Comment on FR Doc # N/A


The Honorable Arne Duncan
Secretary of Education
U.S. Department of Education
400 Maryland Ave, SW
Washington, DC 20202

Dear Secretary Duncan:

I strongly applaud the Administration’s focus on increasing transparency and accountability in higher education. In regard to the proposal to create a college ratings system, my colleagues and I agree with the comments by the Association of Public and Land-Grant Universities (APLU) that such a system should focus on informing students and parents, and include data elements that reflect the diverse goals and backgrounds of students in higher education and the institutions that serve them.

Texas has long focused on using objective data to inform students, parents and other higher education stakeholders and to hold institutions accountable. Our state does some of the most robust higher education data collection and analysis in the nation. We employ multiple media to disseminate these data to students, parents, and others, including Online Institutional Resumes, our annual Texas Public Higher Education Almanac, and our Compare College TX website.

Additionally, these data routinely inform funding and policy decisions made by the Texas Legislature. Earlier this year, the Legislature adopted an outcomes-based funding methodology for community colleges that incorporates institutional performance on five categories of student success, and a funding methodology for our state technical colleges based on workforce data. A legislative change to prioritize academically prepared students with financial need in our largest state financial aid program was predicated on data demonstrating such students graduate at twice the rate of their peers.

One thing we have learned in Texas is the critical importance of getting the measures right. We agree with APLU that the current federal definition of an institution’s graduation rate, which includes students who attend only that institution, does not represent the reality of many students. In 2012, 35% of Texas public university graduates had completed 30 or more semester credit hours at a two-year institution. Transfer has become a vital pathway for many Texas students to achieve a degree, and institutions’ success with these students should be recognized and commended. For this reason, the Coordinating Board’s definition of graduation rate explicitly includes students who graduated from the same institution or another Texas public or independent institution.

In regard to employment measures, we agree that these are important data points. As mentioned, the Texas State Technical College System has just embraced a funding methodology that rewards those institutions for the wage premium their former students earn in the job market. However, this model is not compatible with all students or institutions, and any rating system must recognize that post-graduation success is more than a salary figure. For instance, Texas includes both employment and enrollment in a graduate program in our measures of post-baccalaureate degree status. Graduates employed in lower-paid but socially important fields, such as teaching, are filling a vital need and should be recognized as a successful outcome.

Finally, how these data are presented will be critical to making any ratings system accessible and useful to students, parents, and the institutions themselves. Definitions and methodologies must be extremely clear so that prospective students can prioritize which measures are most relevant to them, and institutions can meaningfully compare their performance to their peers. Institutions should be able to offer contextual input embedded with the data, and viewers should be made aware that additional perspectives on measures and rankings are available through the institutions’ website and other entities (such as the Coordinating Board). And the system will need an intuitive, engaging public interface that provides for ease of comparison while providing the depth of data that will allow readers to drill down into the specific performance of individual institutions.

Thank you for the opportunity to offer these comments, and please do not hesitate to let me know if I can provide any more information on this or any other matter impacting higher education.


Raymund A. Paredes



College ranking comments

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Comment Period Closed
Jan 31 2014, at 11:59 PM ET
ID: ED-2013-IES-0151-0081
Tracking Number: 1jy-8a6l-qz70

Document Information

Date Posted: Feb 6, 2014
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Submitter Information

Submitter Name: Raymund Paredes
City: Austin
Country: United States
State or Province: TX
Category: State Higher Education Office