NCAN Joins 14 Partners on Pell Grant Recipient Data Collection Recs

April 19, 2016

Carrie Warick, Director of Partnerships and Policy

NCAN has long advocated for better information to help students decide where to enroll in college. Part of that push is to make Pell Grant recipient graduation rates available by institution. Our partners at Ed Trust took a big step forward with their data release last fall, but it is clear from the time and resources it took to complete that annually updated information would need to come from the federal government. When the the National Center for Education Statistics announced at the beginning of the year that it would collect Pell Grant recipient graduation rates, NCAN commended them for this important step forward. However, after spending more time analyzing the impact of their proposal, which would group all Pell Grant recipients together making it impossible to disaggregate the data or compare it to the nationally used (though out of date) first-time, full-time graduation rate, NCAN has decided to join with over a dozen partner organizations to suggest adjustments in how the data are collected and used. 

In order for this information to be useful to students, NCES must take great care it how it collects the data. Students need to be able to answer how a "student like me" will fair at a given institution and being able to compare the graduation rate to the nationally listed graduation rate, as well as to look at students of color or part time students is important. Further, it is crucial that these data are used to help students evaluate their likely success at an institution, or how an institution serves Pell Grant recipients overall, not to evaluate the full impact of the Pell Grant program, given the eroding purchasing power of the Pell Grant. 

In response to NCES' call for comments on their proposal, NCAN has joined with 14 partner organizations through the Postsecondary Education Data Collaborative to share our feedback on how NCES should collect and use these data. Please see a portion of the letter below or download the full letter here

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April 18, 2016
Mr. Richard Reeves
IPEDS Program Director
National Center for Education Statistics

Dear Mr. Reeves:

This letter is submitted on behalf of the Postsecondary Data Collaborative (PostsecData), in response to the proposed addition of a Pell Grant recipient cohort to the Outcome Measures (OM) Survey component of the Integrated Postsecondary Education Data System (IPEDS). PostsecData is comprised of organizations committed to the use of high-quality postsecondary data to improve student success and advance educational equity.

It is very encouraging that the Department of Education (ED) is taking steps to include indicators of the postsecondary success of Pell recipients in IPEDS. The higher education community – including PostsecData – has frequently advocated for the addition of Pell graduation rates to IPEDS. For example, a 2008 IPEDS Technical Review Panel (TRP) recommended establishing a Pell Grant sub-cohort in the Graduate Rate Survey. Additionally, the Committee on Measures of Student Success (CMSS) called for ED to direct the National Center for Education Statistics (NCES) to add Pell graduation rates to IPEDS and convene a TRP to determine how to do so.

These data could provide students, policymakers, institutions, and policy researchers with information on how outcomes for low-income students vary across institutions and how they compare with the outcomes of more well-resourced classmates. While Sec. 488(a)(3) of the Higher Education Opportunity Act of 2008 (HEOA) requires institutions to disclose graduation rates disaggregated based on Pell status, research has shown inadequate compliance with this disclosure requirement. Furthermore, as a disclosure requirement, these data are difficult to collect and use in a comprehensive way because gathering them requires contacting thousands of individual colleges. We applaud ED for responding to the clarion call for the addition of low-income student outcomes to IPEDS. To ensure these data are as useful as possible, we make the following recommendations that advise on appropriate ways to use the results, propose a series of technical specifications, and present alternate solutions that would implement those specifications:

A. Use Pell graduation rates to measure success for low-income students, not the effectiveness of the Pell Grant program

B. Make the results more useful by improving how the Pell cohort and outcome data are specified

1. Do not combine students of varying attendance and enrollment patterns into one Pell cohort
2. Define Pell recipients as those students who receive Pell when they initially enroll in college (Pell at entry), not those who receive Pell at any point while enrolled in college (Pell ever)
3. Require all institutions to report outcomes for Pell students, not only degree-granting institutions
4. Report Pell outcomes after 100, 150, and 200 percent of program time instead of (or in addition to) after 6 and 8 years
5. Disaggregate cohorts by credential sought

C. Implement an alternate solution for collecting essential data on Pell student outcomes

1. Incorporate a Pell cohort into the Graduation Rate Survey (GRS)
2. Disaggregate each OM cohort by Pell, using the existing OM survey
3. Disaggregate each OM cohort by Pell, using a revised OM survey

Each of these recommendations is discussed in detail in the full letter.

Most importantly, in designing a Pell completion rate metric, we urge the Department to avoid combining students of differing attendance and enrollment statuses into one Pell recipient cohort, and we emphasize the importance of framing the data’s purpose as advancing educational equity and institutional improvement rather than program evaluation.

This letter is supported by 15 organizations committed to high-quality postsecondary data. We truly value the Department's efforts to improve postsecondary data systems, we support efforts to collect more comprehensive data on student outcomes, and we commend NCES for taking this step in what is certainly the right direction. Our hope is that, by providing multiple alternatives to the proposed measures, NCES will have not only the additional information and substantive feedback it seeks from the higher education community, but the freedom to adopt a measure that truly helps us best understand how to support millions of low-income students and the institutions that serve them. Moreover, student-level data collection would streamline collection and reporting, allowing for the most useful metrics to be calculated with less concern about reporting burden, so we support the development of such a system. Thank you for the opportunity to comment on the proposed changes as well as for thoughtful consideration of our feedback and recommendations. 

Sincerely,

Association of Public & Land-grant Universities
Campaign for College Opportunity
Center for Law and Social Policy
Complete College America
Data Quality Campaign
Georgetown Center on Education and the Workforce
Institute for Higher Education Policy
National Association for College Admission Counseling
National College Access Network
National Skills Coalition
New America
Pell Institute for the Study of Opportunity in Higher Education
Southern Education Foundation
The Education Trust
Western Interstate Commission for Higher Education
Young Invincibles





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