Comment on FR Doc # N/A


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The existence of appropriate metrics of success among postsecondary institutions is of critical importance to the general public as both consumers and investors in higher education. Currently, the Department of Education’s existing data elements are inadequate and, in application to a Postsecondary Institutions Rating System (PIRS), threaten the quality of American higher education by limiting the focus on solely graduating more students, faster, and with lower costs. Without including measures of educational quality, a rating system that focuses on cost, access, and economic value will likely disincentivize institutions from emphasizing the educational core. For example, institutions may strive to increase graduation rates by decreasing academic rigor, and one way to decrease cost might be to sacrifice teaching quality by hiring less qualified faculty or increasing class sizes. Further, there have been growing concerns about the rigor of U.S. colleges and universities that could threaten our international reputation (e.g. Arum & Roksa, 2010). If institutions are solely to be rated on their cost efficiency and graduation rates, what is to keep institutions from significantly decreasing their educational standards?

Educational quality measures must not be forgotten if we are to maintain the integrity of the postsecondary sector as a fundamentally educative enterprise. By including measures of educational quality, PIRS could encourage institutions to keep high standards that will strengthen our graduates' abilities to solve complex 21st century problems and contribute to our competitiveness internationally. While the Department does not currently have the ability to include adequate measures of educational quality in PIRS given the limitations of existing federal data elements and collection mechanisms, it is our view that the Department should recognize and support the development of such metrics to eventually be included in PIRS.

Thus, we highlight our College Educational Quality (CEQ) project as an example to inform PIRS. This response focuses on questions 1.2 (metrics that could be created for PIRS using data not currently collected by the Department or other Federal agencies) and 5.2 (examples of existing ratings systems that could be used to inform PIRS) of the Department’s Request for Information. The CEQ project aims to create alternative, innovative, and comprehensive measures of educational quality across institutions that could contribute to public understanding of college and university quality. While we do not advocate the use of CEQ, specifically, in any federal college rating system, we offer our project as evidence that collecting in-depth data on the educational (rather than economic) value of college is possible and necessary.

The conventional wisdom around collecting in-depth data related to postsecondary educational quality at the institution level is that “it cannot be done” due to the diversity of postsecondary institutions, complexity of measuring educational quality, and burden to institutions. Yet, the lessons learned from our first CEQ pilot projects demonstrate that both institutions and faculty are invested in finding better ways of measuring educational quality. For example, more than 30% of faculty sampled consented to take part in our project with no incentives offered. We believe that collecting and reporting data related to educational quality must be done, and the progress of the CEQ project exemplifies the possibility for data on educational quality to be included in a system like PIRS in the future.


The quality of a college education must be considered in any rating or incentive plan in order to make the promise of access to higher education realized, to increase the stature of education in the U.S., and to increase our competitiveness around the world. Currently, the Department of Education lacks data elements, metrics, and ability to collect adequate information related to educational quality. The College Educational Quality project provides evidence that institutions and faculty are invested in finding better metrics. As a result, we suggest future support for the development, creation, and collection of adequate measures of postsecondary educational quality. Without such metrics, a system like PIRS that focuses solely on cost, access, and economic outcomes will have unintended consequences that could threaten the stature and educational value of U.S. postsecondary institutions.




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Comment Period Closed
Jan 31 2014, at 11:59 PM ET
ID: ED-2013-IES-0151-0028
Tracking Number: 1jy-8a4l-frvw

Document Information

Date Posted: Feb 6, 2014
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Submitter Information

Submitter Name: Corbin Campbell
City: New York
Country: United States
State or Province: NY
Category: Academic/Think Tank