NAICU Washington Update

Dept. Ed. Tries Carrot and Stick to Get States' Private College Data

November 04, 2011

NAICU has submitted comments in response to a Department of Education notice making extension of a state data reporting deadline contingent on states' reporting of apparently unrelated data on their private colleges.  The NAICU letter notes that, under the plan, "the Department is requiring the collection of even more data . . . in effect negating the extension by requiring additional work in exchange for additional time."

The deadline extension applies to the longitudinal data requirements attached to states' receipt of 2009 State Fiscal Stabilization Funds (SFSF). The stimulus funds were made contingent on states collecting information about their students - including the number of their high school graduates who enroll in college. This unusual new notice permits states to apply for an extension for SFSF reporting to December 31, 2012.  The Department estimates that 43 States will need additional time to obtain the required information.

States would gain the extension, however, only if they provide additional data not called for in the original SFSF parameters.  Those elements include the state's reporting on the amount of aid it provides to private colleges (including student aid and research funds), whether the state has a data-sharing agreement with any private college, and if so, whether such an agreement permits the state to track recent high school graduates.

The NAICU letter notes that the rationale for the additional data collection is not clear.  Whether or not a private (or out-of-state public college) receives funds from a state has no bearing on the number of the state's high school graduates in attendance.

The letter goes on to note that "the addition of extraneous new reporting requirements in order to allow States more time to meet requirements already proving difficult is, at best, a counter-productive step. It is also an unusual exercise of regulatory authority to use a deadline extension to gather new information about a sector of higher education that had little, if any, access to the funds to which the original requirements were tied."

In closing, the NAICU letter requests the Department to delete the requirements for extraneous data collection, and to permit states simply to request a deadline extension to December 31, 2012.

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