That's exactly it. Right now, barring government action, so long as I can keep students coming to my door there's no incentive to perform.

Schools like ITT Tech have shown, in my mind difinitively, that if you're willing to pay enough for student acquisition you can have absolutely terrible outcomes, still saddle up students with tens/hundreds of thousands of dollars in student debt, fail to get them jobs, and for some inexplicable reason they'll still keep coming.