The Center for Public Interest Law’s role extends beyond the classroom. Since 1980, CPIL’s faculty, professional staff, and law student interns have engaged in numerous in-depth research projects, followed by advocacy to implement findings and conclusions. Since 1994, much of CPIL’s advocacy has occurred in the context of the California legislature’s “sunset review” of the necessity and performance of California occupational licensing agencies. CPIL has engaged in advocacy related to the following California regulatory boards and programs:
- CPIL Comments on Draft Report of the Advisory Committee on the Auditing Profession of the U.S. Department of the Treasury (6/13/08) (pdf)
- CPIL Opposition to AB 2473 (Niello and Ma) (4/3/08) (pdf)
- CPIL Opposition to AB 2473 (Niello and Ma) re: CPA Cross-Border Practice (3/5/08) (pdf)
- CPIL Opposition to Board of Accountancy's Cross-Border Practice Proposal (11/12/07) (pdf)
- CPIL Letter to Senate B&P Committee: Oppose AB 1868 Unless Amended (6/12/06) (pdf)
- Further CPIL Opposition to AB 1868's "Tax Services" Loophole (5/3/06) (pdf)
- AB 1868 (Bermudez): CPIL Opposition to "Tax Services" Loophole (3/29/06) (pdf)
- Letter to CBA Requesting Reconsideration of the "Tax Services" Issue (3/14/06) (pdf)
- Letter to CBA President and Members: AICPA’s Control of Uniform CPA Exam (7/25/05) (pdf)
- Open Letter to the California Board of Accountancy (5/28/02) (pdf)
- Testimony to Assembly Committee on Business and Professions -- Hearing on Accounting Practices and Corporate Audits: Protection of Consumers, Employees, and Shareholders (2/19/02) (pdf)
- Testimony in Opposition to AB 585 (Nation): Uniform Accountancy Act (4/24/01) (pdf)
- Sunset Review Oral Testimony: Opposition to Uniform Accountancy Act (4/4/01) (pdf)
- Sunset Review Written Testimony (1/4/01) (pdf)
- Sunset Review Oral Testimony: Opposition to Uniform Accountancy Act (12/5/00) (pdf)
- Testimony to California Board of Accountancy: Opposition to Uniform Accountancy Act (11/18/99) (pdf)
- 1995 Sunset Review Written Testimony (12/4/95) (pdf)
- Comments of the Center for Public Interest Law: Sunset Hearing of the California State Athletic Commission (3/18/15)
- Testimony to the Joint Legislative Sunset Review Committee (1/6/2004) (pdf)
- Exhibit A: Financial Documents Pertaining to the Boxer Pension System Produced by the Athletic Commission in its Sunset Report (pdf)
- Exhibit B: Legal Memorandum Concerning the Assessment of Pension Fees For Boxing Contests Held on Tribal Lands (pdf)
- Exhibit C: Third Letter to the Commission Requesting Pension Fund Documents and Data (pdf)
- Exhibit D: Boxers’ Pension Fund Balance Sheets Produced by Commission On January 5, 2004 (pdf)
- Sunset Review Testimony (11/24/95) (pdf)
- CPIL Letter to State Bar Regarding Illegal Meeting in Violation of Bagley-Keene Open Meeitng Act (June 23, 2016)
- CPIL Oppose Unless Amended Letter to Senate Judiciary Committee on AB 2878 (Stone) regarding State Bar (June 22, 2016)
- Professor Robert C. Fellmeth featured in Los Angeles Times opinion piece calling for reforms to the structure of the State Bar of California (June 19, 2016)
- CPIL’s Testimony to the State Bar’s 2016 Governance in the Public Interest Task Force (Apr. 25, 2016)
- CPIL Opposes AB 2878 (Stone), the State Bar’s 2017 dues bill, unless it is amended to restructure the State Bar (Apr. 19, 2016)
- CPIL’s Ed Howard featured in news story on state audit finding that the State Bar’s discipline system put the public at significant risk (Feb. 23, 2016)
- CPIL Succeeds In Imposing Transparency Requirements on State Bar of California; Amended SB 387 Signed by Governor Brown (Oct. 9, 2015)
- CPIL Opposes SB 387, State Bar’s Annual Dues Bill (July 6, 2015)
