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Higher Education Transparency and Consumer Choice

NASFAA Consumer Information Task Force Report

August 22, 2014
A recent report from The National Association of Student Financial aid Administrators (NASFAA) argues that consumer information requirements for postsecondary institutions could be enhanced, streamlined or eliminated to limit regulatory burden on institutional officials. The report details 15 recommendations ranging from improving the Department of Education’s College Navigator to repealing the ban on the federal-level student unit record system.

Among the report’s other recommendations:

Obama Administration Should Stop Punting on For-Profit College Job Placement Rates

October 17, 2013

[This post is largely adapted from a previous post that ran on Higher Ed Watch in October 2011.]

Last week I argued that the U.S. Department of Education needs to develop a single, national standard that for-profit colleges would be required to use when calculating job placement rates. Department officials could go a long way in achieving this by revisiting a proposal they offered in the summer of 2010 that would have established a standard methodology to use when determining these rates.

Currently, the federal government leaves it up to accrediting agencies and states to set the standards that for-profit schools must use to calculate the rates, and to monitor them. The only exception is for extremely short-term job training programs, which must have employment rates of at least 70 percent to remain eligible to participate in the federal student loan program.

In June 2010, as part of a package of draft regulations aimed at improving the integrity of the federal student aid programs, the administration proposed extending the standards that short-term programs are required to use to all for-profit college and vocational programs that are subject to the Gainful Employment rules. The proposal was met with a firestorm of protest from for-profit college officials, as the federal methodology is much more strict than that used by accreditors and state agencies.

For example, under the Education Department’s requirements, students are only considered to be successfully placed if they have been employed in their field or a related one for at least 13 weeks within the first six months after graduating. In comparison, some accreditors and state agencies apparently allow schools to consider a graduate to be successfully placed if they work in their field for as little as a day.

Meanwhile, the Education Department has established a strict regulatory regime to make sure the rates are not rigged (the extent to which the agency actually holds short-term programs to these standards is unclear). Institutions are required to provide documentation proving that each of the graduates included in their rates is employed in the field in which he or she trained. According to the Department’s rules, acceptable documents “include, but are not limited to, (i) a written statement from the student’s employer; (ii) signed copies of State or Federal income tax forms; and (iii) written evidence of payments of Social Security taxes.” 

To be fair, for-profit colleges were not the only institutions that objected to the proposal. Community colleges and state universities that have training programs that fall under the Gainful Employment requirements also complained that the plan was too stringent. These institutions may have found these requirements to be especially daunting since they generally have not had to track job placements before.

A Recipe for Failure

How did the Education Department’s political leaders respond to this criticism? They punted. Instead of sticking to their guns or devising an alternative proposal, they kicked the issue to the National Center for Education Statistics (NCES). Under the final program integrity regulations, which were released in October 2010, the Department directed the NCES to convene a Technical Review Panel “to develop a placement rate methodology and the processes necessary for determining and documenting student placement” that schools would be required to use to fulfill this mandate.

But putting NCES in charge of developing a federal standard for calculating these rates turned out to be a major blunder. First, this was not an assignment that the NCES had sought out or has typically been asked to do. After all, the Department was not just asking the center to provide technical assistance in devising a new methodology but to take the reins in setting a new federal policy in this highly contentious and controversial area. Second, the Technical Review Panel that the Department chose to carry out this assignment included a number of representatives from schools that were opposed to this effort.

All of this was a recipe for failure. So it was hardly a surprise that, after two days of discussions on this topic in March, the review committee was not able to reach an agreement. The panel suggested in a final report on its deliberations that "the topic be explored in greater detail by the Department of Education.” Translation: This is a job for the Department, and not NCES.

The Education Department's hands have been tied since because the final regulations explicitly require schools to use "a methodology developed by the National Center for Education Statistics, when that rate is available." In the meantime, the job placement rates that for-profit colleges are required to disclose under the new rules are the same ones they report to accreditors and state regulatory agencies. As I've written previously, the methodologies that for-profit schools use to calculate these rates vary state by state and accreditor by accreditor, making them impossible to compare. And because neither accreditors nor state regulators have historically put much of an effort into verifying these rates, the schools don’t seem to have any qualms about gaming them.

As Department officials rewrite the Gainful Employment rules, they need to revisit this issue. Otherwise, prospective students will have to continue relying on faulty information when choosing whether to attend a for-profit college.

