10 unchanged sentences
to add a branch campus in Temecula, California in order to accommodate 250 to 400 additional students.
−Removed: HDMC offers ultrasound tech (“UT”),
−Removed: vocational nursing (“VN”), VN Associate of Applied Science degree program, Associate Degree of Nursing, nursing assistant,
−Removed: MRI Associate of Applied Science, cardiac sonography, pharmacy technician, dental assisting, clinical medical assisting, medical administrative
−Removed: assisting programs, medical billing and coding, veterinary assistant, phlebotomy technician avocational, nursing assistant avocational,
−Removed: UT Associate of Applied Science degree programs, and an EMT program.
−Removed: HDMC also has obtained approval from the Accrediting Council for
−Removed: Continuing Education and Training (“ACCET”) to offer a surgical technology Associate of Applied Science program and sterile
−Removed: processing technician program and plans to begin doing so in October 2025, pending receipt of approval from the Bureau for Private Postsecondary
−Removed: Education (“BPPE”) and ED.
−Removed: As of June 30, 2025, HDMC had 1,956 students
−Removed: enrolled in its programs.
+Added: HDMC offers Ultrasound Technician
+Added: (“UT”), vocational nursing (“VN”), VN Associate of Applied Science degree program, Associate Degree of Nursing,
+Added: Nursing Assistant, MRI Associate of Applied Science, Cardiac Sonography, Pharmacy Technician, Dental Assisting, Clinical Medical Assisting,
+Added: Medical Administrative Assisting, Medical Billing and Coding, Veterinary Assistant, Phlebotomy Technician avocational, UT Associate of
+Added: Applied Science degree programs, EMT, Surgical Technology Associate of Applied Science, and Sterile Processing Technician programs.
+Added: of June 30, 2026, HDMC had 2,097 students enrolled in its programs.
Coast College (“CCC”)
−Removed: was established in the State of California in 1983.
−Removed: In 1991, CCC moved to its current location in Salinas, California to accommodate
−Removed: growing enrollment numbers and the addition of new training programs.
−Removed: offers the following certificate or degree programs:
−Removed: business administrative specialist, computer specialist:
−Removed: accounting, medical
−Removed: administrative assistant, medical assisting, nursing assistant, UT, UT Associate of Applied Science, veterinary assistant,
−Removed: veterinary assistant, veterinary technology, Associate of Applied Science, VN, surgical technology (Associate of Applied Science),
−Removed: dental assisting, sterile processing technician, and pharmacy technician.
−Removed: CCC also offers an
−Removed: avocational phlebotomy technician program.
−Removed: CCC also has obtained approval from ACCET to offer an MRI Associate of Applied Science
−Removed: Program and cardiac sonography Associate of Applied Science programs and plans to begin doing so in October 2025, pending receipt of
−Removed: additional approvals.
+Added: CCC was established in the State of California in
+Added: In 1991, CCC moved to its current location in Salinas, California to accommodate growing enrollment numbers and the addition of
+Added: new training programs.
+Added: In September 2026, CCC entered into a lease for a new, additional location in Houston, Texas, which CCC currently projects to open in November 2026, subject to receipt of the required regulatory and accreditation approvals.
+Added: CCC offers the following certificate or degree programs:
+Added: Computer Specialist:
+Added: Accounting, Medical Administrative Assistant, Medical Assisting, Nursing Assistant, UT, UT Associate of Applied Science,
+Added: Veterinary Assistant, Veterinary Technology Associate of Applied Science, VN, Surgical Technology (Associate of Applied Science), Dental
+Added: Assisting, Sterile Processing Technician, Pharmacy Technician, MRI Associate of Applied Science, and Cardiac Sonography Associate of Applied
+Added: CCC also offers an avocational Phlebotomy Technician program.
As of June 30, 2026, CCC had 576 students enrolled in its programs.
2 unchanged sentences
Integrity’s campus is located in Pasadena, California.
−Removed: Integrity offers VN,
−Removed: VN Associate of Applied Science, Registered Nurse to Bachelor of Science in Nursing (“RN to BSN”), medical assisting, medical
−Removed: billing and coding, veterinary assistant, and Diagnostic Medical Sonography programs.
−Removed: Integrity earned initial accreditation from
−Removed: the National League for Nursing Commission for Nursing Education Accreditation (NLN CNEA) for its Bachelor of Science in Nursing RN-
−Removed: BSN Track in June 2025.
−Removed: Integrity also plans to offer an emergency medical technician (“EMT”) program beginning in early
−Removed: 2026 and is in the process of obtaining approvals for the program (for which Integrity is not planning to seek ED approval because it
−Removed: does not intend to make Title IV funds available for students who enroll in the program).
−Removed: For purposes of our financial statements, Legacy
−Removed: Education, L.L.C.
+Added: Integrity offers
+Added: VN, Registered Nurse to Bachelor of Science in Nursing (“RN to BSN”), Medical Assisting, Medical Billing and Coding,
+Added: Veterinary Assistant, Sterile Processing Technician, and Diagnostic Medical Sonography programs.
+Added: Integrity earned initial
+Added: accreditation from the National League for Nursing Commission for Nursing Education Accreditation (NLN CNEA) for its Bachelor of
+Added: Science in Nursing RN to BSN Track in June 2025.
+Added: Integrity also plans to offer an Emergency Medical Technician (“EMT”)
+Added: program (for which Integrity is not planning to seek ED approval because it does not intend to make Title IV funds available for
+Added: students who enroll in the program).
+Added: Integrity has filed its application for the program with the California Bureau for Private
+Added: Postsecondary Education, is awaiting final approval and expects to begin offering the program in late 2026.
+Added: For purposes of our
+Added: financial statements, Legacy Education, L.L.C.
is deemed to have acquired Integrity in December 2019.
−Removed: As of June 30, 2025, Integrity had 202 students enrolled in
−Removed: its programs.
+Added: As of June 30, 2026, Integrity
+Added: had 196 students enrolled in its programs.
Costa Medical Career College (“CCMCC”)
−Removed: offers the following certificate and degree programs:
−Removed: surgical technology (Associate of Applied Science), sterile processing technician,
−Removed: pharmacy technician, diagnostic medical sonography, medical assisting with phlebotomy, dental assisting, vocational nursing, clinical
−Removed: medical assisting, EKG/ECG technician, medical administrative assistant/billing and coding specialist and medical assisting and phlebotomy
−Removed: As of June 30, 2025, CCMCC had 448 students enrolled in its programs.
−Removed: In 2003, HDMC began offering
−Removed: classes in Lancaster, CA (main campus).
−Removed: In 2008, HDMC began offering
−Removed: classes in Bakersfield, CA (branch campus).
−Removed: In October 2009, our current
−Removed: Chief Executive Officer, LeeAnn Rohmann founded our Company.
−Removed: In July 2010, we acquired
−Removed: the assets of HDMC.
−Removed: From 2011 to 2013, HDMC
−Removed: received VA approval, Workers Investment Act approval and Department of Rehabilitation approval for its programs.
−Removed: In April 2013, HDMC received
−Removed: ACCET accreditation.
−Removed: In December 2013, HDMC
−Removed: received Board of Professional Nursing and Psychiatric Technicians (“BVNPT”)
−Removed: accreditation of new licensed vocational nurses curriculum on a provisional basis, which provision was removed in 2017.
−Removed: In March 2014, HDMC became
−Removed: eligible to participate in the Title IV Programs and, in April 2014, received its first disbursements under the Title IV Programs.
−Removed: From 2015 to 2017, HDMC
−Removed: added pharmacy technician and dental assisting programs, went through re-accreditation with ACCET, received approval to participate
−Removed: in Cal Grant programs, and was removed from provisional status by BVNPT.
−Removed: In January 2018, the UT
−Removed: Associate of Applied Science (“AAS”) degree program was approved by BPPE and ACCET to offer through interactive distance learning.
−Removed: In July 2018, HDMC received
−Removed: branch approval for the Temecula, CA campus.
−Removed: In July 2018, HDMC introduced
−Removed: medical billing and coding programs and online UT AAS program.
−Removed: In December 2018, we entered
−Removed: into the management services agreement with Integrity.
−Removed: In December 2018, ED conducted
−Removed: and completed a program review at HDMC to confirm compliance with Title IV regulations, noting only minor findings.
−Removed: In January 2019, we acquired
−Removed: In January 2019, HDMC received
−Removed: approval for licensed vocational nurse students (20 students) for Bakersfield, CA.
−Removed: In February 2019, the UT
−Removed: AAS degree program was approved by ED.
−Removed: In February 2019, HDMC
−Removed: opened its campus in Temecula, CA.
−Removed: In December 2019, we acquired
−Removed: a 24.5% ownership interest in Integrity.
−Removed: In September 2020, we acquired
−Removed: the remaining 75.5% interest in Integrity.
−Removed: In 2021 and 2022, we received
−Removed: hybrid approval for all programs, launched new accredited programs of Cardiac Sonography AAS, Vocational Nursing AAS, and Ultrasound
−Removed: AAS in CCC, and obtained the Vocational Nursing program in HDMC Temecula.
−Removed: In 2023, we launched new
−Removed: accredited programs of Certified Nurse Assistant program at HDMC, Magnetic Resonance Imaging AAS (HDMC), Veterinary Assisting (ICH),
−Removed: Vocational Nursing (CCC), RN approval (HDMC).
−Removed: In January 2024, we started
−Removed: our first Associates Degree of Nursing program (HDMC).
+Added: CCMCC was established in the State of California
+Added: CCMCC’s campus is located in Antioch, California.
+Added: CCMCC offers the following certificate and degree programs:
+Added: Surgical Technology (Associate of Applied Science), Sterile Processing Technician, Pharmacy Technician, Diagnostic Medical
+Added: Sonography, Medical Assisting with Phlebotomy, Dental Assisting, Clinical Medical Assisting, EKG/ECG Technician, Medical
+Added: Administrative Assistant/Billing and Coding Specialist, and Phlebotomy (avocational) programs.
+Added: CCMCC also has obtained approval from
+Added: ACCET and BPPE to offer programs in Cardiac Sonography Associate of Applied Science, Veterinary Assistant, and MRI Associate of
+Added: Applied Science, and plans to begin offering the programs in the second quarter of fiscal 2027.
+Added: As of June 30, 2026, CCMCC had 508
+Added: students enrolled in its programs.
+Added: 2003, HDMC began offering classes in Lancaster, CA (main campus).
+Added: 2008, HDMC began offering classes in Bakersfield, CA (branch campus).
+Added: October 2009, our current Chief Executive Officer, LeeAnn Rohmann founded our Company.
+Added: July 2010, we acquired the assets of HDMC.
+Added: 2011 to 2013, HDMC received VA approval, Workforce Investment Act approval and Department of Rehabilitation approval for its programs.
+Added: April 2013, HDMC received ACCET accreditation.
+Added: December 2013, HDMC received Board of Vocational Nursing and Psychiatric Technicians (“BVNPT”) accreditation of new
+Added: licensed vocational nurses curriculum on a provisional basis, which provision was removed in 2017.
+Added: March 2014, HDMC became eligible to participate in the Title IV Programs and, in April 2014, received its first disbursements under
+Added: the Title IV Programs.
+Added: 2015 to 2017, HDMC added pharmacy technician and dental assisting programs, went through re-accreditation with ACCET, received approval
+Added: to participate in Cal Grant programs, and was removed from provisional status by BVNPT.
+Added: January 2018, the UT Associate of Applied Science (“AAS”) degree program was approved by BPPE and ACCET to offer through
+Added: interactive distance learning.
+Added: July 2018, HDMC received branch approval for the Temecula, CA campus.
+Added: July 2018, HDMC introduced medical billing and coding programs and online UT AAS program.
+Added: December 2018, we entered into the management services agreement with Integrity.
+Added: December 2018, ED conducted and completed a program review at HDMC to confirm compliance with Title IV regulations, noting only minor
+Added: January 2019, we acquired CCC.
+Added: January 2019, HDMC received approval for licensed vocational nurse students (20 students) for Bakersfield, CA.
+Added: February 2019, the UT AAS degree program was approved by ED.
+Added: February 2019, HDMC opened its campus in Temecula, CA.
+Added: December 2019, we acquired a 24.5% ownership interest in Integrity.
+Added: September 2020, we acquired the remaining 75.5% interest in Integrity.
+Added: 2021 and 2022, we received hybrid approval for all programs, launched new accredited programs of Cardiac Sonography AAS, Vocational
+Added: Nursing AAS, and Ultrasound AAS in CCC, and obtained the Vocational Nursing program in HDMC Temecula.
+Added: 2023, we launched new accredited programs of Certified Nurse Assistant program at HDMC, Magnetic Resonance Imaging AAS (HDMC), Veterinary
+Added: Assisting (ICH), Vocational Nursing (CCC), RN approval (HDMC).
+Added: January 2024, we started our first Associate Degree of Nursing program (HDMC).
April 2024, HDMC was re-accredited by ACCET through April 2029 for all programs.
−Removed: In December 2024 we acquired the assets of Contra Costa Medical Career College
+Added: December 2024, we acquired the assets of Contra Costa Medical Career College
April 2025, CCC was re-accredited by ACCET through April 2030 for all programs.
−Removed: June 2025 Integrity earned initial accreditation from the National League for Nursing Commission
−Removed: for Nursing Education Accreditation (NLN CNEA) for its Bachelor of Science in Nursing RN-
−Removed: BSN Track through February 2031.
+Added: June 2025, Integrity earned initial accreditation from the National League for Nursing Commission for Nursing Education Accreditation
+Added: (NLN CNEA) for its Bachelor of Science in Nursing RN- BSN Track through February 2031.
+Added: February 2026, Integrity was re-accredited by ABHES through February 2032 for all programs.
+Added: April 2026, CCMCC was re-accredited by ACCET through April 2031.
the United States, the post-secondary education market is large, fragmented, and competitive.
−Removed: According to National Center for Educational
−Removed: Statistics, as of the 2022-23 school year, degree granting career colleges served approximately 1.7 million undergraduate students, which was approximately 8.0% of the estimated 21.5 million total undergraduates in degree
−Removed: Further, the COVID-19 pandemic significantly reduced the
−Removed: number of students enrolled in post-secondary education institutions in recent years.
−Removed: According to estimates released by the National
−Removed: Student Clearinghouse Research Center, total enrollments in all higher education sectors increased 2.4% and 3.2% in the spring of 2024 and 2025, respectively.
−Removed: Enrollment at proprietary colleges increased 5.1% and 3.7% in the spring of 2024 and 2025, respectively.
−Removed: The industry is heavily dependent
−Removed: on continued availability of federal student financial assistance under Title IV of the Higher Education Act (“Title IV Programs”),
−Removed: and concerns about potential reductions in such funding also could negatively affect demand for higher education.
+Added: According to the National Center for
+Added: Education Statistics, as of the 2022-23 school year, degree granting career colleges served approximately 1.7 million
+Added: undergraduate students, which was approximately 8.0% of the estimated 21.5 million total undergraduates in degree programs.
+Added: According to estimates released by the National Student Clearinghouse Research Center, total enrollments in all higher education
+Added: sectors increased 2.4% and 3.2% in the spring of 2024 and 2025, respectively.
+Added: Enrollment at proprietary colleges increased 5.1% and
+Added: 3.7% in the spring of 2024 and 2025, respectively.
+Added: The industry is heavily dependent on continued availability of federal student
+Added: financial assistance under Title IV of the Higher Education Act (“Title IV Programs”), and concerns about potential
+Added: reductions in such funding also could negatively affect demand for higher education.
Notwithstanding
−Removed: weaker demand dynamics in past years, including the more recent adverse impact from the COVID-19 pandemic, we believe that over
−Removed: time, demand for post-secondary education in the United States will continue to increase as a result of demographic, economic, and
−Removed: social trends.
−Removed: The 2022 U.S.
−Removed: Census Bureau reported that approximately 64.0 million adults over the age of 25 in the United States
−Removed: did not have more than a high school education, and approximately 32.2 million adults over the age of 25 had some college experience
−Removed: but had not completed a college degree.
+Added: periods of weaker demand in past years, we believe that demographic, economic, and social trends may support growth
+Added: over time in demand for career-focused postsecondary education in the United States.
+Added: According to the U.S.
+Added: Census Bureau, in 2024, approximately
+Added: 64.0 million adults age 25 and older in the civilian noninstitutionalized population had a high school diploma or equivalent as their
+Added: highest level of educational attainment, and approximately 32.2 million had some college experience but no college degree.
Other trends that could positively impact demand for our programs include:
−Removed: increasing demand by employers
−Removed: for certain types of professional and skilled workers;
−Removed: growth in the number of
−Removed: high school graduates from 2.8 million in 1999-2000 to an estimated 3.8 million in 2022-2023, according to the National Center for
−Removed: Education Statistics;
−Removed: the significant and measurable
−Removed: income premium and enhanced employment prospects attributable to post-secondary education;
−Removed: a number of initiatives
−Removed: underway to reduce the cost of a post-secondary education;
−Removed: a continued demand from
−Removed: working adults for programs offered by accredited institutions.
+Added: demand by employers for certain types of professional and skilled workers;
+Added: in the number of high school graduates from 2.8 million in 1999-2000 to an estimated 3.8 million in 2022-2023, according to the National
+Added: Center for Education Statistics;
+Added: significant and measurable income premium and enhanced employment prospects attributable to post-secondary education;
+Added: number of initiatives underway to reduce the cost of a post-secondary education;
+Added: continued demand from working adults for programs offered by accredited institutions.
Market Opportunity
10 unchanged sentences
an aging population who will depend on the skills our students are able to provide as healthcare workers.
−Removed: target demographic is early to mid-20-year-old with a desire to better their economic situation by choosing a program with strong job
+Added: target demographic is early- to mid-20-year-olds with a desire to better their economic situation by choosing a program with strong job
opportunities, primarily within a 100-mile radius of each campus for most programs for ease of drive and availability.
3 unchanged sentences
and advice, more so than your traditional college students.
−Removed: According to the Bureau of Labor Statistics, employment in the healthcare and social assistance industry is projected to grow 8.4% from
−Removed: 2024 to 2034 resulting in over 1.9 million new jobs.
−Removed: This growth rate is much stronger than other industries, largely due to the aging
−Removed: population and the growing prevalence of chronic conditions.
+Added: to the Bureau of Labor Statistics, employment in the healthcare and social assistance industry is projected to grow 8.4% from 2024 to
+Added: 2034 resulting in over 1.9 million new jobs.
+Added: This growth rate is much stronger than other industries, largely due to the aging population
+Added: and the growing prevalence of chronic conditions.
Growth Strategies
growth strategy goals consist of the following:
−Removed: Plan for moderate growth
−Removed: in existing programs.
−Removed: Approval of registered
−Removed: nursing programs in Bakersfield and Salinas, California.
−Removed: Add Associate of Applied
−Removed: Sciences degrees to our shorter programs.
−Removed: Add registered dental assisting
−Removed: to our dental assistant program.
−Removed: New programs in dental
−Removed: hygiene and surgical technician.
−Removed: Continued launch of new
−Removed: program offerings, including online offerings.
−Removed: Launch new branch campuses,
−Removed: including in California and beyond.
−Removed: Acquire new institutions
−Removed: (new locations, new programs) outside of California, including in Nevada, Colorado and New Mexico and programs in business, automotive
−Removed: and trade to increase national footprint.
−Removed: Meet benchmark standards
−Removed: for completion and placement.
+Added: for moderate growth in existing programs.
