a program review of APUS’s administration of Title IV programs during the 2021-2022 and 2022-2023 award years, which includes, among other things, a review of compliance with the 90/10 Rule.
+Added: APUS has not yet received a program review report from ED.
+Added: Accordingly, at this time, we cannot predict the outcome of the APUS program review, when it will be completed, whether there will be any adverse findings in the resulting program review report, what findings there may be related to 90/10 Rule compliance, if any, or whether ED will place any liability or other limitations on APUS as a result of the review.
+Added: In order to participate in TA, institutions must agree to participate in DoD’s ICP.
An institution that, through the ICP, is found noncompliant with DoD requirements and demonstrates an unwillingness to resolve a finding may be subject to a range of penalties from a written warning to termination of the institution’s participation in TA.
2 unchanged sentences
Upon request, in May 2020, APUS submitted a self-assessment in connection with the ICP.
−Removed: On November 30, 2020, DoD issued a report finding that APUS did not clearly articulate certain policies or clearly make certain disclosures.
+Added: In November 2020, DoD issued a report finding that APUS did not clearly articulate certain policies or clearly make certain disclosures.
As required, APUS submitted its corrective action plan and related evidentiary support and in April 2021, APUS was informed that the review had been completed, and no further actions are required.
+Added: In February 2025, ICP notified APUS that it will conduct a review of APUS compliance with the DoD MOU.
Potential Effect of Regulatory Violations
13 unchanged sentences
Generally, these agencies require institutions to notify them, and sometimes require institutions to obtain their approval, in advance of opening a new location or implementing new programs.
−Removed: APUS is regulated by its institutional accreditor, the HLC, as well as a state agency in West Virginia.
−Removed: RU’s is regulated by its institutional accreditor, the HLC, as well as the six state agencies where RU physical campuses are located, which include Florida, Illinois, Kansas, Minnesota, North Dakota, and Wisconsin.
−Removed: HCN is regulated by ABHES, and the state agencies in Ohio, Indiana, and Michigan.
−Removed: GSUSA is regulated by the Accrediting Council for Continuing Education & Training, as well as a district agency in the District of Columbia.
+Added: APUS is regulated by its institutional accreditor HLC as well as a state agency in West Virginia.
+Added: RU is regulated by its institutional accreditor HLC as well as the state agencies in Florida, Illinois, Kansas, Minnesota, North Dakota, and Wisconsin.
+Added: HCN is regulated by its institutional accreditor ABHES as well as the state agencies in Ohio, Indiana, and Michigan.
+Added: GSUSA is regulated by its institutional accreditor ACCET as well as a district agency in the District of Columbia.
Change in Ownership Resulting in a Change of Control
6 unchanged sentences
RU also pursued post-closing notices and consents related to the change in ownership.
−Removed: State agencies, accreditors, boards of nursing, and other relevant regulators also required further action with respect to the Rasmussen Acquisition.
+Added: agencies, accreditors, boards of nursing, and other relevant regulators also required further action with respect to the Rasmussen Acquisition.
For example, HLC required an additional site visit within six months of the closing date of the Rasmussen Acquisition, and the visit occurred in February 2022.
21 unchanged sentences
The ownership interest threshold for publicly traded corporations remains at 25%, as described above.
−Removed: For entities that are not closely held or publicly traded corporations, including limited liability companies, limited liability partnerships, limited partnerships, and similar types of legal entities, the final regulations increase the ownership interest threshold from 25% to 50% for a change in ownership that results in a change in control automatically triggering ED’s approval process, and also provide that ED’s approval process may apply when a change in control occurs despite not meeting the 50 percent threshold.
+Added: For entities that are not closely held or publicly traded corporations, including limited liability companies, limited liability partnerships, limited partnerships, and similar types of legal entities, the final regulations increase the ownership interest threshold from 25% to 50% for a change in ownership that results in a change in control automatically triggering ED’s approval process, and also provide that ED’s approval process may apply when a change in control occurs despite not meeting the 50% threshold.
