Collateral Damage: The Problem With Proposed Institutional Performance Standards for Federal Financial Aid

It is easy to teach good students. The “star teachers” at Harvard or Stanford can assume a certain knowledge base as starting points in their classes and can set expectations that the majority of their students can reasonably meet. They have a narrow range of students, all of whom have been carefully selected through an extensive admissions process.

It’s quite different, teaching at a campus that has something close to open admissions. Nothing, in terms of student knowledge, can be assumed, especially if the student population includes a large number of “international” students. Expectations change in each class each semester based on an evaluation of each student group. The range of students is extensive, and it is never possible to tell what it will be in any particular section. Generally, one or two students would probably be able to compete in an elite classroom and one or two are in the process of washing out… with the rest all over the spectrum between, but in no discernible pattern. One class one year might do extremely well. Another the next year might do quite poorly. It becomes impossible to predict with accuracy–and it has little to do with the quality of the instruction.

Though all teachers must start where the students are, that place is particularly difficult to determine when the students range greatly, not having been “sorted” before arriving on campus as they are a elite and other “selective” institutions. It also leaves the teacher (and the institution) in a vulnerable position, for no base “platform” of student expectations has been (or can be) established. Therefore, “outcomes” do vary substantially–especially in quantifiable areas such as rates of graduation, etc.

When these outcomes are used for evaluating the institutions, the institutions are going to be less likely to take chances on the very students who need them most–those who have the greatest education needs.

Just as the real “star teachers” are not those who teach the best students but those willing to work with those students most at risk for failure, the “star institutions” are those willing to take a chance on the students who no one else will accept. And they are those who, in both cases, have the skills and support abilities needed by those students. They are also willing to deal with a high level of failure–experiencing real failure being part of what it means to be a star.

Even in the best of situations, it is almost impossible to bring all such students to the point where they are going to receive degrees. Often, it is impossible to do so within a proscribed period of time.

By setting benchmarks of average time to graduation, etc. (as has been suggested), the federal government would be assuming a certain base platform for incoming students even at the most open campuses. As a result, such platforms will be instituted where they do not already exist, and the students with the greatest needs (who sometimes also have the greatest potential) will be shut out of college, the institutions no longer willing to take a risk on them–just the sort of risk they are now best able to take.

The editorial board of The New York Times argues today that:

graduation rates, loan defaults and percentages of low-income students enrolled are extremely useful indicators of which colleges are serving their students and the country well and which are not.

Maybe so… but only if there is a common base for entrance into college, which there is not. So, no, these indicators are of only limited utility.

I understand the desire to limit the predatory practices of some for-profit colleges and of various “diploma mills,” but the collateral damage might be those students with the weakest backgrounds who could best make use of the “star teachers” at many of our community colleges and other institutions with low bars to student enrollment. Those teachers really are stars, much more than their colleagues at elite institutions. That they do not succeed with every student does not gainsay that: The institutions, the teachers, and the students are operating in near-impossible conditions. They need more support, not more threats to funding or to financial aid for their students.

The Education Trust (I know nothing about the organization) has issued a report suggesting new minimum performance standards for institutions of higher education. The report, Tough Love: Bottom-Line Quality Standards for Colleges, suggests that the federal government:

Raise the Floor Above the Current Bottom 5 Percent
Minimum Standards for Low-Income Student Access and Degree Completion

  • Pell, full-time freshman enrollment: 17 percent
  • Six-year, full-time freshman graduation rate: 15 percent
  • Student loan repayment rate (optional interim proxy three-year cohort default rate: 28 percent)

Time Frame for Improvement

  • Fair notice of new minimum performance standards (at least one year)
  • Opportunity to appeal designation for those institutions that may be the only option within a certain geographic area or that overwhelmingly serve non-first-time, full-time students but perform better with those students than with first-time, full-time students
  • Federal monetary and technical assistance for institutions below graduation and loan repayment standards

Low-access colleges have three years to improve, succeeding if the average Pell enrollment rate over the next three years equals or exceeds 17 percent.
Low-graduation colleges have four years to improve, with two additional years if they are on track to graduate at least 15 percent of students by the end of six years, succeeding if the average graduation rate during this time frame equals or exceeds 15 percent.
Low-loan repayment colleges will also have time to improve. A specific time frame is to be determined upon availability of data, but should be, at a minimum, at least three years.

Sanctions for No Improvement
Low-access “Engines of Inequality” will be subject to losing institutional grant and tax benefits, including tax-exempt bonds to nonprofits and the charitable interest deduction to both the institution and affiliated foundations.
Low-graduation “College Dropout Factories” and low-loan repayment “Diploma Mills” will be subject to losing institutional grant and tax benefits as well as all eligibility to receive federal student aid, including grant, loan, and tax aid.

While the goals may themselves be fine, this will put real ‘open-door’ institutions in a precarious position. Because they take chances on students, they cannot guarantee any degree of student success. That will always be an unknown. Though predatory institutions may find themselves shut out, legitimate ones serving the most in-need students will also find the door closing on them–unless they change to stabler and more stringent entrance requirements.

Let’s hope that, as new performance criteria are put into place, the institutions taking the greatest risks and doing the hardest and best work with the most in-need students will not find themselves, and their students, collateral damage to an attack on someone else.

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