+Added: of registered nursing programs in Bakersfield and Salinas, California.
+Added: programs in dental hygiene
+Added: launch of new program offerings, including online offerings.
+Added: new branch campuses in California and beyond, including CCC’s planned campus in Houston, Texas.
+Added: new institutions (new locations, new programs) outside of California, including in Texas, Nevada, Colorado and New Mexico and
+Added: programs in trades to increase national footprint.
+Added: benchmark standards for completion and placement.
business strategy is based on helping our graduates succeed, which we believe will drive our financial results.
1 unchanged sentence
the following operating strategies:
−Removed: Focusing on student and
−Removed: graduate success, including improving retention rates while maintaining high standards of academic quality and rigor;
−Removed: Maintaining and improving
−Removed: upon our ability to offer affordable degrees, where graduates receive a high return on their investment;
−Removed: Expanding and optimizing
−Removed: our relationship-based marketing efforts and increasingly personalizing the prospective student experience;
−Removed: Further strengthening and
−Removed: expanding our product offering and the alignment of our offering with employer needs.
+Added: on student and graduate success, including improving retention rates while maintaining high standards of academic quality and rigor;
+Added: and improving upon our ability to offer affordable degrees, where graduates receive a high return on their investment;
+Added: and optimizing our relationship-based marketing efforts and increasingly personalizing the prospective student experience;
+Added: strengthening and expanding our product offering and the alignment of our offering with employer needs.
are focused on the following operational priorities to deliver these strategies:
8 unchanged sentences
the development of our curricula, the recruitment of our faculty and staff, and the design of our support services.
−Removed: We look for opportunities to improve our student’s educational experience and increase the likelihood of students
+Added: We look for opportunities to improve our students’ educational experience and increase the likelihood of students
successfully completing their programs.
17 unchanged sentences
We also seek to drive growth through a multifaceted strategy of enhancing existing program offerings, developing
−Removed: new and innovative programs, and branching and acquisitions.
+Added: new and innovative programs, branching and acquisitions.
for-profit, post-secondary education industry is highly competitive and highly fragmented with no single participant controlling a significant
15 unchanged sentences
obtain a degree, the quality and size of our alumni base, and our relationship with other learning institutions.
−Removed: of our local competitors include San Joaquin Valley College, Career Care Institute, UEI College, Bakersfield
−Removed: College and the Pima Medical Institute.
+Added: of our local competitors include San Joaquin Valley College, Career Care Institute, UEI College, Bakersfield College, American Career College, and the Pima Medical
Such competitors may have greater financial resources and greater brand recognition than us.
−Removed: For example, public institutions receive government subsidies and other financial sources not available to for-profit schools.
+Added: In addition, public institutions
+Added: receive government subsidies and other financial sources not available to for-profit schools.
and Recruiting
20 unchanged sentences
We continue to build strong relationships with high school guidance counselors and instructors
−Removed: by offering annual seminars at our training facilities to further familiarize these individuals on the strengths of our programs.
−Removed: recruiting efforts are conducted by a group of approximately 20 campus-based and field representatives who meet directly with
−Removed: prospective students during presentations conducted at high schools, or during a visit to one of our campuses.
−Removed: enrolling in our programs must have a high school diploma or a General Educational Development Certificate and demonstrate
+Added: by offering annual seminars at our training facilities to further familiarize these individuals with the strengths of our programs.
+Added: Our recruiting efforts are conducted by a group of approximately 20 campus-based and field representatives who meet directly
+Added: with prospective students during presentations conducted at high schools, or during a visit to one of our campuses.
+Added: Students enrolling in our programs must have a high school diploma or a General Educational Development Certificate and demonstrate
competence in writing and logical reasoning.
−Removed: For programs leading to a degree students must also complete an application and pass
−Removed: one or more entrance assessments, including the Wonderlic Scholastic Level Exam (“SLE”) or HESI for the Vocational Nursing programs.
−Removed: While each of our programs has different admissions criteria, we screen all applications and counsel the students
−Removed: on the most appropriate program to increase the likelihood that our students complete the requisite coursework and obtain and
−Removed: sustain employment following graduation.
−Removed: As of June 30, 2025, our diverse population was comprised of 61% Hispanic, 13% Black/African American, 12% White, 5% Asian, 1% Native Hawaiian or Other Pacific
−Removed: Islander, and 1% American Indian or Alaksa Native.
−Removed: The age distribution shows 49% of our students are 25 and older, while 51% are 24 or
−Removed: younger, with a significant majority of 88% being Women and 12% being Men.
+Added: For programs leading to a degree students must also complete an application and pass one
+Added: or more entrance assessments, including the Wonderlic Scholastic Level Exam (“SLE”) or TEAS for the Vocational Nursing programs.
+Added: While each of our programs has different admissions criteria, we screen all applications and counsel the students on the most appropriate
+Added: program to increase the likelihood that our students complete the requisite coursework and obtain and sustain employment following graduation.
+Added: As of June 30, 2026, our diverse population was comprised of 60% Hispanic, 11% Black/African American, 14% White, 6% Asian, 5% Two or
+Added: More Races, 1% Native Hawaiian or Other Pacific Islander, and 1% American Indian or Alaska Native, with 2% Race and Ethnicity unspecified.
+Added: The age distribution shows 48% of our students are 25 and older, while 52% are 24 or younger, with a significant majority of 86% being
+Added: women and 13% being men and 1% Gender unspecified.
We enroll students continuously throughout the year, with our largest classes enrolling in late summer or early fall following
17 unchanged sentences
difficulty academically, we offer tutoring, remediation and assistance and guidance from the program director.
−Removed: With an average program
−Removed: retention rate of 86%, our focus on student success and support throughout their educational journey is evident.
−Removed: core mission is to prepare students for competitive careers in their chosen fields.
+Added: With an average monthly
+Added: program retention rate of 98.1%, our focus on student success and support throughout their educational journey is evident.
+Added: Our core mission is to prepare students for competitive careers in their chosen fields.
As of June 30, 2026, we boast an average
−Removed: placement rate of 74.5%, with individual rates of 74.9% for High Desert Medical College, 74.1% for Central Coast College, and 74.6%
−Removed: for Integrity College of Health.
−Removed: CCMCC has achieved an average placement rate of 73.8%.
−Removed: Additionally, our students
−Removed: have achieved an 81.8% NCLEX Pass Rate and a 50.0% Veterinary Technician National Exam Pass Rate, demonstrating the effectiveness of
−Removed: our programs.
+Added: placement rate of 72.7%, with individual rates of 73.2% for High Desert Medical College, 72.0% for Central Coast College, 73.4% for Contra
+Added: Costa Medical Career College and 67.5% for Integrity College of Health.
+Added: Additionally, our students have achieved an 82.4% NCLEX Pass
+Added: Rate and a 60.0% Veterinary Technician National Exam Pass Rate, demonstrating the effectiveness of our programs.
and Employees
1 unchanged sentence
significant and appropriate academic credentials.
−Removed: We hire our faculty in accordance with established criteria set by the California Code
−Removed: of Regulations and accreditation standards, including relevant work experience and educational background.
−Removed: We require meaningful industry
−Removed: experience of our teaching staff in order to maintain the quality of instruction in all of our programs and to address current and industry-specific
+Added: We hire our faculty in accordance with established criteria set by relevant state law
+Added: and accreditation standards, including relevant work experience and educational background.
+Added: We require meaningful industry experience
+Added: of our teaching staff in order to maintain the quality of instruction in all of our programs and to address current and industry-specific
issues in our course content.
1 unchanged sentence
instructional development seminars, annual reviews, technical upgrade training, faculty development plans and weekly staff meetings.
−Removed: also employ non-faculty staff in student services, academic advising and academic support, enrollment services, administration,
−Removed: financial aid, information technology, human resources, finance and other administrative functions.
−Removed: The staff of each campus
−Removed: typically includes a campus director, a director of education, a registrar, a career services coordinator, a financial-aid officer, a business officer
−Removed: and a career advisor and instructors, all of whom are industry professionals with experience in our areas of study.
−Removed: of June 30, 2025, we had approximately 103 full-time faculty, including program directors, as well as approximately 147 part-time faculty.
+Added: also employ non-faculty staff in student services, academic advising and academic support, enrollment services, administration, financial
+Added: aid, information technology, human resources, finance and other administrative functions.
+Added: The staff of each campus typically includes
+Added: a campus director, a director of education, a registrar, a career services coordinator, a financial-aid officer, a business officer and
+Added: a career advisor and instructors, all of whom are industry professionals with experience in our areas of study.
+Added: of June 30, 2026, we had approximately 120 full-time faculty, including 16 program directors, as well as approximately 180 part-time
of June 30, 2026, we and our institution also employed approximately 185 combined non-faculty staff in the areas of university services,
14 unchanged sentences
or relocation of existing locations and changes in corporate structure and ownership.
−Removed: of our institutions (HDMC, CCC, Integrity and CCMCC) participate in the Title IV Programs, as well as other federal and state financial
−Removed: aid programs and are subject to extensive regulation by ED, other federal and state educational agencies and accreditors.
+Added: of our institutions (HDMC, CCC, Integrity and CCMCC) participates in the Title IV Programs, as well as other federal and state financial
+Added: aid programs and is subject to extensive regulation by ED, other federal and state educational agencies and accreditors.
and CCMCC are approved to offer, and must comply with applicable requirements related to, veterans education assistance administered
32 unchanged sentences
HDMC with locations in Lancaster,
−Removed: Bakersfield, and Temecula, CCC with a location in Salinas, Integrity with a location in Pasadena, and CCMCC with a location in Antioch.
−Removed: Generally, the recertification process includes a review by ED of an institution’s educational programs and locations, administrative
−Removed: capability, financial responsibility and other oversight categories.
−Removed: The current expiration date of the program participation agreements
−Removed: for HDMC and CCC is September 30, 2026.
−Removed: Integrity and CCMCC are currently participating in the Title IV Programs under a temporary provisional
−Removed: program participation agreement in connection with their change in ownership and control resulting from our acquisition of the institutions.
−Removed: The CCMCC temporary provisional program participation agreement had an expiration date of January 31, 2025 and the Integrity temporary
−Removed: provisional program participation agreement had an expiration date of November 30, 2020, but each temporary provisional program participation
−Removed: agreement continues on a month-to-month basis thereafter based on the institution’s submission to ED of certain required documentation
−Removed: and remains in effect until the conclusion of ED’s review of Integrity’s and CCMCC’s pending applications for approval
−Removed: of their change in ownership and control.
+Added: Bakersfield, and Temecula, CCC with a location in Salinas and a planned new location in Houston, Texas, Integrity with a location in
+Added: Pasadena, and CCMCC with a location in Antioch.
+Added: Generally, the recertification process includes a review by ED of an institution’s
+Added: educational programs and locations, administrative capability, financial responsibility and other oversight categories.
+Added: The current expiration
+Added: date of the program participation agreements for HDMC and CCC is September 30, 2026, and these institutions have timely applied for recertification
+Added: by ED and remain eligible to participate in the Title IV Programs during ED’s review of the recertification applications.
+Added: The current expiration date of the program participation agreement for Integrity is March 31, 2029.
+Added: CCMCC is currently participating
+Added: in the Title IV Programs under a temporary provisional program participation agreement in connection with the change in ownership and
+Added: control resulting from our acquisition of the institutions.
+Added: The CCMCC temporary provisional program participation agreement had an expiration
+Added: date of January 31, 2025, but it continues on a month-to-month basis thereafter based on the institution’s submission to ED of
+Added: certain required documentation and remains in effect until the conclusion of ED’s review of CCMCC’s pending application for
+Added: approval of its change in ownership and control.
typically provides provisional certification to an institution following a change in ownership resulting in a change of control and also
1 unchanged sentence
capability and financial responsibility.
−Removed: Our Integrity and CCMCC institutions are currently approved under a temporary provisional program
−Removed: participation agreement which (as described in a subsequent section) permits an institution to continue participating in the Title IV
−Removed: Programs on a month-to-month basis while ED reviews the change in ownership and as long as the institution timely submits certain documentation
−Removed: to ED during the process.
−Removed: An institution that is provisionally certified receives fewer due process rights than those received by other
−Removed: institutions in the event ED takes certain adverse actions against the institution, is required to obtain prior ED approvals of new campuses
−Removed: and educational programs and may be subject to heightened scrutiny by ED.
−Removed: However, provisional certification does not otherwise limit
−Removed: an institution’s access to Title IV Program funds.
+Added: Integrity is currently approved under a provisional program participation agreement following ED’s approval of its change in ownership and CCMCC is currently approved under a temporary provisional program participation agreement.
+Added: An institution that is provisionally certified receives fewer due process rights than those received by other institutions in the event
+Added: ED takes certain adverse actions against the institution, is required to obtain prior ED approvals of new campuses and educational programs
+Added: and may be subject to heightened scrutiny by ED.
+Added: However, provisional certification does not otherwise limit an institution’s access
+Added: to Title IV Program funds.
October 31, 2023, ED published a final rule revising its Title IV Program certification regulations with an effective date of July 1,
15 unchanged sentences
The revised certification regulations are expansive, complex and could
−Removed: be difficult for our institutions to comply with their applicable requirements as interpreted by ED.
−Removed: If ED finds that any of our institutions
−Removed: do not fully satisfy all required eligibility and certification standards, ED could limit, condition, suspend, terminate, revoke, or
−Removed: decline to renew our institutions’ participation in the Title IV Programs or impose liabilities or other sanctions.
−Removed: Continued Title
−Removed: IV Program eligibility is critical to the operation of our business.
−Removed: If our institutions become ineligible to participate in the Title
−Removed: IV Programs, or have that participation significantly conditioned, we may be unable to conduct our business as it is currently conducted
−Removed: which would have a material adverse effect on our business, financial condition, results of operations and cash flows.
+Added: be difficult for our institutions to comply with as interpreted by ED.
+Added: If ED finds that any of our institutions do not fully satisfy
+Added: all required eligibility and certification standards, ED could limit, condition, suspend, terminate, revoke, or decline to renew our
+Added: institutions’ participation in the Title IV Programs or impose liabilities or other sanctions.
+Added: Continued Title IV Program eligibility
+Added: is critical to the operation of our business.
+Added: If our institutions become ineligible to participate in the Title IV Programs, or have
+Added: that participation significantly conditioned, we may be unable to conduct our business as it is currently conducted which would have
+Added: a material adverse effect on our business, financial condition, results of operations and cash flows.
Authorization.
−Removed: Our institutions are subject to the educational laws and regulations of the State of California where our physical
−Removed: campuses are located.
−Removed: We also may be subject to the educational laws of other states if we acquire a new institution in the state or
−Removed: if one of our institutions adds a new campus in the state or otherwise conducts other operations in the state covered by applicable state
−Removed: educational law including, but not limited to, student recruitment, advertising, or certain types of distance education.
−Removed: State educational
−Removed: laws establish standards and requirements for, among other things, student instruction, faculty qualifications, campuses and facilities,
−Removed: educational programs, financial stability, administrative staff, marketing and recruiting, distribution of information to current and
−Removed: prospective students, payment of refunds to students who withdraw, private and institutional loans, distance education, student services,
−Removed: student complaints, student admissions, transfer of academic credits, substantive changes, acquisitions, and policies and minimum graduation
−Removed: and job placement outcomes for institutions and/or their individual educational programs.
−Removed: Our institutions are authorized to operate
−Removed: by the California Bureau for Private Postsecondary Education (“BPPE”).
−Removed: We also may be required to obtain approvals and comply
−Removed: with requirements of state agencies that regulate certain occupational educational programs such as, for example, VN and phlebotomy.
−Removed: The California Board of Registered Nurses approves the Associate degree of Nursing program at HDMC.
−Removed: The VN programs at HDMC, Integrity
−Removed: and CCMCC are approved by BVNPT.
−Removed: The phlebotomy programs at HDMC and CCC are approved by California Department of Public Health.
−Removed: we are subject to state consumer protection laws.
+Added: Our institutions are subject to the educational laws and regulations of the State of California where our
+Added: physical campuses are located, and CCC’s new additional location in Houston will be subject to the educational laws and
+Added: regulations of the State of Texas.
+Added: We also may be subject to the educational laws of other states if we acquire a new institution in
+Added: the state or if one of our institutions adds a new campus in the state or otherwise conducts other operations in the state covered
+Added: by applicable state educational law including, but not limited to, student recruitment, advertising, or certain types of distance
+Added: State educational laws establish standards and requirements for, among other things, student instruction, faculty
+Added: qualifications, campuses and facilities, educational programs, financial stability, administrative staff, marketing and recruiting,
+Added: distribution of information to current and prospective students, payment of refunds to students who withdraw, private and
+Added: institutional loans, distance education, student services, student complaints, student admissions, transfer of academic credits,
+Added: substantive changes, acquisitions, and policies and minimum graduation and job placement outcomes for institutions and/or their
+Added: individual educational programs.
+Added: Our institutions are authorized to operate by the California Bureau for Private Postsecondary
+Added: Education (“BPPE”).
+Added: CCC must obtain approval from the Texas Workforce Commission (“TWC”) to operate its
+Added: planned new campus in Houston, Texas, and has not yet submitted its application to the TWC;
+Added: however, no assurance can be provided
+Added: that we will receive the TWC approval or the Texas Higher Education Coordinating Board approvals described below in a timely manner,
+Added: We also may be required to obtain approvals and comply with requirements of state agencies that regulate certain
+Added: occupational educational programs such as, for example, VN and phlebotomy.
+Added: The California Board of Registered Nursing approves the
+Added: Associate degree of Nursing program at HDMC.
+Added: The VN programs at HDMC, Integrity and CCMCC are approved by BVNPT.
+Added: The phlebotomy
+Added: programs at HDMC, CCC and CCMCC are approved by the California Department of Public Health.
+Added: CCC will also require Texas Board of
+Added: Nursing approval to offer VN and registered nursing programs at the new planned campus in Houston, Texas.
+Added: CCC has submitted a letter
+Added: of intent to the Texas Board of Nursing and expects to submit its application after it receives TWC approval.
+Added: In addition, CCC will
+Added: require approval from the Texas Higher Education Coordinating Board (“THECB”) to offer degree programs at the Houston
+Added: campus, and expects to submit its applications to the THECB for UT, cardiac sonography, MRI and registered nursing degree programs
+Added: at the same time as its TWC application.
+Added: In addition, we are subject to state consumer protection laws.
general in many states have become more active in enforcing consumer protection laws, including, for example, laws related to marketing,
9 unchanged sentences
or other governmental authorities of us and other for-profit educational institutions.
−Removed: education laws and regulations may limit our campuses’ ability to operate or to award degrees, diplomas, or certificates or offer
−Removed: new programs.
−Removed: Moreover, under the HEA, authorization by state education agencies is necessary to maintain eligibility to participate
−Removed: in the Title IV Programs.
−Removed: ED regulations also require institutions offering postsecondary education through distance education to students
−Removed: located in a state in which the institution is not physically located (as determined by the institution at the time of a student’s
−Removed: initial enrollment and, if applicable, upon formal receipt of information from the student that their location has changed to another
−Removed: state) to meet state educational requirements in that state or participate in a state authorization reciprocity agreement in order to
−Removed: disburse Title IV funds to such students.
−Removed: We have obtained approval to offer portions of our programs via distance education from ACCET
−Removed: for CCC, CCMCC and HDMC, ABHES for Integrity, and from BPPE for HDMC, CCC, CCMCC and Integrity.
