Comment on FR Doc # N/A


I am the president of the Kansas Independent College Association, a non-profit association founded in 1976 to promote the interests of the 18 independent, non-profit, regionally accredited, degree-granting institutions of higher education in Kansas and strengthen their ability to provide a high-quality, affordable, and meaningful education to our nearly 25,000 students.

We share your interest in improving access, affordability, transparency, and positive outcomes for college students. The KICA institutions have proactively taking steps to do so, through tuition freezes, 4-year tuition guarantees, loan forgiveness programs, and partnerships to improve career preparation and opportunities.

We have earnest concerns about the proposed postsecondary institution ratings system and the deleterious effects it could have on private colleges in Kansas. We have substantial doubts that any such system will be able to provide useful comparative data to prospective students and their families. No one measure, nor any small set of criteria, can adequately compare the thousands of effective colleges and universities in the U.S. Even among only Kansas’ private colleges, such an effort would be nearly impossible. Consider the differences just in comparing the following:

A 2-year college whose focus has long been serving low-income, urban, minority students and whose graduates often enter health care and education fields in the local communities
A 4-year college whose students are often dual enrolled with a nearby public university and whose graduates often go into the ministry in smaller, rural communities across the country
A 4-year university with growing, nationally recognized programs in biological sciences and fine arts

These are just small facets of three of our eighteen private institutions and even with these over-simplifications it would be fruitless to compare costs, employment, or earnings of recent graduates, and even more fruitless to define each institution’s “quality” or “value” by a summary metric.

Despite our concerns about the intent of the proposed postsecondary ratings system, the Department has been clear that you intend to move ahead. Thus, we offer these comments to guide its development toward a tool that will cause less damage and will be of greater use to students, families, and institutions.

If there must be a rating system...
1.Let the prospective student decide what the weighting should be. Providing information to consumers is a valuable service and does not require a “rating” to be effective. In fact, weighting the various characteristics of colleges imposes an arbitrary value judgment on what each student should or should not care about. Your objective should be to help prospective students find the institution that best fits them. Each individual student may define “best fit” differently – some may care deeply about high salary immediately upon graduation. Others may seek a place to explore their own values or a place known for experiential education and study abroad opportunities.

2.Combine quantitative and qualitative information. We encourage students to visit campuses when choosing where to apply and where to attend because there is power in storytelling. One of the hallmarks of KICA’s private, non-profit colleges is the personal attention our institutions provide to each individual student. We would be appalled by institutions that treated students as just the sum of their numbers – ACT score, GPA, class rank, etc. You should not treat institutions as merely the sum of their numbers either. While some standardized data may be useful, allow colleges to also tell their own story that shares their mission, character, and personality.

3.Show the importance of opportunity cost. Tuition and costs, whether “sticker price” or “actual price” are only one side of the affordability story. We anticipate whatever rating system you develop will include cost data and graduation rates. But if you do not help students and families see the connection between the two, you are missing a valuable opportunity. Use your pulpit to explain opportunity cost to provide context to differences in tuition and graduation rates. According to NAICU research, a fifth year to complete a degree means an average of $44,455 in lost income on top of the tuition and other direct costs of that additional year. Thus, a private college degree in four years can actually cost a student $20,000 less than a public college degree that takes five years.

While none of these three recommendations will fully resolve our concerns with the overall proposal, they will move the proposal toward something that will be helpful rather than an impediment to the Department’s goal to offer fair and accurate consumer information to prospective students and their families.

I and any of our member presidents would be happy to provide additional assistance. Thank you for the opportunity to provide our input.
Comment Period Closed
Jan 31 2014, at 11:59 PM ET
ID: ED-2013-IES-0151-0041
Tracking Number: 1jy-8a5u-tq4v

Document Information

Date Posted: Feb 6, 2014
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Submitter Information

Submitter Name: Matt Lindsey
City: Topeka
Country: United States
State or Province: KS
Organization Name: Kansas Independent College Association
Category: Association/Organization