- CPIL Executive Director Interview with Californians for Attorney Regulation Reform featured on YouTube
- Further CPIL Testimony on State Bar's Proposal to Amend its Open Meeting Rules (4/22/13) (pdf)
- CPIL Testimony on State Bar's Proposal to Amend its Open Meeting Rules (11/29/12) (pdf)
- CPIL’s Letter Supporting SB 163 (Evans); overhauls composition and method of selection of State Bar Board of Governors (9/16/11) (pdf)
- CPIL Testimony to the State Bar's Governance in the Public Interest Task Force (1/10/11) (pdf)
- CPIL Letter to the State Bar's Governance in the Public Interest Task Force (11/29/10) (pdf)
- CPIL Letter to the Legislature: Four Concerns About the State Bar of California (7/2/10) (pdf)
- CPIL Comments Regarding Online Publication of State Bar Notices of Disciplinary Charges (6/23/08) (pdf)
- CPIL Comments on State Bar's Malpractice Insurance Disclosure Rule (3/17/08) (pdf)
- CPIL Comments on State Bar's Alternative Discipline Program Rules (3/17/08) (pdf)
- CPIL Comments on State Bar's Insurance Disclosure Rule (8/3/07) (pdf)
- CPIL Comments to State Bar on Proposed Rule Pertaining to Permanent Disbarment (6/6/06) (pdf)
- Letter to Governor Wilson to Restore Bar Disciplinary Process (5/1/98) (pdf)
- Final Report of the State Bar Discipline Monitor (09/91) (pdf)
- Initial Report of the State Bar Discipline Monitor (06/87) (pdf)
- Sunset Review Testimony (12/4/95) (pdf)
- Testimony of the Center for Public Interest Law to the Little Hoover Commission on the Governor's Reorganization Plan No. 1: Written Testimony / Oral Testimony (01/13/05) (pdf)
- Testimony on Proposed Standards for Consumer Complaint Disclosure (11/5/01) (pdf)
- Testimony on AB 269 (Correa): Enforcement Oversight (10/4/01) (pdf)
- Testimony to the Little Hoover Commission on the Department of Consumer Affairs (10/27/97) (pdf)
- CPIL Supports SB 465 (Hill), which would encourage better flow of information about contractors into the Contractors’ State License Board (June 13, 2016)
- CPIL Supports SB 465 (Hill) regarding Contractor Self-Reporting of Settlements to CSLB (July 7, 2015)
- Final Report: Contractors State License Board Enforcement Program Monitor (4/1/03) (pdf)
- Third Report: Contractors State License Board Enforcement Program Monitor (10/1/02) (pdf)
- Second Report: Contractors State License Board Enforcement Program Monitor (4/1/02) (pdf)
- Initial Report: Contractors State License Board Enforcement Program Monitor (10/10/01) (pdf)
- Sunset Review Testimony (7/26/00) (pdf)
- Sunset Review Testimony (11/24/95) (pdf)
- Letter Opposing Dental Materials Fact Sheet (10/15/01) (pdf)
- Letter in Support of SB 26 (Figueroa) (7/9/01) (pdf)
- 1996 Sunset Review Testimony (11/12/96) (pdf)
- 1995 Sunset Review Testimony (11/24/95) (pdf)
- Sunset Review Testimony (11/24/95) (pdf)
- Robert C. Fellmeth Post-Hearing Letter to Little Hoover Commission (2/12/2016)
- Robert C. Fellmeth Testimony of February 4, 2016 on occupational licensing in California
- Robert C. Fellmeth Testimony of October 23, 2014 on the Bagley-Keene Open Meeting Act and the Public Utilities Commission
- Testimony of the Center for Public Interest Law to the Little Hoover Commission on the California Public Utilities Commission and the Bagley-Keene Open Meeting Act / Watch Video (8/26/14)
- Testimony of the Center for Public Interest Law to the Little Hoover Commission on the Governor's Reorganization Plan No. 1: Written Testimony / Oral Testimony (01/13/05) (pdf)
- Testimony to Little Hoover Commission's Acupuncture Advisory Committee (10/22/03) (pdf)
- Testimony to the Little Hoover Commission on the Department of Consumer Affairs (10/27/97) (pdf)
- CPIL Continues to Oppose SB 1177 (Galgiani), CMA’s attempt to permit the Medical Board to recreate its failed “diversion program” for substance-abusing physicians (June 13, 2016)
