President Napolitano delivered her comments on the draft framework for a new system of college ratings in a letter to the Department of Education.
Dear Secretary Duncan:
The University of California (UC) appreciates the Department of Education's invitation to comment on the draft framework for a new system of college ratings. As the nation's largest public research university, UC applauds President Obama's commitment to strengthen the performance of colleges and universities in promoting access, affordability, and improved student outcomes in higher education.
UC educates nearly 190,000 undergraduates and 50,000 graduate students across its 10 campuses. It serves as a model for the nation's colleges and universities in combining access, affordability and positive student outcomes. Many public institutions enroll large numbers of first-generation-college and low-income students. Similarly, many nationally ranked private and public institutions provide quality instruction, high-value degrees, and excellent graduation and time-to-degree rates. As recognized in Washington Monthly, UC's unique contribution to California and to higher education is its success in combining world-class quality with such a large and diverse student body. Fully 42 percent of UC's undergraduate students are Pell Grant recipients; 41 percent are the first in their families to attend college.
UC is open to engaging in a national discussion of a framework for a college ratings system that leads to increased institutional accountability and provides families and students with important information when they are selecting a college. Further, UC supports increased transparency and improved data analysis to ensure that taxpayer-funded student financial aid is directed to institutions that show success in offering high-quality educational opportunities to students from a broad range of family income levels, and in assisting students achieve academic success without taking on unmanageable levels of debt. In looking at ways to sustain the federal government's investment in student financial aid over the long-term, UC would like to continue to be part of the conversation about data elements, collection, analysis, methodology, reliability, validity, consistency, variability, and other aspects of the Department's proposal.
Data Sources
The UC system is committed to preserving and enhancing access and affordability, and we take pride in our record of educating students from across all socioeconomic communities and backgrounds. UC has a strong commitment to transparency in the areas of cost, educational outcomes, and the quality of the student experience. As a public and regionally-accredited institution, UC provides a significant amount of consumer information publicly on our website and has long committed to transparency and accountability to policymakers, taxpayers, parents, and students through our annual Accountability Reports, which can be found online at accountability.universityofcalifornia.edu. In addition, as a public institution, UC is subject to careful auditing, oversight and program effectiveness reviews by the California State Legislature and State government. As a regionally-accredited institution, UC is subject to rigorous evaluation by the Western Association of Schools and Colleges.
UC strongly recommends that any college ratings system developed by the Department should seek to minimize additional and redundant reporting on public institutions. UC therefore supports the Department's decision to rely primarily on existing sources of data from federal administrative data systems and data collections, such as the Integrated Postsecondary Education Data System (IPEDS) and the National Student Loan Data System (NSLDS) in constructing the new ratings system. Leveraging these existing data sources will encourage a basic level of consistency in reporting standards and avoid burdening institutions with new and potentially inconsistent reporting requirements.
With respect to existing data sources, the Department collects a great deal of postsecondary education data through IPEDS that can be deployed in the proposed ratings system. IPEDS contains data on student enrollment, financial aid, and degree completion that many institutions already use for comparative analysis and benchmarking. The historical data and the standardization of definitions and data elements across institutions, which are available in IPEDS, provide a good baseline for a ratings system. UC recognizes, however, certain limitations with IPEDS and encourages the Department to continue its efforts to broaden the scope of IPEDS, to address the weaknesses inherent in information that is self-reported, and to assure that data are valid and comparable in different contexts.
Completion Rates
Transfer Students. As currently conceived, many of the metrics for the college ratings framework, such as completion rates, would focus only on first-time full time undergraduate students. For many public institutions, such as UC, limiting the college ratings system metrics to first-time full-time undergraduate students would not account for the full population of students who are served. One of UC's highest priorities is to ensure that a UC education remains accessible to all Californians who meet its admissions standards. This goal is articulated in California's Master Plan for Higher Education, which calls for UC to admit all qualified freshman applicants in the top 12.5 percent of California public high school graduates and all qualified California Community College transfer students. Accordingly, nearly 30 percent of UC's undergraduate class is composed of transfer students from community colleges. The Department should continue to explore alternatives to the IPEDS-based completion rate that would incorporate completion outcomes for all federally aided students, including part-time students and transfer in students.
