On September 10, 2014 I traveled to Washington, DC to testify on the Postsecondary Institution Ratings System (PIRS) before the Advisory Committee on Student Financial Assistance. I testified based on a set of notes, rather than fully written remarks, but after several requests I have attempted to summarize my comments here.
Members of the committee, thank you for the opportunity to testify today. I came in from Wisconsin because I believe it is clear that students across the country need our colleges and universities to do a better job meeting their needs. As Andrew Kelly and I wrote in our new book Rethinking Financial Aid, the federal government must act to compel institutions of higher education to serve students from low-income families in particular. The question is not if we should do this, but rather how? To that end, here are five recommendations for the PIRS ratings system.
1. The purpose of the ratings should be to ensure public safety rather than to promote consumer choice.
The federal government is currently subsidizing colleges and universities that encourage students to take on a great deal of debt per year of schooling yet provide few prospects for credential completion. Federal support for these schools should end in order to protect students and families, irrespective of the reduction in their “choices.” The students who most need your help—economically disadvantaged people facing serious constraints— are the least likely to use ratings to inform their choices. This is not a shopping decision. It is worth noting that in many settings, including health care, the effects of consumer information have been found to be null and even negative. Proceed in stages, employing minimum standards to remove institutions from Title IV eligibility. Start with institutions that clearly have plenty of resources available to support students. This includes institutions that have sizable per-student endowments and also receive Title IV funds. Next, move to school that garner a disproportionate fraction of their revenue from Title IV.
2. Rate colleges and universities based on factors within their control.
Schools control their admissions practices but often do not control their available resources. Do not reward institutions for having large endowments or penalize them for inadequate state appropriations. Financial resources are more often a condition of success in higher education, not an outcome of institutional practices. Try to avoid perpetuating an already uneven playing field.
3. Make accessibility a requirement for a strong rating.
Capacity is a prerequisite for access. Facilitating college attainment among disadvantaged students requires making room for them. Ensure that institutions are accessible by measuring the extent to which they are increasing the number of available seats over time. Creaming is a common instinct among subjects of accountability. Focus on preventing institutions from reducing access in order to achieve high ratings; it is not enough to simply reward them for good behavior. Examine the metrics used in the Workforce Investment Act, and the technical assistance required to help training providers meet their measures without creaming.
4. Exempt community colleges from the ratings.
Public two-year colleges have a distinct mission and role in higher education. They are explicitly designed to serve their local communities and the vast majority of their students do not participate in a college choice process that will be influenced by these ratings. Giving a community college a poor rating will not serve a community; it will not create positive changes or help the school improve. It will only serve to dissuade students from pursuing college at all, and contribute to woes felt by educational deserts. Efforts to improve student outcomes should be driven by other processes, not this ratings system.
5. Remember the first principle of educational policymaking — “Do No Harm.”
Creating an inadequate ratings system could compromise educational opportunities for millions of low-income students. The unintended consequences created by poor incentives may trigger responses that will be hard to undo.