- CPIL Supports SB 482 (Lara), which would curb the epidemic of prescription drug overdoses and deaths (June 7, 2016)
- CPIL Opposes SB 1177 (Galgiani), CMA’s attempt to recreate the Medical Board’s diversion program for substance-abusing physicians (Apr. 18, 2016)
- CPIL Supports SB 1033 (Hill), which requires physician disclosure of probation status to patients (Apr. 4, 2016)
- View A. B&P Hearing on AB 2346 (Gonzalez) (diversion program for impaired physicians) on April 29, 2014 (see 14:43 - 47:13 of video clip)
- CPIL's Letter in Support of SB 304 (Price and Gordon) (4/24/13) (pdf)
- CPIL's Written Testimony on Medical Board's 2013 Sunset Review (2/26/13) (pdf)
- CPIL’s Letter Supporting AB 536 (Ma); preserves Medical Board’s public disclosure of physician criminal convictions (9/23/11) (pdf)
- CPIL Oral Testimony at Senate Hearing on Health Practitioners’ Substance Abuse Programs (3/10/08) (pdf)
- CPIL Written Testimony for Senate Hearing on Health Practitioners’ Substance Abuse Programs (2/29/08) (pdf)
- Testimony on the Bureau of State Audits' Examination of the Medical Board's Diversion Program (6/11/07) (pdf)
- FINAL REPORT: Medical Board of California Enforcement Program Monitor (11/1/05)
- INITIAL REPORT: Medical Board of California Enforcement Program Monitor (11/1/04)
- Testimony on Proposed Changes to MBC's Public Disclosure Policy (5/9/02) (pdf)
- Testimony at Joint Legislative Sunset Review Committee's Special Hearing on MBC (5/1/02) (pdf)
- Testimony on Proposed Changes to Medical Board's Public Disclosure Policy (1/22/02) (pdf)
- 1997 Sunset Review Testimony (11/27/97) (pdf)
- Physician Discipline in California: A Code Blue Emergency (4/5/89) (pdf)
- 2001 Sunset Review Testimony (oral) (12/5/01) (pdf)
- 1997 Sunset Review Testimony (11/17/97) (pdf)
Ensuring Oversight of Private, For-Profit Postsecondary Schools
On behalf of vulnerable adult student populations such as military veterans and former foster youth, the Center for Public Interest Law (CPIL) and Children's Advocacy Institute (CAI) are advocating to improve the oversight and regulation of private, for-profit postsecondary schools. Too often, these for-profit schools charge high tuition, spend public funds and generate high debt for their students — with dubious results. Many of these schools engage in highly visible and potentially misleading marketing campaigns aimed solely at increasing their profits, and they are not committed to providing students with a quality education. Due in part to the lack of appropriate student support services provided by these schools, many students drop out prior to graduating, and those who do graduate rarely find the lucrative careers commonly touted in the schools' ubiquitous advertising. Either way, they are saddled with debt that many are unable to climb out from under.
A July 2012 report by Sen. Tom Harkin (D-IA) and the Senate Health, Education, Labor and Pensions (HELP) Committee revealed that although federal taxpayers are investing billions of dollars a year in for-profit colleges, “more than half of the students who enrolled in in those colleges in 2008-9 left without a degree or diploma within a median of four months.” Consider some of the other findings from this report:
- For-profit colleges are owned and operated by businesses. Like any business, they are ultimately accountable by law for the returns they produce for shareholders. While small independent for-profit colleges have a long history, by 2009, at least 76% of students attending for-profit colleges were enrolled in a college owned by either a company traded on a major stock exchange or a college owned by a private equity firm. The financial performance of these companies is closely tracked by analysts and by investors.
