On December 17, 2013, the Department of Education posted a notice in the Federal Register, asking for public input into how best to design the metric to rate colleges that was proposed by President Obama in August 2013. Many of you have asked for guidance on how to respond.
The most fundamental problem with the request by the Department is that the proposal is based on a flawed assumption that it is possible to assess and rate the quality of America’s diversity of institutions of higher education by a “single set of measures” or “rating.” However, since the Administration is forging ahead despite strong sentiment that this whole notion is problematic; because there will be many who will be poised to write in to applaud the step; and, because some who oppose the idea of a rating will weigh in under the belief that a better metric is preferential to a worse one, I encourage you to participate and offer the following recommendations for submission of comments:
- Reiterate why it is not possible to reliably and validly assess the value of such diverse institutions using a “single set of measures” or “rating”;
- Embrace our shared interest in working with the Administration on the common goals of access, affordability, and transparency;
- Encourage the federal role in providing consumer information, particularly as it relates to making some key data points commonly available to help students find a best fit college.
- Reference that NAICU’s U-CAN effort was developed in response to policy makers’ calls during the last decade for such consumer transparency and could serve as a launching point for a joint effort between institutions and the federal government. Here is what U-CAN teaches us a federal consumer information system should do:
- Ask consumers what they want. When you do, what is discovered may be different than what policy analysts want to know or use to judge schools.
- Make it long and short enough. Too little information can be misleading, too much overwhelming. U-CAN incorporates 49 data points within the two-page profiles using reader-friendly info graphics, charts, and graphs recommended by focus groups.
- Include both quantitative and qualitative information. Beyond facts and data points, prospective students told us they wanted to know about the nature of the institution so they could determine “fit.” U-CAN allows institutions to tell their own story through 26 links on each college’s profile, so students can learn more about what each school is really like.
Submissions can be sent by January 31, 2014 via the Federal eRulemaking Portal (type ED-2013-IES-0151 in the Search function to access the appropriate Request for Information), or via postal or commercial mail (address them to Richard Reeves, National Center for Education Statistics, Attention: Postsecondary Institution Ratings System RFI, U.S. Department of Education, 1990 K Street NW., 8th Floor, Washington, DC 20006). The Department will not accept faxed or e-mailed comments.
To read what others are saying about the proposal and for more ideas on some points you might wish to make, see the commentaries NAICU has collected on this topic. Thanks to all of you who have written so eloquently on this proposal, and continue to advocate for a better approach.
I hope to see most of you at our upcoming Annual Meeting in early February.
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