To ETPL or Not to ETPL?

Hi Everyone-

Hope your summer is going well. Last week Pathways Consultants attended the Application Workshop with the CA Bureau of Private Post-Secondary Education (BPPE). We wanted to learn more about the BPPE's Approval to Operate application process and the Eligible Training Provider List (ETPL). For those of you who operate vocational training programs and were formerly on the ETPL, you may have some questions about how these two governmental departments work together. 

You also have probably been severely impacted by the requirement that all former programs on the ETPL must reapply for their status. For a few years the Bureau of Private Post-Secondary Vocational Education was disbanded under Governor Schwarzenegger. The Bureau of Private Post-Secondary (not vocational) Education is back with a vengeance. In order to be on the ETPL you MUST first be approved by the BPPE. So here's what I learned about the application process:

1. The BPPE exists to protect consumers. It's sole purpose is to ensure that students who are paying fees are getting what they pay for. It's part of the Department of Consumer Affairs.  Think of what happened with Heald!
2. You must be approved under the status "Approval to Operate an Institution Non-Accredited." Some people have suggested that they fall under the "Exempt" status which is a shorter and less expensive application process. When speaking with leadership at the BPPE they assured me that very few organizations will qualify and be approved under that category.
3. The application review and approval process takes about 2 years! The BPPE is severely backlogged, as you can imagine. Those who take the Application Workshop will be fast-tracked and will be approved in months, rather than years, including consultants who are assisting organizations with their application. 
4. Each application is reviewed and the organization will receive one deficiency letter outlining exactly what they need to do to successfully complete the application for approval. The BPPE recommends that you respond within 30 days. If you don't respond within a year of your application date, you forfeit your application and your $5,000 application fee.
5. If the program you are applying for ALSO has a licensing requirement with the state, such as barbering or certified nursing assistant, you must also work with the BPPE's department of Quality of Education Unit to review and approve the educational program. Make sure you understand your licensing requirements as well.

The application process is insanely complicated and detailed. The questions are geared toward organizations that do not currently operate as a school but intend to. Meaning, you must prove that you have staffing, equipment, space, curriculum, facilities.  But according to the BPPE you can not operate as a school until you are approved, which can take up to 2 years. 

For those of us who are community based organizations providing training that is paid for with grant dollars, like WIA/WIOA  or private funders, this application process forces you to change your operations to conform with the organizational structures of a private post-secondary school. Think transcripts, financial aid and student catalogs. 

The process and the subsequent audits to comply with the BPPE post-secondary school model creates a parallel universe for community based organizations which are already working hard to comply with other federal, state and county requirements for funding, case files, student enrollment, etc. 

If you are interested in getting assistance from Pathways Consultants on your application, we are happy to serve as consultants/advisors or work to collect and create the required application materials on your behalf.

We also want to hear from you if you are interested in talking with our state representatives about reviewing/revising these policies for future ETPL applicants to increase the number of nonprofit training providers on the list. Please talk to us!

Amanda Gerrie and Kim Coulthurst

Pathways Consultants

510-325-6959