Comment on FR Doc # N/A


January 31, 2014

Richard Reeves
National Center for Education Services
Attention: Postsecondary Institution Ratings System RFI
U.S. Department of Education
1990 K St NW, 8th Floor
Washington, DC 20006

Dear Mr. Reeves,

On behalf of the 138 U.S. member and affiliate institutions of the Council for Christian Colleges & Universities (CCCU), I write to affirm the comments of the National Association of Independent Colleges & Universities (attached) regarding the proposal by the Department of Education to institute a Postsecondary Institution Ratings System and to echo many of their points and concerns.

Our colleges are pleased to support the president’s commitment to issues of access, affordability, and transparency. CCCU institutions are proud of their high graduation rates and low default rates and that their students graduate with student loan debt well below the national average. However, in spite of these favorable performance statistics, we do not support a national ratings system generated by the government.

In fact, we believe that a single ratings metric generated by the government would be harmful to the president’s important goals listed above. Such a system, especially if tied to institutional eligibility for aid, would hurt the most vulnerable students. Colleges would threaten their own well-being by accepting low-income, first-generation students whose lower-than-average graduation rates could harm their rating. We believe this is detrimental for institutions that want to serve those students, and thus is ultimately detrimental for the students themselves.

Additionally, the president has rightly acknowledged that not all students are the same, and he has encouraged education for all, whether a person is seeking to be an air-conditioner mechanic or a philosophy professor, or needs job retraining for a second or third career path. A ratings system contradicts this idea. Colleges and universities offer different programs based on different missions with different state funding levels that reach different types of students. Thus, any attempt to create a single ratings system would be fatally flawed upon inception and could diminish the vast variety of higher education options available to students and thus harm the president’s 2020 goal for more college graduates.

Nor do all students possess the same aspirations upon graduation. Consistent with the president’s goal of encouraging more Americans to serve their fellow man, many CCCU graduates aspire to work in fields of service upon graduation. Many serve as teachers in low-income school districts or in third-world countries; others feed the needy in the U.S. or work to provide clean water in the developing world. The president’s support for and expansion of the income-based repayment program recognizes that the important work we need willing citizens to perform is not always the most lucrative (though statistics do show that while humanities and social science majors make less than their pre-professional and engineering peers upon graduation, by the end of their careers they make more).

Currently, students do not face a shortage of information. The internet is replete with information about colleges of all types. While relevant and reliable information is at a premium, we believe the federal government could best help students by partnering with the higher education community in teaching applicants how to ask the right questions about how to evaluate a college and how to find the college that is best for that respective student, not best for John or Jane Doe generally.

We say “best” because we believe that any ratings system would in fact become a ranking system. The moment a student compares the rating of one school to that of another school, ratings become rankings. Further, both systems allow, if not encourage, profiling based on razor-thin distinctions that do not take into consideration what is best for an individual student.

Students of different ages, from different backgrounds, who aspire to different careers are all served by our vast and diverse higher education system. There is no possibility for a single ratings system to capture that complexity. We strongly encourage the federal government to recognize this and to instead partner with higher education to help students and institutions alike achieve their potential.


William P. Robinson, Ph.D.
Interim President
Council for Christian Colleges & Universities



CCCU Ratings System Comments 1-31-14

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Comment Period Closed
Jan 31 2014, at 11:59 PM ET
ID: ED-2013-IES-0151-0125
Tracking Number: 1jy-8a6s-jt02

Document Information

Date Posted: Feb 6, 2014
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Submitter Information

Submitter Name: Bill Robinson
Category: Association/Organization