NCAN Testimony to ACSFA

September 11, 2014

Carrie Warick, Director of Partnerships and Policy

On Friday, September 12, 2014, NCAN provided testimony to the Advisory Committee on Student Financial Assistance (ACSFA) regarding the Postsecondary Institutions Ratings System (PIRS) development. ACSFA, an independent research body appointed by Congress, used their Summer 2014 hearing to provide a forum for interested parties to provide feedback to the Administration and Congress on PIRS. NCAN along with 19 other witnesses all participated. You can read NCAN's comments in full below. 

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Thank you for this opportunity to comment on the Postsecondary Institutions Ratings System development.  My organization, the National College Access Network (NCAN), and its over 400 members and affiliates work in communities across the country to help students to and through college.  Our students are mostly low-income and the first in their families to attend college.  

Even before the President called for a ratings system, there was a growing conversation within the higher education data community around what data was needed, for whom, and for what purposes. We support the creation of a college ratings system because as a country, we need to help students make choices that support success. As this conversation has evolved over the past year, much time has been spent on data availability and fairness to colleges. But not enough time as been spent discussing the first, and to us most important, goal of the ratings system, “to identify colleges providing the best value” to students. College students, only half of whom are first-time, full time and less than 20% of whom are students who are first-time, full-time students living on campus, need to be able to answer the most important question of: where will a student like me succeed? Our recommendation is to define value not by a salary to tuition return on investment, or one specific number/letter/star rating but rather whether or not an institution is accessible, affordable, and gives the student a legitimate chance of earning a degree.

College choice matters.  Institutions have wide-ranging outcomes for the same profile of student, as evidenced in the Education Trust’s College Results Online tool.  That is, colleges with similar resources, enrollments regarding academic achievement, and/or racial composition could have very different outcomes or graduation rates, sometimes by as much as 20 percentage points. Today’s students are in need of the right information to help them make decisions about attending a school that best matches their academic qualifications and provides the best environment to support ultimate completion.  Students who fail to do so are less likely to graduate. 

Prospective students need a ratings, not a rankings, system to compare peer institutions across multiple factors, similar to using a ratings system like Consumer Reports.  In previous PIRS conversations, many commenters took for granted that the ratings system would levy a single rating on institutions that would be comprised of a variety of characteristics, and ultimately could be turned into a ranked list. While a single rating may eventually be needed for the accountability goals of the President’s proposal, especially if tied to ability to participate in Title IV federal student aid programs, the best way to serve consumers is to use multiple ratings. The tool used to present the information to students must be built specifically with students in mind. Once this tool is built, then using the same data, additional calculations can be created to address the accountability goals.

This student friendly ratings system should focus on what prospective students need to know about accessibility, affordability, and the possibility of success. The accessibility measures should focus on the ability of underrepresented students to access the institution. Measurements could include the percentage of Pell Grant recipients, rated based on the national average, and the percentage of various racial/ethnic groups, rated based on the state’s demographic profile. Also to consider is the percentage of students who transfer out of the institution with upward transfer considered a positive outcome and lateral or downward transfer considered negative. The affordability measures should focus on net price and student debt. Measurements could include net price by income quintile, average student loan debt, the percentages of students with loans, and the ability of those students to repay their loans. The success measures should focus on students’ ability to complete a degree or credential. Measurements could include overall graduation rate compared to the national average, graduation rates by race or ethnic group, and graduation rates of Pell Grant recipients.

Of these factors, what is the most important to one student is not necessarily the most important to another. For this reason, weighting the above measures and then giving one combined score does not best serve students. Instead, the Department of Education should take an approach similar to Consumer Reports and provide a rating for each category. These multidimensional ratings should be straightforward – not weighted or adjusted in anyway – so that consumers know exactly at what they are looking. The charts should then be sortable by the circumstances of a specific student. For example, filters would include location, academic fit, and institution type. For place-based students, distance from home is an important filter. All students must be able to create lists based on their GPA range and SAT or ACT score. And many students will want to filter based on institution type such as two-year, four-year, public or private, but it is paramount that students, especially place-based students, be able to compare across sectors.

The above data elements are mostly available, though they do need some improvement. The transfer rates and part-time status of students is coming to IPEDS soon and should be integrated without further delay. The Pell Grant recipient graduation rate is the most important piece of data currently missing from our field. A first step to address this was the addition of the Pell Grant status flag in the National Student Loan Database System (NSLDS). While it will take until 2017 for four-year graduation rates and through 2019 for six-year rates, it is a step in the right direction. Or, Congress could make the data instantly available by requiring institutions to report their Pell Grant recipient graduation rates to the U.S. Department of Education. Because colleges are already required to disclose this information to students, it should not add additional burden.

We should liberate all data currently available for the good of informing students about their options for college-going.  If we have information ready to help first-time, full-time students to make educated choices, we should move ahead quickly.  On a parallel track, we should commit to a full exploration of complete data that would give the full picture to those students who are not first time, full-time students.  This latter step will only enhance the Department’s ability to create a more complex accountability measure in the future.

We urge you to not let the perfect be the enemy of the good. The Department of Education’s first priority should be the development of the above system that is targeted to consumers before a federal accountability system is considered. Students need a place to go to for accurate information that they can use to compare schools based on the characteristics most important to them. Developing this system is feasible, but not easy. Focusing specifically on the first part of the goal, the one that can most immediately serve students, should be in the forefront. Once this task is well on its way to completion, then the Department can consider what additional adjustments are needed to create the additional layer of an accountability system for institutional financial aid eligibility.

NCAN looks forward to continuing this broad conversation about college affordability and metrics.  We appreciate this opportunity to comment today.  Thank you again for having this important conversation about college affordability.  We appreciate the opportunity to share comments and know that students will be its ultimate beneficiaries.

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