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Policy is meant to address problems as they’re understood. When the problems aren’t fully understood, the policy intervention can misfire pretty badly. 

The higher ed policy world is lit up with commentary on the proposed new rules for “gainful employment” regulations. The details are complicated, but in essence, the idea is to crack down on programs that are designed for the benefit of the institution that offers them, rather than for the benefit of the students. If high numbers of graduates prove to be so loaded with debt, and so poorly paid, that they can’t pay back their loans, then the providers of those programs will have to either improve the outcomes or lose eligibility for Federal financial aid.

“Gainful employment” regulations apply to “terminal” programs that are supposed to lead to jobs. They don’t apply to, say, liberal arts transfer programs at community colleges, since those programs were never intended to be either terminal or vocational.  They were designed to be the first two years of a four year degree, so judging outcomes by wages a year out wouldn’t make sense. A year out should mean the junior year of college.  Most currently-enrolled undergraduates don’t make very much.  Of course, they also have student loan deferments, so between low wages and deferments, applying wage-loan metrics wouldn’t shed much light.

The details of the new proposal are many -- seriously -- and complicated, and I won’t pretend to have mastered all of them. They’re also subject to legal challenge and shifting political winds. My community college colleagues have already pointed out, correctly, that loan default rates can be a misleading measure when only a very small portion of the student body takes out loans at all. I’ll add concern about the difficulty of assuming a clean division between “academic” and “vocational” programs.

Teacher Education is a good illustration. It’s a classically vocational program, in the sense that it’s entirely oriented around preparing for a specific job.  But you don’t get a teaching job, at least in most states, with only an Associate’s degree. A full-time K-12 teaching job requires a Bachelor’s at a minimum, and they frequently require going beyond that as a condition of keeping the job.  So the program is “vocational,” in the sense that’s it’s oriented around a particular job, but it’s also “transfer.” And the eventual outcomes have at least as much to do with the four-year college as with the community college, making “accountability” that much more complicated.

Much the same applies to engineering, human services/social work, criminal justice, and, increasingly, nursing. Policies that assume a clean divide between ‘vocational’ and ‘transfer’ programs will have a difficult time addressing these.

If current trends continue, though, I’d expect to see programs like these become progressively larger parts of the system. They’re already too big to write off as exceptions, but soon, they’ll be big enough to constitute a category of their own.  We need to be careful not to write policy that will get in the way.

If anything, I’d like to see more awareness at the high school level -- including guidance counselors and parents -- that for many students, posing the question as “community college or a four-year school” gets the conjunction wrong. For many students, community college AND a four-year school is the best answer.  It’s a straightforward way to keep costs down without sacrificing ambition.  For that pathway to thrive, though, policy has to allow for it.

In practice, the current focus seems to be primarily on for-profit providers, some of which have alarmingly bad outcomes. By all means, crack down on the worst abuses. But let’s not get so focused on the abuses that we inadvertently penalize or shut down what is increasingly the best option for many students. 

Community colleges suffer a certain invisibility when their graduates go on to graduate from higher-level places and go on to do great things. That’s bad enough; let’s not make a bad situation worse by building policies that premise accountability on false assumptions.

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