What American Public Education, Inc. told the SEC could break it.

TA students were ~41% of APUS course registrations; potential elimination, funding cuts or eligibility changes to DoD TA could materially reduce military-service-member enrollments.

“Students participating in TA constituted approximately 41% of APUS's adjusted net course registrations for 2025. We do not know the scale or nature of future actions that may be taken with respect to TA, which could include eliminating those programs, reducing the funds, benefits, or level of reimbursement available thereunder, changing the eligibility criteria for beneficiaries, enacting new restrictions on institutional participation”

As for-profit institutions, APEI's schools must keep federal funds (Title IV, TA, VA) below 90% of revenue under the 90/10 Rule (tightened by ARPA), or face sanctions including loss of Title IV eligibility.

“The HEA requires all for-profit education institutions to comply with what is commonly referred to as the 90/10 Rule, which imposes sanctions on institutions that derive more than 90% of their total revenue on a cash accounting basis from Title IV programs, TA, and VA programs, and other federal educational assistance funds, as calculated under ED's regulations.”

APUS revenue is concentrated in federal payors — DoD Tuition Assistance 41%, VA benefits 26%, ED Title IV 19% — while RU draws 78% from Title IV, creating heavy dependence on government education funding.

“At APUS, students utilizing DoD's TA programs as their primary source of payment accounted for 41% of revenue in 2025, those utilizing VA education benefits 26%, those utilizing ED's Title IV programs 19%, and those utilizing cash and other sources 14%.”

Debt incurred for the Rasmussen Acquisition requires dedicating cash flow to servicing, with credit-agreement limits on dividends and uncertainty about generating sufficient cash flow.

“The indebtedness we incurred in connection with the Rasmussen Acquisition requires us to dedicate a portion of our cash flow to servicing this debt, thereby reducing the availability of cash to fund other business initiatives.”

APEI relies on third parties to administer elements of APUS, RU and HCN Title IV participation; their failure or non-compliance could cause loss of Title IV eligibility.

“We rely on third parties to administer elements of APUS's, RU's, and HCN's participation in Title IV programs and their failure to perform services as agreed or to comply with applicable regulations could cause us to lose our eligibility to participate in Title IV programs.”