News, Views and Careers for All of Higher Education
May 22 Outside the Circle
In 2004, the U.S. Department of Education proposed to modernize its system of gathering information from the nation’s colleges. Among other provisions, it would have required colleges to begin submitting privacy-protected data about individual students’ academic progress. The goal was straightforward: replace a cumbersome series of surveys about discrete topics (enrollment, graduation rates, finance, etc.) with a single survey that would ultimately yield far more accurate information about institutions.
This “unit record” system would have provided much more accurate information about individual colleges. The current federal graduation rate measure, for example, doesn’t give colleges credit for students who transfer and graduate elsewhere — a problem in an era of increasing mobility. By matching student records from multiple institutions, the system would give colleges full credit for students who start or finish their careers elsewhere. Colleges with a transfer mission, like community colleges, would benefit most. The system would also show “net price” — student costs after institutional financial aid packages are taken into account, which often runs thousands of dollars less than the sticker prices commonly reported by the press. In other words, the unit record system would make most colleges look more successful and less expensive than current data suggest. And these are only a few of the informational benefits the system would bring.
Yet the reaction to the proposal from parts of the higher education community was nothing short of apoplexy. While the public university and community college associations were generally supportive, lobbyists from organizations like the National Association of Independent Colleges and Universities began throwing around words like “Orwellian” with abandon. Public opinion surveys filled with leading questions were commissioned, op-eds were placed in The Washington Post, and meetings were convened with members of Congress. The very idea of thousands of colleges and universities sending electronic files bulging with Social Security numbers, diploma information, and other potentially sensitive data about millions of students to a single repository in Washington — one presumably full of huge, ominously buzzing computer servers where the data would be analyzed without students’ consent — was said to be dangerous and downright un-American. It would also be a terrible financial burden, institutions said, another unfunded mandate sucking funds away from students and education.
So awful was this idea that higher education lobbyists had language inserted in proposed versions of the federal Higher Education Act to ban the system outright, language that is now being considered in final negotiations over the bill. When the Spellings Commission on the Future of Higher Education released a draft report endorsing the system in late June 2006, the president of NAICU, David Warren, called it “an assault on Americans’ privacy and security in the shadow of the fourth of July.”
All of which is strange, given that just such a centralized, DC-based system — complete with the big computers, social security numbers, and all the rest — already exists. The same institutions that are busy denouncing the hypothetical federal system happily send individual student data to this very real system, several times a year. It’s called the National Student Clearinghouse, and it’s located one of those indistinguishable suburban office buildings off the highway in Herndon, Va., about 25 miles from the halls of Congress, where it’s run by a non-profit organization founded by the student loan industry. I’ve been there, twice.
The fact that some higher education leaders are waging war against the federal system while simultaneously supporting the lender-enabled system does much to separate rhetoric from reality when it comes to questions of information systems, student privacy and higher education. It turns out to be perfectly possible to gather and organize massive amounts of potentially sensitive information about college students in a safe, responsible way. And most colleges are more than willing to participate — as long as it’s in their financial best interest to do so.
The Clearinghouse was founded in 1993, and was originally named the National Student Loan Clearinghouse, because that’s exactly what it was, and is: a solution to a student loan information problem. America is a big country; there are thousands of colleges and universities, along with thousands of financial institutions that provide student loans. Most students don’t start paying off their loans until after they leave college. That means that lenders have a vested interest in knowing exactly when students leave, so they can start sending them polite (and eventually less polite) letters asking them to repay. Lenders can’t really rely on students for this information. ("Yeah bro, still in school. Majoring in, um, art history now. It’s my, you know, personal calling.") They have to get it from the colleges themselves. Historically, that meant that each lender had to maintain some kind of ongoing information reporting relationship with hundreds or thousands of colleges, while each college had to do the same with hundreds or thousands of lenders. It was a hassle, and the Clearinghouse provided a better way.
The Clearinghouse is basically a gigantic nexus and storage facility for information about college enrollment. Every month or two, participating colleges send an electronic file to Herndon with a list of all the students currently enrolled. Lenders send a list of all the students to whom they’ve lent money. The Clearinghouse puts the lists together, and sends a third list back to each lender, detailing which of their borrowers are still enrolled and which are not. Instead of colleges dealing with thousands of lenders and lenders dealing with thousands of colleges, everyone just deals with one organization, the Clearinghouse.
