Comment on FR Doc # N/A


Founded in 1889 as a missionary training institute in Boston, MA, Gordon College has grown to be one of the nation’s top-ranked Christian liberal arts colleges, combining strong academic credentials with an intentional, faith-based community. We draw students from all 50 states and more than 55 countries, and have alumni of our 38 majors and 42 concentrations working in every professional field all around the globe. We are a small institution of less than 2,000 students, but we offer a robust and academically rigorous curriculum, and work to shape well-rounded graduates prepared for leadership worldwide.

I and my colleagues respect the Administration’s desire to increase the information provided to consumers about institutions of higher education. We also share the Administration’s interest in working toward the common goals of access, affordability, and transparency in higher education. However, I would like to express reservations with the proposal to establish a government-based rating system – particularly one that determines funding decisions – because of the inevitable subjectivity required to design such a system, and the uneven outcomes it would create.

The fundamental challenge with a federal rating system for colleges and universities is that it is simply not possible to consistently assess the operations of institutions that are diverse and fundamentally different in their size, resources, educational approach, and value propositions. A one-size-fits-all, single set of measures or “rating” system would be inherently flawed from the start, even among institutions of higher education that have a similarly stated “mission,” to use the language of the proposal. The size of the institution's student and faculty populations, geographic location and area cost of living, majors and degrees offered, endowment size, public versus private, and numerous other variables even among those with shared “missions” distinguish America’s large and diverse cohort of institutions of higher education. Comparing them as if comparing apples to apples is flawed reasoning.

The rating system aims to measure the comparative “value” offered by individual colleges and universities to students and graduates. However, a rating is simply the function of the inputs chosen, and value is an inherently subjective term that is difficult to quantify. Specifically, the Administration runs the risk that quantitative inputs are too heavily weighted, simply because they are more readily measurable and accessible. For example, if the rating over-weights the starting or mid-career salaries of a university’s graduates, this suggests that colleges that place graduates in lucrative fields like finance or law or medicine are more “valuable” than those who place their graduates in fields like social work, teaching, ministry, or the arts and humanities. I urge the Administration to not treat higher education merely as a commodity that produces graduates earning salaries, as Gordon, like many small liberal arts colleges, prioritizes the goal of shaping well-rounded students who value a lifelong approach to learning, and are inspired to serve others through ministry, volunteerism, philanthropy, and other not-for-profit activities, sometimes at the expense of high-paying careers.

The government rating would be public and therefore not only used to determine federal funding decisions but would also inevitably be considered by private foundations, donors, and others and thus shape their funding decisions as well. Therefore, the effect of a positive or negative rating would be compounded in the marketplace, widening the gap between federally-determined institutional winners and losers in any given year based solely on the inherently subjective criteria chosen as inputs. I hope this makes it clear how much a rating would “raise the stakes” for institutions of higher education, and place the government in the direct role of determining institutional winners and losers.

I am confident that these are issues which have already been considered by the Administration, but I simply want to emphasize a few of the ways a rating system could deeply complicate my job and the jobs of my colleagues who are leading similar institutions around the country. This is a financially difficult time for educational institutions as well as the populations we serve, and I urge caution and incrementalism rather than rushing into an ecosystem-wide sea change that would result from a poorly conceived, one-size-fits-all numerical rating based on subjective criteria.

Thank you again for the opportunity to provide feedback, and I hope the Administration will continue to partner with those of us leading institutions of higher education as we all work toward the shared goal of ensuring the health and vibrancy of American colleges and universities

Respectfully yours,

D. Michael Lindsay
Gordon College
255 Grapevine Road
Wenham, MA 01984
Comment Period Closed
Jan 31 2014, at 11:59 PM ET
ID: ED-2013-IES-0151-0073
Tracking Number: 1jy-8a6k-thqn

Document Information

Date Posted: Feb 6, 2014
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Submitter Information

Submitter Name: Dr. Michael Lindsay
Category: College President