Starting to Understand the Implications
I'll choose to stick with "you read it here first"
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As subscribers probably recognize, I have described how the current set of proposed rules in the recent Notice of Proposed Rule Making (NPRM) goes well beyond Gainful Employment rules that are centered on non-degree programs and the for-profit sector. From May 22 under the section introducing some new visualizations of program data:
Inside Higher Ed had a very good article yesterday that expands on this point and gets input from various industry observers.
For those who think that a change in administration would end this approach, you might want to think again. This IHE article last week described a series of bills introduced by Senate Republican leaders, with a section that touches on the Gainful Employment-type metrics.
If you read one portion - the College Transparency Act - you will see that Republican leaders (in the Senate, at least) are pushing for very similar disclosures. The difference being that the CTA has improvements in that it defines data sharing agreements between the Department of Education (ED) and the IRS (earnings data) and the Census Bureau (measuring what high school graduates earn for comparison), and that it clarifies the metrics for those in the workforce. With the current ED proposed rules, the actual details of the data sharing is hidden. But the point is that both major political parties are pushing similar transparency metrics.
Visualizations of Impact
I have revised the visualizations of the Gainful Employment data that could apply to all academic programs with sufficient data to show both metrics. On the vertical axis is a measure of Debt to Earnings (also known as Excess Debt Payments), where ED calculates that students have more debt than they can handle (8% of total earnings or 20% of discretionary earnings). Up is bad, down is good, zero is dividing line. On the horizontal axis is a measure of Earnings Premium (program graduates making more than a state average of high school graduates without a postsecondary degree). Left is bad, right is good, zero is dividing line.
To pass both metrics, a program would need to be in the bottom right quadrant. To avoid making prospective students sign a disclosure form that they have seen this data (too much debt), a program would need to be in the bottom two quadrants.
The size of each program is a rough measure of its enrollment.
With that in mind, let’s look at all academic programs with sufficient data, color coded by the credential type (Associate’s, Bachelor’s, etc).
Notice that there are a lot of programs that would fail the Debt to Earnings metric requiring a signed disclosure by students. This is particularly true for graduate programs - Master’s, Doctoral, First Professional degrees.
What if we did the same view but color coded by control, to show the differences between public, private nonprofit and private for-profit institutions?
For-profits have somewhat larger percentages of programs failing the Earnings Premium metric, but privates and publics have a greater percentage failing the Debt to Earnings metric (mostly for privates).
Let’s pick one program to clarify how the data is laid out (all from the College Scorecard). George Washington University (GWU) and its Law degree would fail the Debt to Earnings metric and require disclosure.
Trust me, if these rules make it through the process as proposed, this type of program disclosure will have an enormous impact. And I don’t think many people in higher education understand the implications.
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