−Removed: The State of California does not,
−Removed: however, presently participate in any state authorization reciprocity agreement whereby our institutions may offer programs via distance
−Removed: education to students located in other states without our applicable state authorizations from those other states.
−Removed: Our institutions presently
−Removed: do not have any state postsecondary authorizations outside of California.
−Removed: In addition, an institution must make disclosures readily available
−Removed: to enrolled and prospective students regarding whether programs leading to professional licensure or certification meet state educational
−Removed: requirements, and provide a direct disclosure to students in writing if the program leading to professional licensure or certification
−Removed: does not meet state educational requirements in the state in which the student is located (which is only California for our current students).
−Removed: Under ED’s rules effective July 1, 2024, an institution must certify that its programs satisfy the applicable educational requirements
−Removed: for professional licensure or certification needed to practice or find employment in an occupation for which the program prepares a student
−Removed: in the state in which the school or where a student is located or intends to seek employment (which, although our current students are
−Removed: located in California, could be a state other than California and could require us to refrain from enrolling students in a state if our
−Removed: program does not satisfy the applicable educational requirements in the state).
−Removed: We believe the Title IV-eligible educational programs
−Removed: offered by our institutions satisfy all currently applicable state educational requirements for professional licensure or certification.
+Added: education laws and regulations may limit our campuses’ ability to operate or to award degrees, diplomas, or certificates or
+Added: offer new programs.
+Added: Moreover, under the HEA, authorization by state education agencies is necessary to maintain eligibility to
+Added: participate in the Title IV Programs.
+Added: ED regulations also require institutions offering postsecondary education through distance
+Added: education to students located in a state in which the institution is not physically located (as determined by the institution at the
+Added: time of a student’s initial enrollment and, if applicable, upon formal receipt of information from the student that their
+Added: location has changed to another state) to meet state educational requirements in that state or participate in a state authorization
+Added: reciprocity agreement in order to disburse Title IV funds to such students.
+Added: We have obtained approval to offer portions of our
+Added: programs via distance education from ACCET for CCC, CCMCC and HDMC, ABHES for Integrity, and from BPPE for HDMC, CCC, CCMCC and
+Added: The State of California does not, however, presently participate in any state authorization reciprocity agreement whereby
+Added: our institutions may offer programs via distance education to students located in other states without applicable state
+Added: authorizations from those other states.
+Added: Our institutions presently do not have any state postsecondary authorizations outside of
+Added: California, although CCC plans to seek postsecondary authorization in Texas and has not yet submitted its application to the TWC.
+Added: CCC does not currently plan to provide programs via distance education to residents of states other than California and Texas, and
+Added: the other Legacy institutions only provide distance education to residents of California.
+Added: In addition, an institution must make
+Added: disclosures readily available to enrolled and prospective students regarding whether programs leading to professional licensure or
+Added: certification meet state educational requirements, and provide a direct disclosure to students in writing if the program leading to
+Added: professional licensure or certification does not meet state educational requirements in the state in which the student is located
+Added: (which is only California for our current students, and will include Texas once students begin classes at the planned campus in
+Added: Under ED’s rules effective July 1, 2024, an institution must certify that its programs satisfy the applicable
+Added: educational requirements for professional licensure or certification needed to practice or find employment in an occupation for
+Added: which the program prepares a student in the state in which the school is located or where a student is located or intends to seek
+Added: employment (which, although our current students are located in California, could be a state other than California and could require
+Added: us to refrain from enrolling students in a state if our program does not satisfy the applicable educational requirements in the
+Added: We believe the Title IV-eligible educational programs offered by our institutions satisfy all currently applicable state
+Added: educational requirements for professional licensure or certification.
legislatures often consider legislation affecting regulation of postsecondary educational institutions.
Our institutions are located
−Removed: in California which has expansive laws and regulations impacting for-profit schools like our institutions.
−Removed: Enactment of this legislation
−Removed: and ensuing regulations, or changes in interpretation of existing regulations, may impose substantial costs on our institutions and require
−Removed: them to modify their operations in order to comply with the new regulations.
−Removed: If we are unable to comply with applicable past, current
−Removed: or future state education, consumer protection, licensing, authorization or other requirements, or determine that we are unable to cost
−Removed: effectively comply with new or revised requirements, we could be subject to liabilities, sanctions and other consequences.
−Removed: Factor – Any failure to comply with state laws and regulatory requirements, including educational requirements, or new state
−Removed: legislative or regulatory initiatives affecting our institutions, could have a material adverse effect on our total student enrollment,
−Removed: results of operations, financial condition and cash flows .”
+Added: in California (although we anticipate CCC will soon operate a location in Texas) which has expansive laws and regulations impacting
+Added: for-profit schools like our institutions.
+Added: Enactment of this legislation and ensuing regulations, or changes in interpretation of
+Added: existing regulations, may impose substantial costs on our institutions and require them to modify their operations in order to
+Added: comply with the new regulations.
+Added: If we are unable to comply with applicable past, current or future state education, consumer
+Added: protection, licensing, authorization or other requirements in California, Texas, and in any other states in which we may operate in
+Added: the future, or determine that we are unable to cost effectively comply with new or revised requirements, we could be subject to
+Added: liabilities, sanctions and other consequences.
+Added: See “Risk Factor – Any failure to comply with state laws and
+Added: regulatory requirements, including educational regulations, or new state legislative or regulatory initiatives affecting our
+Added: institutions, could have a material adverse effect on our total student enrollment, results of operations, financial condition and
+Added: cash flows .”
Institutional
16 unchanged sentences
would suffer .”
−Removed: Programmatic Accreditation .
−Removed: states and professional associations require professional programs to be accredited.
−Removed: While programmatic accreditation is not a sufficient
−Removed: basis to qualify for institutional Title IV Program certification, programmatic accreditation may improve employment opportunities for
−Removed: program graduates in their chosen field.
−Removed: Moreover, ED requires an institution to hold programmatic accreditation for an educational program
−Removed: if required by a state or federal agency (including as a condition of employment in the occupation for which the institutional program
−Removed: prepares the students).
−Removed: The veterinary technology program at CCC is accredited by American Veterinary Medical Association.
−Removed: Registered Nurse to Bachelor of Science in Nursing has received initial accreditation from the Commission for Nursing Education Accreditation.
−Removed: Additionally, CCC is pursuing initial programmatic accreditation with ABHES for the Surgical Technology Associate of Applied Science program
−Removed: for consideration during the Spring 2026 visit cycle.
−Removed: The Associate of Applied Science in Surgical Technology at CCMCC is accredited by
−Removed: ABHES and will engage in reaccreditation in the Spring 2026 visit cycle.
−Removed: All of the Title IV-eligible educational programs offered by
−Removed: our institutions are within the scope of institutional accreditation from either ACCET or ABHES, and we do not believe any of our Title
−Removed: IV-eligible educational programs that do not hold programmatic accreditation are required to hold programmatic accreditation by any currently
−Removed: applicable state or federal agency.
−Removed: Those of our programs that do not have programmatic accreditation where available, or fail to maintain
−Removed: such accreditation, may experience adverse publicity, loss of access to Title IV funds, declining enrollments, litigation or other claims
−Removed: from students or suffer other adverse impacts, which could result in it being impractical for us to continue offering such programs.
+Added: Accreditation .
+Added: Many states and professional associations require professional programs to be accredited.
+Added: programmatic accreditation is not a sufficient basis to qualify for institutional Title IV Program certification, programmatic
+Added: accreditation may improve employment opportunities for program graduates in their chosen field.
+Added: Moreover, ED requires an institution
+Added: to hold programmatic accreditation for an educational program if required by a state or federal agency (including as a condition of
+Added: employment in the occupation for which the institutional program prepares the students).
+Added: The veterinary technology program at CCC is
+Added: accredited by the American Veterinary Medical Association.
+Added: Integrity’s Registered Nurse to Bachelor of Science in Nursing
+Added: program has received initial accreditation from the Commission for Nursing Education Accreditation.
+Added: In the Spring 2026 visit cycle,
+Added: ABHES conducted a reaccreditation visit for CCMCC’s Associate of Applied Science in Surgical Technology.
+Added: CCMCC was granted
+Added: reaccreditation for the program, with no comments, through February 28, 2033.
+Added: Additionally, CCC and HDMC are pursuing initial
+Added: programmatic accreditation with ABHES for the Surgical Technology Associate of Applied Science program.
+Added: ABHES completed its Fall
+Added: 2026 visit for CCC’s program and its visit report is pending;
+Added: CCC expects the ABHES commission to consider the program in
+Added: January 2027, with a decision expected in mid-February 2027.
+Added: HDMC expects to submit its self-study in November 2026 for a Spring
+Added: 2027 visit, with consideration by the ABHES commission expected in July 2027 and a decision expected in August 2027.
+Added: Title IV-eligible educational programs offered by our institutions are within the scope of institutional accreditation from either
+Added: ACCET or ABHES, and we do not believe any of our Title IV-eligible educational programs that do not hold programmatic accreditation
+Added: are required to hold programmatic accreditation by any currently applicable state or federal agency.
+Added: Those of our programs that do
+Added: not have programmatic accreditation where available, or fail to maintain such accreditation, may experience adverse publicity, loss
+Added: of access to Title IV funds, declining enrollments, litigation or other claims from students or suffer other adverse impacts, which
+Added: could result in it being impractical for us to continue offering such programs.
Recognition of Accrediting Agencies.
1 unchanged sentence
accrediting agencies that accredit our colleges and universities.
−Removed: Each of our institutions currently are accredited by an ED-recognized
+Added: Each of our institutions is currently accredited by an ED-recognized
accrediting agency.
1 unchanged sentence
of Congress, ED’s Office of Inspector General and ED over recent years.
−Removed: ED held negotiated rulemaking sessions between January
−Removed: and March 2024, and the negotiators did not reach consensus on proposed language.
−Removed: ED proposed expanding requirements related to accrediting
−Removed: agencies’ conflict of interest policies and student achievement standards, for example.
−Removed: ED terminated the negotiated rulemaking
−Removed: process for accreditation as of December 20, 2024.
−Removed: However, ED published a proposed regulatory agenda in early September 2025 that, among
−Removed: other things, includes a proposal to engage in negotiated rulemaking to provide institutions flexibility to change accreditors and “remove
−Removed: other burdensome requirements that erect barriers to entry for new accreditation agencies.” This proposal is in its early stages
−Removed: and, therefore, we cannot predict whether and how such a rulemaking would impact the accreditors that accredit our institutions or the
−Removed: accreditation requirements applicable to our institutions.
−Removed: ED withdraws recognition from ACCET and/or ABHES, ED may continue our schools’ eligibility for a period of up to 18 months from
−Removed: the date of the withdrawal of recognition, and our schools could apply for accreditation from the other ED-recognized accrediting agencies.
+Added: held negotiated rulemaking sessions between April and May 2026 to consider amendments to the regulations respecting the
+Added: Secretary’s recognition of accrediting agencies and related institutional eligibility requirements for the Title IV Programs.
+Added: The negotiators reached consensus on the proposed rule, which covers topics including institutions switching from one accreditor to
+Added: another, the recognition process for accrediting agencies, and the recognition criteria for accrediting agencies, including
+Added: requirements for their standards and policies regarding acceptance of transfer credit, institutional outcomes, academic freedom, and
+Added: violations of federal and state law.
+Added: On August 19, 2026, ED published a notice of proposed rulemaking containing language materially
+Added: identical to the consensus language and will undergo a period of public notice and comment before ED makes any amendments and
+Added: publishes the final regulations.
+Added: Therefore, we cannot predict the ultimate content and timing of the final regulations.
+Added: the new regulations could go into effect is July 1, 2027.
+Added: Any future regulations or regulatory changes resulting from this
+Added: negotiated rulemaking process could impact the ability of the accreditors that accredit our institutions to maintain recognition by
+Added: ED and the accreditation requirements applicable to our institutions.
+Added: We cannot predict whether and how such rulemaking would impact
+Added: our institutions and operations.
+Added: ED withdraws recognition from ACCET and/or ABHES in the future, ED may continue our schools’ eligibility for a period of up to
+Added: 18 months from the date of the withdrawal of recognition, and our schools could apply for accreditation from the other ED-recognized
+Added: accrediting agencies.
ED could impose provisional certification and other conditions and restrictions on our schools during this period.
−Removed: If ACCET and/or ABHES
−Removed: lose recognition from ED and our schools are unable to obtain accreditation from a different ED-recognized accrediting agency in the
−Removed: required time period, our schools could lose eligibility to participate in Title IV Programs.
+Added: If ACCET and/or ABHES lose recognition from ED and our schools are unable to obtain accreditation from a different ED-recognized accrediting
+Added: agency in the required time period, our schools could lose eligibility to participate in Title IV Programs.
Congressional
17 unchanged sentences
cost of such compliance is excessive, or if funding is materially reduced, our revenues or profit margin could be materially adversely
−Removed: recently, on July 4, 2025, the President signed into law the One Big Beautiful Bill Act (“OBBBA”), which has a general effective
−Removed: date of July 1, 2026 and makes changes to the HEA, including the Title IV programs.
−Removed: ED intends to conduct a negotiated rulemaking process
−Removed: in 2025 for the purpose of establishing new regulations impacting the new OBBBA requirements.
+Added: July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”), which became effective July 1, 2026
+Added: and makes changes to the HEA, including changes impacting the Title IV programs.
+Added: ED conducted a negotiated rulemaking process in 2025
+Added: and 2026 for the purpose of establishing new regulations implementing the new OBBBA requirements.
See “Education Regulations –
−Removed: Negotiated Rulemaking.” Consequently, we expect the new requirements will impact our institutions and operations, but we cannot
−Removed: predict the ultimate scope, content, and impact of the new OBBBA requirements under future ED regulations and guidance.
−Removed: We are currently
−Removed: assessing, and will continue to assess, the potential impact of the requirements on us and our institutions.
−Removed: Among other things, the
−Removed: OBBBA establishes limits on the amount of Title IV loans students and parents can borrow.
−Removed: These limits will not apply to students that
−Removed: will be enrolled as of the effective date, up until their expected time of completion as defined by the OBBBA.
−Removed: The OBBBA establishes
−Removed: a limit of $20,000 annually and $65,000 in total for PLUS loans taken out by parent borrowers for undergraduate programs.
−Removed: The OBBBA also
−Removed: creates a lifetime loan limit of $257,500 for all borrowers.
−Removed: It also requires institutions to prorate loans for students attending less
−Removed: than full-time.
−Removed: We are in the process of evaluating the impact these loan limitations may have on our institutions and enrollments and
−Removed: the extent to which alternative sources of funding such as third-party loans may be needed for some of our students.
−Removed: OBBBA also establishes a new accountability measure that applies to our degree programs and that is based on a comparison of
−Removed: graduate earnings to the earnings of working adults without degrees under a complex formula that ED is expected to address in future
−Removed: Under the new accountability measure, an associate degree program would lose its Title IV loan eligibility if the
−Removed: median earnings of a cohort of graduates are less than the median earnings of working adults with a high school diploma and no
−Removed: further degrees for two out of three years.
−Removed: ED will create a process for appealing the programmatic median earnings data.
−Removed: Institutions that do not meet the accountability measure for one year will also be required to notify students of the risk of losing
−Removed: Our institutions offer a limited number of associate degree programs that will be subject to the new accountability
−Removed: We cannot yet predict with certainty whether our degree programs will meet the accountability measure or whether they will
−Removed: be at risk of losing eligibility to participate in the Title IV loan programs.
−Removed: OBBBA also restricts student eligibility for the Pell Grant by disqualifying students with a student aid index that equals or exceeds
−Removed: twice the amount of the total maximum Pell Grant, and disqualifying students who receive grant aid from non-federal sources that equals
−Removed: or exceeds the student’s cost of attendance for that period.
−Removed: We are evaluating whether and to what extent this change might impact
−Removed: the Pell eligibility of some of our students and whether alternative sources of financial aid, such as third-party loans, might be necessary
−Removed: for these students.
−Removed: The OBBBA also establishes Workforce Pell Grants for eligible students enrolled in certain short-term educational
−Removed: programs that meet eligibility requirements.
−Removed: The eligibility requirements include criteria related to the program’s length and
−Removed: a determination of eligibility by the state.
−Removed: Many of our programs are longer than the eligibility requirements, but we are evaluating
−Removed: whether opportunities exist for other current or future programs at our institutions.
+Added: Negotiated Rulemaking.” We are currently assessing, and will continue to assess, the potential impact of the requirements on us
+Added: and our institutions.
+Added: Among other things, the OBBBA establishes limits on the amount of Title IV loans students and parents can borrow.
+Added: These limits will not apply to students that will be enrolled as of the effective date, up until their expected time of completion as
+Added: defined by the OBBBA.
+Added: The OBBBA establishes a limit of $20,000 annually and $65,000 in total for PLUS loans taken out by parent borrowers
+Added: for undergraduate programs.
+Added: The OBBBA also creates a lifetime loan limit of $257,500 for all borrowers.
+Added: It also requires institutions
+Added: to prorate loans for students attending less than full-time.
+Added: We are in the process of evaluating the impact these loan limitations may
+Added: have on our institutions and enrollments and the extent to which alternative sources of funding such as third-party loans may be needed
+Added: for some of our students.
+Added: OBBBA also establishes a new accountability measure that applies to our degree programs and that is based on a comparison of graduate
+Added: earnings to the earnings of working adults without degrees.
+Added: See “Education Regulations - Financial Value Transparency, Gainful
+Added: Employment, and Accountability Regulations.” We cannot yet predict with certainty whether our degree programs will meet the accountability
+Added: measure or whether they will be at risk of losing eligibility to participate in the Title IV loan programs.
+Added: OBBBA also restricts student eligibility for the Pell Grant.
+Added: See “Education Regulations – Negotiated Rulemaking.”
+Added: Based on our assessment, we do not currently expect this change to have a material impact on the Pell eligibility of our
+Added: OBBBA also establishes Workforce Pell Grants for eligible students enrolled in certain short-term educational programs that meet
+Added: eligibility requirements.
+Added: See “Education Regulations - Negotiated Rulemaking.” We do not plan to participate in the
+Added: Workforce Pell Grants at this time but we may evaluate potential opportunities under the regulations in the future.
Additionally,
11 unchanged sentences
We are continuing to monitor the process.
−Removed: As previously reported, there are indications based on recent elections that the new administration, and potentially
−Removed: Congress, will attempt to dissolve ED, diminish its operational role, and/or transfer some or all of its functions to one or
−Removed: more agencies.
−Removed: See the Company’s Quarterly Report on Form 10-Q, filed with the SEC on February 13, 2025, for the section titled
−Removed: “Regulatory Updates” for additional information.
−Removed: In March 2025, ED implemented a reduction in force (“RIF”) that,
−Removed: coupled with resignations by ED staff, reportedly reduced ED’s workforce by approximately half.
−Removed: The RIF also eliminated several
−Removed: school participation divisions, including the school participation division that previously oversaw the operations of our institutions,
−Removed: and eliminated or significantly reduced several other offices or divisions within ED.
−Removed: We currently are working with other offices and
−Removed: personnel at ED on some of our pending matters, but it is possible that we could encounter delays and difficulties obtaining timely ED
−Removed: approval of recent and future acquisitions of other schools.
−Removed: See “Education Regulations – School Acquisitions” and
−Removed: “Education Regulations – Change of Control.” We also could encounter delays and difficulties obtaining timely ED approval
−Removed: of new campuses or other educational programs for which we wish to offer Title IV funds to students and which require ED approval.