Pell Grant Recipients. An additional metric that would be valuable to include in any college ratings system is the Pell Grant student graduation rate. Since reauthorization of the Higher Education Act in 2008, all institutions are required to calculate and disclose four-, five-, and six-year graduation rates separately for students receiving Pell Grants. This metric highlights how well students from low income and disadvantaged backgrounds are succeeding at postsecondary institutions, a metric which is often masked by the overall graduation rate. This measure would help the Department assess the extent to which institutions are supporting low-income students funded by the Pell Grant program.
Institutional Groupings
UC appreciates the Department's continued consideration of how differences in institutional characteristics and mission ought to be taken into account when rating institutions. This is consistent with President Obama's goal to compare institutions with similar missions.
The proposal to simply group two-year and four-year institutions, however, may be too basic because it cannot adequately distinguish between institutions of different sizes, selectivity, and mission. Within four-year institutions alone, for example, the cost structures, student demographics, and assets/endowments of private institutions may allow for more robust financial aid programs than those possible for most public institutions, which maintain a mission of educating large numbers of students from all socioeconomic backgrounds. Moreover, research-intensive institutions (public and private) should be separately grouped and assessed since their research infrastructure leads to higher costs while offering a distinctive student learning experience that incorporates exposure to faculty research. For profit institutions should be separately grouped and assessed, because their missions are more directly employment-oriented, and their profit-oriented models can have a significant impact on access and affordability.
In drilling down to more specific elements of a ratings system, it is important that metrics be adjusted to account for different governance and control, level of research activity, and other variable factors. Using a more detailed classification system would provide a clearer picture of comparative institutional strengths and how well institutions are fulfilling their particular educational missions.
Labor Market Success
The Department has made a positive step toward addressing UC's concerns about the use of short-term earnings of alumni as a metric for rating institutions' labor market success. Limiting the evaluation of earnings for recently-graduated alumni to a threshold measure of "substantial employment" will help avoid devaluing the contributions of those students who seek employment in the public service or nonprofit sectors shortly after graduation.
As the Department continues to develop metrics for evaluating labor market success, it will be important to identify a source that offers standardized and reliable data for all states and institutions. The Department must also remain cognizant that graduate employment and earnings are susceptible to factors both inherent in the institution's mission and identity, such as the population served, and the goal of the institutions (e.g., preparation for graduate study vs. preparation for non-academic careers in technical fields). Factors external to the institution, such as proximity to high paying industries and variations in the regional economy and labor markets should also be taken into account.
Student Debt
One of the most significant areas of concern in higher education revolves around students who incur substantial levels of debt for educational programs of little value. UC believes that there should be mechanisms in the college ratings system to identify poorly performing institutions, and that federal oversight should target resources to identify and impose sanctions on institutions with high default rates, unsustainable levels of student debt and low completion rates.
The federal student loan default rate will be an important metric to consider in assessing access and affordability. This figure is one way to assess the manageability of student debt, which is influenced by the size of the debt relative to the income students are able to secure after graduation. It also reflects on the extent to which institutions are fulfilling their obligation to inform student borrowers on the responsibilities of debt repayment. The Department already calculates the default rate from each institution in a standardized fashion and displays it publicly in many venues. As such, the federal student loan default rate will be easy to incorporate into a ratings system and will be valuable from both an accountability and a consumer-information perspective.
Conclusion
Thank you for your consideration of the University of California's comments on the draft college ratings framework. UC looks forward to continuing to work with the Department to ensure that any new ratings system provides policymakers and the public with appropriate, manageable, and reliable information about higher education institutions. We believe that any rating system must be eminently useful, not only for providing information to students, families, consumers, and the public, but also for protecting the integrity of the federal government's investment in student financial aid. We look forward to continuing to work with the Department as it considers how best to present information about access, affordability, and outcomes in a way that increases transparency and meaningfully informs student choice.
Yours very truly,
Janet Napolitano
President
University of California