Comment on FR Doc # N/A
This is a Comment on the Department of Education (ED) Notice: Request for Information To Gather Technical Expertise Pertaining to Data Elements, Metrics, Data Collection, Weighting, Scoring, and Presentation of a Postsecondary Institution Ratings System
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The University of Alaska thanks the Department of Education for extending an opportunity for stakeholders like us to engage in the process of establishing a Postsecondary Institution Ratings System (“PIRS”). We fully support identifying and implementing effective ways to make institutions of higher education more accountable and to better inform prospective students and their families' decisions on postsecondary opportunities. We have attached a letter that includes our thoughts, recommendations, and concerns in establishing a PIRS, which we hope is helpful to the process.
In our attached letter, we provide detailed recommendations on the data elements (i.e., graduation rates, affordability, and learning outcomes) the Department should consider using for rating the performance of postsecondary institutions. Additionally, we express our concerns with the Department likely using employment data as part of the college ratings system, as well as the potential lack of support some institutions may experience in striving to meet the metrics incorporated in the PIRS.
We also share our recommendations on how the Department should weight and score various information, including having one index for each area of measurements (i.e., access, outcomes, and costs). We also encourage the Department to consider control factors such as student diversity, selectivity, institutional financial stability, etc. in all performance comparisons. Further, we urge the Department to implement routine evaluations of control factors involved in the data reported through PIRS for validity and to determine what needs to be adjusted, as needed.
In discussing our recommendations for the development of comparison groups, we refer to an approach described in Postsecondary Opportunity's November 2013 article on "Actual versus Predicted Institutional Graduation Rates." We also strongly urge the Department to create a PIRS that does not indirectly punish institutions with open-access missions by failing to place us in appropriate comparison groups. Further, we ask the Department to consider for comparison groups other factors out of an institution’s control, as well as disaggregating student data for comparison purposes by subgroups. In doing so, we suggest subgroups the Department should consider.
Lastly, we share our thoughts on how the PIRS should be presented and ask that the Department to avoid structuring the PIRS as a rankings system.
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Comment Period Closed
Jan 31 2014, at 11:59 PM ET
Tracking Number: 1jy-8a6j-i9q5
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Date Posted: Feb 6, 2014
Submitter Name: Patrick Gamble
Country: United States
State or Province: AK
Organization Name: University of Alaska
Submitter's Representative: Carla Beam
Government Agency Type: State
Government Agency: University of Alaska
Category: Institution of Higher Education