As I was driving to work on the Friday that Christmas break began, I heard on the radio that the U.S. Department of Education was releasing its plan for federal college ratings that day. I had two immediate reactions reflecting different parts of my DNA.
Putting my blogging hat on, my initial thought was that I needed to write a post analyzing the plan for Monday publication, but then I came to my senses and realized that no one would have the time or interest to read about federal college ratings (or any other issue I might write about) three days before Christmas.
The cynic/conspiracy theorist within me noted that a common government tactic is to “hide” bad news by releasing late on a Friday afternoon when the media and public are not paying attention. How bad must the plan be to justify “dropping” it on the Friday before Christmas?
I have read the plan and realize there was no sinister intent. The Obama administration had promised release of the plan in fall of 2014, and the following Sunday happened to be the first day of winter.
There’s also no plan. A Chronicle of Higher Education article describes it as “heavy on possibilities and light on details.” That assessment is generous. At this point the Department of Education has only a vague idea of what the final version might look like. The release describes it as a college ratings “framework.” It might be more accurately described as a skeleton, only with enough bones missing that a casual observer would be hard-pressed to identify the animal.
The goal of measuring access and affordability is laudable. So is the decision to “avoid rankings and false precision” and focus on outcomes rather than input factors. The question is how easy it is to actually measure those things.
The easiest way to measure an institution’s commitment to access is the percentage of enrolled students receiving Pell Grants, but how good a measure is that? I have previously written about the danger of confusing measuring what we value with valuing what we can easily measure. Does the current threshold for Pell eligibility capture all the students for whom access to higher education is limited economically? Another potential metric, the number or percentage of first generation students, is complicated by lack of a consistent definition for what constitutes a first gen student.
With regard to affordability, what do metrics like “average net price” and “average loan debt” tell us, and what are their limitations? The Department of Education acknowledges that current net price data is incomplete, including only students receiving aid (which might be okay). In addition, public institutions only report average net price data for in-state students. At this time, average federal loan debt is not being considered in the proposed ratings, and the Education Department recognizes that using that data could lead some institutions to encourage students to take out more expensive private loans rather than federal loans in order to game the ratings.
The proposed ratings are on shakiest ground when it comes to measuring outcomes. Should degree completion be measured over four years or six years? Should four-year institutions be penalized for students who transfer to another four-year school? And how meaningful is data on earnings? Those numbers are more heavily influenced by what a student majors in than from where he or she graduates. Should we measure earnings five years beyond graduation or over a lifetime? And is a school that produces lots of investment bankers and lawyers “better” than one which produces teachers and those with non-profit service careers?
Another issue to be determined is how institutions will be grouped for meaningful comparison given differing missions and student populations. In Virginia, the College of William and Mary and Virginia State University are both four-year public institutions, but have little else in common. Should they be compared?
Far more interesting are several larger philosophical questions. What’s the purpose of the ratings? Is it to provide information to consumers, or is it to hold institutions accountable? Is it possible to design a rating system that does both?
Are ratings preferable to rankings? The Department of Education plans to place schools in three categories for each metric—“high-performing,” “low-performing,” and those in the middle. Those categories would seem to have been developed in consultation with Goldilocks and the three bears. A year ago two analysts at the American Enterprise Institute crunched the numbers using three thresholds—25% Pell recipients, 50% graduation rate, and net price under $10,000. They concluded that only a few institutions are terrible in all three areas (access, affordability, outcomes), but only 19 four-year institutions exceed all three thresholds.
That would seem to answer a question raised in the Department of Education draft, about whether consumers would find it easier to see only a single comprehensive rating. A single rating would probably be easier, but easier is not better when it leads to the “false precision” that so many of us find troubling in attempts to rank colleges. Back in February, Bob Morse, U.S. News’s guru of false precision, gave advice and asked questions at a symposium on the technical issues underlying federal college ratings. That’s like Wyle E. Coyote serving as an expert witness at a conference devoted to Roadrunner protection.
The ultimate question is whether rating colleges is a legitimate function of the federal government. The answer to that question may depend on one’s political leanings about the role of government, but you don’t need to be a member of the Tea Party to question whether the Department of Education should be rating colleges. At the same March meeting where Bob Morse spoke, another speaker suggested that the government should develop a database and leave it to others to figure out how to use it.
A lot depends on whether this is comparable to the gainful employment rules put into place with regard to for-profits, and I don’t think it is. In that case, the federal government had a legitimate interest in protecting taxpayers from fraud, because a number of for-profits were operating an economic model where a huge amount of revenue was coming from federal financial aid for an “education” that was leaving students unprepared for employment and in debt. A fundamental principle of ethics is “treat like cases alike,” and this doesn’t seem to fit. In any case, there’s a lot of work to be done and questions to be answered before federal college ratings will make sense.