−Removed: “Education Regulations – Opening Additional Campuses and Adding Educational Programs.”
−Removed: March 2025, the President issued an Executive Order calling for all necessary steps to close ED although the executive order did not
+Added: There are indications the new administration, and potentially the U.S.
+Added: Congress, will attempt to dissolve ED, diminish
+Added: its operational role, and/or transfer some or all of its functions to one or more agencies.
+Added: In March 2025, ED implemented a reduction
+Added: in force (“RIF”) that, coupled with resignations by ED staff, reportedly reduced ED’s workforce by approximately half.
+Added: The RIF also eliminated several school participation divisions, including the school participation division that previously oversaw the
+Added: operations of our institutions, and eliminated or significantly reduced several other offices or divisions within ED.
+Added: We currently are
+Added: working with other offices and personnel at ED on some of our pending matters, but it is possible that we could encounter delays and
+Added: difficulties obtaining timely ED approval of recent and future acquisitions of other schools.
+Added: See “Education Regulations –
+Added: School Acquisitions” and “Education Regulations – Change of Control.” We also could encounter delays and difficulties
+Added: obtaining timely ED approval of new campuses or other educational programs for which we wish to offer Title IV funds to students and
+Added: which require ED approval.
+Added: See “Education Regulations – Opening Additional Campuses and Adding Educational Programs.”
+Added: March 2025, President Trump issued an Executive Order calling for all necessary steps to close ED although the executive order did not
indicate the process or timing for accomplishing this task nor identify where some of the functions of ED might be transferred.
−Removed: to monitor developments in this area, but cannot yet predict whether the administration or Congress will be successful in closing or
−Removed: further reducing ED and/or transferring some or all of its functions to one or more agencies, or whether such a proposal would disrupt
+Added: and 2026, ED announced several new interagency agreements under which other federal agencies will provide certain services to ED.
+Added: continue to monitor developments in this area, but cannot yet predict whether the administration or Congress will be successful in closing
+Added: or further reducing ED and/or transferring some or all of its functions to one or more agencies, whether such a proposal would disrupt
or change the availability of Title IV funds to us and our students or change the rules applicable to us and our schools to continue
−Removed: receiving Title IV funds.
−Removed: We also cannot predict the success of any litigation challenging any efforts to close or restructure ED.
−Removed: executive or legislative action impacting ED, the availability of Title IV funds, or the rules applicable to us could have a material
−Removed: adverse effect on us and our institutions.
−Removed: Value Transparency and Gainful Employment Regulations.
−Removed: In May 2021, ED announced its intention to initiate a rulemaking process
−Removed: on several topics, including gainful employment.
−Removed: On May 19, 2023, ED published a notice of proposed rulemaking on financial value transparency
−Removed: and gainful employment, and on October 10, 2023, ED published final regulations which became effective on July 1, 2024.
−Removed: Multiple lawsuits
−Removed: were filed challenging these regulations, and these were consolidated into one case.
−Removed: We cannot predict the outcome of this case.
−Removed: financial value transparency and gainful employment regulations include standards for annually evaluating postsecondary educational programs
−Removed: based on the calculation of debt-to-earnings rates and an “earnings premium” measure.
−Removed: The rule establishes formulae for calculating
−Removed: these rates using data such as student debt, student earnings data, and median earnings data for working adults with only a high school
−Removed: diploma or GED, which the rule uses to compare to median earnings data of the institution’s graduates.
−Removed: Under the regulations, ED
−Removed: will annually calculate and publish the debt-to-earnings rates and median earnings data for our educational programs.
+Added: receiving Title IV funds, or whether our operations will be impacted by the implementation of the interagency agreements.
+Added: We also cannot
+Added: predict the success of any litigation challenging any efforts to close or restructure ED.
+Added: Any executive or legislative action impacting
+Added: ED, the availability of Title IV funds, or the rules applicable to us could have a material adverse effect on us and our institutions.
+Added: Value Transparency, Gainful Employment, and Accountability Regulations.
+Added: On May 19, 2023, ED published a notice of proposed rulemaking
+Added: on financial value transparency and gainful employment, and on October 10, 2023, ED published final regulations which became effective
+Added: on July 1, 2024.
+Added: The financial value transparency and gainful employment regulations included standards for annually evaluating postsecondary
+Added: educational programs based on the calculation of debt-to-earnings rates and an “earnings premium” measure.
If these calculations
1 unchanged sentence
consecutive years, those educational programs would lose Title IV Program eligibility.
−Removed: ED also requires institutions to provide warnings
−Removed: to current and prospective students about programs in danger of losing of Title IV Program eligibility which could negatively impact
−Removed: our retention of current students and enrollment of new students in these programs.
−Removed: The regulations also require certifications and data
−Removed: reporting to ED and providing required student disclosures related to gainful employment.
−Removed: Some of the data ED will use to calculate the
−Removed: debt-to-earnings rates and earnings premium measures is not yet readily accessible to institutions.
−Removed: Therefore, it is difficult for us
−Removed: to predict how our institutions will perform under the new standards and the extent to which our programs could lose Title IV Program
−Removed: eligibility under the new standards.
−Removed: We also do not have control over some of the factors that could impact the rates and measures for
−Removed: our programs which could make it difficult to mitigate the impact of the regulations on our programs.
−Removed: However, the new regulations could
−Removed: require us to modify or eliminate programs to comply with the new regulations and could result in the loss of Title IV Program eligibility
−Removed: for our programs that fail to comply with the regulations which could have a material adverse effect on our student population and our
−Removed: As noted elsewhere, our degree programs also will be subject to a new separate earnings measure under the OBBBA.
−Removed: Factor - ED’s financial value transparency and gainful employment regulations may limit the programs we can offer students and
−Removed: increase our cost of operations.”
+Added: Multiple lawsuits were filed challenging these
+Added: regulations, and these were consolidated into one case in the U.S.
+Added: District Court for the Northern District of Texas.
+Added: ED subsequently
+Added: filed a motion for summary judgment, which was granted by the court on October 2, 2025, upholding the validity of the regulations.
+Added: November 24, 2025, the plaintiffs appealed the summary judgment ruling.
+Added: We cannot predict the outcome of the appeal at the Fifth Circuit
+Added: Court of Appeals.
+Added: rule establishes formulae for calculating these rates using data such as student debt, student earnings data, and median earnings data
+Added: for working adults with only a high school diploma or GED, which the rule uses to compare to median earnings data of the institution’s
+Added: Under the regulations, ED will annually calculate and publish the debt-to-earnings rates and median earnings data for our
+Added: educational programs.
+Added: ED published final regulations on July 1, 2026 that create new accountability measures based in part on the accountability metrics in
+Added: the OBBBA and the metrics in the existing gainful employment rules.
+Added: The new earnings premium measure applies to all degree and non-degree
+Added: programs at all institutions and eliminates the debt-to-earnings rate measure in the existing gainful employment regulations.
+Added: earnings premium measure for undergraduate programs (as opposed to the separate measure for graduate programs), the median annual earnings
+Added: of program completers are compared to the “earnings threshold,” which is the median earnings of holders of high school diplomas
+Added: who are working adults aged 25-34 using the methodology prescribed in the regulations.
+Added: If a program does not meet the applicable standard,
+Added: the institution must provide a prescribed warning to students and prospective students explaining that it has not passed ED’s standards
+Added: based on reported earnings of program graduates and that the program could lose access to Direct Loans based on the next calculated metrics.
+Added: The warning must also include information about accessing the program information website maintained by ED and explain that the student
+Added: must acknowledge the student viewed the warning in order for the institution to disburse Title IV funds to the student.
+Added: If the program
+Added: fails the earnings premium measure in two out of three consecutive award years for which the earnings premium measure is calculated,
+Added: this would result in the program’s loss of eligibility for Title IV Direct Loans once ED completes a termination action under its
+Added: established proceedings, unless the institution successfully appeals under those proceedings.
+Added: If more than 50% of an institution’s
+Added: Title IV-recipient students enrolled in, or more than 50% of the institution’s total Title IV funds are from, programs that fail
+Added: the earnings premium measure in two out of three consecutive award years for which the earnings premium measure is calculated, the institution
+Added: could be deemed not administratively capable and be placed on provisional status, and the programs could potentially lose access to all
+Added: Title IV HEA funds if the institution does not successfully appeal the determination.
+Added: If the institution meets this threshold in at least
+Added: one of the three most recent consecutive award years, the institution must provide a warning explaining that program could also lose
+Added: access to the other Title IV funds.
+Added: The final rule also, among other things, describes the process and formulas for calculating earnings
+Added: accountability measures, revises the requirements for institutional reporting to ED, specifies the period of ineligibility for programs
+Added: that fail the earnings premium measure, allows for limited retention of eligibility during orderly program closure, and modifies the
+Added: institutional data ED is required to disclose on its program information website (this data will continue to include a program’s
+Added: earnings premium measure).
+Added: new regulations will go into effect on July 1, 2027 with certain provisions having taken effect on August 31, 2026.
+Added: It is expected that the first accountability measure calculations will take place in early 2027, and that programs cannot lose
+Added: eligibility under the new rules until July 1, 2028 after the second accountability measures have been calculated.
+Added: These dates are
+Added: subject to change.
+Added: We are currently evaluating the potential impact of the regulations on the Company.
+Added: If one or more of our
+Added: programs fail to comply with the new requirements, those programs could lose access to Title IV Direct Loans, and potentially all
+Added: Title IV eligibility, which could have a material adverse effect on our student population and our revenues.
+Added: The new regulations
+Added: could also require us to modify or eliminate programs to comply with the new regulations.
+Added: expect the new regulations will impact our institutions and operations, but we cannot predict the ultimate scope, content, and impact
+Added: of the regulations and guidance including any regulations further implementing the new OBBBA requirements.
+Added: We are currently assessing,
+Added: and will continue to assess, the potential impact of the new requirements on us and our institutions and to monitor the negotiated rulemaking
+Added: issued guidance on August 11, 2026 requiring institutions that failed to report, or fully report, gainful employment data for prior
+Added: years to provide such data by January 15, 2027.
+Added: If one or more of our institutions fail to meet the October 1, 2026 reporting
+Added: deadline for the most recent year of gainful employment data or fail to provide any missing gainful employment data for prior years
+Added: by January 15, 2027, ED could impose fines or sanctions or could take administrative action against our institutions.
Defense to Repayment Regulations.
7 unchanged sentences
the BDR regulations, borrowers with federal student loans disbursed after July 1, 2017 can assert a defense to repayment and be eligible
−Removed: for relief based on a nondefault, favorable, contested judgement against the institution from a state or federal court;
+Added: for relief based on a nondefault, favorable, contested judgment against the institution from a state or federal court;
the institution failed to perform its obligations under a contract with the student or a claim the institution committed a “substantial
17 unchanged sentences
disclosures of judicial and arbitration filings and awards pertaining to a borrower defense claim.
−Removed: other things, the revised 2022 version of the BDR regulations also amended the processes for borrowers to receive from ED a discharge
−Removed: of the obligation to repay certain Title IV Program loans when the BDR applications are received on or after, or pending with ED as of
−Removed: July 1, 2023.
−Removed: The revised 2022 version of the BDR regulations applies the revised federal BDR standard to all BDR claims received on
−Removed: or after, or pending with the Secretary as of July 1, 2023, but would not allow for recovery against institutions for discharged amounts
−Removed: first disbursed prior to July 1, 2023 unless the BDR claim would have been approved under the substantive BDR standard applicable to
−Removed: the time period in which the loan was disbursed as set forth in the prior versions of the BDR regulations.
−Removed: The defenses to repayment
−Removed: are based on certain acts or omissions, including misrepresentations by an institution or a covered party.
−Removed: The regulations establish
−Removed: detailed procedures and standards for the loan discharge processes, including the information required for borrowers to receive a loan
−Removed: discharge, and the authority of ED to seek recovery from the institution of the amount of discharged loans.
−Removed: The 2022 version of the revised
−Removed: BDR regulations were to take effect on July 1, 2023, in addition to certain closed school loan discharge provisions part of the same
−Removed: rule, but are currently enjoined and delayed.
−Removed: The Career Colleges and Schools of Texas (“CCST”) filed a complaint challenging
−Removed: the regulations in February 2023.
+Added: other things, the revised 2022 version of the BDR regulations also amended the processes for borrowers to receive from ED a
+Added: discharge of the obligation to repay certain Title IV Program loans when the BDR applications are received on or after, or pending
+Added: with ED as of July 1, 2023.
+Added: The revised 2022 version of the BDR regulations applies the revised federal BDR standard to all BDR
+Added: claims received on or after, or pending with the Secretary as of July 1, 2023, but would not allow for recovery against institutions
+Added: for discharged amounts first disbursed prior to July 1, 2023 unless the BDR claim would have been approved under the substantive BDR
+Added: standard applicable to the time period in which the loan was disbursed as set forth in the prior versions of the BDR regulations.
+Added: The defenses to repayment are based on certain acts or omissions, including misrepresentations by an institution or a covered party.
+Added: The regulations establish detailed procedures and standards for the loan discharge processes, including the information required for
+Added: borrowers to receive a loan discharge, and the authority of ED to seek recovery from the institution of the amount of discharged
+Added: The 2022 version of the revised BDR regulations was to take effect on July 1, 2023, in addition to certain closed school loan
+Added: discharge provisions that are part of the same rule, but are currently enjoined and delayed.
+Added: The Career Colleges and Schools of
+Added: Texas (“CCST”) filed a complaint challenging the regulations in February 2023.
In April 2024, the U.S.
−Removed: Court of Appeals for the Fifth Circuit granted a preliminary injunction to
−Removed: block enforcement of the revised 2022 version of the BDR regulations while the case is pending.
−Removed: Further, the OBBBA, enacted July 4, 2025,
−Removed: delays the effective date of the 2022 version of the revised BDR regulations for ten years, until July 1, 2035.
−Removed: Therefore, the amendments
−Removed: to the BDR regulations that were to take effect on July 1, 2023 are not in effect, but the previous BDR regulations in effect prior to
−Removed: July 1, 2023, generally remain in effect in the meantime and apply different substantive standards and procedures based on when a BDR
+Added: Court of Appeals
+Added: for the Fifth Circuit granted a preliminary injunction to block enforcement of the revised 2022 version of the BDR regulations while
+Added: the case is pending.
+Added: Further, the OBBBA, enacted July 4, 2025, delays the effective date of the 2022 version of the revised BDR
+Added: regulations for ten years, until July 1, 2035.
+Added: Therefore, the amendments to the BDR regulations that were to take effect on July 1,
+Added: 2023 are not in effect, but the previous BDR regulations in effect prior to July 1, 2023, which first became effective in 2020,
+Added: generally remain in effect in the meantime and apply different substantive standards and procedures based on when a BDR
claimant’s loans were disbursed.
+Added: CCST filed an amended complaint in March 2026 to also challenge the version of the BDR
+Added: regulations that became effective in 2020.
+Added: We cannot predict the outcome of this pending litigation.
June 22, 2022, ED reached a settlement with plaintiffs in the case titled Sweet v.
−Removed: Cardona , which was filed by student loan
−Removed: borrowers to challenge ED’s adjudication of BDR claims.
−Removed: The settlement resulted in automatic relief of claims pending as of
−Removed: June 22, 2022 that were filed against institutions on a list of about 150 institutions named in the settlement agreement, which did
−Removed: not include any of our institutions.
−Removed: In addition, under the settlement, any borrower who filed a defense to repayment claim between
−Removed: June 22, 2022 and November 15, 2022 are “Post-Class Applicants” whose applications will be adjudicated under the 2016
−Removed: version of the BDR regulations and will be decided by January 2026.
−Removed: HDMC received and timely responded to seven BDR applications
−Removed: from Post-Class Applicants.
−Removed: CCC, Integrity, and CCMCC (at least since we acquired CCMCC) have not received any BDR applications
−Removed: from Post-Class Applicants.
−Removed: It is possible that we could receive BDR claims in the future.
−Removed: If we or our representatives are found to
−Removed: have engaged in certain acts or omissions under the broad definitions contained in the 2016 version of the BDR regulations, or other
−Removed: BDR regulations that could be in place in the future, we could be subject to substantial repayment obligations and subject to other
+Added: Cardona , which was filed by student loan borrowers
+Added: to challenge ED’s adjudication of BDR claims.
+Added: The settlement resulted in automatic relief of claims pending as of June 22, 2022
+Added: that were filed against institutions on a list of about 150 institutions named in the settlement agreement, which did not include any
+Added: of our institutions.
+Added: In addition, under the settlement, any borrower who filed a defense to repayment claim between June 22, 2022 and
+Added: November 15, 2022 are “Post-Class Applicants” whose applications were to be adjudicated under the 2016 version of the BDR regulations
+Added: and decided by January 2026.
+Added: HDMC received and timely responded to seven BDR applications from Post-Class Applicants.
+Added: CCC, Integrity,
+Added: and CCMCC (at least since we acquired CCMCC) did not receive any BDR applications from Post-Class Applicants.
+Added: If we or our representatives
+Added: are found to have engaged in certain acts or omissions under the broad definitions contained in the 2016 version of the BDR regulations,
+Added: or other BDR regulations that could be in place in the future, we could be subject to substantial repayment obligations and subject to
+Added: other sanctions.
+Added: March 2026, CCC has received six BDR applications from ED, HDMC has received eighteen BDR applications from ED, and Integrity has received
+Added: four BDR applications from ED.
+Added: CCC, HDMC, and Integrity have either timely responded to, or are in the process of timely responding to,
+Added: these BDR applications, disputing the validity of the claims.
+Added: CCMCC has not received any BDR applications in 2026.
+Added: ED published guidance
+Added: on March 30, 2026 explaining that it had resumed adjudicating BDR applications that are not impacted by the Sweet v.
+Added: Cardona settlement.
+Added: The guidance explains that ED will adjudicate the BDR applications under the currently effective regulations, and that ED will notify
+Added: institutions of the applications received.
+Added: It is possible that we could receive BDR claims in the future, including because the March
+Added: 30, 2026 guidance indicates ED had not yet notified institutions of BDR claims that would be adjudicated under the version of the BDR
+Added: regulations that became effective in 2020.
+Added: If we or our representatives are found to have engaged in certain acts or omissions under
+Added: the definitions contained in the BDR regulations, or other BDR regulations that could be in place in the future, we could be subject
+Added: to substantial repayment obligations and subject to other sanctions.
enjoined 2022 version of the BDR regulations, and the versions of the BDR regulations that are currently in effect and that could be
−Removed: in effect in the future, could have a material adverse effect on our business, financial condition, results of operations, and cash
−Removed: flows and result in the imposition of significant restrictions on us and our ability to operate, including a requirement that our
−Removed: institutions to submit a letter of credit based on expanded standards of financial responsibility.
−Removed: See “Education Regulations
−Removed: - Financial Responsibility Standards.”
+Added: in effect in the future, could have a material adverse effect on our business, financial condition, results of operations, and cash flows
+Added: and result in the imposition of significant restrictions on us and our ability to operate, including a requirement that our institutions submit a letter of credit based on expanded standards of financial responsibility.
+Added: See “Education Regulations - Financial Responsibility
recent years, ED has been more active in processing BDR applications and has recently distributed claims to institutions for an opportunity
6 unchanged sentences
also grants closed school loan discharges to students when it determines the student’s institution or campus has closed.
