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Request for Information To Gather Technical Expertise Pertaining to Data Elements, Metrics, Data Collection, Weighting, Scoring, and Presentation of a Postsecondary Institution Ratings System

January 31, 2014

U.S. Department of Education
Attention: National Center for Education Statistics
1990 K Street NW, 8th Floor
Washington, DC 20006

Re: Request for Information To Gather Technical Expertise Pertaining to Data Elements, Metrics, Data Collection, Weighting, Scoring, and Presentation of a Postsecondary Institution Ratings System

Dear Sir or Madam:

Last fall, Young Invincibles convened a group of Portland Community College students to discuss the need for better information about college choices. Ebony, a nineteen year-old, first generation student told us that she wished she had known more about how her schools’ graduates performed in nursing school as well as the workforce. Currently, no one can tell Ebony what proportion of Portland Community College Students successfully transferred and graduated from any institution, not to mention success rates in nursing school or workforce outcomes in the industry. With so much at stake, we must do more to help students like Ebony make informed decisions about their future.

For this reason, we appreciate the Department’s effort to equip students with better information through a Postsecondary Institutional Ratings System (PIRS). Done well, we believe that such a system can help students make informed choices and receive more value from their post-secondary investments.

However, the Department faces a daunting task on several fronts. First, the Department expects PIRS to assist consumers and hold institutions accountable. These two goals are very different and likely require different systems. Second, basing aid on ratings could unintentionally harm low-income students who face barriers to successful outcomes.

Third, the Department currently lacks the necessary data to make PIRS successful. Using the wrong data could render the system useless, or worse, counter productive. Fourth, the Department has set a very fast timeline for PIRS, giving it few opportunities to address the above challenges.

Finally, we feel it is important to note that information and incentives alone will not solve the problem of college affordability. States cut per-student higher education expenditures by an average of 28 percent between fiscal years 2007 and 2012, and in response, institutions hiked tuition an average of 27 percent. Any comprehensive solution for college affordability must address state disinvestment.

We hope the following comments from the student perspective will constructively contribute to your efforts. Specifically, we ask the Department for the following:

1. Incorporate data that students care most about: affordability, job placement rates, and the ability to pay back their loans.

2. Present information to students in a clear and understandable format.

3. Engage the public through an outreach campaign about the ratings system.

4. Distinguish between using PIRS for consumer information and institutional accountability.

5. Use the ratings to set a minimum performance bar for institutions to receive aid and reward institutions who successfully serve low-income students.

6. Establish privacy protections for student level data.

To read the full Comment, click here.