Thursday, July 07, 2011


Gainful Employment, on the Ground

In an effort to crack down on unscrupulous for-profits, the Feds have passed a massive unfunded mandate on community colleges. We’re supposed to report a series of statistics on “gainful employment” certificate programs. The idea is to give prospective students a realistic sense of what they would actually get for their money, were they to enroll. It’s a sort of nutritional labeling for a certain kind of education.

But it’s a real pain in the neck here in the trenches. (I know, I know, trenches don’t have necks. Just go with it.)

The first issue is defining which programs are covered. As near as I can tell -- and I endured a webinar sponsored by the federal government, which was about as exciting as the phrase “webinar sponsored by the federal government” would lead you to believe -- it doesn’t apply to degree programs, to certificates with fewer than ten students enrolled, or to certificates earned in the course of earning a degree. (An example of that might be a CNA earned on the way to a Nursing degree.) The “fewer than ten” rule is intended to screen out any personally identifiable information. If Steve is the only graduate a program has ever had, then knowing the average salaries of graduates would tell you what Steve makes. Steve could argue, with merit, that his salary is none of your damn business. So we have a threshold of ten.

Having narrowed down the scope of the certificates to which the new mandate applies, though, gathering the information is a nightmare.

For one thing, we’re supposed to go back five years in reporting graduates’ salaries. How, exactly, we are to do that is left unspecified. In most programs, we’ve never bothered collecting salary information, since there wasn’t a reason to. It’s hard enough getting students to report that information in a timely and truthful way; adding time travel to the task makes it that much harder.

We’re also supposed to report median student loan levels of students in the programs. That sounds easy until you realize that students routinely switch programs or majors while they’re here. If a student switched from practical nursing to culinary after two semesters, which debt do you count? (Another quirk of using the “median” as a measure: if less than half of the students received loans, then the median is zero, by definition. That’s not uncommon when you have a significant Pell grant population. Not sure how much that statistic helps anyone, but there it is.) We also have students who think they’re dropping out of a degree program, only to discover that they’ve inadvertently fulfilled the requirements for a certificate along the way. Do we count them, even if they took a bunch of additional credits that had nothing to do with the certificate? Although the rules are based on the assumption that students pick a program and then follow it, in practice it sometimes goes the other way. It’s not the most efficient path, but it’s real.

Conceptually, most of these (except time travel) are surmountable. But they take staff time, which means money. Since we were never previously required to capture much of this information, the first round of data recovery involves significant archeology. It’s doable, but the money and time spent doing that is money and time lost from other things. Coming on the heels of three consecutive years of cuts, though, the mandate forces other cuts to be even worse than they already are.

None of this is to argue against the philosophical goal of the regulations, which is to empower students to make informed decisions. It’s just to point out that the data that will be generated will necessarily be partial and noisy, as well as time-bound and expensive. Ironically enough, the sector whose abuses started the whole thing -- the for-profits -- are in much better shape to comply with the mandates than community colleges are. With many fewer programs per institution, and with much greater emphasis on job placement, they can likely produce most of what’s required without breaking a sweat.

My unsolicited suggestion: if the Federal department of education wants us to spend money on data gathering and reporting, it can pay for it. Send grants to the colleges to which the mandate applies. Alternately, narrow the mandate to the for-profits. But this is just expensive makework at a time when every dollar counts.

We’ll do our best to comply, since we have to. But this is a costly diversion from the main task at hand, and one that will generate data of limited validity. If the for-profits are a problem, address them, but this approach is counterproductive and costly.

I disagree with your "pain in the neck" analogy. The pain is much lower!

Add this silly mandate to the massive changes in PELL and the loan system/fiasco, my Financial Aid people are drowning in a sea of bullshit.
I agree completely with you. Regulators appear unaware of the burdens they so casually impose, indifferent to the costs in money and time of compliance with their edicts.

It's the same in all regulated industries, not just education. It's the same in all private businesses, subject to a myriad of federally mandated nonsense.

This is why so many people are coming around to the idea of smaller, less intrusive government. Whatever the intentions, government action always triggers the law of unintended consequences.
These kind of unanimous decisions will not help the Students or the economy.
I have to ask: have there really been many cc's implicated in the "useless degree" scandal? Most of what I've heard is entirely about for-profits. I would also think the cost of getting a certificate from a cc would be much lower than from a for profit, so I don't see the motive for making you do this other than to sabotage the program as unfeasible so the for-profits don't have to do it either.
It's the same in all regulated industries, not just education. It's the same in all private businesses

I'd say it's the same in most large organizations, when the decision-makers are divorced from those implementing the decisions. Back when I was working for a large engineering firm we had complicated time-sheets to fill out, so our valuable time could be correctly billed to a variety of cost centres in 15-minute increments with every-changing codes. One of my co-workers got in trouble for (correctly) isolating the time spent filling in the time-sheet as well as the other administrative book-keeping we had to do.

At my current employer, most of the time-wasting data collection stuff is coming from internal management, not government edit. So in my experience it's too many layers of management (and a remote head office) rather than government that's the problem.
Why in the world shouldn't it apply to degree programs?
Yeah, this is just painful, terrible law.

The problem is that pretending that this law, rather than, say, building codes, is the poster child for government intervention is silly. No laws = Somalia. Too many laws = richest country in world. I mean, sure, be sensible, but let's remember which side we're erring on.
I withheld employment and salary information when I graduated/ escaped my graduate program because it was no business of the institution, the statistic-gathering institution, or the Department of Education (state or federal). Students like me are really going to throw a nasty wrench into this new requirement.
It depends on the quality of those certificate programs that the school is giving. Just have to see if they're any good.
Nice post. I'm not attempting to be flippant, but what would happen if you just ignored the regulation? Would the federal government really deny your students access to Pell grants or federally-backed student loans?
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