HLA’s Recommendations for ED to Assess Low-Value Postsecondary Programs


Earlier this month, Higher Learning Advocates submitted comments to the U.S. Department of Education (ED) in response to its request for information (RFI) to assess the financial value of postsecondary programs. Today’s students deserve a system that produces the financial outcomes that matter to them: high-quality learning and programs that lead to timely completion and prepare students for what’s next — either employment or more education.

The ultimate test of whether a program has value is whether completers obtain employment and how much they earn. Potential students want jobs and earnings that will allow them to pay back their student loans.

Principle 1: As ED considers new transparency measures, there should be consistency in requirements. The gainful employment (GE) regulations, if appropriately implemented, will provide students with the information they need to assess potential outcomes and, in turn, an ability to parse between low- and high-value postsecondary programs. ED should align the program-level data and metrics expectations it establishes for GE with what is collected for the RFI on low-value programs and those it identifies for gainful employment.

Principle 2: One measure alone is not enough; it’s necessary to look at a set of metrics. In particular, the low-value program data and metrics used should be based on the following measures:

  1. Median earnings after leaving college. Establish an earnings threshold, such as 20% above high school graduates’ median earnings, and collect the earnings data by completion status at one, three, and five years after completion, a range that acknowledges labor market progression. The earnings threshold should reflect variations in state and/or regional labor markets.
  2. Student debt. Require programs to report on a loan-repayment rate metric and a debt-to-income ratio.
  3. Program-level completion rates. Collect and report employment data for all occupational programs with an explicit employment goal. Institutional completion rates for all associate and bachelor’s degree programs should also be reported for informational purposes.
  4. Job placement rates. Ideally, institutions would report on employment in the occupational field of the program for occupational programs and any employment for all other programs.

Principle 3: Separate the low-value program lists to make them meaningful to students. The Department should produce several lists, including one of programs by credential level and separated by field of study. It should also separate graduate and undergraduate programs by credential level and field of study.

These data should be updated annually and disaggregated by race, ethnicity, gender, disability status, and other characteristics to measure equitable progress.

HLA would like to see other measures and metrics that should be disclosed to students to augment the information provided by the low-financial value program list. These include the financial viability of the institution; tuition, housing, and fees paid per student; and learning mode and location.

Principle 4: Any metrics and measures will reflect the inequities in society; these lists should neither exclude nor ignore that fact. Earnings thresholds can rule out credentials for many occupations that are paid relatively poorly in the labor market, making it difficult for some credentials to overcome labor market pricing, including credentials for child care workers, preschool teachers, teaching assistants, and home health aides. One challenge of this approach is some programs lead to jobs that pay lower wages, but offer a high value to society.

When identifying low-value programs, one must carefully consider the possibility of unintended consequences, particularly ensuring that institutions do not deny access to traditionally underserved student populations. One of the most glaring challenges of this work is related to the debt and earnings outcomes of women and people of color, both of whom experience discrimination in the labor market. Research finds persistently higher debt burdens for students in programs with higher percentages of women and people of color.

Principle 5: Tell students about the program value list, tell them again, and then once more. HLA supports the widespread use of notifications about program value along multiple points of the potential students’ journey to a postsecondary program. Flags should be included on the College Scorecard, FAFSA, and the GI Bill Comparison tool. The Department should also look for ways to provide warnings directly to students, including providing attestations to students. The data should be housed on a Department website that is easily accessible and provides the ability to ensure students have received the data. Additionally, the National Advisory Committee on Institutional Quality and Integrity should encourage accreditors to consider these data in their analysis of institutional performance.

To read HLA’s full comments to ED, see here.



Higher Learning Advocates
Higher Learning Advocates

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