Reporting Burden in Higher Education: The Case of the Clery Act

October 16, 2013
University of Denver Campus Safety Badge

Members of both political parties have decried two seemingly contradictory things in higher education. They want better information to inform students, families, taxpayers, and policy makers – but they also want fewer burdens on institutions, which some say increase costs, stifle innovation, and move schools’ focus away from the primary mission of educating students. While these are both laudatory goals, they appear, at face value, to call for action in opposite, conflicting directions. Students and institutions are left with the worst of both worlds—too much data, reporting, and burden and not enough usable information.

To escape this seeming contradiction between reporting burden and access to information, public discourse and debate should shift away from talking about burden in the generic, abstract sense to the specific ways in which it affects institutions and policy makers. So, let’s look at one of the most heavily cited sources of burden: consumer disclosures. In a 2013 GAO report, this category, which includes campus safety and security reports, was the most frequently cited as burdensome in interviews of experts and higher education officials.

The campus safety component of these disclosures stems from the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, first passed in 1990 as the Student Right-to-Know and Campus Security Act. The law requires colleges to annually report campus security statistics, maintain a public log of recent crime, and provide timely warnings of ongoing threats to students.

The provision grew out of campus safety advocacy efforts led by Connie and Howard Clery, who founded Security On Campus, Inc. (now the Clery Center for Security on Campus) after the brutal and shocking 1986 rape and murder of their daughter Jeanne in her freshman dorm at Lehigh University. The subsequent investigation revealed lapses in security oversight by the university. Her murderer, Josoph M. Henry, a fellow student she did not know, was able to gain access to her dorm by passing through three automatically locking doors that had been propped open with boxes for convenience.  The Clerys also discovered that there had been 38 violent crimes on campus over the prior three years, but no laws at the time required the university to report them to students or prospective students.

After the passage of multiple state laws, the 1990 federal bill was introduced in Congress by Representative William Goodling (R-PA) in response to the Clerys’ advocacy efforts. In introducing the bill, Goodling testified: “This resolution will ensure the Department of Education gives priority status to this important responsibility [of protecting students].... Colleges are trying to hide [crime incidents] because they're in a very competitive business. There's no question they are putting students in danger if they try to cover up the crime that's going on in order to recruit students."  In 1998, Senator Arlen Specter (then R-PA) sponsored legislation tightening the reporting requirements and officially renaming it after Jeanne Clery. At the time of the bill’s passage, Specter spoke at a conference with the Clerys in which he emphasized the importance of campus safety and the lives that would be saved by the bill.

The evidence on whether the act has actually led to a decrease in campus crime in the decades since its passage is mixed. There were no reliable figures before the legislation, and the crime rate fell broadly across the U.S. over the same time period. And although a significant percentage of senior safety and security officials in one study said the law helped bring about improvements to their policies and procedures, most did not see the law as being specifically related to a decrease in crimes in and around campus.  More importantly, it does not seem like students and perspective students are actually using the specific reports and information the law requires. Previous studies and surveys show that the majority of students were not aware of the law and had not read the annual report that it requires, and only 10 percent of students said that they had factored campus crime statistics into their choice of school.

But colleges and universities that don’t meet the law’s stringent disclosure requirements do face significant penalties for violating the act. Each violation is punishable by a fine up to $35,000 per violation and possible loss of Title IV eligibility for the institution. In 1998, Eastern Michigan University was fined $350,000, at that point the largest-ever penalty for violating the law, for failing to quickly and accurately issue warnings after the murder of a student Laura Dickinson in her dorm room. Other institutions, including USC    , have been accused of reporting incidents inaccurately to lower the overall numbers of violent crimes appearing in the log and reports mandated by Congress.

The Clery Act was a strong response by lawmakers to a personal and shocking tragedy. Support for the bill was overwhelming – it passed the House without objection, and the Senate on a voice vote.  The law is not likely to disappear anytime soon – in fact, members have Congress have only piled on more and more requirements to the law. For example, the 1998 reauthorization required institutions to report off-campus crimes that occurred in close proximity to the institution. This led to concern from some institutions on where exactly to draw the line of “close proximity,” given that any tragic event near campus but outside the specified area could bring further negative attention to a school’s policies. Industry organizations also complain that the frequent changes to the law (four in 10 years following its passage) made it nearly impossible to systematically collect and accurately report the information.