−Removed: When an institution
−Removed: or location meets ED’s definition of a closed school or location, affected students can apply for a discharge of the Title IV loans
−Removed: incurred for the program of study the student did not complete due to the closure, and ED grants the discharge if the student meets certain
−Removed: requirements.
+Added: institution or location meets ED’s definition of a closed school or location, affected students can apply for a discharge of the
+Added: Title IV loans incurred for the program of study the student did not complete due to the closure, and ED grants the discharge if the
+Added: student meets certain requirements.
ED also may seek to recover the cost of the discharge from the institution.
−Removed: If any of our locations or institutions close,
−Removed: our institutions could be subject to liabilities for closed school loan discharges.
−Removed: In conjunction with the 2022 revisions to the BDR
−Removed: rule, ED also revised the closed school loan discharge provisions.
−Removed: However, these revisions are also enjoined as well as delayed under
−Removed: We cannot predict the outcome of any future revisions to the closed school loan discharge provisions that ED may initiate.
+Added: If any of our locations
+Added: or institutions close, our institutions could be subject to liabilities for closed school loan discharges.
+Added: In conjunction with the 2022
+Added: revisions to the BDR rule, ED also revised the closed school loan discharge provisions.
+Added: However, these revisions are also enjoined as
+Added: well as delayed under the OBBBA.
+Added: We cannot predict the outcome of any future revisions to the closed school loan discharge provisions
+Added: that ED may initiate.
Revenue Test.
−Removed: Under the HEA, a proprietary institution that derives more than 90% of its total revenue from the Title IV
−Removed: Programs or, for fiscal years beginning on or after January 1, 2023 from all federal educational assistance funds, for two
−Removed: consecutive fiscal years becomes immediately ineligible to participate in the Title IV Programs and may not reapply for eligibility
−Removed: until the end of at least two fiscal years (“90/10 Rule”).
−Removed: An institution whose receipts of applicable funds exceeds 90%
−Removed: of revenue for a single fiscal year will be placed on provisional certification, be required to notify ED and its students of the
−Removed: possibility of a loss of Title IV Program eligibility, and may be subject to other enforcement measures, including a requirement to
−Removed: submit a letter of credit.
−Removed: See “Education Regulations - Financial Responsibility Standards.” If an institution violated
−Removed: the 90/10 Rule and became ineligible to participate in Title IV Programs but continued to disburse Title IV Program funds, ED would
−Removed: require the institution to repay all Title IV Program funds received by the institution after the effective date of the loss of
−Removed: We have calculated the 90/10 Rule percentage
−Removed: for the 2024, 2023, and 2022 fiscal years as follows for HDMC, CCC, and Integrity:
−Removed: HDMC 87.55%, 84.53%, and 82.17%;
+Added: Under the HEA, a proprietary institution that derives more than 90% of its total revenue from the Title IV Programs
+Added: or, for fiscal years beginning on or after January 1, 2023 from all federal educational assistance funds, for two consecutive fiscal
+Added: years becomes immediately ineligible to participate in the Title IV Programs and may not reapply for eligibility until the end of at
+Added: least two fiscal years (“90/10 Rule”).
+Added: An institution whose receipts of applicable funds exceed 90% of revenue for a single
+Added: fiscal year will be placed on provisional certification, be required to notify ED and its students of the possibility of a loss of Title
+Added: IV Program eligibility, and may be subject to other enforcement measures, including a requirement to submit a letter of credit.
+Added: See “Education
+Added: Regulations - Financial Responsibility Standards.” If an institution violated the 90/10 Rule and became ineligible to participate
+Added: in Title IV Programs but continued to disburse Title IV Program funds, ED would require the institution to repay all Title IV Program
+Added: funds received by the institution after the effective date of the loss of eligibility.
+Added: have calculated the 90/10 Rule percentage for the 2025, 2024, and 2023 fiscal years as follows for HDMC, CCC, and Integrity:
87.55%, and 84.53%;
+Added: CCC 80.35%, 79.51%, and 74.48%;
and Integrity 84.71%, 84.19%, and 88.14%, respectively.
−Removed: CCMCC’s 90/10 Rule percentage for its 2022 fiscal
−Removed: year was 21.76%, and for its 2023 fiscal year was 48.63%.
−Removed: CCMCC’s next 90/10 Rule percentage will be reported to ED in
−Removed: connection with the Company’s next annual financial statement and compliance audit submissions.
−Removed: Our calculations of the 90/10
−Removed: Rule percentage for the 2025 fiscal year for HDMC, CCC, Integrity, and CCMCC are due on December 31, 2025 and each are expected to
−Removed: be below 90%.
−Removed: The 90/10 calculations for our institutions are subject to review and potential recalculation by ED.
−Removed: In addition, the
−Removed: 90/10 Rule is complex and there is some ambiguity in certain technical aspects of the calculation methodology by ED under the 90/10
−Removed: If ED comes out with additional guidance of interpretations that are different than our interpretations, ED could recalculate
−Removed: the 90/10 Rule percentages of our institutions, which could result in one or more of the percentages exceeding 90%.
−Removed: eligibility to participate in Title IV Programs for any of our institutions would have a significant impact on the rate at which our
−Removed: students enroll in our programs and on our business and results of operations.
−Removed: Moreover, if an institution violated the 90/10 Rule
−Removed: and became ineligible to participate in Title IV Programs but continued to disburse Title IV Program funds, ED would require the
−Removed: institution to repay all Title IV Program funds received by the institution after the effective date of the loss of eligibility.
+Added: CCMCC’s 90/10 Rule
+Added: percentage available at the time the Company was acquiring CCMCC was 48.63%, for its 2025 fiscal year was 59.80%, and the percentage
+Added: for the 2026 fiscal year is expected to be below 90%.
+Added: Our calculations of the 90/10 Rule percentage for the 2026 fiscal year for HDMC,
+Added: CCC, Integrity, and CCMCC are due on December 31, 2026 and each is expected to be below 90%.
+Added: The 90/10 calculations for our institutions
+Added: are subject to review and potential recalculation by ED.
+Added: In addition, the 90/10 Rule is complex and there is some ambiguity in certain
+Added: technical aspects of the calculation methodology by ED under the 90/10 Rule.
+Added: If ED comes out with additional guidance or interpretations
+Added: that are different than our interpretations, ED could recalculate the 90/10 Rule percentages of our institutions, which could result
+Added: in one or more of the percentages exceeding 90%.
+Added: A loss of eligibility to participate in Title IV Programs for any of our institutions
+Added: would have a significant impact on the rate at which our students enroll in our programs and on our business and results of operations.
+Added: Moreover, if an institution violated the 90/10 Rule and became ineligible to participate in Title IV Programs but continued to disburse
+Added: Title IV Program funds, ED would require the institution to repay all Title IV Program funds received by the institution after the effective
+Added: date of the loss of eligibility.
amended the 90/10 Rule by treating other federal student financial assistance funds in the same manner as Title IV Program funds in the
17 unchanged sentences
However, under a provision of the OBBBA that
−Removed: will be effective July 1, 2026, institutions are permitted to limit the total amount of loans that a student may borrow, and that a parent
+Added: became effective July 1, 2026, institutions are permitted to limit the total amount of loans that a student may borrow, and that a parent
may borrow on behalf of a student, as long as the limit is applied consistently to all students in a program of study.
5 unchanged sentences
involving us could require a significant amount of resources.
−Removed: to reduce the 90/10 Rule percentage for our institutions have and may in the future involve taking measures that involve interpretations
−Removed: of the 90/10 Rule that are without clear precedent, reduce our revenue or increase our operating expenses (or all of the foregoing, in
−Removed: each case perhaps significantly).
−Removed: Because of the changes to the 90/10 Rule made by ARPA and ED, we may be required to make structural
−Removed: changes to our business to remain in compliance, which changes may materially alter the manner in which we conduct our business and materially
−Removed: and adversely impact our business, financial condition, results of operations and cash flows.
−Removed: Furthermore, these required changes could
−Removed: be unsuccessful and could make more difficult our ability to comply with other important regulatory requirements, such as the cohort
−Removed: default rate regulations.
+Added: to reduce the 90/10 Rule percentage for our institutions have involved and may in the future involve taking measures that involve
+Added: interpretations of the 90/10 Rule that are without clear precedent, reduce our revenue or increase our operating expenses (or all of
+Added: the foregoing, in each case perhaps significantly).
+Added: Because of the changes to the 90/10 Rule made by ARPA and ED, we may be required
+Added: to make structural changes to our business to remain in compliance, which changes may materially alter the manner in which we
+Added: conduct our business and materially and adversely impact our business, financial condition, results of operations and cash flows.
+Added: Furthermore, these required changes could be unsuccessful and could make more difficult our ability to comply with other important
+Added: regulatory requirements, such as the cohort default rate regulations.
we cannot predict the need or timing of any such changes, whether these changes would be successful in maintaining compliance with the
90/10 Rule or whether such changes will have other adverse effects on our business.
+Added: current proposed regulatory agenda includes an intent to address certain Title IV eligibility issues via negotiated rulemaking, including
+Added: amendments to the 90/10 Rule.
+Added: We cannot predict whether or when ED may amend the 90/10 Rule or the impact any changes to the 90/10 Rule
+Added: may have on our schools.
default rate.
16 unchanged sentences
would have negative impacts on our operations .”
−Removed: In September 2025, ED released the final cohort
−Removed: default rates for the 2022 federal fiscal year.
−Removed: These are the most recent final rates published by ED.
−Removed: The rates for our existing institutions
−Removed: for the 2022, 2021, and 2020 federal fiscal years are as follows:
+Added: September 2025, ED released the final cohort default rates for the 2022 federal fiscal year.
+Added: These are the most recent final rates published
+Added: The rates for our existing institutions for the 2022, 2021, and 2020 federal fiscal years are as follows:
HDMC 0%, 0%, and 0%;
1 unchanged sentence
Integrity 0%, 0%, and 0%;
−Removed: CCMCC 0%, 0%, and 0%, respectively.
−Removed: Consequently, none of our institutions had a cohort default rate equal to or greater than 30% for
−Removed: the 2022, 2021, and 2020 federal fiscal years.
−Removed: During the COVID-19 pandemic, ED temporarily suspended federal student loan repayment obligations.
+Added: and CCMCC 0%, 0%, and 0%, respectively.
+Added: Consequently, none of our institutions had a cohort
+Added: default rate equal to or greater than 30% for the 2022, 2021, and 2020 federal fiscal years.
+Added: In March 2026, ED released the draft cohort
+Added: default rates for the 2023 federal fiscal year.
+Added: The draft rates for our institutions for the 2023 federal fiscal year are as follows:
+Added: HDMC 0.3%, CCC 1.4%, Integrity 0%, and CCMCC 0.5%.
+Added: During the COVID-19 pandemic, ED temporarily suspended federal student loan repayment
This suspension, which lasted over three years, contributed to a reduction in our cohort default rates.
−Removed: Our cohort default rates could
−Removed: be substantially higher for the periods after October 2023, when the suspension expired if borrowers do not timely repay their federal
−Removed: student loans.
−Removed: We are engaging in activities aimed at reminding borrowers of their obligations to repay loans and to reduce the number
−Removed: of borrowers who default on their loans;
−Removed: however, we cannot predict or guarantee that these activities will be successful or that the
−Removed: cohort default rates will not increase or exceed applicable eligibility thresholds.
+Added: Our cohort default
+Added: rates could be substantially higher for the periods after October 2023, when the suspension expired if borrowers do not timely repay
+Added: their federal student loans.
+Added: We are engaging in activities aimed at reminding borrowers of their obligations to repay loans and to reduce
+Added: the number of borrowers who default on their loans;
+Added: however, we cannot predict or guarantee that these activities will be successful
+Added: or that the cohort default rates will not increase or exceed applicable eligibility thresholds.
Responsibility Standards.
5 unchanged sentences
financial responsibility measurement is the institution’s composite score, which is calculated by ED based on three ratios:
−Removed: the equity ratio, which
−Removed: measures the institution’s capital resources, ability to borrow and financial viability;
−Removed: the primary reserve ratio,
−Removed: which measures the institution’s ability to support current operations from expendable resources;
−Removed: the net income ratio, which
−Removed: measures the institution’s ability to operate at a profit.
+Added: equity ratio, which measures the institution’s capital resources, ability to borrow and financial viability;
+Added: primary reserve ratio, which measures the institution’s ability to support current operations from expendable resources;
+Added: net income ratio, which measures the institution’s ability to operate at a profit.
assigns a strength factor to the results of each of these ratios on a scale from negative 1.0 to positive 3.0, with negative 1.0 reflecting
24 unchanged sentences
that institution may establish its eligibility to participate in the Title IV Programs on an alternative basis by, among other things:
−Removed: posting a letter of credit
−Removed: in an amount equal to at least 50% of the total Title IV Program funds received by the institution during the institution’s
−Removed: most recently completed fiscal year;
−Removed: posting a letter of credit
−Removed: in an amount equal to at least 10% of the Title IV Program funds received by the institution during its most recently completed fiscal
−Removed: year accepting provisional certification;
−Removed: complying with additional ED monitoring requirements and agreeing to receive Title IV Program
−Removed: funds under an arrangement other than ED’s standard advance funding arrangement.
+Added: a letter of credit in an amount equal to at least 50% of the total Title IV Program funds received by the institution during the
+Added: institution’s most recently completed fiscal year;
+Added: a letter of credit in an amount equal to at least 10% of the Title IV Program funds received by the institution during its most recently
+Added: completed fiscal year accepting provisional certification;
+Added: complying with additional ED monitoring requirements and agreeing to receive
+Added: Title IV Program funds under an arrangement other than ED’s standard advance funding arrangement.
in the future, we are required to satisfy ED’s standards of financial responsibility on an alternative basis, including potentially
1 unchanged sentence
including loss of Title IV Program eligibility.
−Removed: ED annually evaluates the financial responsibility
−Removed: of HDMC, CCC, Integrity, and CCMCC on a consolidated basis.
−Removed: We have calculated our composite score for the 2024 fiscal year to be 3.0;
−Removed: however, this score is subject to determination by ED based on its review of our consolidated audited financial statements for the 2024
−Removed: Our next composite score will be calculated based on audited financial statements for the 2025 fiscal year due for submission
−Removed: to ED by December 31, 2025.
−Removed: We expect the composite score for the 2025 fiscal year to exceed 1.5, but the final composite score is subject
−Removed: to our final calculation and to determination by ED based on its review of our consolidated financial statements for the 2025 fiscal year.
−Removed: However, if our composite scores in the future were to decrease, we may become subject to the additional requirements noted above or our
−Removed: Title IV Program eligibility could be affected.
−Removed: We cannot predict how long it will take ED to make its determination or the outcome of
−Removed: its determination.
−Removed: On January 30, 2024, due to a failure to timely return unearned Title IV funds to ED, Integrity was required to submit
−Removed: an acceptable form of financial protection for 25% of the refunds that were made for the fiscal year ended June 30, 2023 in the amount
+Added: ED’s financial responsibility standards also
+Added: include other requirements which, among other things, can deem an institution to lack financial responsibility if (1) the institution’s
+Added: audited financial statements include an adverse, qualified, or disclaimed auditor’s opinion unless ED determines such opinion does
+Added: not have a significant bearing on the institution’s financial condition, or (2) a disclosure in the notes to the financial statements
+Added: about diminished liquidity, ability to continue operations, or ability to continue as a going concern unless ED determines this condition
+Added: has been alleviated.
+Added: annually evaluates the financial responsibility of HDMC, CCC, Integrity, and CCMCC on a consolidated basis.
+Added: We have calculated our composite
+Added: score for the 2025 fiscal year to be 3.0;
+Added: however, this score is subject to determination by ED based on its review of our consolidated
+Added: audited financial statements for the 2025 fiscal year.
+Added: Our next composite score will be calculated based on audited financial statements
+Added: for the 2026 fiscal year due for submission to ED by December 31, 2026.
+Added: We expect the composite score for the 2026 fiscal year to exceed
+Added: 1.5, but the final composite score is subject to our final calculation and to determination by ED based on its review of our consolidated
+Added: financial statements for the 2026 fiscal year.
+Added: However, if our composite scores in the future were to decrease, we may become subject
+Added: to the additional requirements noted above or our Title IV Program eligibility could be affected.
+Added: We cannot predict how long it will
+Added: take ED to make its determination or the outcome of its determination.
+Added: January 30, 2024, due to a failure to timely return unearned Title IV funds to ED, Integrity was required to submit an acceptable form
+Added: of financial protection for 25% of the refunds that were made for the fiscal year ended June 30, 2023 in the amount of $18,828.
+Added: about February 13, 2025, due to a failure to timely return unearned Title IV Program funds to ED in the 2023 fiscal year (prior to the
+Added: Company acquiring CCMCC), CCMCC was required to submit an acceptable form of financial protection in the amount of $15,356.
+Added: and CCMCC have submitted the required financial protection to ED.
+Added: See “Education Regulations - Return of Title IV Program Funds.”
October 31, 2023, ED published final regulations with a general effective date of July 1, 2024 that, among other things, amended the
9 unchanged sentences
The mandatory triggering events include:
−Removed: an institution with a composite
−Removed: score of less than 1.5 has a recalculated composite score of less than 1.0 as determined by ED as a result of an institutional liability
−Removed: from a monetary award or judgment or settlement resulting from a legal proceeding;
−Removed: an institution (or an entity
−Removed: that has submitted financial statements to ED in connection with a change in ownership) is subject to a government enforcement action
−Removed: (sued by a federal or state authority or via a qui tam action) and the action has been pending for 120 days and no motion to dismiss
−Removed: is pending or has been granted;
−Removed: the institution’s
−Removed: recalculated composite score is less than 1.0 after ED initiates action to recoup funds from institution after BDR claim decided
−Removed: in borrower’s favor;
−Removed: an institution or entity
−Removed: that submitted an application with ED for a change of ownership has a recalculated composite score is less than 1.0 after a final
−Removed: monetary judgment, award or settlement that was entered against it at any point through the end of the second full fiscal year after
−Removed: the change of ownership;
−Removed: a proprietary institution
−Removed: with a composite score of less than 1.5 or that underwent a change of ownership in the current or previous fiscal year has a recalculated
−Removed: composite score of.
−Removed: less than 1.0 as determined by ED as a result of a withdrawal of owner’s equity from the institution unless
−Removed: certain exceptions apply;
−Removed: at least half of Title
−Removed: IV funds in the institution’s most recently completed fiscal year are for “failing” gainful employment programs;
−Removed: the institution is required
−Removed: to submit a teach-out plan due to financial concerns;
−Removed: the SEC takes certain actions
−Removed: against a publicly listed entity that directly or indirectly owns at least 50% of an institution or such entity fails to comply with
−Removed: certain filing requirements;
−Removed: the institution did not
−Removed: receive at least 10 percent of its revenue from sources other than Federal educational assistance as calculated under 90/10 rule
−Removed: during its most recently completed fiscal year;
−Removed: the institution’s
−Removed: two most recent cohort default rates are 30 percent or greater, unless a pending appeal could reduce one of the rates;
+Added: an institution with a composite score of less than 1.5 has a recalculated composite score of less than 1.0 as determined by ED as a result of an institutional liability from a monetary award or judgment or settlement resulting from a legal proceeding;
+Added: an institution (or an entity that has submitted financial statements to ED in connection with a change in ownership) is subject to a government enforcement action (sued by a federal or state authority or via a qui tam action) and the action has been pending for 120 days and no motion to dismiss is pending or has been granted;
the institution’s
−Removed: composite score is less than 1.0 when recalculated to reflect the offset of distribution after a contribution;
−Removed: the institution or entity
−Removed: included in financial statements is subject to adverse or impermissible conditions under a financing arrangement as a result of ED
−Removed: the institution declares
−Removed: financial exigency to government agency or accrediting agency;
−Removed: the institution or an owner
−Removed: files for a receivership or is ordered to appoint a receiver.
