I'm obviously not a tax or business attorney, but the concept of non-profit educational institutions owning for-profit subsidiary isn't going to bode well with the IRS. Legally, a non-profit entity can own a for-profit business however how those profits are used and/or distributed is going to raise some flags. These organizations do not want to risk losing their tax-exempt status.

Also, I could be wrong but something tells me that the commoditization of education is not a business that traditional non-profit institutions would want to engage with simply because of the damage it could due to their brand.

Obviously, Altius has thought through these issues, so it would be interesting to get their perspective.