Comment on FR Doc # N/A


I am the Assistant Vice President for Government & Community Relations at Pace University and I am writing to respond to the December 17, 2013 Department of Education notice asking for public input about how best to design the metric to rate colleges that was proposed by the President in August 2013. Pace University is a private university with campuses in New York City and Westchester County, enrolling more than 13,000 students in bachelor’s, master’s, and doctoral programs in its College of Health Professions, Dyson College of Arts and Sciences, Lubin School of Business, School of Education, School of Law, and Seidenberg School of Computer Science and Information Systems. Pace University is committed to providing access and opportunity to a diverse population.

Pace offers traditional degree programs as well certificates and bachelor’s completion programs; traditional on-campus programs as well as a rich offering of on-line and blended programs. Over 92% of our new undergraduate freshman students receive financial aid and 43 % of those students are Pell eligible. Overall, 70.7% of our students receive some type of financial aid and the University commits over $130 million dollars a year to supporting its students with institutional aid.

Perhaps the most troubling aspect of the President’s proposal is that there is an assumption made that it will be possible to assess and rate higher education institutions collectively, under a “single set of measures” or “rating.” It will be impossible to reliably and validly assess the value of such diverse institutions using a “single set of measures” or “rating.” To provide an alternative to this proposal, I would like to bring attention to the University & College Accountability Network (U-CAN) that was developed and is maintained by the National Association of Independent Colleges and Universities (NAICU). This network is designed to offer prospective students and their families’ concise, Web-based consumer-friendly information about private, nonprofit colleges and universities in a common format.

The U-CAN network was created through focus groups that consisted of students and parents who told NAICU the information they needed most to make an informed college choice. Their input and comments shaped the format and content of the consumer information template, which includes comparable institutional data, and provides many targeted links to the institution's Web site for more detailed information on specific aspects of the institution. U-CAN is free, both to users and to the colleges and universities that choose to participate and we encourage the administration to review it.

We encourage the federal government to play a pivotal role in providing consumer information and hope to have an open and productive discussion that will be a good starting point for us to move forward and find common ground. We support the President’s broad objectives and appreciate the administration’s commitment to those objectives and your willingness to work together to develop and implement this proposal. Attached please find our suggestions, comments and concerns regarding the President’s Higher Education Proposal which we hope will be carefully considered. Pace University remains committed to working with the Administration with a shared goal of improving, access, affordability and transparency.


Vanessa J. Herman
Assistant Vice President, Government & Community Relations
Pace University
New York City: (212) 346-1025



Federal Register Response ED-2013-IES-0151

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Comment Period Closed
Jan 31 2014, at 11:59 PM ET
ID: ED-2013-IES-0151-0034
Tracking Number: 1jy-8a5p-yhqw

Document Information

Date Posted: Feb 6, 2014
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Submitter Information

Submitter Name: Vanessa J. Herman
Category: Private/Non-Profit Institution of Higher Education