Actually doing this is harder than it sounds. The student loan industry invested millions of dollars in getting the organization off the ground, and it currently employs nearly 100 full-time people to manage the process, which involves a lot of matching algorithms, data protocols, and the afore-mentioned large computers. But the important thing to understand is that it works. As of today, over 91 percent of all the college students in America are enrolled at one of the 3,100 colleges and universities that send individual information about them to the Clearinghouse, whether or not they took out a student loan. The Clearinghouse employs elaborate security procedures that have never been breached, and is fully compliant with the Family and Educational Rights and Privacy Act (FERPA).
While the Clearinghouse was originally created to fulfill a specific purpose, it has gradually branched out into other areas, including providing degree verification for employers and information for researchers and K–12 school systems. It was Clearinghouse data that allowed Chicago Public Schools to learn that less than half of its graduates who went on to college were earning a bachelor’s degree within six years, and at some local institutions success rates were lower than 20 percent. The Clearinghouse also provides reports and analyses to colleges, letting them find out, for example, where all the students they accepted but didn’t enroll chose to enroll instead.
It’s all perfectly logical and above-board. Which is the point — colleges and universities have no principled objection to centralized databases of student information. They’re happily sending unit-record data to one right now. There are, for example, 43 private colleges and universities represented on NAICU’s board of directors. Of them, 38 were enrolled in the Clearinghouse system as of April 21, 2008.
The controversy around the proposed federal unit record database is a power struggle masquerading as a fight for student privacy. Colleges don’t mind sharing information with lenders because they have a mutually beneficial relationship, each providing a market for each other’s services. By contrast, colleges are deeply suspicious of any new entanglements with the federal government. Throughout the nation’s history, Uncle Sam has adopted a hands-off approach to higher education, providing no direct operating support and asking for little or no say in the conduct of universities in return. That appears to be changing, as federal lawmakers are increasingly asking tough questions about price and quality, suggesting that the former is too high and the latter is too low.
There is an important discussion to be had about the federalism and the proper relationship between the academy and the state. The U.S. Department of Education doesn’t have an unlimited claim on student information, and the benefits of any system should be weighed against the costs of compliance for institutions. More broadly, the need for public accountability must be balanced with the American higher education’s traditional strengths of diversity and autonomy. And the need for stringent privacy protections for students goes without saying. Of course, the National Center for Education Statistics, where higher education data is held, already collects large amounts of student-level data through its extensive series of longitudinal surveys. And like the Clearinghouse, its security record is unblemished.
But the private college lobby doesn’t want to have a serious conversation about these issues. Instead, they’ve built an argument on hypocrisy and misrepresentation, arguing on Capitol Hill against student information systems even as they help build one just a short drive away.
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Thanks for our annonymous “friend’s” help in telling us the “truth” on a public blog. I can think of no incident in which staffers from the Hill have asked for NAICU’s help in drafting reasonable alternatives, in which they have not received such help.
As a matter of fact, although we are best known for our strong and clear (and sometimes controversial) policy positions, we are also known as excellent readers of legislation and frequently use this expertise to draft creative alternative solutions for legislative problems (many of which can be found in the conference draft of HEA).
Perhaps our “friends” would like to identify themselves publicly so we could engage in a public discussion of bill subsections.
The HEA is a serious piece of legislation we are all working on to make better. Lets not dismiss the many serious policy questions Congress has before it by making this into an anonymous backstabbing among associations over who is better or who is most influential. Our collective members deserve better than that.
Sarah Flanagan
sarah flanagan, VP government relations, at 2:35 pm EDT on May 22, 2008
It is disappointing that Kevin Carey has chosen to launch his “Outside the Circle” column with a reprise of his mean-spirited attacks on the National Association of Independent Colleges and Universities (NAICU) due to our opposition to the establishment of a federal student unit record data system.
We have explained our position many times over the past four years, but it bears repetition now. Put most simply, we believe that establishment of a federal student unit record data system will jeopardize student privacy and that there is no compelling public policy reason to put student privacy at risk.
A central database containing massive amounts of data for each of the 16.5 million postsecondary students in the United States–including those who do not receive any financial aid–is profoundly counter to the democratic underpinnings of higher education and American society. The existence of such a body of data will inevitable lead to pressures to share the information with other government agencies for ancillary uses and to make additions to the data for non-educational purposes. The potential reach of such a database maintained by the federal government exceeds anything that could be developed and maintained by any private entity.
In terms of the public policy case for building this system, Carey mentions a desire to see that all institutions get “credit” for any student who may have passed through their halls and ultimately received a degree. Putting aside the question of how one would figure out how to divide this credit (and presumably the demerits for students who failed to graduate at all) fairly among the various institutions involved, the fact is that all institutions would look better on their graduation rates. That is simply not a good reason to sacrifice student privacy.
