AAC&U Board of Directors Feedback on US Department of Education College Ratings Framework

Tuesday, February 17, 2015

This statement was submitted on behalf of the AAC&U Board of Directors commenting on the proposed “College Ratings Framework” formally released on December 19, 2014.

As we have noted in previous statements, the Association of American Colleges and Universities (AAC&U) supports the broad goals of the ratings framework—especially goals related to making “college more accessible and affordable” and ensuring that “all students graduate with a quality education of real value.” 

Moreover, we commend the Department of Education for its openness to engaging with the higher education community to explore the limitations and many potential unintended consequences that might result from rating colleges and universities using the limited data systems currently available. We appreciate, in this context, the fact that the proposed metrics related to post-graduation salaries have moved in a productive direction away from simplistic measures of recent graduates’ mean earnings. 

Despite the good faith effort to elicit guidance from the higher education community, however, the AAC&U Board of Directors continues to believe that the project of “rating” entire institutions is fundamentally misconceived—and potentially misleading.  As we have said in previous public comments, the true “value” of college comes from the learning gained, and from the difference that learning makes across the lifespan, in graduates’ economic, civic, and personal development.  Higher education also makes a crucial difference to the economy, with areas well-served by higher education demonstrably more likely to be growing economically and in terms of civic vitality as well.  Finally, higher education’s research and development accomplishments have been fundamental to US success in the global community and economy.

Because the public value of higher education is so multi-faceted, AAC&U holds that it is impossible to reasonably “rate” the “value” of entire institutions of higher education using the limited data points presented in the proposed framework.  We, therefore, do not believe the proposed rating system is appropriate nor will it meet the stated goals articulated for it.

We understand why the Department of Education has chosen to focus on only a few sets of data points since even those few are complex and would need careful weighting to be informative.   Still, the ordinary person will rightly assume that, if the federal government is “rating” colleges, universities, and community colleges, it must have reached a judgment about the quality of their educational programs. 

The public will be wrong in this assumption.  In this sense, the entire project is misleading rather than illuminating for students, families, and the public—and for policy leaders as well. 

The Department is correct to avoid any effort to “rate” the quality of learning or of the different degree programs offered by individual institutions.  With students majoring in literally hundreds of different areas of study, there is no way that a ratings system could meaningfully “compare” different institutions’ educational performance. 

And yet, because the data being proposed for inclusion do not address the most important aspects of the value of pursuing and attaining a college degree, the ratings project has no capacity to guide students wisely in their efforts to obtain a quality degree.

While we oppose the ratings framework as proposed, we do believe that the US Department of Education could and should use the publication of “selected indicators” in a narrower way to steer students away from institutions that have demonstrably bad records in serving the low-income students who most need the added advantage of an opportunity-expanding college education.  Institutions that have 1) few graduates, 2) high levels of student debt and debt defaults, and 3) few graduates earning a living wage following their time in college are clearly bad prospects for low-income (and other) students, and bad priorities for the investment of public dollars.

We, therefore, urge the Department to target any “ratings system” it might develop more narrowly on whether institutions are actually expanding opportunity for low-income students, singling out for low ratings those institutions that are failing low-income students while receiving significant public investment of tax dollars intended to expand their educational opportunities.

As AAC&U begins its Centennial year of dialogue focused squarely on advancing inclusive excellence in higher education, we urge the Department to continue its focus on ensuring that our entire higher education system improves its capacity to serve well students from lower income groups and from racial and ethnic groups traditionally less well-served by education.   It is fully in the public interest to target investments and accountability systems toward these students—and to provide data about how well they are served by our nation’s higher education institutions.  These students surely need educational opportunity more than ever and, given clear demographic and economic shifts, our nation’s entire future success—both in its democracy and its economy—will depend on how well we educate these students.  We welcome—and will heartily support—any efforts to target the ratings system and/or other educational incentive programs toward providing meaningful access to higher education institutions that have proven track records of educating effectively and fully students from low-income groups and from underrepresented groups.

Other AAC&U Statements on Proposed US Department of Education College Ratings System

Taking the Lead on Evidence
May 30, 2014

AAC&U Responds to President Obama's Proposed College Ratings System
November 11, 2013

Ensuring the Value of US Higher Education
August 28, 2013