Despite the burden and mixed evidence on its utility to students and their families, then, the Clery Act seems deeply entrenched as a key reporting requirement. And yet, key higher education questions for students, families, and the nation – for example, accurate graduation rates, complete student debt figures, and students’ post-education employment prospects – still can’t be answered. And yet, lawmakers have resisted asking schools to report those outcomes, hiding behind the generic guise of burden.

The difference is that campus crime advocates like the Clerys have an evocative story, a powerful movement, and personal champions on Capitol Hill behind them. That combination was enough in this case to overcome the higher education lobby’s pleas for relief from reporting burden. Meanwhile, students’ voices and their families’ interest in the unknowable information about students’ outcomes are drowned out by lobbyists. That’s why the reporting requirements under the Clery Act will be reliably maintained – and other critical questions of the value of college have been shoved to the back.

What Might Ratings-Based Financial Aid Look Like?

September 18, 2013

Last month, President Obama stood before a crowd at the University at Buffalo to propose a new higher education affordability initiative. The plan calls for the U.S. Department of Education to rate colleges prior to the 2014-15 academic year. Then the Department would tie financial aid to those ratings by 2018 – a carrot-and-stick approach to college quality. But we wonder if the Department’s version will really have the teeth to penalize bad actors, and how feasible it really is.

So far, there’s not much information on the White House’s plan. For the most part, all we have to go off of is a White House fact sheet that summarizes the plan. According to the fact sheet,

“Over the next four years, the Department of Education will refine [the ratings], while colleges have an opportunity to improve their performance and ratings. The Administration will seek legislation using this new rating system to transform the way federal aid is awarded to colleges once the ratings are well developed. Students attending high-performing colleges could receive larger Pell Grants and more affordable student loans." [emphasis added]

There are a few items of note here. First, the White House acknowledges that any such effort will require congressional approval. That means that, at least without a sea change in the political environment, this may never come to fruition. But second, and more interestingly, the White House’s examples look at only the “carrot” side of the carrot-and-stick – more available aid for high-performing schools, without any clear punitive measures for poor-performing ones.

Of course, it’s far too early to say what implementation would look like. But it closely resembles an idea that the New America Foundation first published in Rebalancing Resources and Incentives in Federal Student Aid, and which Senior Policy Analyst Stephen Burd dug into deeper in Undermining Pell. Our proposal included both the “carrot” and the “stick” – a Pell bonus for high-performing schools that enroll a larger share of low-income students, and a Pell matching requirement for wealthy schools that divert aid away from low-income students.

The New America Pell Grant bonus differs somewhat from the administration’s. The administration plans to use a ratings system that will likely include a broad range of quality metrics; we would give the bonuses to public and private four-year schools that enrolled large shares of low-income students or to community colleges with strong student outcomes. Our Pell Grant bonus would be double the size of the maximum grant (currently $5,550).

We used data from the Federal Education Budget Project to calculate the costs and estimated the Pell bonuses alone (without the baseline costs of the Pell Grant program at these eligible schools) at $23.6 billion over 10 years for public and private four-year schools and $34.9 billion for community colleges. Those figures include schools that qualified for the proposed bonus based on 2010 data, as well as schools on the cusp of qualifying, which we assume would be willing to work a little harder for a substantial payoff.

At four-year schools, we found that the federal government already disburses $1.2 billion in Pell grant funding to already-qualifying schools,  and another $344 million to the 86 near-qualifiers. That made the math pretty easy – for the additional costs of the program over the baseline, we simply rounded up to provide a conservative estimate, and then counted up 10 years with built-in inflationary increases.

At community colleges, the math was a little trickier. We wanted to use quality metrics, a more simplistic version of those the Department of Education might use under a new rating system. It’s tough to see how community colleges are performing, though, because of limitations in the data. For example, the Department collects graduation rates only for first-time, full-time students, but public two-year colleges serve largely nontraditional students who don’t meet those qualifications. And students who transfer from a two-year to a four-year college without an associate’s degree are only marked as transfers, with no way to track them through the rest of their educational experiences.

