On Monday Sen. Lamar Alexander (R-TN), chairman of the Senate Committee on Health, Education, Labor and Pensions (HELP), released white papers in an effort to focus attention on three topics related to the upcoming reauthorization of the Higher Education Act: student consumer information requirements, risk-sharing in the student loan programs, and accreditation.
The Senator has requested public comment by April 24 on these papers. NASFAA will submit comments, and in turn would like to hear from you. Please send your comments to email@example.com.
Senator Alexander calls for a new approach to focus the federal role in postsecondary data and transparency:
“During the upcoming reauthorization of the Higher Education Act, policymakers have the opportunity to refocus the scope of data and disclosure policy, which currently creates some of the most burdensome requirements on institutions. Rather than create massive collections of unused data and unread disclosures, policy should promote purposeful and accurate data for evaluating the efficacy of federal student aid programs and providing transparency to students and families on postsecondary options.”
This white paper reviews the development and legislative history of higher education data collection, use of statistics, and federal involvement in consumer information requirements. The report notes the growth of data collection to include 11 annual surveys through IPEDS with more on the way. In addition, it cites NASFAA’s 2014 Consumer Information Task Force Report that found disclosures to students required of institutions “can be divided into 17 different categories containing more than a hundred components and many more individual data elements.”
The report lays out three elements of a strategy designed to ensure public access to accurate, comparable data on institutions of higher education, and to ensure that purposeful and consumer friendly information enables students and families to select the college or university that best fits their needs. Sen. Alexander’s strategy is to:
The report identifies several problems in the area of consumer information that need to be addressed:
1. Some federally collected data may serve no purpose for policymakers or consumers.
The report acknowledges that Congress is partially to blame for the mountain of data and disclosures on institutions, but points out that significant data collections not outlined by law were added by the Department of Education.
Federal investment in higher education goes to students rather than institutions, thus “the value of maintaining extremely detailed data unrelated to student enrollment, safety and success, or protection of the federal dollar, is ripe for debate. Policymakers must examine this trove of information in the context of the federal government’s current relationship with institutions of higher education and the consumer-driven nature of the market. Collected data should either assist policymakers or inform consumers.”
Alexander calls for a debate on eliminating federal data collection or disclosures unrelated to the needs of federal program management or consumer decision-making. This concept includes elimination of data on items unrelated to student financing, success or safety, and more legislative oversight on data collection to prevent its overgrowth.
NASFAA’s Consumer Information Task Force Report advocates the elimination of non-Title IV-related disclosures, and recommends a study to evaluate the usefulness and utility of certain reports and statistics that are not directly related to Title IV student aid.
2. Despite expansive data collections, the federal government lacks key information regarding student success necessary for policymakers evaluating the effectiveness of federal programs and informed consumer decision-making.
The report points out shortcomings of graduation rates that do not account for returning or transfer students, and lack of information on long term outcomes related to earnings, which would require access to data on students after college. The report observes that there is a “debate about the value, or appropriateness, of attributing a direct correlation between students’ higher education and the earnings of recent graduates.”
The report calls for a policy discussion over the proper purpose of examining the data, and the role of multiple players that have been collecting information piecemeal, and promises discussions around what key questions policymakers have, but cannot answer, as well as appropriate uses and limitations on the uses of data by federal officials.
One of the concepts that should be debated, according to the report, is to create an exception under FERPA and allow some new student level data to be collected for all students. Part of this debate would also allow a student unit record system at the federal level.
NASFAA’s Consumer Information Task Force Report also highlights issues with graduation rates, and calls for a repeal of the ban on a federal student unit record. A student unit record would allow for the assessment of student success (including transfer rates), completion rates, and salaries by major or program. It could follow students as they move through and between postsecondary institutions and into the workforce and it would address current shortcomings with IPEDS.
3. Data collection and preparation is highly burdensome for colleges and universities.
The report cites the results of the 2010 Higher Education Regulations Study conducted by the Advisory Committee on Student Financial Assistance. That study placed overlapping and inconsistent timeframes for reporting, and the volume and scope of requested data and consumer disclosure requirements as the second and third most burdensome higher education regulations.
As part of the debate to increase data quality and transparency, the report suggests using existing administrative data in NSLDS to conduct analysis and public reporting on return on investments in the federal student aid program. Institutions could permit third-party organizations or states to maintain and report student success measures on behalf of institutions to the federal government.
4. Consumers do not use federal postsecondary data, consumer disclosures or tools when navigating the higher education marketplace.
The report found that thirteen separate federally maintained data portals or consumer tools through which the public can find information on institutions or student trends in financial aid are scattered across different agency websites. According to the report, students are most likely to use a generic search engine and view individual institutions’ websites instead of third-party or government sites. The report also cites advocacy group and researcher findings that institutions often fail to display, or make easily available, mandated tools such as net price calculators.
The report suggests consolidating the various access points for federally managed postsecondary information into a single portal housed at the Department with coordination from other interested federal agencies, and conducting extensive consumer testing on what information is needed and how it should be presented. Also recommended is a single institutional disclosure page for prominent inclusion on college and university websites, and either requiring institutions to prominently place and simplify net-price calculators, or create a universal net-price calculator.
NASFAA’s Consumer Information Task Force Report suggests that information availability be focused on College Navigator. The task force also calls for consumer testing at the federal level prior to the imposition of any new requirement.
5. Federal data is being manipulated--diminishing its comparability and obscuring transparency.
The report states that “there are not strong enough limits established on the role of data for accountability purposes,” and expresses concern that the Department of Education is selectively manipulating postsecondary data in a way that limits transparency.
Alexander’s suggestions for debate include measures to prohibit the Department from requiring new data collections or new metrics unless authorized by law.
Publication Date: 3/25/2015