The final regulations also require institutions to notify ED and students of a planned change in ownership that results in a change in control at least 90 days in advance.
−Removed: In addition, the final regulations impose reporting obligations on institutions for changes in ownership that do not result in a change in control, lowering the threshold for reporting such changes from 25 percent to 5 percent ownership interest for all entity types.
+Added: In addition, the final regulations impose reporting obligations on institutions for changes in ownership that do not result in a change in control, lowering the threshold for reporting such changes from 25% to 5% ownership interest for all entity types.
The final regulations also:
−Removed: require additional financial protection (i.e., letters of credit) when a new owner is lacking financial statements or as ED determines necessary;
−Removed: and eliminate the existing requirement that ED continue an institution’s participation with the same terms and conditions in their Title IV agreement as prior to the transaction.
+Added: (i) require additional financial protection (i.e., letters of credit) when a new owner is lacking financial statements or as ED determines necessary;
+Added: and (ii) eliminate the existing requirement that ED continue an institution’s participation with the same terms and conditions in their Title IV agreement as prior to the transaction.
In addition, the final regulations define “main campus” and modify the definitions of “additional location” and “branch campus” to clarify that a location must be within the same “ownership structure” of the institution.
17 unchanged sentences
The new campus location must satisfy all other applicable requirements for institutional eligibility, including approval by the relevant state authorizing agency and the institution’s accrediting agency.
−Removed: Provisionally certified institutions of higher education such as APUS and RU, and institutions on HCM1 like RU, must seek prior approval from ED to offer new academic programs eligible for Title IV program funds and to open new locations at which Title IV program funds will be disbursed.
+Added: Provisionally certified institutions of higher education such as APUS and RU, and institutions on HCM1 like APUS, RU and HCN, must seek prior approval from ED to offer new academic programs eligible for Title IV program funds and to open new locations at which Title IV program funds will be disbursed.
A fully certified degree-granting institution generally is not obligated to obtain ED’s prior approval for a new location, an additional program leading to a degree at the same level previously approved by ED, or a new program that both prepares students for gainful employment in the same or related recognized occupation as an education program that has previously been designated as an eligible program at that institution and meets certain minimum-length requirements.
5 unchanged sentences
In addition, we may be subject to audits and investigations relating to these contracts, and any violations could result in civil and criminal penalties and administrative sanctions, including termination of contract, refund or suspension of payments, forfeiture of profits, payment of fines, and suspension or debarment from future government business.
−Removed: Our GSA Schedule contract is set to expire on March 4, 2024, and GSUSA is preparing its application for a new GSA Schedule contract.
−Removed: If a new contract is not entered into, GSUSA’s government business would be materially adversely impacted.
+Added: GSUSA’s GSA Schedule contract was renewed on March 4, 2024, and expires on March 1, 2044.
+Added: Failure to maintain a GSA Schedule contract would materially adversely impact GSUSA’s business.
Information about risks associated with GSUSA’s contracts being governed by the FAR is provided in the “Risk Factors” section of this Annual Report.
2 unchanged sentences
Due to the substantial amount of federal funds disbursed to schools through Title IV programs, TA and education benefits administered by the VA, the large number of students and institutions participating in these programs, and significant political interest in the cost of education, Congress continues to show interest in regulation and oversight of institutions of higher education, especially those that are for-profit.
−Removed: In addition, ED announced its intent to hold negotiated rulemaking sessions in 2024 to address other topics for which proposed or final regulations have not yet been issued, including the recognition of accrediting agencies, institutional eligibility, return of Title IV funds, cash management, and third-party servicers.
+Added: In addition, ED withdrew or terminated pending rulemakings pertinent to postsecondary education shortly before the change in the Presidential administration.
+Added: It is unclear what ED’s rulemaking priorities will be under the new administration, or if the administration will curtail ED’s operations, budget and rulemaking authority.
+Added: For more information, see the Risk Factor captioned “The postsecondary education regulatory environment has changed and may change in the future as a result of U.S.
+Added: federal elections”.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.