V. Schray Testimony Page 1 Testimony of Vickie L. Schray
Senior Vice President, Regulatory Affairs and Public Policy Bridgepoint Education
Before the Performance Standards Advisory Committee Wisconsin Education Approval Board
February 22, 2013
Mr. Chairman and members of the Performance Standards Advisory Committee of the Education Approval Board, I would like to thank you for the opportunity to provide comments as you begin your deliberation of proposed performance standards for program completion and graduate placement. My name is Vickie Schray, Senior Vice President, Regulatory Affairs and Public Policy for Bridgepoint Education. I am responsible for the management of federal and state regulations and public policy as they affect Bridgepoint Education and our two regionally accredited universities. Prior to joining Bridgepoint, I served in a variety of leadership positions with the U.S. Department of Education and had the great honor of leading a number of higher education reform initiatives aimed at building
accountability systems, improving transparency and increasing student success at the federal, state and institutional level.
I would first like to commend you for your willingness to collaborate with the community and your thoughtful approach to wrestling with a very important and very complex issue. It’s important to frame this discussion within the broader context of the changing higher education environment and the national quality assurance system that includes the federal government, states and all accreditors as students are becoming increasingly mobile and institutions such as ours operate in a national market. This is especially true for distance education programs operated by both public and private institutions. There is a growing demand for higher education, especially from non-traditional students who want even greater options in the delivery of high-quality higher education. The need to increase access and affordability and find more cost-effective solutions in every aspect of higher education is critical at both the state and federal level. There is a continued call for increased accountability and we are witnessing a major shift in policy from access to success with an emphasis on education and employment outcomes. Finally, there is the changing structure and delivery of higher education including new types of
educational institutions and the increasing use of distance learning that allows institutions to operate on not only a national but a global scale.
Our two regionally accredited, degree granting institutions, Ashford University and University of the Rockies, are responding to all of these pressures in order to better meet the needs of today’s students. We have created innovative cost-effective strategies that we apply in all aspects of our operation to ensure that we’re able to provide access to a quality education at an affordable price. The majority of our distance education students are independent, working adults that represent the non-traditional student. Both Ashford and Rockies are committed to transparency in the interests of informing prospective student decision-making, institutional continuous improvement, and accountability for public and private funds.
As you begin your deliberations I would like to suggest that what is needed is more time to study the implications of your proposal within the broader national conversation and specifically focus on the following three areas:
V. Schray Testimony Page 2 Accountability for All— All higher education institutions should be held accountable for performance--not just a few--and any accountability system that is developed should establish a level playing field with clear and consistent measures and expectations based in part on the programs the institutions offer and the students they serve. This is clearly an issue in Wisconsin where you are proposing performance expectations that very few of your own public institutions could meet.
Consumer Information—Federal and state governments should work with accreditation partners to establish consistent measures of performance for all institutions and programs so that students have easy access to simple and comparable information about programs at both public and private
institutions. Inconsistent measures with varying levels of data quality create more confusion and can actually mislead not inform consumers. Many students compare and enroll in programs at institutions serving national markets especially programs offered through distance education. As a result, states must align their efforts with more comprehensive national initiatives so students in their states have access to consistent information across the full array of public and private institutions.
Performance Measures and Standards—Establishing valid and reliable performance measures and realistic and fair performance standards requires time. It is recommended that independent experts work with government agencies and a representative cross-section of institutions to propose and test measures with actual data allowing them to identify and resolve problems. This approach also allows time for institutions to develop reporting systems that can provide high-quality data based on clear and consistent data standards. As you will see, we have a number of questions about your proposed measures and are concerned that you have not fully developed specified data standards to ensure comparable information across institutions.
In addition, setting performance expectations usually involves a more comprehensive analysis of performance levels in the baseline period using real data and identifies realistic benchmarks of performance that may be increased gradually over time. As noted above, you have established
benchmarks that have little relationship to current higher education performance in your own state and little relationship to systems that incent institutions to improve over time from baseline performance to meet required expectations.
I would like to now briefly touch on these three areas. Accountability for “ALL” or Accountability for “SOME?”
Wisconsin and a number of other states have taken a major leadership role in establishing performance accountability systems to drive improvement in higher education and to protect their citizens. Most states have now established performance-reporting systems for higher education that address one or more performance measures. It is important to note that these performance accountability systems and related state regulatory systems (e.g., program approval, proprietary school certification) represent a layer of quality assurance in higher education that is largely disconnected from and inconsistent with the quality standards and processes used in accreditation and in what is being established at the national and federal level.