His second public policy case was that student unit record data would show “net price.” It is not clear why one needs to collect individual student data to do net price calculations. Certainly, this is not an assumption that the Congress is making–given that net price calculations are anticipated for many of the provisions of the same bill that prohibits the development of a federal student unit record data system.
There are several longitudinal students conducted by the National Center for Educational Statistics that capture individual student information for research into student demographic characteristics, program persistence and completion, and post-baccalaureate education and employment. These students, based on scientifically valid samples of students, have been useful addressing policy questions and do not compromise individual student data.
One final point warrants comment, and that is Carey’s remarks about “public opinion surveys filled with leading questions”–a not-so-veiled reference to a survey commissioned by NAICU in 2006 in which over 60-percent of respondents expressed opposition to the establishment of a federal student data collection system. Leading questions?? You be the judge:
1. The federal government has proposed a system where colleges and universities would be required to report individual student’s academic, financial aid, and enrollment information. This data would be linked to individual students through a unique identifier, and potentially to information from the student’s high school and elementary records. Would you support or oppose requiring colleges and universities to report individual student information to the federal government? (Total Support 33%; Total Oppose 62%)
2. Now I would like to read you statements from supporters and opponents of this requirement. Please tell me which statement you agree with more:
Statement A: (Some/Other) people say that having more detailed information about college students would promote greater accountability for colleges and universities.
Statement B: (Some/Other) people say that enough data is already collected at the college and university level, and that reporting individual data is a breach of privacy that could result in abuses of people’s personal information.
Which statement do you agree with more? (Total Statement A — 27%; Total Statement B — 68%)
3. Now I would like to read you some additional statements from supporters and opponents of this requirement:Statement A: (Some/other) people say that collecting data on individual students makes colleges and universities more transparent, so people can see if these institutions are being well-managed.
Statement B: (Some/other) people say that collecting individual student data is just costly and intrusive and does not address or solve any pressing public policy issue. Which of these positions comes closest to your own position?(Total Statement A — 34%; Total Statement B — 60%)
sarah flanagan, VP Government Relations at NAICU, at 3:20 pm EDT on May 22, 2008
What a deliciously disingenuous article, in which young Mr. Carey gives, in his own voice, the principal reasons that independent colleges oppose a federal student unit-record database:
The U.S. Department of Education doesn’t have an unlimited claim on student information, and the benefits of any system should be weighed against the costs of compliance for institutions. More broadly, the need for public accountability must be balanced with the American higher education’s traditional strengths of diversity and autonomy. And the need for stringent privacy protections for students goes without saying.
All that precedes is just resentful fluff, because your columnist is eager to boil down everything about a college to a number — say, 63.7 — and then place them all in rank order based on that number. He has already tried such a thing for community colleges for the Washington Monthly. Other naive stakeholders would love to draw a bright line around this index score for which a college would “pass” or “fail” — regardless of its mission, its history, its mix of academic programs, its mix of students, its neighborhood, among a whole array of unquantifiable factors.
The flawed premise of Mr. Carey’s article is that there is not enough information for parents or outsiders to assess colleges. He himself points out how this is untrue by noting the piles of data already in the hands of the National Center for Education Statistics, including sample surveys that are already answering the lion’s share of important questions about students and their performance nationwide. NCES’s reams of campus-specific data has become more readily available thanks to the work of the IPEDS data team.
Our campuses are fully equipped to tell the stories of their students’ success — and they do. There is plenty of additional data already available to anyone who asks. No one, Mr. Carey included, has yet answered the key question: What would we learn from a federal unit-record database — massive in cost to the taxpayer and to the campuses — that we don’t already know?
Robert P. Burke, Association of Independent Colleges and Universities of Ohio, at 3:50 pm EDT on May 22, 2008
Well if the clearinghouse already has most of the information, why doesn’t the Federal Government just buy the reports it needs from the clearinghouse? It would save a fortune in tax dollars needed to set up the redundant system and prevent universities from having to duplicate effort. It would even fix the concern of letting the nasty feds get their hands on all the dangerous data.
Just Stating the Obvious, at 3:50 pm EDT on May 22, 2008
It’s hard to read Ms. Flannigan’s remarks and keep a straight face. NAICU claims to defend “democratic underpinnings” of higher ed by fighting against Big Brother? I’m sorry, but when I think of private colleges in the US, “democracy” isn’t the first word that comes to mind.
