Comment on FR Doc # N/A


The attached letter represents comments submitted by Metropolitan State University of Denver (MSU Denver) in response to the Department's Federal Register notice seeking information from the higher education community about data elements, metrics, methods of data collection, methods of weighting or scoring, and presentation frameworks for a Postsecondary Institution Ratings System (PIRS) for assessing the performance of institutions of higher education (IHEs) and advancing institutional accountability while also enhancing consumer access to useful information.

MSU Denver's comments are focused in the following three areas:

(1) Accountability – Data Element, Metrics and Data Collection. Recommendation: use the Voluntary System of Accountability (VSA) as a building block for the PIRS framework.

(2) Access, Affordability, and Outcomes. Recommendations: keep separate issues of rating systems for the purposes of consumer awareness and ratings systems for the purpose of examining value of federal investment in higher education of the federal taxpayer; work to ensure that institutions that have kept their costs low are not punished if they cannot further reduce costs; not hold institutions with a “new majority” of post traditional higher education students to the IPEDS time-to-graduation standards and do not punish institutions for transferred loan debt.

(3) Comparison Groups. Recommendation: examine the work of the National Center for Higher Education Management Systems (NCHEMS) with respect to creating comparative groups based upon similarity such as size, diversity of student body, economic status of student body, similarity of academic offerings, level of state support and tuition per student, etc.



MSUD_Jordan PIRS Comment letter_FINAL

View Attachment:

Comment Period Closed
Jan 31 2014, at 11:59 PM ET
ID: ED-2013-IES-0151-0023
Tracking Number: 1jy-8a4g-nv60

Document Information

Date Posted: Feb 6, 2014
Show More Details  

Submitter Information

Submitter Name: Stephen Jordan
Organization Name: Metropolitan State University of Denver
Submitter's Representative: Amy Budner Smith
Government Agency Type: State
Government Agency: Metropolitan State University of Denver
Category: College President