Recognizing the data were so prohibitively absent as to keep us from finding a great measure, we calculated a combined graduation-and-transfer rate as a proxy. If the schools had a combined rate of at least 50 percent, they were eligible for a bonus. Many of the schools didn’t have good enough data for us to even arrive at a figure, but of the remaining schools, 262 were eligible, with Pell disbursements totaling $1.5 billion. We found another 120 who were close enough to qualify if they stretched a little further, and added their $1.2 billion in existing Pell money. We rounded up to $3.0 billion to account for missing and not-yet-successful institutions, baked in an inflationary increase, and added up the five- and 10-year costs. Again, those costs are in addition to, not including, the amount of Pell money that already goes to those schools.

Obviously, the New America proposal is not identical – or even similarly oriented – to the White House’s proposal. Ours focused on the needs of low-income students, not the quality of institutions (though with better data on colleges, a stronger focus on quality could be a rising tide that lifts all students).

But our proposal is instructive in a few ways. For one thing, the plan is going to be expensive. New America’s proposal, taken in total, is deficit-neutral, and we made up for the costs of the plan with savings from other proposals. Congress won’t be so lucky, and given the ongoing fiscal debates lawmakers are having, a plan that has one-year costs of upwards of $5 billion won’t be the most popular one. For another, the careful wording in the White House fact sheet means there’s no clear protection against bad behavior, at least in this part of the plan – just an incentive for good behavior. That may arguably be less effective than having both.

Any plan to tie financial aid to ratings is a long way off, and even the ratings system is a few years down the line. By 2018, we’ll have a different president, many different members of Congress, and undoubtedly new approaches to reforming higher education. It remains to be seen whether the plan will be strong enough to survive all that, or whether the 2018 political climate will actually be more amenable to these types of proposals. In the meantime, the New America Foundation will be watching for signs of life with this proposal, as well as the president’s other ideas.

The Ed Dept.'s New Proposed Language for Gainful Employment is Out. Here's What You Need to Know

August 30, 2013

With a little bit more than a week until the next round of negotiated rulemaking on gainful employment kicks off on Sept. 9, the U.S. Department of Education today released its initial proposal for the new rule along with reams of supporting data. Higher Ed Watch will be digging into this information over the coming days, but here's what you need to know right now.

President Obama Aims to "Shake Things Up" in Higher Ed

August 23, 2013
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When President Obama said he was going to “shake things up” in higher education just under a month ago, many of us didn’t really believe it, fatigued from lofty presidential promises that failed to go anywhere due to Congressional gridlock and the effective workings of the higher education lobby. Well, we were wrong. This week he revealed his bold new vision for higher education that will focus on three key areas: paying for performance, promoting innovation and competition, and ensuring that student debt remains affordable. The first priority—paying for performance—could be the most ambitious reform to higher education funding since the creation of federal financial aid.

Speaking to a large crowd of mostly college students at SUNY Buffalo, Obama explained, “Our first priority is aimed at providing better value for students -- making sure that families and taxpayers are getting what we pay for.  Today, I’m directing Arne Duncan, our Secretary of Education, to lead an effort to develop a new ratings system for America’s colleges before the 2015 college year.”  

A ratings system based on college performance across the dimensions of access, affordability, and outcomes would be a welcome alternative to input- and prestige-focused rankings. In his speech, the president called out the much-derided (but much-used) US News and World Report rankings:  

Right now, US News and World Report puts out their rankings [each year], and it encourages a lot of colleges to focus on ways to…game the numbers, and it actually rewards them, in some cases, for raising costs.  I think we should rate colleges based on opportunity.  Are they helping students from all kinds of backgrounds succeed, ...on outcomes, on their value to students and parents? 

Even if the president had stopped with the creation of a new ratings system, this would have been big news and a huge step because it doesn’t require congressional approval, making it harder for the education lobby to thwart. But he didn’t stop there. He challenged the way that federal financial aid dollars are allocated by proposing that they be based on these outcomes-focused ratings, rather than enrollments (examples from the White House fact sheet include providing larger Pell grants or more affordable federal student loans to students at high-performing colleges).   