This is a pretty weak (and unconvincing) argument that really adds nothing to the “policy debate.” A policy debate should not be guided by special interest surveys or Big Brother scare tactics.
States have been operating unit record databases for years and I have yet to hear about data breaches...has anybody else? Clarification on this question would add a lot of value to the policy debate.
And if private data were “stolen,” what exactly would the thief gain access to? Transcripts and financial aid records? Wow, I bet those sell like hotcakes on the black market. We give our banks and credit card companies more information than what a student would give to unit record databases. Plus, there’s no way to link these records to SSN, so it’s a moot point, right?
If we (well, NAICU) want to keep US higher ed in the 20th Century, so be it. That sounds more like we’d be preserving the “self interest” of higher ed rather than the “democratic underpinnings” of higher ed.
Big Brother, I.C.U., at 4:30 pm EDT on May 22, 2008
Are the data elements sent to the Clearinghouse really the same as those proposed for the unit record system? Hardly, in my opinion, but I’ll let you decide.
Clearinghouse required fields ——————————————- Name Permanent address Date of birth Enrollment status (full time or parttime) Expected graduation dateDirectory block indicator (FERPA suppression)
Unit Record fields ————————— Name SSN Permanent address Date of birth State of residence Gender Race/ethnicity Citizenship Program Degree plan Program length Varsity sport High school graduation date Institution UNITID Transaction date Redisclosure flag Start date End date Number of courses Credit hours Attendance Level Census date Transaction date Tuition and fees Total price of attendance State residency status Campus residency status Dependency status Federal grants State grants Institutional grants Loans Assistantships Transaction date Degree granted Degree date Exclusion flagReady for transfer
———————————————————
Granted, Clearinghouse does provide the ability for schools to upload other items should they wish, but these other itemsare optional.
Carol Livingstone, Associate Provost for Information Management at University of Illinois at Urbana-Champaign, at 4:30 pm EDT on May 22, 2008
The fact that Sarah Flanagan doesn’t once mention the Student Clearinghouse in her reply speaks for itself. Are we to believe that “A central database containing massive amounts of data for each of the 16.5 million postsecondary students in the United States–including those who do not receive any financial aid–is profoundly counter to the democratic underpinnings of higher education and American society,” but that a massive central database containing somewhat less data about over 90% of those students, including those who do not receive any financial aid, is, in NAICU’s view, perfectly okay? That’s absurd.
As for Mr. Burke’s reference to “young Mr. Carey” — I’m 37. I’d hate see what kind of diminutive words he applies to college students.
Kevin Carey, Research and Policy Manager at Education Sector, at 4:55 pm EDT on May 22, 2008
So in what specific ways does this threaten student privacy? All of the data that would be linked by the unit record system already exists and is managed somewhere—the feds, colleges, and other sources (such as states) have information stored in different places. Are you suggesting that data integration is the violation of student privacy? Do you believe that states that have begun employing longitudinal student-level databases are also guilty of violating student privacy? What about when my alma matter sells my contact information to credit card companies or insurance companies?
As for the lack of a “compelling public policy reason” to support this unit record system, I think it may be disingenuous to link the unit record system merely to institutional accountability (question 2 of the survey), which is apparently a cause of panic these days. It seems to me that this system would also open doors to meaningful research on students that cannot be addressed by the limitations of NCES longitudinal studies. Given the changing dynamics of student characteristics and enrollment patterns in every corner of higher education, wouldn’t it be a benefit to the public to be able to conduct better research on how to maximize student persistence and success? What about gaining deeper insights into adult learners? Wouldn’t we able to learn much more about how higher education changes over time and create more responsive policy recommendations for institutional and political leaders?
Is higher education the only industry that believes that gaining quality information about their clients is a bad thing?
Differences in opinion is one thing, but working behind the scenes to have the very idea of a unit record system banned is hardly a “policy debate"—its pulling the rug out from what could be a very fruitful discussion between the public, researchers, institutional leaders and policymakers.
Driving Blind, at 5:00 pm EDT on May 22, 2008
It’s embarrassing to see Ms. Flanagan and Mr. Burke cloak the basest self-interest in high-flown rhetoric.
With the amount of money taxpayers that spend subsidizing the minority of Americans who are fortunate enough to have the opportunity for higher education, Congress and the public are more than entitled to receive simple report cards showing which institutions are putting that support to good use (U. Texas San Antonio), and which are not (Chicago State).
But the lobbying groups have a vested interest in obscuring that question, lest their members be compelled to answer ever more uncomfortable questions about price and quality.
