To: Richard Reeves
National Center for Education Statistics
U.S. Department of Education
1990 K Street NW, 8th Floor
Washington DC 20006
ATTN: Postsecondary Institution Ratings System RFI
Docket ID ED–2013–IES–0151
The Institute for Higher Education Policy (IHEP) submits these comments on the Administration’s proposed Postsecondary Institution Ratings System (PIRS), published in the Federal Register on December 17, 2013. Celebrating its 20th year anniversary, IHEP is a non-profit, non-partisan research organization committed to promoting access to and success in higher education for all students, with a particular focus on populations that have been traditionally underserved by our postsecondary system.
IHEP applauds the President’s proposal to create a system that would, first and foremost, provide better information to help students and parents choose colleges that offer them the “best value.” Too many of today’s students are paying far too much at institutions that offer them far too few chances for success. Ensuring that information is provided to students in a timely, easy-to-digest format (popularly referred to as “consumer information”) can, in fact, act as a form of soft accountability, allowing students to “vote with their feet” in the direction of institutions that will serve them well.
However, given the immense – and growing – student and public investment in higher education, we cannot afford “soft accountability” alone. The federal government must use real stakes to improve – or sanction as needed – institutions that are not serving students well, which is why IHEP also supports the Administration’s proposal to develop a rating system to assess and tie college performance to the distribution of Title IV financial aid.
That said, the design of the system will need to differ depending on its purpose: consumer information or institutional accountability. While most of the metrics might remain the same, they should be applied differently in different contexts. In short, IHEP recommends separate rating systems be developed for each purpose. In guiding the development of those systems, IHEP also offers the following three principles underlying our recommendations:
- Critical information on post-college outcomes, completion, cost, and access is key
- Contextualize information without undue complexity and in relation to the consequences
- Collect better data, but don’t delay providing information now