Is a college or program delivering something of value to its students?
That’s a question that’s notoriously tricky to answer. How the government approaches it can have major implications for students, families, schools and taxpayers. Despite the stakes, policymakers don’t always have easy access to the data to determine what metrics to use — improvement in earnings, the ability to pay down the debt a student took on to finance their education or something less tangible — and how best to evaluate schools based on those metrics.
A joint initiative between George Washington University, Columbia University and the National Student Legal Defense Network, which represents student loan borrowers in litigation, is hoping to solve, or at least mitigate this conundrum.
The idea is that by bringing regulatory lawyers together with academic experts, the Postsecondary Equity and Economics Research project can identify and probe questions that might be useful to policymakers considering how best to hold colleges accountable and ensure they’re delivering for the most vulnerable students.
The project includes leading higher education economists from Columbia and GW as well as Vanderbilt University, Southern Methodist University and more. Staffers from Student Defense, many of whom have worked in various legal capacities at the Department of Education, will provide regulatory and policy insight.
The enterprise comes at a pivotal time. The Biden administration is in the midst of reviewing a suite of regulations that govern schools’ ability to access federal financial aid, the experience of borrowers repaying their student loans and more.
“We’re entering a new era in higher education and what hopefully will soon be a post-COVID world with a new administration that’s come in,” said Aaron Ament, the co-founder of Student Defense. “There will be a real need for policymaking and rulemaking over the next couple of years to protect students from a whole host of various practices.”
Why having the right data is crucial for students, schools and taxpayers
Having answers to the right questions and access to relevant data will be crucial as regulators think through these rules. Often the government’s regulations that determine if a school is a risk to taxpayers or students rely on some kind of data-related metric, for example, whether students are successfully repaying their loans or if their earnings have improved.
Institutions found violating the government’s regulations can lose access to federal financial aid money, a major source of funding for most colleges. At the same time, schools that may not be delivering students’ a return on their investment could slip through the cracks if the government uses the wrong metric or one that is easily manipulated.
As members of the new initiative evaluate potential strategies for holding schools accountable, they’ll also be paying close attention to how those policies could impact underserved students. For one, students of color, veterans, low-income students and working adults are often disproportionately impacted by the practices of predatory schools.
At the same time, colleges that educate large shares of low-income, first-generation students, students of color and working adults are often doing this work with fewer resources than colleges serving wealthier students.
As a result, there are times when these schools may appear like a risk to taxpayers and students based on the government’s metrics, even when they are providing students with valuable degrees.
Inspired by their own experience
The idea for the project came out of the founders’ own experiences. The first time Ament remembers feeling the need for better coordination between regulatory lawyers and academics was in 2013 while working as special counsel in the Department of Education’s Office of the General Counsel.
At the time, the agency was looking for the best metrics to hold colleges accountable to a rule that requires that career preparation programs — often found at for-profit colleges — to be adequately preparing students for gainful employment.
Participants in the negotiated rulemaking process, which allows agencies to develop proposed regulations through engaging with stakeholders, had suggested the rate at which students who attended these programs defaulted on their student loans, a measure that would have taken into account the outcomes of students who didn’t complete the program, instead of only those who graduated.
“We looked around and we couldn’t find any published academic studies as to what would serve as a basis to create a standard,” Ament said. “Eventually that measure got dropped.”
Stephanie Cellini, a professor of public policy and economics at GW, who is leading the project’s academic work, said her time as a fellow for the House of Representatives’ committee on education and labor, is part of what motivated her to work with Student Defense to launch the initiative.
“It was difficult to find those academic studies on a quick turnaround basis that were directly related to the policy questions that we were grappling with,” she said.
Cellini said making the participating academics’ research more directly relevant to policymakers probably won’t require huge changes, instead the project will likely provide guidance on framing or honing work the academics were already planning to do.
The types of questions the group is considering investigating include topics consumer advocates and think tank staffers have been concerned about for years. For example, whether federal loan programs for parents and graduate students, — which have both been implicated in the run up in student debt and the challenges borrowers face repaying it — could be improved to promote equity and accountability.
Cellini said she’s particularly interested in short-term programs and how tipped income or self-employment may affect how successful these courses appear at improving earnings. Tips, which typically aren’t captured in traditional earnings metrics, have been a source of controversy in evaluating whether certain programs comply with regulations.
Having good data on the role of tipped income and self-employment in evaluating short-term programs’ success is relevant to a question on the minds of policymakers right now: Whether to allow students to use the Pell grant — the money the government provides to low-income students to attend college — to pay for these courses, which are less than 15 weeks and geared towards a specific job or skill.
Though these questions may only seem of interest to those steeped in higher education and student loan policy, getting them right — or wrong — has the potential to impact students and the economy more broadly, Cellini said.
“Higher education is such a key to unlocking lifetime earnings gains, for many students, most students, but not all — especially at certain types of institutions and programs,” she said.
“Students don’t always have all the information they need to make the optimal decision about their college choices,” she added. “Government here has a role to play in using the data that are available to help ensure that students are enrolling in programs and institutions where they will see those gains and they will see positive outcomes in their lifetimes.”
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