+Added: recalculated composite score is less than 1.0 after ED initiates action to recoup funds from the institution after a BDR claim
+Added: is decided in the borrower’s favor;
+Added: an institution or entity that submitted an application with ED for a change of ownership has a recalculated composite score of less than 1.0 after a final monetary judgment, award or settlement that was entered against it at any point through the end of the second full fiscal year after the change of ownership;
+Added: a proprietary institution with a composite score of less than 1.5 or that underwent a change of ownership in the current or previous fiscal year has a recalculated composite score of less than 1.0 as determined by ED as a result of a withdrawal of owner’s equity from the institution unless certain exceptions apply;
+Added: the institution received
+Added: at least half of its Title IV funds in the institution’s most recently completed fiscal year from educational programs
+Added: that are “failing” under the earnings accountability criteria;
+Added: the institution is required to submit a teach-out plan due to financial concerns;
+Added: the SEC takes certain actions against a publicly listed entity that directly or indirectly owns at least 50% of an institution or such entity fails to comply with certain filing requirements;
+Added: institution did not receive at least 10 percent of its revenue from sources other than Federal educational assistance as calculated
+Added: under 90/10 rule during its most recently completed fiscal year;
+Added: institution’s two most recent cohort default rates are 30 percent or greater, unless a pending appeal could reduce one of the
+Added: institution’s composite score is less than 1.0 when recalculated to reflect the offset of distribution after a contribution;
+Added: institution or entity included in financial statements is subject to adverse or impermissible conditions under a financing arrangement
+Added: as a result of ED action;
+Added: institution declares financial exigency to government agency or accrediting agency;
+Added: institution or an owner files for a receivership or is ordered to appoint a receiver.
also may determine that an institution lacks financial responsibility if one or more of the following discretionary triggering events
occurs and the event is likely to have a significant adverse effect on the financial condition of the institution:
−Removed: a show cause or similar
−Removed: order from the institution’s accrediting agency or a government authority;
−Removed: a notice from the institution’s
−Removed: state authorizing or licensing agency of an intent to withdraw or terminate the institution’s state authorization or licensure
−Removed: if the institution does not take steps to comply with state requirements;
−Removed: the institution (or an
−Removed: owner entity covered by the regulation) is subject to a default, delinquency, or other adverse creditor event or to a condition not
−Removed: permitted under the regulation under or related to a loan agreement or other financing agreement or has a judgement awarding monetary
−Removed: relief entered against it that is subject to appeal or under appeal;
−Removed: there is a significant
−Removed: fluctuation in Pell Grant and/or Direct Loans received by an institution during a period of award years;
−Removed: high annual drop-out rates
−Removed: from the institution as determined by ED;
−Removed: ED requires the institutions
−Removed: to provide additional financial reporting due to a failure to meet financial responsibility standards or indicators of significant
−Removed: change in the financial condition of the institution;
−Removed: ED forms a group process
−Removed: to consider pending borrower defense to repayment claims that could be subject to recoupment;
−Removed: a program is discontinued
−Removed: that enrolls more than 25% of the institution’s total enrolled students who receive Title IV Program funds;
−Removed: the institution closes
−Removed: a location that enrolls more than 25% of its total enrolled students who receive Title IV Program funds;
−Removed: the institution, or one
−Removed: of its programs, is cited by a State agency for failing to meet requirements;
−Removed: the institution, or one
−Removed: of its programs, loses eligibility to participate in another Federal educational assistance program;
−Removed: a publicly traded company
−Removed: that directly or indirectly owns at least 50% of the institution discloses in public securities exchange filing that it is under
−Removed: investigation for possible violation of law;
−Removed: the institution is cited
−Removed: by another federal agency and risks losing education assistance funds by that agency;
−Removed: the institution is required
−Removed: to submit a teach-out plan due to concerns other than those constituting a mandatory triggering event;
−Removed: any other event or condition
−Removed: that ED finds is likely to have significant adverse effect on the financial condition of the institution.
+Added: show cause or similar order from the institution’s accrediting agency or a government authority;
+Added: notice from the institution’s state authorizing or licensing agency of an intent to withdraw or terminate the institution’s
+Added: state authorization or licensure if the institution does not take steps to comply with state requirements;
+Added: institution (or an owner entity covered by the regulation) is subject to a default, delinquency, or other adverse creditor event
+Added: or to a condition not permitted under the regulation under or related to a loan agreement or other financing agreement or has a judgment
+Added: awarding monetary relief entered against it that is subject to appeal or under appeal;
+Added: is a significant fluctuation in Pell Grant and/or Direct Loans received by an institution during a period of award years;
+Added: annual drop-out rates from the institution as determined by ED;
+Added: requires the institutions to provide additional financial reporting due to a failure to meet financial responsibility standards or
+Added: indicators of significant change in the financial condition of the institution;
+Added: forms a group process to consider pending borrower defense to repayment claims that could be subject to recoupment;
+Added: program is discontinued that enrolls more than 25% of the institution’s total enrolled students who receive Title IV Program
+Added: institution closes a location that enrolls more than 25% of its total enrolled students who receive Title IV Program funds;
+Added: institution, or one of its programs, is cited by a State agency for failing to meet requirements;
+Added: institution, or one of its programs, loses eligibility to participate in another Federal educational assistance program;
+Added: publicly traded company that directly or indirectly owns at least 50% of the institution discloses in public securities exchange
+Added: filing that it is under investigation for possible violation of law;
+Added: institution is cited by another federal agency and risks losing education assistance funds by that agency;
+Added: institution is required to submit a teach-out plan due to concerns other than those constituting a mandatory triggering event;
+Added: other event or condition that ED finds is likely to have a significant adverse effect on the financial condition of the
regulations require an institution to notify ED of the occurrence of a mandatory or discretionary triggering event and, in some cases,
18 unchanged sentences
access to Title IV Program funds, which would materially and adversely reduce the enrollments and revenues of our institutions.
−Removed: proposed regulatory agenda first published in early September 2025 includes an intent to address certain issues including financial responsibility
−Removed: requirements via negotiated rulemaking.
−Removed: We cannot predict how ED will address these requirements or the impact the changes to financial
−Removed: responsibility requirements may have on our schools.
+Added: current proposed regulatory agenda includes an intent to address certain topics including financial responsibility requirements via negotiated
+Added: We cannot predict whether or how ED will address these requirements or the impact any future changes to financial responsibility
+Added: requirements may have on our schools.
of Title IV Program Funds.
14 unchanged sentences
fiscal year ended June 30, 2023 in the amount of $18,828.
−Removed: In January through March 2024, ED conducted negotiated rulemaking to prepare
−Removed: proposed regulations on several topics including the rules pertaining to returns of Title IV Program funds.
−Removed: On July 24, 2024, ED promulgated
−Removed: proposed amended regulations related to return of Title IV calculations.
−Removed: ED published the final regulations on January 3, 2025, with
−Removed: a general effective date of July 1, 2026.
−Removed: The regulations codify ED’s guidance requiring the date of determination of withdrawal
−Removed: to be documented within 14 days after the student’s last date of attendance for institutions that take attendance;
−Removed: remove the option
−Removed: for clock-hour programs to use the “cumulative” method to calculate Title IV earned;
−Removed: and changes Return of Title IV calculations
−Removed: for programs offered in modules.
−Removed: We are evaluating whether and the extent to which the new regulations may negatively impact our performance
−Removed: of return of title IV.
+Added: On or about February 13, 2025, due to a failure to timely return unearned Title
+Added: IV Program funds to ED in the 2023 fiscal year (prior to the Company acquiring CCMCC), CCMCC was required to submit an acceptable form
+Added: of financial protection in the amount of $15,356.
+Added: Integrity and CCMCC have submitted the required financial protection to ED.
+Added: January through March 2024, ED conducted negotiated rulemaking to prepare proposed regulations on several topics including the rules
+Added: pertaining to returns of Title IV Program funds.
+Added: On July 24, 2024, ED promulgated proposed amended regulations related to return of
+Added: Title IV calculations.
+Added: ED published the final regulations on January 3, 2025, with a general effective date of July 1, 2026.
+Added: regulations codify ED’s guidance requiring the date of determination of withdrawal to be documented within 14 days after the
+Added: student’s last date of attendance for institutions that take attendance;
+Added: remove the option for clock-hour programs to use the
+Added: “cumulative” method to calculate Title IV earned;
+Added: and change Return of Title IV calculations for programs offered in
ED has promulgated a substantial number of new regulations in recent years that impact our business, including, but
6 unchanged sentences
business, requiring a large number of reporting and operational changes and resulting in changes to and elimination of certain educational
−Removed: July 24, 2025, ED announced it intends to establish two negotiated rulemaking committees:
−Removed: one that will consider changes to the federal
−Removed: student loan programs and one that will consider institutional and programmatic accountability, including changes to the Pell Grant.
−Removed: The rulemaking is intended to implement recent changes to the Title IV, HEA programs included in the OBBBA.
+Added: July 24, 2025, ED announced its intent to establish two negotiated rulemaking committees to implement recent changes to the Title IV,
+Added: HEA programs included in the OBBBA.
+Added: The first of the two negotiated rulemaking committees (the RISE Committee) convened for one session
+Added: in September and October and one session in November.
+Added: On November 6, 2025, the RISE Committee reached consensus on proposed regulations
+Added: related to topics including, for example, new federal student loan borrowing limits for certain borrowers and educational programs, and
+Added: the agreed upon language was incorporated into a notice of proposed rulemaking published January 30, 2026.
+Added: After a period of public notice
+Added: and comment, ED published the final rule in the Federal Register on May 1, 2026.
+Added: The final rule includes reduced limits on PLUS loans
+Added: taken out by parent borrowers for undergraduate students to the amounts of $20,000 annually and $65,000 in the aggregate per dependent
+Added: It also limits aggregate loans over a student borrower’s lifetime to $257,500.
+Added: This limitation does not apply to student
+Added: borrowers during the expected time to complete their credential if the student is enrolled in a program as of June 30, 2026 and a Direct
+Added: Loan was made for the program prior to July 1, 2026.
+Added: Institutions will also be required to reduce federal student loan limits for students
+Added: who are enrolled as less than full-time students or enrolled in a period of enrollment of less than one full academic year.
+Added: The new regulations
+Added: went into effect on July 1, 2026 along with the relevant changes in the OBBBA which became effective on that date.
+Added: second of the two negotiated rulemaking committees (the AHEAD Committee) convened for one session in December 2025 and one session in
+Added: January 2026.
+Added: On December 12, 2025, the AHEAD Committee reached consensus on proposed regulations related to Pell Grants, including the
+Added: new Workforce Pell program.
+Added: The agreed upon language was incorporated into a notice of proposed rulemaking published March 9, 2026 and
+Added: ED solicited comments on the proposed rule with such comments due by April 8, 2026.
+Added: ED published the final regulations on May 19, 2026.
+Added: The regulations clarify which educational programs are eligible for the Workforce Pell program introduced by the OBBBA.
+Added: Under the OBBBA
+Added: and the final regulations, to be eligible a program must meet certain short-term length requirements (at least 8 but less than 15
+Added: weeks and (i) at least 150 but less than 600 clock hours, (ii) at least four but less than sixteen semester or trimester hours, or (iii)
+Added: at least six but less than 24 quarter hours) and comply with certain other prohibitions.
+Added: The regulations also clarify processes for approval
+Added: by state governors, the Secretary of Education, and a separate “value-added earnings” measure.
+Added: Among other requirements,
+Added: approval from a governor requires the governor to determine the program prepares students for an occupation that aligns with the state’s
+Added: workforce needs, and the Secretary determines whether the program meets completion, placement rate, and value-added earnings requirements.
+Added: To comply with the value-added earnings measure, the program’s total published tuition and fees may not exceed the value-added
+Added: earnings (as defined in the final regulations) of working students who received a Pell Grant for enrollment in the program and completed
+Added: the program within the applicable cohort period.
+Added: The new regulations went into effect on July 20, 2026.
+Added: Many of our programs are longer
+Added: than the eligibility requirements for the Workforce Pell program, therefore we do not plan to participate at this time, but may evaluate
+Added: potential opportunities under the regulations in the future.
+Added: January 9, 2026, the AHEAD Committee reached consensus on proposed regulations that create new accountability measures based in part
+Added: on the accountability metrics in the OBBBA and the metrics in the existing gainful employment rules.
+Added: The consensus language was incorporated
+Added: into a notice of proposed rulemaking published April 20, 2026 which underwent a period of public notice and comment (with such comments
+Added: due by May 20).
+Added: ED published the final regulations on July 1, 2026.
+Added: The new earnings premium measure applies to all degree and non-degree
+Added: programs at all institutions and eliminates the debt-to-earnings rate measure in the existing gainful employment regulations.
+Added: one or more of our programs fail to comply with the new requirements, those programs could lose access to Title IV Direct Loans, and
+Added: potentially all Title IV eligibility, which could have a material adverse effect on our student population and our revenues.
+Added: regulations could also require us to modify or eliminate programs to comply with the new regulations.
See “Education Regulations
−Removed: – Congressional Action.” We expect the new requirements will impact our institutions and operations, but we cannot predict
−Removed: the ultimate scope, content, and impact of the new OBBBA requirements under future ED regulations and guidance.
+Added: - Financial Value Transparency, Gainful Employment, and Accountability Regulations.”
+Added: expect the new regulations will impact our institutions and operations, but we cannot predict the ultimate scope, content, and impact
+Added: of the regulations and guidance including any regulations further implementing the new OBBBA requirements.
We are currently assessing,
−Removed: and will continue to assess, the potential impact of the requirements on us and our institutions and to monitor the negotiated rulemaking
+Added: and will continue to assess, the potential impact of the new requirements on us and our institutions and to monitor the negotiated rulemaking
+Added: held negotiated rulemaking sessions between April and May 2026 to consider amendments to the regulations respecting the Secretary’s
+Added: recognition of accrediting agencies and related institutional eligibility requirements for the Title IV Programs.
+Added: See “Education
+Added: Regulations – ED Recognition of Accrediting Agencies.” The negotiators reached consensus on the proposed rule, and on August
+Added: 19, 2026, ED published a notice of proposed rulemaking containing language materially identical to the consensus language which will undergo a period of public notice and comment before
+Added: ED makes any amendments and publishes the final regulations.
+Added: The earliest date the new regulations could take effect is July 1, 2027.
+Added: Any future regulations or regulatory changes resulting from this negotiated rulemaking process could impact the ability of the accreditors
+Added: that accredit our institutions to maintain recognition by ED and the accreditation requirements applicable to our institutions.
+Added: predict whether and how such rulemaking would impact our institutions and operations.
April 4, 2025, ED announced its intention to conduct negotiated rulemaking to prepare proposed regulations on topics pertaining to Title
5 unchanged sentences
June 30, 2025 to July 2, 2025.
−Removed: We cannot predict the ultimate timing, content, and impact of any regulations and guidance ED might propose
−Removed: and ultimately adopt.
−Removed: In addition, the President directed federal agencies on April 9, 2025 to identify existing regulations that are
−Removed: unlawful or otherwise objectionable and to take steps to repeal or modify these regulations.
−Removed: We cannot predict what rules ED might attempt
−Removed: to repeal or modify, the timing and outcome of these efforts, or the impact of any regulatory repeals of modifications on our business
−Removed: proposed regulatory agenda published in early September 2025 indicates an intent to address several topics (including through rulemaking),
−Removed: including accreditation, changes in ownership, cash management, administrative capability, and financial responsibility requirements,
−Removed: civil rights investigations, and privacy of education records.
−Removed: Whether via sub-regulatory guidance or a rulemaking process, we cannot
−Removed: predict how ED’s actions on these topics will impact schools like ours.
−Removed: Future regulatory actions by ED or other agencies that
−Removed: regulate our institutions are likely to occur and to have significant impacts on our business, require us to change our business practices
−Removed: and incur costs of compliance and of developing and implementing changes in operations, as has been the case with past regulatory changes.
+Added: ED published a notice of proposed rulemaking on public service loan forgiveness on August 18, 2025, and
+Added: published the final regulations on October 31, 2025 with an effective date of July 1, 2026.
+Added: The regulations include provisions that,
+Added: among other things, amend components of the public service loan forgiveness program.
+Added: current proposed regulatory agenda indicates an intent to address several topics (including through rulemaking), including changes in
+Added: ownership, cash management, administrative capability, program length requirements, financial responsibility requirements, and the 90/10
+Added: We cannot predict how ED’s actions on these topics will impact schools like ours.
+Added: Future regulatory actions by ED or other
+Added: agencies that regulate our institutions are likely to occur and to have significant impacts on our business, require us to change our
+Added: business practices and incur costs of compliance and of developing and implementing changes in operations, as has been the case with
+Added: past regulatory changes.
cannot predict with certainty the ultimate combined impact of the regulatory changes which have occurred in recent years, nor can we
54 unchanged sentences
timely submits certain documentation during the course of ED’s review.
−Removed: ED’s proposed regulatory agenda published in early
−Removed: September of 2025 includes an intent to address certain issues including change of ownership requirements.
−Removed: We cannot predict how
−Removed: ED will address these requirements or the impact the changes to change of ownership requirements may have on our schools.
+Added: ED’s current proposed regulatory agenda includes an
+Added: intent to address certain issues including change of ownership requirements.
+Added: We cannot predict how ED will address these requirements
+Added: or the impact the changes to change of ownership requirements may have on our schools.
time required for ED to act on such an application may vary substantially.
11 unchanged sentences
could be impacted by any conditions or restrictions imposed by ED or other agencies on the institution under our ownership.
−Removed: December 31, 2019, we entered into a Membership Interest Purchase Agreement with the sole member of Integrity.
−Removed: We purchased from the
−Removed: sole member of Integrity on that date 24.5% of her interest and obtained an exclusive option to acquire her remaining membership interest
−Removed: upon payment of $100, which was exercised on September 15, 2020.
−Removed: For purposes of our financial statements, our acquisition of Integrity
−Removed: is deemed to have been effective as of December 31, 2019.
−Removed: We believe that a change in ownership and control of Integrity did not occur
−Removed: until September 15, 2020 under the change in ownership and control standards of ED and the other educational agencies that regulate Integrity,
−Removed: but these standards are subject to interpretation by the respective agencies.
−Removed: The review by ED of the change in ownership and control
−Removed: of Integrity in connection with our acquisition of Integrity remains ongoing.
−Removed: Integrity currently holds a temporary provisional program
−Removed: participation agreement with ED in connection with our acquisition of the institution, which has continued its Title IV Program participation
−Removed: on a month-to-month basis pending ED’s approval of the change in ownership and control.
−Removed: If ED concludes that a change in ownership
−Removed: or control of Integrity occurred prior to September 15, 2020, we could be subject to liabilities or other sanctions by ED, which could
−Removed: have a material adverse effect on our business, financial condition, results of operations, and cash flows.
−Removed: Education Antioch, LLC, a wholly-owned subsidiary of Legacy LLC (as defined herein) (the “Buyer”) entered into the APA with
−Removed: Legacy Education Inc., Legacy Education, LLC, a wholly-owned subsidiary of the Company (“Legacy LLC” and together with the
−Removed: Company and the Buyer, the “Buyer Parties”), CCMCC, Contra Costa Medical Career College Online, Inc.
