Comment on FR Doc # N/A


Regarding the request for comments on the U.S. Department of Education’s efforts to develop a Postsecondary Institution Ratings System (PIRS):

I am president of Newman University, a private, Catholic liberal arts university based in Wichita, Kansas, with outreach sites in Kansas, Oklahoma and Colorado and a total population of 3,700 students. Speaking as university president and as a higher education professional with 35 years experience as a teacher and administrator, I have several concerns about the suggested system.

I do not believe it is possible to assess and rate the quality of America’s institutions of higher education using a single set of measures or rating system. These institutions are highly diverse. Some serve a wide variety of students in a community while others focus on a specific part of the population. Some take a traditional approach to education while others have unique, though effective, methods of instruction. Some have expansive academic offerings while others have a relatively narrow range of programs.

Attempting to lump institutions with such diverse characteristics, student populations and missions together in a “one size fits all” rating system cannot accurately or reliably reflect the value of each institution.

I also believe creating a consumer ratings system as outlined could have unintended consequences, such as causing consumers to depend on a single system when choosing a college rather than seeking data from several sources. Because “value” is a subjective matter, a rating system based on data points as outlined in PIRS could also be misleading. What one person values from a college education may be quite different than what another values, yet both are valid. Creating a system with the appearance of complete objectivity would not best serve the needs of consumers.

I and many of my colleagues have concerns about how the PIRS considers graduation rates. While the rate of students who begin college at one institution and graduate six years later from that same college may appear low, the school in question may be very successful in helping students who transfer from other schools or return to college at a later age to complete their degrees. We also have concerns regarding how graduates’ earnings will factor into a rating system. We believe that focusing on this topic may not reflect the true value of higher education, or that colleges could receive lower ratings for producing graduates in important but lower-earning fields, such as teaching, social work, or nonprofit.

Additionally, we question if a “standardized” rating system will actually be effective in reducing college costs.

This is not to say that we disagree with efforts to increase public information about colleges. I believe institutions and the Administration have a shared interest in providing data on access, affordability, and transparency in higher education. To this end, we encourage the Administration to provide the key data points to help students find a college that best fits their needs and desires, which could lead to much better outcomes for students and institutions alike.

Newman University is a member of the National Association of Independent Colleges and Universities. The NAICU has developed a system called U-CAN to meet policy makers’ calls for consumer transparency. I believe U-CAN could serve as a starting point for institutions and the government to address issues relating to quality, value, access and accountability.

The U-CAN system has already shown us that a consumer information system should:
Ask consumers what they want. Their answers can be different than what policy makers want or think they need to provide an accurate rating of schools.
Create a survey that is long and short enough. Asking consumers to provide too much information can be overwhelming, while too little may not provide an accurate picture of consumers’ views. The U-CAN system uses 49 data points in a two-page, reader-friendly profile.
Include both quantitative and qualitative information. Prospective students tell us they want to know about the nature of an institution, so they can determine if it’s a good fit for them. U-CAN allows institutions to tell their own stories through 26 links on each school’s profile, giving students ample options to find out what each school is really like.

These are only a few ways U-CAN and other approaches to data gathering and analysis can produce more accurate information on the relative value, quality and nature of institutions of higher learning.

Education is a highly complex, nuanced, subjective and, in many ways, personal process. I applaud efforts to improve the quality, accessibility and transparency of higher education, while lowering costs and increasing the flow of information about higher education to consumers. I do not believe, however, that the system as outlined is the correct way to achieve these desired outcomes.

Thank you for your consideration.
Comment Period Closed
Jan 31 2014, at 11:59 PM ET
ID: ED-2013-IES-0151-0017
Tracking Number: 1jy-89zv-owsn

Document Information

Date Posted: Feb 6, 2014
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Submitter Information

Submitter Name: Noreen Carrocci
City: Wichita
Country: United States
State or Province: KS
Category: College President