- Congress has failed to counterbalance investor demands for increased financial returns with requirements that hold companies accountable to taxpayers and students for providing quality education, support, and outcomes. Federal law and regulations currently do not align the incentives of for-profit colleges so that the colleges succeed financially when students succeed.
- Many for-profit colleges fail to make the necessary investments in student support services that have been shown to help students succeed in school and afterwards, a deficiency that undoubtedly contributes to high withdrawal rates.
- More than half a million students who enrolled in 2008-09 left without a degree or certificate by mid-2010. Among two-year Associate degree-seekers, 63% of students departed without a degree.
- The vast majority of the students left with student loan debt that may follow them throughout their lives, and can create a financial burden that is extremely difficult, and sometimes impossible, to escape.
- In the absence of significant reforms that align the incentives of for-profit colleges to ensure colleges succeed financially only when students also succeed, and ensure that taxpayer dollars are used to further the educational mission of the colleges, the sector will continue to turn out hundreds of thousands of students with debt but no degree, and taxpayers will see little return on their investment.
CPIL and CAI have joined with a USD-wide campaign to address these abuses. The USD Initiative to Protect Student Veterans joins the efforts of military leaders and elected officials to educate and protect military veterans from the misleading practices of some for-profit educational institutions and lenders. Under the direction of Col. Patrick Uetz, USMC (ret.), the Initiative’s multi-pronged approach includes
- a research component;
- the Veterans Legal Clinic, which assists veterans who have disputes with for-profit schools or lenders over the use of GI Bill funds and education related loans, and which is directed by Robert F. Muth, who previously served as a Captain and Judge Advocate in the U.S. Marine Corps; and
- state and federal advocacy led by CAI and CPIL, along with powerful allies such as Public Advocates assisting us on our state work and noted youth education advocate David Halperin contributing greatly to our work at the federal level.
Read more information on CPIL/CAI's advocacy and ongoing activities in this area.
- March 9, 2021 - CPIL joins with other organizations to submit a letter to the legislature re Bureau of Private Postsecondary Sunset Review Hearing
- December 7, 2018 - Comment of Groups Representing Veterans, Consumers, and Children in Support of Proposed Rulemaking to Title 12 of California Code of Regulations Regarding CSAAVE Title 38 Approval of Postsecondary Institutions
Resources
- How the 90/10 Rule Loophole Harms Veterans (published May 28, 2020, by Third Way)
- Veterans Legal Clinic
- Veterans Education Success
- Public Advocates
- David Halperin
- Senator Tom Harkin: For-Profit College Investigation Website
- Huff Post: For Profit Colleges
- California Bureau for Private Postsecondary Education
- How to File a Complaint
- What to Know about For-Profit Colleges Before You Enroll
- State by State Summary of Private Postsecondary School Oversight and Governing Statutes and Regulations
- Robert Fellmeth Quoted in Los Angeles Times Article on Low Retention Rates of Unaccredited Law Schools
- Robert C. Fellmeth OpEd Published in San Jose Mercury News
- Robert C. Fellmeth Testimony of October 23, 2014 on the Bagley-Keene Open Meeting Act and the Public Utilities Commission
- Testimony of the Center for Public Interest Law to the Little Hoover Commission on the Public Utilities Commission and the Bagley-Keene Open Meeting Act / Watch Video (8/26/14)
- Plunging Into Darkness: Energy Deregulation Collides with Scarcity (article by CPIL Executive Director Robert C. Fellmeth, submitted to the Conference on Competition, Consumer Protection and Energy Deregulation (11/2/01; Chicago, Il), sponsored by the Institute for Consumer Antitrust Studies and Loyola University Chicago Law Journal) (pdf)
- Citizens' Utility Boards: Because Utilities Bear Watching (report by Beth Givens with forward by CPIL Executive Director Robert C. Fellmeth) (pdf))