Last year, when the president proposed tying just a small portion of federal campus-based financial aid dollars (i.e. Perkins loans, federal work-study) to “value” in his State of the Union, the higher education lobby cried foul—stating that the proposal was both: 1) Too small to matter; and 2) Too large a federal intrusion. Given that the president just proposed tying a much larger pot of money to outcomes—Title IV aid that is the lifeblood of most institutions of higher education—perhaps he agreed that his first attempt was too modest. But he clearly disagrees that this is too large a federal intrusion, and said as much in his speech:

And I’ve got to tell you ahead of time, these reforms won’t be popular with everybody, especially those who are making out just fine under the current system.  But my main concern is not with those institutions; my main concern is the students those institutions are there to serve…It is time to stop subsidizing schools that are not producing good results, and reward schools that deliver for American students and our future.

We couldn’t agree more. And we’re glad that our (low) expectations for the speech were mistaken. A rating system is coming. One that will be created after much careful consideration and participation with stakeholders and one that we hope is based on much better data that focus on access, affordability, and outcomes. Once this happens, students, families, and taxpayers will have a better understanding of the value of specific institutions, and Congress will no longer be able to ignore the good and bad actors the ratings reveal. Instead, lawmakers will know where money should be focused to get the most bang-for-the-constituent-buck.

Stay tuned in the coming days for more analysis of the White House proposal.

CHEAT SHEET: President Obama’s Higher Ed Plan: What Requires Congressional Approval?

August 22, 2013

We’ve been getting a lot of questions about what in President Obama’s higher education proposal requires Congressional approval. We’ve made this cheat sheet to give you a quick and dirty look. This is not meant to be exhaustive. Instead, it’s a straightforward way to evaluate what the President has power to do while clarifying some important requirements.

As an added benefit, the cheat sheet follows each point in the White House fact sheet on the President’s plan to make college more affordable. It’s available as a picture, Excel spreadsheet, and PDF for your convenience.

And if it isn’t obvious, green means President Obama has the go-ahead. Red means stop for Congressional gridlock. 

Click on image to enlarge it.

Stay tuned in the coming days for more analysis of the White House proposal.

Edited 8/22/2013 to add a note to "Make all borrowers eligible for Pay-As-You-Earn (PAYE)"

Obama Education Plan and New America Research

August 22, 2013
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President Obama today announced a bold new plan for higher education that aims to make college more affordable. Many of the features of the Obama plan have been the subject of research and analysis by the New America Foundation’s Education Policy Program in the recent past. This blog post sets out how New America’s research links with, and can help to shape, the current round of higher education reform efforts. It is our hope that our readers will find it a helpful resource.

This post closely aligns with the White House’s fact sheet on the President’s plan to make college more affordable. 

Paying for Performance

Policy 1. Tie financial aid to college value

What New America has said: “Colleges have traditionally received federal financial aid with few strings attached. In order to create new accountability mechanisms for improving data collection and to require colleges to provide more information about their success in serving students, we would hold colleges accountable for quality and affordability by extending broad accountability metrics to all higher education institutions.” (January 2013 report, Rebalancing Resources and Incentives in Federal Aid)

Policy 2. Challenge states to fund public colleges based on performance

What New America has said: "With the economy stuck in neutral, tuition prices and student loan debt skyrocketing, and parents and students increasingly questioning the value of a college degree, our public institutions urgently need a different approach to the challenge of educating an increasingly diverse mix of students at a reasonable cost. For this reason at the national level, there should be a competitive grant program, like Race to the Top for Higher Education, that challenges public higher education institutions to innovate." (May 2013 report, The Next Generation University)

Policy 3. Hold students and colleges receiving student aid responsible for making progress toward a degree

What New America has said: “One area ripe for experimentation is how colleges disburse federal student aid. Financial aid is typically distributed in one or two lump sums, which may work well for students attending traditional four-year colleges that generally require large upfront payments from students and their families. But in cases where the primary costs students face are not large upfront payments, but more regular, ongoing costs of living, it may be counterproductive to distribute aid in one or two large disbursements… Changing aid delivery to smaller, more regular disbursements at low-cost institutions could provide these students with more reliable income, create greater incentives to persist, and protect students who have to withdraw during the semester from having to pay back large amounts of aid.” (January 2013 report, Rebalancing Resources and Incentives in Federal Aid)

Promoting Innovation and Competition

Policy 4. Challenge colleges to offer students a greater range of affordable, high-quality options than they do today

What New America has said: “In an era when college degrees are simultaneously becoming more important and more expensive, students and taxpayers can no longer afford to pay for time and little or no evidence of learning. Federal policy should encourage traditional institutions to think differently about how they deliver and award credit for learning and also create a space for nontraditional institutions and organizations to prove their ability to help students achieve real, objectively verified learning outcomes.” (September 2012 report, Cracking the Credit Hour)

What New America has said: “At a time when a higher education is more important to individual and collective prosperity than ever before, students need online courses and degree programs that are effective, affordable, and grounded in public values. A State U Online model is achievable, but only if states and higher education institutions work together to share their resources and reduce barriers that prevent students from moving seamlessly through the system – credits in hand.” (April 2013 report, State U Online)

Policy 5. Give consumers clear, transparent information on college performance to help them make the decisions that work best for them.

