A possible model for identifying the riskiest colleges for students

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Perhaps more than any other group of potential students, veterans are at risk of abuse by unscrupulous institutions. That’s partly because the federal GI Bill makes billions of dollars in assistance available to hundreds of thousands of registered veterans (and their family members) every year, and because the funds have historically had fewer requirements for institutions enrolling these students than many federal student aid programs.

That’s about to change. Two laws enacted by Congress in recent years have required each state’s agencies that approve colleges’ eligibility for the GI Bill program to conduct “risk-based” reviews to assess whether institutions are leaving students better off and providing a welcome back taxpayers. However, adoption has been slow, largely because these agencies, like many industry regulators, don’t have enough staff or time to make informed judgments about all potential vendors.

To facilitate their work, some nonprofit groups and the National Association of State Endorsing Agencies have developed and tested a framework, based on publicly available data on student outcomes, complaints, and financial and financial trends. institutional enrollment issues (such as large increases or decreases in enrollment), designed to help agencies identify education providers that pose the greatest risk to veterans and taxpayers, so they can focus their review on these establishments.

The model “uses publicly available metrics to measure the likelihood of risk posed by all institutions receiving GI Bill dollars in each state and allows [approving agencies] to prioritize limited oversight resources toward more in-depth scrutiny of the most risky institutions,” the American Legion and EducationCounsel, a policy and strategy firm, said in a report outlining the new approach. Site visits that followed the data reviews “identified numerous risky institutional practices and outcomes, such as a significant number of student complaints and poor institutional financial health that put students at risk of sudden closure. colleges”.

The “risk-based” framework is notable not only for its possible role in educating veterans, but also for how it could be used by state agencies, accreditors, and federal officials to identify poor quality providers in federal student aid programs. .

Risk-based regulation

The idea that different colleges pose different degrees of risk to students (in terms of poor individual performance) and to governments (in terms of poor investment in the aid they provide to students) is not new, and most agencies, accreditors and regulators have sought to gather information on institutional performance to decide which places deserve the most scrutiny. The U.S. government, for example, has long subjected colleges it deems at financial risk of closure to what it calls heightened cash scrutiny, to limit their access to federal student aid funds. (A 2017 Government Accountability Office report examined how the agency identifies financially risky institutions.)

Many accrediting agencies, often encouraged by established public and private non-profit institutions that consider themselves “good actors”, have experimented with “differential accreditation”, which imposes different standards on colleges based on their sector, their background and other factors.

More recently, states like Massachusetts, swayed by the “sudden” closure of struggling colleges for some time, have explored screening tools to identify struggling colleges whose closure could harm students. And last fall, the U.S. Department of Education created an enforcement office within its federal student aid unit, which it describes as taking a “learning-based approach to monitoring and compliance.” the risks”.

Like most such efforts, historical efforts to guard against risk in the field of veterans’ education have focused on financial compliance, such as whether colleges have actually distributed the aid they receive from government to students. Legislation passed by Congress in 2017 and 2021 required the Veterans Administration and the state agencies it works with to broaden their scrutiny to determine whether institutions provide substandard education, actively mislead students in error or are at risk of closing, said policy manager Nathan Arnold. counselor at EducationCounsel.

But the state agencies tasked with conducting these reviews only have one full-time employee, and they should focus their review on the programs that pose the greatest risk, Arnold said.

EducationCounsel brought together a group of 22 policy experts (see box below) to identify a set of publicly available data points that could be collected and used to separate high-risk colleges from low-risk colleges so that agencies can more rigorously examine, through in-depth reviews of institutional documents, followed by on-site visits if necessary, the riskiest programs. (The measurements used appear on the right.)

In the pilot, Arnold said, state approval agencies found a generally strong correlation between institutions identified as high risk in the review process and actual issues identified during subsequent site visits.

“Each pilot found issues they wouldn’t have found otherwise” during their standard compliance surveys, he said. A state official quoted in the report said, “When I think about compliance investigations versus the new risk-based process, I feel like I have blinkers on which I was finally able to take off. “.

The 2021 GI Bill requires state approval agencies to begin using risk-based approaches by October.

Perspectives in other contexts

Arnold and others involved in the project believe that a risk-based mechanism like this could easily be used elsewhere in higher education, and the report offers guidance for those involved, for example, in negotiations U.S. Department of Education’s Current Accountability Statements for Higher Education.

“In many cases, it’s the same schools and the same data,” Arnold said. “We could say to many states tomorrow, ‘We did this for your VA agency, we could do this for your Title IV agency. »

Higher education accountability experts have almost unanimously agreed that differentiating by risk is a good approach to regulating postsecondary education.

Barbara Brittingham, former chair of the New England Commission on Higher Education, an institutional accreditor, said many accreditors use a risk-based approach to finances, but tend to favor “qualitative data” versus the quantitative approach favored here.

Kristin Blagg, senior research associate at the Urban Institute’s Center for Education Data and Policy, said she thinks “this kind of model might be more applicable for state authorizers and accreditors. , as the use of a risk filter could be a kind of data backbone for accreditors seeking to establish minimum accreditation standards or identify schools worthy of further scrutiny.

Robert Kelchen, professor and head of the department of educational leadership and policy studies at the University of Tennessee at Knoxville, said a risk-based approach “deserves attention,” but it would take work to reflect some of the criteria used to judge risk. for veterans within a broader higher education context.

He also cited the political issues that arise whenever policymakers identify problems in traditional colleges and universities.

“The fundamental question here is, if the data suggests a college should be closed, will policymakers follow suit and allow state or federal agencies to close a college?” said Kelchen, author of the 2018 Responsibility of higher education (Johns Hopkins University Press). “Will colleges complain, yell, threaten lawsuits, if they get put on a list of colleges needing further review?”

Political issues were also central to the concerns of Rebecca S. Natow, assistant professor of educational leadership and policy at Hofstra University and author of Revisiting the role of the federal government in higher education (Teachers College Press).

She said by email that an accountability regime that applied to all colleges and universities — as this one presumably would — would struggle to garner the kind of bipartisan support that alumni measures do. fighters have.

“The two major political parties were much less likely to agree on accountability policies affecting Title IV programs more broadly, such as the gainful employment rule,” Natow said. This could be prompted by executive action, as many federal higher education policies have been, but it usually results in legal challenges and flip-flops when a new administration takes office.

Leaving things in the hands of the states, on the other hand, usually results in very uneven regulation, with some states being stringent and others less so, Natow said.

But somehow, she said, it makes sense to inject a risk-based approach into higher education regulation. “The model appears to be a useful accountability tool for identifying institutions with risk factors associated with adverse student outcomes,” Natow said.

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