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Ensuring Higher Ed Reforms Don’t Hurt the Students They Intend to Help

The Civil Rights Project commissioned seven original research papers to assess the possible consequences of the Department of Education’s proposed postsecondary reforms. CRP also convened a lively forum in Washington, DC on Tuesday, September 2, 2014, which included presentations of the new research. In this article, Graduate Student Researcher Zahra Mojtahedi provided background on the important issues involved and considers how changes to the eligibility standards for federal financial aid and the development of a college ratings system may disproportionately affect rates of access and completion at Minority Serving Institutions (MSIs).

Ensuring higher ed reforms don’t hurt the students they intend to help

Zahra Mojtahedi 


Every year, the U.S. Department of Education provides billions of dollars in federal financial aid through Title IV to eligible students, enrolled in eligible institutions. In August 2013, President Obama announced plans to develop a postsecondary ratings system that would seek to rate colleges based on access, affordability, and student outcomes and to ultimately, with congressional approval, reward schools that do well by tying college ratings to the amount of federal student aid received.  


Over the last year, several contentious debates have emerged surrounding the proposed ratings system that have particular implications for Minority-Serving Institutions (MSIs), which can include not only Historically Black Colleges and Universities (HBCUs), Tribal Colleges and Universities (TCUs), and Hispanic-Serving Institutions (HSIs), but also colleges and universities serving higher rates of minority students, such as many community colleges.


Last December, the National Center for Education Statistics (NCES) requested public comment to help inform the development of the Postsecondary Institution Ratings System (PIRS), receiving well over a hundred responses from a wide spectrum of individuals and higher education groups. The majority expressed serious concerns about the development of a ratings system, including reservations about ‘one-size-fits-all’ approaches to designing metrics for a concept as subjective as “college value,” with many doubting institutions could be fairly compared given such divergent missions and student needs. For example, an imprudent usage of post-graduate earnings as a measure of student success may not only harm colleges with liberal arts missions, whose graduates often go on to accomplish important things in less lucrative fields, but may also punish many MSIs for the discrimination some of their students face in the labor market.


There also may be some underlying tensions between a goal of expanding access to vulnerable students from less academically-prepared and underrepresented backgrounds and improving a college’s retention and graduation statistics, the latter of which can be more easily achieved by enrolling students who are less vulnerable and more likely to graduate. The Department of Education insists that special factors will be considered for colleges that enroll students from disadvantaged backgrounds, such as how well they help enroll and graduate Pell-eligible students. However, it remains to be seen whether methodological adjustments could counteract the perverse incentives and consequences that may come, such as colleges taking actions to improve their ratings at the cost of expanding access and meeting the needs of the most vulnerable students who are often low-income and students of color.


Some question the underlying assumption that producing a ratings system would substantially influence individual college choice decisions for low-income and underrepresented groups. Low-income, first-generation, and underrepresented minority students, particularly those who would live in areas with mainly poorly rated postsecondary options, may not take the ratings system into account to the extent that the administration assumes they will. Such students may choose college based more on affordability and convenience, with little to no consideration towards a school’s ratings status on paper. Even if the ratings system were to be heavily utilized by such prospective students, the geography of opportunity matters and serious doubts would remain about their flexibility to choose a higher-rated college that may provide a better value, in theory, but may be further from their home, less affordable and a less optimal choice in practice.


There are also serious shortcomings in the ability of existing data to accurately reflect the inner workings of MSIs and higher education institutions in general. Numerous sources point to the limited breadth and reliability of the Integrated Postsecondary Education Data System (IPEDS), which would likely be one of the main data systems used to inform the ratings. For example, IPEDS fails to adequately account for both transfer students and 6.7 million part-time undergraduates, many of whom come from socio-economically disadvantaged backgrounds. IPEDS also does not capture the advantages that many well-prepared incoming students enjoy from the get-go, potentially easing the burden on some schools and leaving institutions that serve predominantly low-income, first-generation and non-traditional students, at a likely disadvantage. Indeed, any college ratings system can run the risk of rewarding schools that mainly serve the most privileged students, where student achievement may be more linked to background than to the impact of the college.


The proposed ratings system is just one part of a series of higher education initiatives and concern remains high within institutions and beyond, to ensure reforms are carried out in a way that do not harm underrepresented minorities and MSIs in the process. In October 2011, the Department of Education implemented changes to restrict the eligibility requirements for Parent PLUS loans amid growing unease over both the relatively undesirable terms of Parent PLUS loans and the degree to which the parent borrowers are drowning in debt. The consequences of this policy change were felt immediately. Families that were previously eligible could no longer access Parent PLUS loans and the impact was especially acute at HBCUs, where substantial reductions in enrollment have affected both the college-going aspirations of underrepresented students and the financial health of HBCUs already operating in constrained budgetary environments. The U.S. Department of Education recently announced it is moving forward in a rulemaking process to amend regulations surrounding Parent PLUS loan eligibility. However, financial aid policy remedies, in general, could benefit from a more thorough consideration of how underlying racial wealth disparities may propel parents with limited alternatives to risk financial security for their children’s education. 


To broaden the public dialogue and explore policy alternatives as well as make sure these changes and the ratings system overall contribute to racial equity, CRP convened a one-day higher education research and policy briefing on Tuesday, September 2, 2014 at the U.C. Capitol Visitor's Center in Washington, D.C.  The event brought together national experts presenting the latest research on the potential impact of higher education reforms on MSIs and minority students. In addition to exploring the potential consequences of the proposed ratings system, there was a timely discussion on the potential negative consequences of financial aid policy changes that may disproportionately harm underrepresented communities, particularly at HBCUs. The briefing also included a case study on the detrimental impact of unmet financial aid need on student retention at a specific HBCU, along with commentary from Deputy Under Secretary of Education Jamienne Studley on the overarching issues explored at the event. 


CRP's Partners in this initiative include the American Council on Education; Excelencia in Education; United Negro College Fund (UNCF); University of Pennsylvania’s Center for Minority Serving Institutions; University of Wisconsin-Madison’s HOPE Lab, and Vanderbilt University’s Center for Access, Equity, and Diversity Research.


 The recorded broadcast is available at


Zahra Mojtahedi is a Graduate Student Researcher at the Civil Rights Project and a Master of Public Policy candidate at the Luskin School of Public Affairs at UCLA. Zahra received her B.A. in Political Science from UC Berkeley.



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