Feedback on Ratings, Round 3

Several college groups offer some advice to the Education Department on how to structure the ratings system that they believe shouldn't be built in the first place. 

February 19, 2015
 

WASHINGTON -- From the moment President Obama called for a federal college ratings system some 18 months ago, colleges and universities have criticized the idea and lobbied against it.

But as the Obama administration charges ahead with the proposal -- officials just last week said they’d have a first draft ready by summer -- some higher education groups that had been critical of the plan are, to some extent, beginning to play ball with the Department of Education.  

Several prominent associations are now offering advice, albeit limited, for how the administration should structure a federal ratings system that they believe, and continue to stress, shouldn’t be built in the first place.  

That reluctant input on the ratings system is part of the feedback department officials have received over the past several weeks. Public comments on their 17-page “framework” document were due Wednesday, after the department extended the deadline by a day due to a snowstorm on Tuesday that closed federal offices here.

The thrust of the feedback reviewed by Inside Higher Ed reiterates the wide-ranging concerns of many in higher education about the ratings system. In spite of their opposition, though, some groups offered the type of specific feedback on the particulars of the ratings plan that department officials have sought.

The American Association of Community Colleges, for instance, remains opposed to ratings, but pointed department officials to the Social Security Administration as “likely the best source” for any earnings data. And if the department decides to publish earnings information, the group said, officials should break down that information by academic program rather than publishing aggregate data for an entire college.

Public universities, too, reiterated their opposition to the ratings but said they supported efforts to cut off federal funding to institutions that perform poorly on certain metrics like students’ rates of degree completion, employment and repaying their loans. The comments from the Association of Public and Land-grant Universities echoed an “alternative” to the ratings plan that the group has previously proposed.  

The Association of American Universities -- while maintaining that it “is inappropriate for the federal government to rate institutions” -- offered tepid support for evaluating colleges’ ability to produce graduates who find employment that pays above a certain minimum amount.

That approach, wrote AAU President Hunter Rawlings, “could serve to identify bad actors without placing an undue emphasis on salaries.” But he added that the metric would need to be adjusted for variations in living costs across the country.

The AAU also cautiously praised the administration’s proposal to include institutional improvement as a metric in the rating system. But the group, which represents the nation’s elite research universities, worried that “top-performing institutions may have limited opportunity for improvement, for which they should not be penalized.”

A central issue that department officials have left undecided in the ratings proposal is whether the system should assign a singular rating to colleges or publish institutions’ performance on various metrics.

Several higher education associations weighed in on that question, telling the department that they would find more palatable a ratings system that involves multiple data points rather than an aggregate rating. For instance, Rawlings wrote that using “disaggregated data would be more useful for consumers and institutions, and would avoid the tricky issues associated with weighting and combining metrics.”

Still, many other critics of the ratings system did not offer any specific feedback on the various questions posed by the department’s framework document.  

Those groups, like the National Association of Independent Colleges and Universities, which represents private institutions, said that the ratings system was a bad idea when it was first proposed, and remains one today.

“Our member presidents have been consistent in our belief that rating colleges is not possible, whether done by private commercial entities or by the federal government,” wrote David L. Warren, the group’s president.

The American Council on Education wrote that the department’s December draft is “so incomplete, tentative and amorphous that it is impossible to offer the type of critique that this undertaking would otherwise require.”

Unions representing faculty members, like the American Federation of Teachers, similarly spent pages of comments railing against the ratings system.

Proponents Push for Debt Information

Among the advocacy groups and think tanks that support the ratings system, commenters said the administration should include student debt information as part of the rating system.

“It is one of the most common questions students have about an institution and one of the biggest concerns,” wrote the National College Access Network, a collection of groups that advocate for low-income students.

In addition, a coalition of groups dubbed the Postsecondary Data Collaborative called on the department to break down colleges’ graduation rates and other performance metrics by race and ethnicity.

Adjusting for Student Characteristics

The latest round of comments also showed stark disagreements over whether the Obama administration should adjust a college’s performance in the ratings system based on the demographics of the students the college enrolls.

Both the AACC -- the community college association -- and the AAU, the research university group, said they opposed such an approach, which is controversial.

The department should categorize colleges, wrote AACC President Walter G. Bumphus, according to “broad groupings of student and institutional characteristics, rather than impose a complex regression-based measure with questionable validity and reliability issues.”

“Rather than increasing transparency, adjusting outcomes risks turning the ratings system into a black box that neither consumers nor institutions fully understand,” wrote Rawlings, the AAU president.

Meanwhile, the United Negro College Fund, which advocates for private historically black colleges and universities and opposes the rating system, said the ratings must include adjustments for student demographics in order to allow accurate comparisons.

“Without these adjustments,” wrote Michael L. Lomax, the group’s president and CEO, “a ratings system would create an inaccurate picture of institutional impact, penalizing institutions that serve a high proportion of at-risk students.”

The APLU, the public university group, similarly embraced the risk-adjustment approach in its alternative ratings plan, calling on the department to apply a “student readiness index” to performance metrics like graduation rates and levels of employment.  

Next Steps

Education Department officials have said they’ll use the feedback as they produce a first iteration of the ratings -- including names of colleges -- by this summer.

Because the ratings system is not part of a regulatory process with firm rules governing public comments, officials have said they are free to continue to solicit informal feedback on the ratings in the coming months.

Denise Horn, a department spokeswoman, said the agency would release all of the comments it has received on the ratings framework by this Friday.

***

Following is a partial list of some of the ratings comments that groups have already made publicly available or that have been obtained by Inside Higher Ed:

American Association of Community Colleges

American Council on Education (with 25 other groups)

American Federation of Teachers

Association of American Colleges and Universities

Association of American Universities

Association of Private Sector Colleges and Universities

Association of Public and Land-grant Universities

Education Reform Now

National Association for Equal Opportunity in Higher Education

National Association of Independent Colleges and Universities

National Association of Student Financial Aid Administrators

National College Access Network

Postsecondary Data Collaborative (coalition representing nine groups)

The Institute for College Access and Success

United Negro College Fund

Young Invincibles 

 

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