I recommend Carey’s other work on this topic too, e.g.:
http://www.educationsector.org/re...ly.com/features/2006/0609.carey.html
BenjaminL, at 12:50 pm EDT on May 25, 2008
Kevin Carey presents a superficial review of some of the facts on this issue that, alas, misrepresents the current scope of the National Student Clearinghouse (NSC), the complexity of creating a true “student unit record” and the politics associated with this issue over several years. I have a good deal of experience with this issue, have spent more than 20 years in various roles attempting to create an individual student record for every federal aid recipient within the Department of Education, rather than program-specific systems that did not communicate with each other.
That the NSC exists—and contains SSNs and selected other student data including enrollment and degree attainment—is undeniable. But those limited, but very important, data and functions are a world away from the true student unit record system about which higher education—and some in the Congress—expressed concerns about over-reaching proposals from the Department of Education. However, the relatively small amount of data submitted to the NSC is a small fraction of the dozens (hundreds under some scenarios) of data elements that are required for a true unit record system. It is not at all clear that the NSC is the appropriate site for a unit record system if one were to be created.
The question of when and for what purposes a unit record system is necessary is an important one. Ironically, the problem most often cited as justification for creating such a system—inaccurate graduation rates—can be addressed without a unit record system by simply changing the calculation. Currently, neither the institution from which the student transfers nor the accepting institutions can “claim” the student as a graduate. The simple answer would permit the accepting institution to include the transfer student in their graduation rate calculation. And the NSC knows where these students have enrolled and can track them to permit an accurate count.
Similarly, determining net price for students does not require a unit record system. In fact, neither families nor policy makers need to know net price for individual students at individual institutions. They need to know net price for classes of students(e.g., first year students by income) at individual institutions (e.g. for family enrollment decisions) and across institutions (e.g., to judge the effectiveness of aid policies).
Neither accurate graduation rate information nor net price information (or for that matter most important policy questions) require a very expensive central data system. In fact, industry has moved away from data wharehousing (moving data from disparate data bases into central data bases) to data mining these individual data bases. A straightforward approach to achieving Carey’s stated goals would require all institutions to calculate and present standard data on their web sites and provide powerful search tools to access and aggregate these data.
Higher education associations, including NASULGC, AAU and NAICU have begun working on such an approach, although these efforts appear to have escaped Carey’s attention.
I agree with Carey that this is a very important discussion to undertake. But participants in this discussion deserve full accounts and accurate information.
Brian K. Fitzgerald, at 6:55 am EDT on May 28, 2008
This is an incredibly stupid sentence. “And the need for stringent privacy protections for students goes without saying. ” I think there is a lot that can be said about this. The assumption that colleges are somehow holy sights and academics are the priests and priestesses is actually correct. Colleges are like cults. Students go in, turn 18, and all of a sudden, the college sees it as its duty to sever that student from any and all parental ties. If that student is struggling with a mental health issue it is more expedient for the college to “protect” that student’s privacy and not get him help, and not involve parents. And then when that student makes poor judgement decisions, becomes violent or commits suicide, the college can smugly defend themselves as protectors of privacy rights. Give me a break. They are not concerned with the student. They are concerned with the implications of violating FERPA and losing their federal funding. It’s all about money. It just sounds good when couched in terms of privacy protection.
Privacy issues of students should be THE topic of discussion. Parents certainly have no rights regarding the child whose tuition they are paying for. And colleges are absolutely free to do whatever they want and are accountable to no one. Our son went to college, developed a mental health issue, the college utterly dismissed our concerns, advised our son to place us on a Persona Non Grata list, and in the name of protecting his privacy helped him to disappear at the end of the semester. And now they send us a bill for room damages???? Ludicrous.
You people at Higher Ed need to take a reality check and start advocating for change with this destructive policy.
ccbassin, at 3:35 pm EDT on May 29, 2008
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Telling the Private College Story
Amen. But it’s too bad that NAICU (and ACE, to a large extent) are no longer taken seriously in think tanks and on the Hill. An example appeared in The Chronicle this week, where Hill staffers complained that when they sought help from higher education associations in drafting legislation, the results were laughable.
Private colleges have a better story to tell than their associations put forward. But rather than telling this story, they have sought doggedly to keep information about themselves opaque on the curious presumption that it is better to withhold information from students, parents, and elected representatives than it is to open up and argue from a position of strength about the burdensome collection of unnecessary data.
In the end they are going to wind up with both bad legislation and less credibility.
Friend Telling Unpleasant Truth, at 11:00 am EDT on May 22, 2008