Comment to the U.S. Department of Education Regarding Proposed College Rating System

January 30, 2014

Dear Department of Education Colleagues,

Thank you for the many ways in which the department partners with colleges and universities to advance our society, including its democracy. These joint efforts have benefited countless students and the country as a whole.

It is in this spirit of shared purpose that I write about the complicated challenges posed by the number of students and families who in pursuing higher education inadvertently make unwise financial decisions that harm their futures and end up wasting federal money. Helping these vulnerable families and reducing waste are goals that should be shared by all in the higher education community as well as in government.

I appreciate the opportunity to comment here, as a college president, on the effort to develop a system of rating colleges that would better inform students and families and provide a measure for the disbursement of federal financial aid.

Regarding information for families, I would point out that a great deal already exists. There are so many compilations of this information because of the understandable belief of numerous organizations that if only a little more of it were presented in a somewhat different way, students and families would make wiser choices. There is no proof, however, that this is true. It seems instead that vulnerable students and families either do not know to access this information or lack the ability to make effective use of it.

Since it is hard to believe that the next compilation of information will prove finally to be the definitive one, vulnerable individuals might be better served, and fewer federal dollars wasted, if low-income students and families could receive personal counseling on college financing. Affluent families have access to this, though low-income ones have greater need of it. Perhaps such counseling could be a requirement for certain aid programs. Perhaps a pilot project would show that the cost of such an arrangement would be exceeded by the reduction in waste.

I won’t expand here on how the proposed capturing of income and other data on graduates raises logistical and privacy issues and seems inappropriately to value, say, bankers over teachers. I know that you have heard about these concerns from many others.

Let me instead point out that if there must be a rating on which federal aid is allocated, it would seem important that it be absolute rather than relative. Grading on a curve could penalize well performing but under-resourced schools because of their innate inability to compete in such a Darwinian system. I encourage you instead to set minimum standards of institutional performance, that there be few of them, and that they be sensitive to the differing roles played by various sectors of the higher education community.

Any such system must avoid penalizing students for factors outside their control. Many students have just one viable higher education option—their local community college. If that college fails, for reasons of its own, to meet minimum standards, reducing the financial aid of its captive students would affect perversely those students and the access that we’re all working to advance. If there must be a system of sticks, it should penalize schools (and I would argue only the real outliers as objectively measured) rather than students.

Perhaps instead there could be a system of carrots, with incentives to colleges and universities that improved their performance. Perhaps, again, a pilot would show that such a program paid for itself.

For these reasons I encourage you to:

  • Maintain a healthy skepticism that more information will result in better choices.
  • Consider the logistical and privacy implications of gathering personal data.
  • Avoid valuing people based on their earnings.
  • Assess schools using absolute, rather than relative, measures.
  • Avoid penalizing schools for being under-resourced.
  • Avoid penalizing students for factors outside their control.
  • Think instead about creative approaches that could provide guidance to vulnerable students and families and that could entice schools to improve performance.

Thank you for the thoughtfulness that I understand you are applying to your deliberations, to which I hope these remarks make some small contribution.

Sincerely yours,

Adam F. Falk


Williams College