The importance of looking beyond one sector or one state in establishing metrics is illustrated by the fact that according to the National Student Loan Clearinghouse Research Center, 42.7% of students who began their college education at a four year proprietary institution completed their education, while only 35.4% of students who began their college education at a community college completed. In fact,
V. Schray Testimony Page 3 the national graduation average for all institutions is currently just under 50%. Closer to home in Wisconsin, according to data submitted to the U.S. Department of Education, through the IPEDS database, only 1 technical college, 3 four-year public institutions, 4 independent colleges/universities, and none of the UW Colleges (2 Year institutions) would be able to meet a 60% graduation threshold. We understand that the EAB does not have the authority to establish standards for all institutions but at the very least you should coordinate with those bodies that have responsibility for other sectors in order for students and state policymakers to understand college completion and the overall effectiveness of their higher education system in increasing educational attainment of your citizens. In addition, the EAB and other higher education governance bodies should work with national organizations to establish more comprehensive efforts across all higher education using consistent measures and performance expectations.
We agree that institutions should be held accountable for the success of the students they educate and welcome clear accountability for results as long as there is a level playing field. Again, to level the playing field you need to use the same performance standards applied to all postsecondary institutions based in part on the programs they offer and the students they serve.
Consumer Information or Consumer Confusion?
The stated goal of the EAB is to create policies that best protect the consumer and provide them with the information they need to make informed decisions. Having multiple federal and state agencies and accrediting bodies establishing different measures does not provide simple and comparable information to consumers especially those non-traditional students that may not have assistance or support in making sense of the myriad of data sources and inconsistent information.
A number of national initiatives are underway that are inconsistent with or in conflict with the proposed EAB metrics. We think these initiatives have great promise because they establish consistent measures and are taking steps to provide all institutions with the data they need to report high-quality data through data sharing clearinghouses for measuring completion and employment and earnings. These national initiatives are now beginning to produce consumer information that will be inconsistent with your efforts and this information will be incorporated in career and educational guidance systems that will be used by many traditional and non-traditional students throughout your state.
For example, the College Completion Challenge, which is sponsored by the American Association of Community Colleges, sets a goal of increasing the percentage of students with high quality degrees and certificates by 50%. The College Completion Agenda, sponsored by The College Board, sets a goal for 25-34 year old with an Associate’s Degree or higher at 55% and President Obama’s 2020 goal calls for an increase in national graduation rates by 50%.
Consumer information must be based on consistent measures, using high-quality, reliable data that is provided to students on all institutions in a consistent format so that they can make an accurate comparison. Institutional and program information and performance on a limited set of institutions do not constitute consumer information or transparency and in fact may lead to consumer confusion.
V. Schray Testimony Page 4
How Good is Good Enough?
Many of the comments the EAB has received identify some major issues in data quality and methods for determining performance standards and adjusting for people served. We have a number of other questions that left unanswered could lead to a system that is easily “gamed” and would result in inconsistent data.
How did you set the level? It does not seem to be based on actual performance levels and it’s not clear whether you have the data systems in place to have full confidence in setting the level. You propose an alternative approach to calculating graduation rate that would be calculated
over 12 month time period beginning with the student start date. It is unclear how a non-term institution would calculate the graduation rate.
The EAB is proposing to only count transfers if verified. How will you verify? Will data be self-reported by the student?
It is implied that there will be a consistent policy regarding drop-outs? What is the policy? Is it up to the institution to determine the length of time the student needs to be gone or will the EAB provide that guidance?
Performance measures established for any institution should take into consideration the length of the program. For four-year programs, the normal time to completion is measured at 6 years for 150% of time. These traditional programs have two semesters per year and would have to maintain a 92% retention rate to reach a 60% graduation rate at the end of the 6 year mark. However, proprietary schools tend to operate year round and often have different term periods, which means, that during the same time period, private sector institutions will have gone through a year and a half worth of
instruction.
Research has shown that programs of different term lengths tend to have different retention rates, so a comparison between a 4 year program and a 6 month program would not make sense. To determine if a program is successful, programs should be compared to programs of similar length. To ensure equity between traditional and non-traditional instructional calendars, measures should be based on an institution’s term, rather than on an annual basis.
Exploring other factors that may lead to student success might provide more useful and timely information to judge a program’s success and result in metrics that would minimize the potential for unintended consequences.
Conclusion and Recommendations.
I’ve learned a great deal from my previous work at the national level working with the states and local institutions in creating performance measures and quality assurance systems for postsecondary education as a means to assure quality and inform and protect consumers. Based on this experience I strongly encourage you to give additional thought to the issues that I’ve identified as you devise a plan going forward.
I encourage you to phase in performance standards by setting a departure point based on the current average performance levels of institutions with performance standards adjusted for student "risk profiles." You would then move the departure point up while continuing to adjust for types of students being served with the objective of both improving data quality and allowing institutions to make changes (e.g., enrollment management, retention policies) to improve performance. Again, the idea is
V. Schray Testimony Page 5 to start a continuous improvement process that can move the vast majority of institutions up over time. Based on this approach and the data currently available, the targets you have proposed are not a “minimum standard” but rather an “aspirational goal” for institutions.
The EAB is embarking on an area of critical importance and one that requires careful and deliberate consideration of all aspects of the issue to ensure that state policies don’t result in unintended consequences that create barriers to student access and success
