NAICU Washington Update

NAICU Submits Comments on Proposed Postsecondary Institutional Ratings System

February 12, 2015

Late last year, the Department of Education invited public comment on its framework for a college rating system. Responding to that invitation, NAICU submitted comments to the Department that reiterated the Association’s support for President Obama’s focus on access, affordability, and transparency, especially in the form of consumer information. NAICU’s comments, however, stressed that the Association and its members could not support any effort that would substitute a federal rating for an individual’s judgment about what is important and valuable in an educational experience.

It is not too late to provide comments to the Department. Comments are due by February 17 and can be submitted through this online form: or by email to

NAICU’s comments expressed support for efforts by the federal government to help students and families who are weighing options in higher education to make better informed choices that go beyond the commercial ratings and rankings and rely on the facts. NAICU also expressed concern that the weighting and assignment of value to that information must remain squarely in the hands of individuals. It is a fundamentally impossible task for the federal government to design a ratings system that is both a useful consumer information tool and an effective accountability system.

Key Provisions of the Ratings Framework

  • The proposal still envisions developing a federal system for evaluating colleges, and making that system available to the public. It is not clear if the ultimate ratings system will simply consist of a single rating for each institution, or if a series of ratings based on such categories as “affordability,” “access,” and “success” will be created. In either event, the concept of a federal values metric or metrics persists.
  • The proposal identifies 12 categories of data that might be used to create this ratings system: percentage of a college’s enrollment receiving Pell; Expected Family Contribution (EFC) gap; family income; percentage of enrolled students who are the first in their family to attend college; average net price; net price by family income; average loan debit, completion rates; transfer rates; labor market success; graduate school attendance; and loan performance outcomes.
  • The proposal currently combines institutions into two broad categories (4-year & 2-year) for comparison purposes, and excludes less-than-2-year and graduate institutions. Administration officials are still considering if there is a better method for determining peer institutions.
  • The proposal anticipates making adjustments based on student characteristics. Such adjustments would most likely be applied to earnings and completion measures, based on the Free Application for Federal Student Aid (FAFSA) information.

Additionally, Representatives Bob Goodlatte (R-VA) and Mike Capuano (D-MA) have reintroduced a resolution in the U.S. House of Representatives condemning the proposed institutional ratings system, and are actively seeking co-sponsors. The resolution (H. Res. 26) is identical to the language introduced during the 113th Congress that was cosponsored by a bipartisan coalition of 35 Members of Congress.