−Removed: (“CCMCC Online”
−Removed: and together with CCMCC, “Sellers”) and, solely with respect to certain portions of the APA, Stacey Orozco and Bulmaro Orozco,
−Removed: the sole owners CCMCC and CCMCC Online (the “CCMCC Transaction”).
+Added: June 29, 2026, ED confirmed Integrity remains an eligible institution that
+Added: qualifies to participate in the Title IV Programs and issued a provisional program participation agreement to Integrity, which will remain
+Added: in effect until March 31, 2029.
+Added: Education Antioch, LLC, a wholly-owned subsidiary of Legacy LLC (as defined herein) (the “Buyer”) entered into an Asset
+Added: Purchase Agreement (“APA”) with Legacy Education Inc., Legacy Education, LLC, a wholly-owned subsidiary of the Company
+Added: (“Legacy LLC” and together with the Company and the Buyer, the “Buyer Parties”), CCMCC, Contra Costa Medical
+Added: Career College Online, Inc.
+Added: (“CCMCC Online” and together with CCMCC, “Sellers”) and, solely with respect to
+Added: certain portions of the APA, Stacey Orozco and Bulmaro Orozco, the sole owners of CCMCC and CCMCC Online (the “CCMCC
+Added: Transaction”).
The CCMCC Transaction was consummated on December 18, 2024.
35 unchanged sentences
Institutions that are licensed by BPPE by means of accreditation,
−Removed: like CCMC, are required to notify BPPE of the change within 30 days of the change and demonstrate that the substantive change was
+Added: like CCMCC, are required to notify BPPE of the change within 30 days of the change and demonstrate that the substantive change was
made in accordance with the institution’s accreditation standards.
10 unchanged sentences
of ownership.
−Removed: California State Approving
−Removed: Agency for Veterans Education (“CSAAVE”) :
−Removed: CSAAVE requires approved institutions to make a post-change submission
−Removed: to CSAAVE for approval of the change when there has been a material change to the institution’s current approval.
−Removed: CCMCC provided
−Removed: notice to CSAAVE of the change on November 12, 2024, and submitted the change of ownership forms.
−Removed: On April 28, 2025, CCMCC provided additional
−Removed: information to CSAAVE regarding its reapproval and on May 1, 2025, CSAAVE approved the application.
−Removed: Accreditation Bureau
−Removed: of Health Education Schools (“ABHES”) :
−Removed: ABHES requires institutions that hold ABHES programmatic accreditation to
−Removed: notify it of any change in organizational oversight or legal structure, and to submit a completed application for change in legal
+Added: State Approving Agency for Veterans Education (“CSAAVE”) :
+Added: CSAAVE requires approved institutions to make a post-change
+Added: submission to CSAAVE for approval of the change when there has been a material change to the institution’s current approval.
+Added: CCMCC provided notice to CSAAVE of the change on November 12, 2024, and submitted the change of ownership forms.
+Added: On April 28, 2025,
+Added: CCMCC provided additional information to CSAAVE regarding its reapproval and on May 1, 2025, CSAAVE approved the application.
+Added: Accreditation
+Added: Bureau of Health Education Schools (“ABHES”) :
+Added: ABHES requires institutions that hold ABHES programmatic accreditation
+Added: to notify it of any change in organizational oversight or legal structure, and to submit a completed application for change in legal
status, ownership, or control within five days after the change.
1 unchanged sentence
dated January 29, 2025, ABHES approved the change in ownership.
−Removed: California Board of
−Removed: Vocational Nursing and Psychiatric Technicians (“BVNPT”) :
−Removed: BVNPT instructed CCMCC to submit formal notification of
−Removed: the change of ownership after receiving BVNPT’s approval to admit a new class of students.
−Removed: CCMCC received such approval on
−Removed: February 4, 2025 and submitted the required form for the change of ownership on February 12, 2025, and is awaiting approval.
−Removed: California Department
−Removed: of Public Health, Laboratory Field Services (“CDPH”) :
−Removed: CDPH requires certain training programs undergoing a change
−Removed: of ownership to notify CDPH within 30 days after the change has occurred and submit a new application package.
−Removed: CCMCC notified CDPH
−Removed: of the change and submitted the application on February 6, 2025, and is awaiting approval.
+Added: Board of Vocational Nursing and Psychiatric Technicians (“BVNPT”) :
+Added: BVNPT instructed CCMCC to submit formal notification
+Added: of the change of ownership after receiving BVNPT’s approval to admit a new class of students.
+Added: CCMCC received such approval
+Added: on February 4, 2025 and submitted the required form for the change of ownership on February 12, 2025.
+Added: BVNPT verified it had received
+Added: notice of the change of ownership on July 17, 2025.
+Added: Department of Public Health, Laboratory Field Services (“CDPH”) :
+Added: CDPH requires certain training programs undergoing
+Added: a change of ownership to notify CDPH within 30 days after the change has occurred and submit a new application package.
+Added: notified CDPH of the change and submitted the application on February 6, 2025.
+Added: CDPH approved the application, and the approval is
+Added: valid through January 2027.
+Added: CCMCC is in the process of submitting its next renewal application.
agencies require us to obtain other approvals in connection with the CCMCC Transaction, we will be required to undergo an application
47 unchanged sentences
or restrictions imposed by ED on one or more of our institutions.
−Removed: institutions may encounter difficulty timely identifying and reporting to ED on the electronic application for each of our institutions’ several hundred owners.
−Removed: Integrity may also encounter additional difficulty reporting ownership
−Removed: given ED has not yet approved the prior change in control of Integrity and, as a result, we could encounter difficulty obtaining access
−Removed: to the electronic application.
−Removed: ED has informed us that it only will require us to report owners with a five percent or greater ownership
−Removed: interest in the Company although this guidance could change in the future and we could encounter difficulty identifying and timely reporting
−Removed: owners under current or future ED guidance.
−Removed: Our institutions will also be required to timely report any additional changes to ownership
−Removed: percentages and given the frequency such changes can occur for a publicly traded company, we may have difficulty timely complying with
−Removed: ED’s reporting requirements.
−Removed: These difficulties could result in adverse action by ED, or conditions or restrictions imposed by
−Removed: ED on one or more of our institutions.
+Added: institutions may encounter difficulty timely identifying and reporting to ED on the electronic application for each of our institutions’
+Added: several hundred owners.
+Added: CCMCC may also encounter additional difficulty reporting ownership given ED has not yet approved the prior change
+Added: in control of CCMCC and, as a result, we could encounter difficulty obtaining access to the electronic application.
+Added: ED has informed us
+Added: that it only will require us to report owners with a five percent or greater ownership interest in the Company although this guidance
+Added: could change in the future and we could encounter difficulty identifying and timely reporting owners under current or future ED guidance.
+Added: Our institutions will also be required to timely report any additional changes to ownership percentages and given the frequency such
+Added: changes can occur for a publicly traded company, we may have difficulty timely complying with ED’s reporting requirements.
+Added: difficulties could result in adverse action by ED, or conditions or restrictions imposed by ED on one or more of our institutions.
we decide to issue preferred stock or additional common stock in the future, this issuance could result in a change in ownership or control
4 unchanged sentences
to appoint directors could result in a change in ownership or control requiring regulatory approval.
−Removed: We have verified that most of our education regulators and accreditors
−Removed: do not treat the initial public offering as a change in ownership or control requiring agency approval.
−Removed: If agencies require us to obtain
−Removed: approvals in connection with the initial public offering, we will be required to undergo an application process for approvals from the
−Removed: applicable agencies and could be subject to conditions or restrictions depending on the outcome of the approval process.
−Removed: notified us that we moved forward with the initial public offering without making or obtaining required pre-closing notices and approvals
−Removed: prior to the initial public offering, we could be subject to sanctions by the applicable agencies including loss of our approvals from
−Removed: these agencies.
−Removed: On July 30, 2024, ED provided written confirmation the initial public offering as described would not constitute a change
−Removed: of control under its regulations.
−Removed: However, subsequent offerings, transactions or other events could be deemed to be a change of control
−Removed: in the future.
+Added: have verified that most of our education regulators and accreditors did not treat the Company’s initial public offering that occurred
+Added: in 2024 as a change in ownership or control requiring agency approval.
+Added: If agencies require us to obtain approvals in connection with
+Added: the initial public offering, we will be required to undergo an application process for approvals from the applicable agencies and could
+Added: be subject to conditions or restrictions depending on the outcome of the approval process.
+Added: If an agency notified us that we moved forward
+Added: with the initial public offering without making or obtaining required pre-closing notices and approvals prior to the initial public offering,
+Added: we could be subject to sanctions by the applicable agencies including loss of our approvals from these agencies.
+Added: On July 30, 2024, ED
+Added: provided written confirmation the initial public offering as described would not constitute a change of control under its regulations.
+Added: However, subsequent offerings, transactions or other events could be deemed to be a change of control in the future.
regard to the agencies that institutionally accredit our institutions or authorize them to operate in the state of California:
−Removed: BPPE regulations require that institutions that are authorized based on their accredited status and which undergo a change in ownership timely submit notice of such change with accompanying documentation to demonstrate that the change was made in accordance with the applicable accreditation standards.
−Removed: On August 8, 2024, BPPE responded to our request for guidance regarding a potential change of ownership process and stated that it would look to the determinations of ABHES and ACCET with respect to the initial public offering.
−Removed: As described below, ABHES and ACCET have provided written confirmation that the initial public offering as described would not constitute a change in legal status, ownership or control under the respective standards.
−Removed: Based on those responses from ABHES and ACCET, we sought confirmation that our institutions need not undergo an approval process with BPPE prior to the offering, and BPPE confirmed on September 11, 2024 that the initial public offering would not be viewed as a change in control and would not require approval from BPPE.
−Removed: ABHES accreditation standards require that institutions undergoing a change in legal status, ownership or control submit an application for approval of the change at least 90 days in advance, and that ABHES must approve the change before it takes place.
−Removed: ABHES accreditation standards also require institutions undergoing a change in legal status, ownership or control to submit an additional application within five days after the change, which would also be subject to ABHES approval.
−Removed: We requested guidance from ABHES regarding whether the initial public offering as described will constitute a change in in legal status, ownership or control for the purposes of its accreditation standards.
−Removed: On August 12, 2024, ABHES provided written confirmation that the initial public offering as described would not constitute a change in legal status, ownership or control under its standards.
−Removed: ACCET accreditation standards require that institutions undergoing a change in ownership or control submit a notice at least ten days prior to such a change, and further submit an application for approval of such a change within ten days following the change.
−Removed: We requested guidance from ACCET regarding whether the initial public offering as described will constitute a change in ownership or control under its accreditation standards and confirmation no approval would be required from ACCET.
−Removed: On September 6, 2024, ACCET provided written confirmation that the initial public offering as described would not constitute a change in ownership or control under its standards.
−Removed: The California Board of Registered Nursing requires
−Removed: pre-closing approval of a change of ownership before it occurs and requires post-closing approval of a change in organizational structure.
−Removed: We requested confirmation from the California Board of Registered Nursing that the initial public offering as described will not be treated
−Removed: as a change in ownership that requires approval before the offering occurs, but have not received a determination from the agency.
−Removed: the California Board of Registered Nursing determines we were required to obtain the agency’s approval prior to the initial public
−Removed: offering under its statutes, rules or standards, then, as noted above, we could be subject to sanctions by this agency including potential
−Removed: loss of our approval.
−Removed: are in the process of initiating communications with our education regulators and accreditors on this subject and have not received
−Removed: responses as to whether they will treat the initial public offering as a change in ownership or control requiring agency approval.
−Removed: If we are required to go through a change of ownership and/or control review process with these agencies, one or more of these
−Removed: agencies could impose additional conditions or restrictions or delay or decline to issue an approval.
−Removed: If an agency does not require
−Removed: us to go through a change of ownership and/or control review process, we may be required to submit notices or other information to
−Removed: the agency which could result in further scrutiny or inquiries by the agency.
+Added: BPPE regulations require that institutions that are authorized based on their accredited status and which undergo a change in ownership
+Added: timely submit notice of such change with accompanying documentation to demonstrate that the change was made in accordance with the
+Added: applicable accreditation standards.
+Added: On August 8, 2024, BPPE responded to our request for guidance regarding a potential change of
+Added: ownership process and stated that it would look to the determinations of ABHES and ACCET with respect to the initial public offering.
+Added: As described below, ABHES and ACCET have provided written confirmation that the initial public offering as described would not constitute
+Added: a change in legal status, ownership or control under the respective standards.
+Added: Based on those responses from ABHES and ACCET, we
+Added: sought confirmation that our institutions need not undergo an approval process with BPPE prior to the offering, and BPPE confirmed
+Added: on September 11, 2024 that the initial public offering would not be viewed as a change in control and would not require approval
+Added: ABHES accreditation standards require that institutions undergoing a change in legal status, ownership or control submit an application
+Added: for approval of the change at least 90 days in advance, and that ABHES must approve the change before it takes place.
+Added: ABHES accreditation
+Added: standards also require institutions undergoing a change in legal status, ownership or control to submit an additional application
+Added: within five days after the change, which would also be subject to ABHES approval.
+Added: We requested guidance from ABHES regarding whether
+Added: the initial public offering as described will constitute a change in legal status, ownership or control for the purposes of its
+Added: accreditation standards.
+Added: On August 12, 2024, ABHES provided written confirmation that the initial public offering as described would
+Added: not constitute a change in legal status, ownership or control under its standards.
+Added: ACCET accreditation standards require that institutions undergoing a change in ownership or control submit a notice at least ten
+Added: days prior to such a change, and further submit an application for approval of such a change within ten days following the change.
+Added: We requested guidance from ACCET regarding whether the initial public offering as described will constitute a change in ownership
+Added: or control under its accreditation standards and confirmation no approval would be required from ACCET.
+Added: On September 6, 2024, ACCET
+Added: provided written confirmation that the initial public offering as described would not constitute a change in ownership or control
+Added: under its standards.
+Added: California Board of Registered Nursing requires pre-closing approval of a change of ownership before it occurs and requires post-closing
+Added: approval of a change in organizational structure.
+Added: We requested confirmation from the California Board of Registered Nursing that the
+Added: initial public offering as described will not be treated as a change in ownership that requires approval before the offering occurs,
+Added: but have not received a determination from the agency.
+Added: If the California Board of Registered Nursing determines we were required to obtain
+Added: the agency’s approval prior to the initial public offering under its statutes, rules or standards, then, as noted above, we could
+Added: be subject to sanctions by this agency including potential loss of our approval.
change of control could occur as a result of future transactions in which the Company or our institutions are involved.
1 unchanged sentence
reorganizations and some changes in the board of directors of the Company are examples of such transactions.
−Removed: Once we become a publicly
−Removed: traded corporation, ED regulations provide that a change of control also could occur in one of at least two ways:
−Removed: (a) if a person acquires
−Removed: ownership and control of the corporation so that the corporation is required to file a Current Report on Form 8-K with the Securities
−Removed: and Exchange Commission disclosing the change of control or (b) if the corporation has a shareholder that owns at least 25% of the total
−Removed: outstanding voting stock of the corporation and is the largest shareholder of the corporation, and that shareholder ceases to own at
−Removed: least 25% of such stock or ceases to be the largest shareholder.
+Added: ED regulations provide that
+Added: a change of control of a publicly traded corporation also could occur in one of at least two ways:
+Added: (a) if a person acquires ownership
+Added: and control of the corporation so that the corporation is required to file a Current Report on Form 8-K with the Securities and Exchange
+Added: Commission disclosing the change of control or (b) if the corporation has a shareholder that owns at least 25% of the total outstanding
+Added: voting stock of the corporation and is the largest shareholder of the corporation, and that shareholder ceases to own at least 25% of
+Added: such stock or ceases to be the largest shareholder.
These standards are subject to interpretation by ED.
4 unchanged sentences
Additional Campuses and Adding Educational Programs.
−Removed: For-profit educational institutions must be authorized by their state education
−Removed: agencies and be fully operational for two years before applying to ED to participate in the Title IV Programs.
−Removed: However, an institution
−Removed: that is certified to participate in the Title IV Programs may establish an additional location and apply to participate in the Title
−Removed: IV Programs at that location without reference to the two-year requirement, if such additional location satisfies all other applicable
−Removed: ED eligibility requirements.
−Removed: Our expansion plans are based, in part, on our ability to open new schools as additional locations of our
−Removed: existing institutions and are dependent upon ED’s timely review and approval of new campuses.
−Removed: Effective July 1, 2024, ED has discretion
−Removed: to condition the participation of provisionally certified schools by restricting or limiting the addition of new programs or locations.
−Removed: If ED chose to impose such a condition on one or more of our institutions, that could negatively impact our expansion plans.
+Added: For-profit educational institutions must be authorized by their state
+Added: education agencies and be fully operational for two years before applying to ED to participate in the Title IV Programs.
+Added: institution that is certified to participate in the Title IV Programs may establish an additional location and apply to participate
+Added: in the Title IV Programs at that location without reference to the two-year requirement, if such additional location satisfies all
+Added: other applicable ED eligibility requirements.
+Added: Our expansion plans are based, in part, on our ability to open new schools as
+Added: additional locations of our existing institutions and are dependent upon ED’s timely review and approval of new campuses.
+Added: plans to open a new additional location in Houston, Texas and is in the process of seeking requisite educational agency approvals.
+Added: CCC submitted its application to ACCET for approval of the Houston location on September 17, 2026, and the application is under
+Added: Effective July 1, 2024, ED has discretion to condition the participation of provisionally certified schools by restricting
+Added: or limiting the addition of new programs or locations.
+Added: If ED chose to impose such a condition on one or more of our institutions,
+Added: that could negatively impact our expansion plans.
student may use Title IV Program funds only to pay the costs associated with enrollment in an eligible educational program offered by
24 unchanged sentences
things, that the institution:
−Removed: comply with all applicable
−Removed: federal student financial aid requirements;
−Removed: have capable and sufficient
−Removed: personnel to administer the Title IV Programs;
−Removed: administer the Title IV
−Removed: Programs with adequate checks and balances in its system of internal controls over financial reporting;
−Removed: divide the function of
−Removed: authorizing and disbursing or delivering Title IV Program funds so that no office has the responsibility for both functions;
−Removed: establish and maintain
−Removed: records required under the Title IV Program regulations;
−Removed: develop and apply an adequate
−Removed: system to identify and resolve discrepancies in information from sources regarding a student’s application for financial aid
−Removed: under the Title IV Programs;
−Removed: have acceptable methods
−Removed: of defining and measuring the satisfactory academic progress of its students;
−Removed: refer to the Office of
−Removed: the Inspector General any credible information indicating that any applicant, student, employee, third party servicer or other agent
−Removed: of the school has been engaged in any fraud or other illegal conduct involving the Title IV Programs;
−Removed: not be, and not have any
−Removed: principal or affiliate who is, debarred or suspended from federal contracting or engaging in activity that is cause for debarment
−Removed: or suspension;
−Removed: provide adequate financial
−Removed: aid counseling to its students;
−Removed: submit in a timely manner
−Removed: all reports and financial statements required by the Title IV Program regulations;
−Removed: provide adequate career
−Removed: services and geographically accessible clinical or externship opportunities to its students;
−Removed: disburse funds to students
−Removed: in a timely manner that best meets their needs;
−Removed: does not have programs
−Removed: that “fail” gainful employment rates and measures and that represent 50 percent or more of its total receipts under the
−Removed: Title IV Programs in the most recent award year;
−Removed: does not engage in substantial
−Removed: misrepresentations or aggressive and deceptive recruitment tactics;
−Removed: not otherwise appear to
−Removed: lack administrative capability.