What New America has said: “One of our biggest concerns with government consumer information tools is the assumption that students and families already have enough knowledge about higher education to understand what they are seeing. Higher education involves a lot of jargon. What does default mean? What is a 10-year repayment plan? What is a federal student loan? The [existing] Scorecard misses an opportunity here to raise overall higher education “literacy” for families.” (April 2013 blog post, “New College Scorecard: Will Students Use It?”)

Policy 6. Encourage innovation by stripping away unnecessary regulations.

What New America has said: “Higher education generally suffers from a lack of rigorous experimentation, both in terms of practice and policy. Federal financial aid is no exception...Fortunately, the ability to conduct such evaluations already exists, thanks to legislation passed in 1992. The Experimental Sites Initiative (ESI) allows the Department to waive regulatory and/or statutory financial aid requirements for a small, voluntary group of institutions to reduce burden, improve delivery of aid, or “otherwise benefit” students.” (January 2013 report, Rebalancing Resources and Incentives in Federal Student Aid)

Ensuring that Student Debt Remains Affordable

Policy 7. Help ensure borrowers can afford their federal student loan debt by allowing all borrowers to cap their payments at 10 percent of their monthly income.

What New America has said: “A redesigned federal student loan program would substantially reduce the dangers of borrowing by offering a single repayment plan that is similar to both the ‘Pay-As-You-Earn’ plan that the U.S. Department of Education recently enacted (which itself is meant to mimic a plan in statute set to take effect in 2014) and the income-based repayment plan that was enacted in 2007. Under this proposal, all borrowers would repay their loans as a percentage of their income. Such a system would recognize that some people will never earn enough to fully repay their debt, no matter how earnestly they try.” (January 2013 report, Rebalancing Resources and Incentives in Federal Aid)

Policy 8. Reach out to struggling borrowers to ensure that they are aware of the flexible options available to help them to repay their debt.

What New America has said: “Figuring out how to pay for college is a seriously complex process. Students need to be aware of the terms and conditions of their loans before they sign their promissory notes. But we can’t be complacent in thinking that all students are coming from the same place and have the same general understanding of student loans. For many students and families, a student loan is their first loan, and their unfamiliarity with loan vocabulary will add further mystery to an already opaque process. More needs to be done to educate borrowers about financial aid.” (June 2012 blog post, “What Borrowers Don’t Understand About Student Loans May Hurt Them”) 

Stay tuned in the coming days for more analysis of the White House proposal.

No One's Watching the Watch Lists

July 1, 2013

Last week, the U.S.. Department of Education unveiled the latest set of tuition watch lists, the annual exercise to "shame" colleges and universities by publicly identifying those with the biggest price increases. The lists were arguably the House and Senate's most public effort to tackle rising college costs in the 2008 reauthorization Higher Education Act, and were trumpeted at the time by various members of Congress as an important step to hold colleges accountable for their costs. Yet after three iterations it is clear that the lists are not a meaningful accountability tool, but the end result of a Congressional punt that avoided tough conversations about college costs and instead created little more than a digital version of Congressmen's favorite histrionics--finger wagging and stern talking-tos.

The failure is less the lists themselves and more misplaced expectations about what they could accomplish. The cost of college is a complex problem driven by state budgeting practices, instructional delivery, available competition, and a host of other factors that have their own set of solutions and challenges. In that light, transparency is not a bad thing, but it's an incomplete and insufficient solution that makes for good press releases and tough talk without needing to actually engage in important battles and conversations. 

But tempering expectations can't make up for the morass of lists of limited consumer utility created by Congress. The law requires the production of 54(!) different lists, with six different types of rankings for each of the nine postsecondary sectors . The result is lists for the 89 schools in the private nonprofit less-than 2-year sector that have between one and four institutions on them while no one national ranking.

