While advocates of the proposed "Gainful Employment" regulations promise a variety of improvements for students attending for-profit colleges and universities (FPCUs), there is little research on how these institutions are responding to this heightened form of accountability. Through interviews with senior executives of FPCUs, we used grounded theory to identify three general institutional responses--catalytic, reactionary and status quo--plus16 program-related initiatives. This study assessed responses to increased environmental uncertainty brought about by the potential Gainful Employment regulations.