+Added: with all applicable federal student financial aid requirements;
+Added: capable and sufficient personnel to administer the Title IV Programs;
+Added: the Title IV Programs with adequate checks and balances in its system of internal controls over financial reporting;
+Added: the function of authorizing and disbursing or delivering Title IV Program funds so that no office has the responsibility for both
+Added: and maintain records required under the Title IV Program regulations;
+Added: and apply an adequate system to identify and resolve discrepancies in information from sources regarding a student’s application
+Added: for financial aid under the Title IV Programs;
+Added: acceptable methods of defining and measuring the satisfactory academic progress of its students;
+Added: to the Office of the Inspector General any credible information indicating that any applicant, student, employee, third party servicer
+Added: or other agent of the school has been engaged in any fraud or other illegal conduct involving the Title IV Programs;
+Added: be, and not have any principal or affiliate who is, debarred or suspended from federal contracting or engaging in activity that is
+Added: cause for debarment or suspension;
+Added: adequate financial aid counseling to its students;
+Added: in a timely manner all reports and financial statements required by the Title IV Program regulations;
+Added: adequate career services and geographically accessible clinical or externship opportunities to its students;
+Added: funds to students in a timely manner that best meets their needs;
+Added: not have educational programs that “fail” accountability measures and that represent 50 percent or more of its
+Added: total receipts under the Title IV Programs in the most recent award year;
+Added: not engage in substantial misrepresentations or aggressive and deceptive recruitment tactics;
+Added: otherwise appear to lack administrative capability.
by us to satisfy any of these or other administrative capability criteria could cause our institutions to be subject to sanctions or
1 unchanged sentence
and results of operations.
−Removed: published a notice in early September 2025 regarding its agenda for regulatory initiatives which, among other things, indicated an intent
−Removed: to address certain issues including administrative capability requirements.
−Removed: We cannot predict whether ED intends to address these requirements
−Removed: through negotiated rulemaking, published guidance, or other actions, nor can we predict the impact on our institutions of any changes
−Removed: that might occur to the administrative capability requirements.
−Removed: We are continuing to monitor developments on this topic.
+Added: on the Company’s fiscal year end, our annual compliance audits and audited financial statements were due to ED on December 31,
+Added: Due to issues with ED’s systems which the Company raised to ED prior to the submission deadline, our institutions were
+Added: unable to access the eZ-Audit portal to upload the annual audit submissions to ED.
+Added: As such, ED could conclude that the annual audit
+Added: submissions were not filed timely as required and impose sanctions (which we would have the opportunity to appeal).
+Added: provided the entirety of the annual audit submissions to ED by electronic mail by the required deadline such that ED did receive the
+Added: required annual audit submissions on a timely basis via alternative means, and we subsequently uploaded the HDMC, CCC, CCMCC, and
+Added: Integrity audit submissions to the eZ-Audit portal.
+Added: current proposed regulatory agenda includes an intent to address certain issues including administrative capability requirements.
+Added: cannot predict whether ED intends to address these requirements through negotiated rulemaking, published guidance, or other actions,
+Added: nor can we predict the impact on our institutions of any changes that might occur to the administrative capability requirements.
+Added: continuing to monitor developments on this topic.
on Payment of Commissions, Bonuses and Other Incentive Payments.
7 unchanged sentences
We cannot predict how ED will interpret and enforce the incentive compensation prohibition.
−Removed: The prohibition on
−Removed: incentive compensation has had and will continue to have a significant impact on the productivity of our employees, on the retention
−Removed: of our employees and on our business and results of operations.
−Removed: Failure to comply with the incentive compensation prohibition could result
−Removed: in loss of an institution’s certification to participate in the Title IV Programs, limitations on Title IV Program participation
−Removed: or financial penalties.
−Removed: On July 17, 2024, ED announced it will issue guidance related to the incentive compensation rule no sooner than
−Removed: later that year, but it has not yet issued such guidance.
−Removed: Compliance Reviews Regarding Compliance
−Removed: with Regulatory Standards and Effect of Regulatory Violations.
−Removed: Because we operate in a highly regulated industry, we are subject
−Removed: to compliance reviews and audits as well as claims of noncompliance and lawsuits by government agencies, regulatory agencies and third
−Removed: Our institutions are subject to audits, program reviews, site visits, and other reviews by various federal and state regulatory
−Removed: agencies, including, but not limited to, ED, ED’s Office of Inspector General, state education agencies and other state regulators,
+Added: prohibition on incentive compensation has had and will continue to have a significant impact on the productivity of our employees, on
+Added: the retention of our employees and on our business and results of operations.
+Added: Failure to comply with the incentive compensation prohibition
+Added: could result in loss of an institution’s certification to participate in the Title IV Programs, limitations on Title IV Program
+Added: participation or financial penalties.
+Added: Reviews Regarding Compliance with Regulatory Standards and Effect of Regulatory Violations.
+Added: Because we operate in a highly regulated
+Added: industry, we are subject to compliance reviews and audits as well as claims of noncompliance and lawsuits by government agencies, regulatory
+Added: agencies and third parties.
+Added: Our institutions are subject to audits, program reviews, site visits, and other reviews by various federal
+Added: and state regulatory agencies, including, but not limited to, ED, ED’s Office of Inspector General, state education agencies and
+Added: other state regulators, the U.S.
Department of Veterans Affairs and other federal agencies, and by our accrediting agencies.
−Removed: In addition, each of our institutions
−Removed: must retain an independent certified public accountant to conduct an annual audit of the institution’s administration of Title IV
−Removed: Program funds.
+Added: each of our institutions must retain an independent certified public accountant to conduct an annual audit of the institution’s
+Added: administration of Title IV Program funds.
Each of our institutions must submit the resulting audit report to ED for review.
34 unchanged sentences
ED also requires institutions to report suspicions of fraud to ED’s Office of the Inspector General.
−Removed: If our efforts
−Removed: to detect and prevent financial aid fraud are unsuccessful or found to be deficient, it could lead to a finding of noncompliance with
−Removed: Title IV requirements, accreditation standards, or other agencies, and could result in liabilities, loss of accreditation or Title IV
−Removed: eligibility, as well as third-party claims.
+Added: 2026, ED published guidance regarding its real-time FAFSA fraud detection process, which reminded institutions that they have a fiduciary
+Added: responsibility for ensuring Title IV funds are disbursed only to eligible students and are responsible for improper payments even in
+Added: cases of fraud.
+Added: If our efforts to detect and prevent financial aid fraud are unsuccessful or found to be deficient, it could lead to
+Added: a finding of noncompliance with Title IV requirements, accreditation standards, or other agencies, and could result in liabilities, loss
+Added: of accreditation or Title IV eligibility, as well as third-party claims.
Financial Assistance Programs.
9 unchanged sentences
federal financial assistance.
−Removed: that provide financial aid to our students face budgetary constraints, which in certain instances has reduced the level of state financial
+Added: that provide financial aid to our students face budgetary constraints, which in certain instances have reduced the level of state financial
aid available to our students.
17 unchanged sentences
which could affect our institutions’ revenues.
−Removed: addition to the Title IV Programs and other government-administered programs, all of our schools participate in alternative loan
−Removed: programs for their students.
−Removed: Alternative loans fill the gap between what the student receives from all financial aid sources and
−Removed: what the student may need to cover the full cost of his or her education.
−Removed: We also extend credit for tuition and fees to many of our
−Removed: students that attend our campuses.
−Removed: We are required to comply with applicable federal and state laws related to certain consumer and
−Removed: educational loans and credit extensions and education financing and are subject to review by federal and state agencies responsible
−Removed: for overseeing compliance with these requirements.
−Removed: Our failure to comply with these requirements could result in repayment
−Removed: liabilities, sanctions, investigations or litigation which could impact our results of operations.
+Added: addition to the Title IV Programs and other government-administered programs, all of our schools participate in alternative loan programs
+Added: for their students.
+Added: Alternative loans fill the gap between what the student receives from all financial aid sources and what the student
+Added: may need to cover the full cost of his or her education.
+Added: We also extend credit for tuition and fees to many of our students that attend
+Added: our campuses.
+Added: We are required to comply with applicable federal and state laws related to certain consumer and educational loans and
+Added: credit extensions and education financing and are subject to review by federal and state agencies responsible for overseeing compliance
+Added: with these requirements.
+Added: Our failure to comply with these requirements could result in repayment liabilities, sanctions, investigations
+Added: or litigation which could impact our results of operations.
January 20, 2022, the CFPB announced its intent to examine the operations of postsecondary schools that extend private loans directly
8 unchanged sentences
in repayment liabilities, sanctions, investigations or litigation which could impact our operations.
−Removed: If the CFPB prioritizes education
+Added: If the CFPB prioritizes regulation
of student loans in the future, the likelihood of these results would increase.
20 unchanged sentences
Associate Degree Nursing
−Removed: Association Degree
+Added: Associate Degree
Cardiac Sonography
Associate of Applied Science
−Removed: 115-130 weeks
+Added: Surgical Technology
+Added: Associate of Applied Science
Ultrasound Technician
5 unchanged sentences
Veterinary Assistant
+Added: Sterile Processing Technician
Vocational Nursing
6 unchanged sentences
Course (Avocational)
+Added: 16 hours/2 days
California Dental Practice Act
4 unchanged sentences
Course (Avocational)
+Added: 32 hours/4 days
Teaching Adult Learner - Strategies and Techniques for Nurses and Allied Health Program Educators
2 unchanged sentences
Course (Avocational)
+Added: 12 hours/2 days
Dispensary Agent Certification
4 unchanged sentences
Course (Avocational)
+Added: 36 hours/4 days
Emergency Medical Technician Certification
17 unchanged sentences
certain cardiac diseases and malfunctions of the heart.
+Added: Resonance Imaging Associate of Applied Science Degree Program
+Added: Magnetic Resonance Imaging program is designed to prepare graduates for employment as an MRI technologist.
+Added: MRI technologists specialize
+Added: in MRI scanners, and as part of the program, students utilize Corsmed technology to simulate everything that happens within the MRI scanner,
+Added: offering state of the art educational modules that complement students’ training by providing remote hands-on ultrasound training,
+Added: real-patient scanning cases and pathologies, didactic instruction, and assessment.
+Added: Technology Associate of Applied Science Degree Program
+Added: Surgical Technology program is designed to prepare students to enter a medical career in the healthcare industry.
+Added: Surgical Technologists
+Added: work to provide quality patient care through functioning in a sterile environment and assisting physicians in operating rooms for procedures
+Added: performed in hospitals, outpatient surgery centers, physician’s offices and other medical facilities.
Nursing Associate of Applied Science Degree Program
7 unchanged sentences
Degree of Nursing
−Removed: High Desert Medical College Associate Degree of Nursing Program (ADN) provides students with a high-quality education in a dynamic,
−Removed: supportive and engaging environment.
−Removed: The nursing curriculum at High Desert Medical College prepares the student to become a
−Removed: Registered Nurse with an associate degree.
−Removed: The program promotes a culture of educational excellence among a diverse student
−Removed: population in collaboration with healthcare partners that leads to an associate degree in nursing licensure.
−Removed: An entry-level
−Removed: professional with the ability to utilize the latest healthcare technology while utilizing current evidence-based practice and
−Removed: clinical reasoning.
−Removed: The acquisition of the knowledge, skills and attitudes to provide safe patient-centered care that meets the
−Removed: changing health care needs of diverse individuals, families, communities and desire for life-long learning.
−Removed: The program strives to
−Removed: foster a commitment to individual excellence, integrity, lifelong learning and professional development within each
+Added: High Desert Medical College Associate Degree of Nursing Program (ADN) provides students with a high-quality education in a dynamic, supportive
+Added: and engaging environment.
+Added: The nursing curriculum at High Desert Medical College prepares the student to become a Registered Nurse with
+Added: an associate degree.
+Added: The program promotes a culture of educational excellence among a diverse student population in collaboration with
+Added: healthcare partners that leads to an associate degree in nursing licensure.
+Added: An entry-level professional with the ability to utilize the
+Added: latest healthcare technology while utilizing current evidence-based practice and clinical reasoning.
+Added: The acquisition of the knowledge,
+Added: skills and attitudes to provide safe patient-centered care that meets the changing health care needs of diverse individuals, families,
+Added: communities and desire for life-long learning.
+Added: The program strives to foster a commitment to individual excellence, integrity, lifelong
+Added: learning and professional development within each graduate.
Technician Diploma Program
3 unchanged sentences
a certification to be employed.
−Removed: Nursing Program Diploma Program
+Added: Nursing Diploma Program
VN program is designed to provide the student with the basic knowledge, skills and abilities to perform the duties of a VN in a health
21 unchanged sentences
American Red Cross and Diploma in medical billing and coding.
+Added: Processing Technician Certificate Program
+Added: sterile processing technician program is designed to prepare students to enter a medical career and play a critical role in preventing
+Added: Sterile processing technicians sterilize, clean, process, assemble, store, and distribute medical equipment and reusable surgical
+Added: instrumentation, utilizing infection control and safety practices during all phases of the process.
Assistant Certificate Program
53 unchanged sentences
Adult Learner -Strategies and Techniques for Nurses and Allied Health Program Educators
−Removed: a 30 hour continuing education course and approved for 30 continuing education units by the Board of Registered Nursing.
−Removed: In this course,
−Removed: students learn how to use the newest educational methods to create a classroom that is suited for adult learners.
−Removed: This is a 10-module
−Removed: course with topics that include teaching theory and strategies, curriculum development and program administration.
+Added: is a 30 hour continuing education course and approved for 30 continuing education units by the Board of Registered Nursing.
+Added: course, students learn how to use the newest educational methods to create a classroom that is suited for adult learners.
+Added: 10-module course with topics that include teaching theory and strategies, curriculum development and program
+Added: administration.
Nursing Pre-Requisite
51 unchanged sentences
Ultrasound Technician
+Added: Cardiac Sonography
+Added: Associate of Applied Science
+Added: Magnetic Resonance Imaging
+Added: Associate of Applied Science
Vocational Nursing
62 unchanged sentences
can complete an UT Associate of Applied Science Degree remotely.
+Added: Sonography Associate of Applied Science Degree Program
+Added: Cardiac Sonography program is designed to prepare graduates for employment as a cardiac sonographer.
+Added: The graduate can work in imaging
+Added: centers, physician’s offices, clinics, mobile units or hospitals that do not require a certification to be employed.
+Added: sonographer plays a key role in today’s modern diagnosis and treatment team of cardiac disorders.
+Added: The cardiac sonographer produces
+Added: two-dimensional ultrasonic recordings of the heart and related blood vessels using ultrasound equipment for use by physicians in diagnosing
+Added: certain cardiac diseases and malfunctions of the heart.
+Added: Resonance Imaging Associate of Applied Science Degree Program
+Added: Magnetic Resonance Imaging program is designed to prepare graduates for employment as an MRI technologist.
+Added: MRI technologists specialize
+Added: in MRI scanners and as part of the program, students utilize Corsmed technology to simulate everything that happens within the MRI scanner,
+Added: offering state of the art educational modules that complement students’ training by providing remote hands-on ultrasound training,
+Added: real-patient scanning cases and pathologies, didactic instruction, and assessment.
Nursing Diploma Program
3 unchanged sentences
of which meets the minimum requirements set forth as necessary for application to take the Vocational Nurse License examination.
−Removed: Technology Associate of Applied Science (“STAAS”) Degree Program
−Removed: STAAS program is designed to prepare students to enter a medical career in the healthcare industry.
−Removed: Surgical Technologists work to provide
−Removed: quality patient care through functioning in a sterile environment and assisting physicians in operating rooms for procedures performed
−Removed: in hospitals, outpatient surgery centers, physician’s offices and other medical facilities.
+Added: Technology Associate of Applied Science Degree Program
+Added: Surgical Technology program is designed to prepare students to enter a medical career in the healthcare industry.
+Added: Surgical Technologists
+Added: work to provide quality patient care through functioning in a sterile environment and assisting physicians in operating rooms for procedures
+Added: performed in hospitals, outpatient surgery centers, physician’s offices and other medical facilities.
Processing Technician Certificate Program
19 unchanged sentences
post details of transactions, and reconcile bank statements in both large and small businesses in many industries.
−Removed: Administrative Specialist Certificate Program
−Removed: business administrative specialist program is designed to prepare students for a career in which they would need office skills such as
−Removed: preparing reports and documents, bookkeeping, keeping schedules, answering telephones, taking messages and providing information.
College of Health
12 unchanged sentences
Veterinary Assistant
−Removed: Vocational Nursing AAS
−Removed: Associate of Applied Science
+Added: Sterile Processing Technician
Career Training Programs
34 unchanged sentences
of Science in Nursing
−Removed: RN–BSN degree program is designed students who possess an associate degree and Diploma Registered Nurse license.
−Removed: The blended or
−Removed: online method of delivery is offered for working nurses who require greater flexibility in the education schedule in order to complete
−Removed: their Bachelor’s degree in nursing.
+Added: RN–BSN degree program is designed for students who possess an associate degree and Diploma Registered Nurse license.
+Added: blended or online method of delivery is offered for working nurses who require greater flexibility in the education schedule in
+Added: order to complete their Bachelor’s degree in nursing.
Assistant Certificate Program
7 unchanged sentences
veterinary front and back-office procedures to prepare the students to work under the supervision of a veterinarian or registered veterinary
−Removed: Nursing Associate of Applied Science Program
−Removed: vocational nursing associate of applied science (VN AAS) program consists of one hundred and one-half credits, of which sixty-eight and
−Removed: one-half credits are transferred into the program.
−Removed: Students must provide a current LVN license to receive these sixty-eight and one-half
−Removed: The remaining credits are completed during the AAS program.
−Removed: The VN AAS degree program builds on the vocational nursing diploma
−Removed: by adding the same one hundred percent online general education and science courses required for graduates of the pre-licensure associate
−Removed: degree registered nursing program.
−Removed: The goal of this post-licensure program is to educate and develop vocational nurses to become more
−Removed: well-rounded professionals through undergraduate general education.
+Added: Processing Technician Certificate Program
+Added: The sterile processing technician program is designed to prepare students to enter a medical career and play a critical
+Added: role in preventing infection.
+Added: Sterile processing technicians sterilize, clean, process, assemble, store, and distribute medical equipment
+Added: and reusable surgical instrumentation, utilizing infection control and safety practices during all phases of the process.
Costa Medical Career College
30 unchanged sentences
of Applied Science in Surgical Technology Degree Program
−Removed: STAAS program is designed to prepare students to enter a medical career in the healthcare industry.
−Removed: Surgical Technologists work to provide
−Removed: quality patient care through functioning in a sterile environment and assisting physicians in operating rooms for procedures performed
−Removed: in hospitals, outpatient surgery centers, physician’s offices and other medical facilities.
+Added: Surgical Technology program is designed to prepare students to enter a medical career in the healthcare industry.
+Added: Surgical Technologists
+Added: work to provide quality patient care through functioning in a sterile environment and assisting physicians in operating rooms for procedures
+Added: performed in hospitals, outpatient surgery centers, physician’s offices and other medical facilities.
Processing Technician Certificate Program
120 unchanged sentences
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.