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Programming Note: There will be no posts over the Memorial Day weekend.
Neil Mosley on Fire
Late last week Neil Mosley, our friend and independent UK-based consultant, published one of the best-written posts I’ve seen all year. His topic was the increasing number of OPM partnership agreements ending in the UK, which not only commented on the headline but more importantly analyzed what is happening with this “stale” market from both the OPM provider and university client side.
What put the post over the top, for me, was his sharply-worded dismissal of the overly-simplistic views of the OPM market that are too often used to explain what is happening.
Those looking for a singular, simple reason to explain the growing number of partnerships coming to an end will be disappointed. There are a range of factors at play. Some OPM critics, including small pseudo-religious sects that seem to live out their days in a simplistic, angsty, Manichean la la land, will point to company performance and how the “evil” private sector is leeching off higher education whilst simultaneously not delivering, and the sector is getting wise to it. However, while they build their plastic populist personas on whatever slightly naff Twitter substitute is currently popular, the complex, nuanced, real world spins around them.
But this dismissal allowed Neil to then provide his own solid analysis.
I interviewed Neil for the On EdTech+ podcast to discuss the post and this topic in depth. You can find the episode at this page (On EdTech+ subscription only). And you can subscribe to the podcast with your own private feed — see this post if you need further instructions.
On to the main update looking at earnings-based accountability rules.
What Footnote 79 Is Actually About
I filed a public comment on a single footnote in the AHEAD NPRM. The footnote is the symptom. The disease runs through every accountability fight I've covered.
I just filed a public comment on what looks like the most arcane possible target: footnote 79 of the AHEAD / Do No Harm NPRM, a single paragraph in the Regulatory Impact Analysis describing one regression. The comment is on the public record at regulations.gov (ID ED-2026-OPE-0100-4904), and I'd encourage you to read it directly — it's short, and the regression tables and the figure carry the argument better than any summary can. The file is also linked below.
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