More importantly, the lists do very little as a consumer tool. Take a look at the highest tuition public 4-year institutions, which enroll one-third of students and where costs are high enough to generate some concerns:

If you live in Pennsylvania, the lists tell you that you're basically screwed. If you don't live in Pennsylvania, the only thing the lists tell you is that you probably shouldn't move to Pennsylvania. But for a typical consumer, there's little of value here. That's because the list presume a national college search when most students don't look much beyond what's nearby. According to the Beginning Postsecondary Students Survey, the first institution attended by 75 percent of students is within 56 miles of their home. And for students at public or private nonprofit 4-year institutions--the two sectors where students are most likely to travel--half still attend schools within 50 and 100 miles, respectively of their homes. 

Other lists are only full of small, obscure rabbinical schools or tribal colleges that enroll at most dozens of people. For example, look at the top 15 private nonprofit 4-year institutions with the greatest percentage increase in net price:

Now shaming an institution with fewer students than enroll in the typical introductory psychology course may be important if it truly is ripping off its students. But its certainly not effective in a world with limited resources for accountability and enforcement.

Not only do the lists not reflect actual students' search, they also lack any other information. The University of Illinois at Urbana-Champaign is more expensive than Chicago State University, but it has a graduation rate of 82 percent compared to 21 percent of students at Chicago State. Surely the extra $6,000 a year is worth considering for having nearly a four times greater chance of completing. That's why the College Scorecard is a much more promising because it combines information not just on cost, but also graduation, borrowing, and other important things that should be at least part of a student's college selection process. 

So what about as an accountability metric? Institutions on the list are required to submit reports to the Department detailing the drivers of cost and what's being done to address them. Maybe the result will be thoughtful analyses and careful planning. Or maybe it will be a set of apologias related to state appropriations, personnel costs, or other factors that check the box and allow schools to move on. But realistically, being one of several hundred colleges on dozens of lists isn't scary--it's a big crowd that it's easy to get lost in. That's why Sarah Lawrence defends its tuition when it ends up as number one on the list, but Wake Forest University, which sits in last place, can keep largely quiet. 

In general, the notion of naming and shaming isn't the worst idea in the world (and it's certainly better than some of the silly reporting disclosure requirements, such as posting file sharing policies, that Congress also included in the Higher Education Act reauthorization). But it needs to decide what it is. If you want a useful consumer tool, then combine it with other targeted information and try to reflect how students actually make choices (and maybe consider enforcing other disclosure requirements around graduation rates that colleges willfully flaunt). If you want it for accountability purposes, then put out one list of 10 and attach some real penalties. But right now it's the worst of both worlds. Shaming the 57-student Talmudical Academy of New Jersey doesn't make consumers any smarter. And taking credit for it as a meaningful attempt to address important and fundamental issues of college cost in this country is just an exercise in misleading buck passing.  

Why Act When You Can Ask For A(nother) Study? House Kicks the Can On Better College Data

May 14, 2013
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For more on this issue, check out this post from Clare McCann on our sister blog, Ed Money Watch.

For those who care about increased higher education transparency, the last few days have been a trip through the Congressional looking glass, culminating with yesterday’s introduction of a bill to “study” higher education transparency. On Thursday a bipartisan group of senators and representatives introduced the Student Right to Know Before You Go Act, which would help provide students, families, and taxpayers with answers to critical questions like whether students at particular institutions graduate, whether they get jobs, and whether they can comfortably pay back their loans. A televised discussion among Senators Wyden (D-OR), Rubio (R-FL), and Warner (D-VA), Representatives Hunter (R-CA) and Andrews (D-NJ), students, and guidance counselors underscored the urgent need for better information about higher education outcomes and value.  

It seems pretty straightforward. Students, families, and policymakers have questions. And this legislation would provide answers. But the day after the legislation was introduced, an unnamed senior Congressional education staffer said of the effort, “But a federal unit record system is only designed to answer questions no one is asking, namely: how do we bring No Child Left Behind and its command and control mentality to higher education.”

Let’s ignore the intentionally distracting NCLB reference and instead focus on this doozy: “designed to answer questions no one is asking.” Perhaps the staffer has fallen through the looking glass, because from this side it seems like everyone is asking these questions.

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