The Nuance Behind the Report Headlines

Dept of Ed regulatory update plus the nuance from WICHE's report on demographic trends that doesn't get covered

In the past week on On EdTech+, we covered a surprising aspect of 2U’s exit from the boot camp market and some interesting findings about noncredit offerings. You can upgrade to On EdTech+ with a free 30-day trial period.

Well, they’re doing it. The US Department of Education (ED) is moving forward with its proposed regulations on Distance Education (adding a virtual location data collection, disallowing asynchronous offerings for clock-hour programs), Return to Title IV (attendance taking for online courses, automatic withdrawals for 14-day periods of student inactivity), and changes to the TRIO program. And all of this despite the very high likelihood that these new rules will be struck down by the incoming Trump administration through the Congressional Review Act (CRA). Some caveats to note:

  • We don’t know what changes that ED has made to these proposed regulations based on the public comment period, but given its history the past few years, I wouldn’t expect too much change.

  • See the first bold highlight above - this is not to remove financial aid for ALL asynchronous online offerings; it’s more on a subset of vocationally-oriented programs.

  • This set of rules does NOT include changes to state authorization or inclusive access.

At first blush, what is surprising is that ED is making an apparently futile move. CRA not only means that what is known as midnight regulations can be repealed by an expedited legislative process within 60 legislative days after the publication of final rules, it also means that future department actions on these items would require legislative action. In other words, if these rules end up being struck down by CRA, any future effort on these topics would require Congress to pass a bill - a much higher standard. Yet ED still feels it should move forward.

We’ll have to wait to see what the final regulations look like, but for now be aware that ED has submitted the rules for OMB / OIRA review, which will take roughly a month.

The Demographic Cliff That Isn’t . . . But Is Still Scary

The Western Interstate Commission for Higher Education (WICHE) just put out its latest projections of high graduates in the US through 2041 in the quadrennial report “Knocking at the College Door”. The lede is that we don’t have a demographic cliff, but we do have a significant, long-term hill that we’re going down in the US that will lead to roughly 500,000 fewer HS graduates per year in the next few decades. And the peak of this hill is 2025.

The total number of high school graduates is expected to peak in 2025 and then decline steadily through 2041. The projected decreases in the number of graduates are primarily driven by the continuing declines in the number of births 18 years earlier. [snip]

Compared to 2023, 38 states are projected to see a decline in the number of graduates by 2041, as most regions in the U.S. continue to shrink. The Midwest and Northeast have already experienced declines in the total number of graduates. The South will continue to defy broader national trends with growth followed by a slight decline at the end of the projections, while the West more closely mirrors national projections.

The report is well-written and includes a great deal of nuance, particularly in describing the ethnicity and race breakdowns. That, though, is my biggest concern. Very few people read full reports and instead look to media coverage that hits the headlines. understand the nuance. Please read the full report.

For example, the headline findings around ethnicity and race call out that the only categories expected to see gains are for Hispanic and Multiracial. For the rest, there are significant declines to expect between 2023 - 2041. This topic is important for colleges and universities wanting to forecast what kinds and what levels of student supports will be needed, particularly with underrepresented minorities needing additional support.

The proportion of future graduating classes that come from underrepresented racial and ethnic backgrounds — particularly Hispanic and Multiracial graduates — will continue to increase. These trends have been consistent since WICHE first produced projections by race and ethnicity and this finding remains true in these projections.

Inside Higher Ed’s coverage is similar to other articles on this topic, just listing the basics.

The racial makeup of high school graduates will also change substantially by 2041, the report predicts. The number of white students is projected to fall by 26 percent, Black students by 22 percent and Asian/Pacific Islanders by 10 percent. Meanwhile, the number of Hispanic students is projected to grow by 16 percent and multiracial students by 68 percent.

68% ?!?

That number for multiracial jumps off the page, as does the following chart, does it not? As does the 26% decline for White students and 22% decline for Black students.

Ethnicity and Race

Ethnicity and race are not immutable, and they are not well-understood or well-defined. The US government essentially defines ethnicity as a broader set of shared culture, which is translated into Hispanic or non-Hispanic. Race is based more on biological observations such as skin color and ancestry. The report describes how the Department of Education uses these terms.

The federal approach is based on two questions. The first asks whether the student is Hispanic. An affirmative answer on this question categorizes the student as Hispanic, no matter which races are indicated in the second question, which inquires about racial identity. This approach is shown in Figure 9.

To make matters worse (for now), the US definitions of ethnicity and race are scheduled to change in 2029.

The conflation of ethnicity and race masks some important nuance. Other data sources can add color to the ED definitions - Census Bureau data shows that 20% of US Hispanics are White and just over 2% are Black.

Multiracial

Further, the WICHE report shows the Census Bureau breakdown of what Multiracial means, and 82% of Multiracial is White plus one other race, and the largest single subgroup is White and Black (38%).

Alternative White and Black Estimates

What I have done is take the WICHE data (provided in Excel form) and created an Alternative White definition: White + 82% of Multiracial + 20% of Hispanic. What you see is that instead of a 26% decline by 2041, you could view this as a 17% decline (the dashed line).

Note that for the following two charts, these are not complete redefinitions that remove double-counting. What is important is to compare the solid and dashed blue lines (White) and the solid and dashed yellow lines (Black) to clarify the point above.

For Black students, the differences are even more stark. Using an Alternative Black definition: Black + 38% Multiracial + 2% Hispanic, we go from a 22% decline to a 51% increase!

The report includes this nuance but without the alternative data estimations.

It is also important to recognize a large number of youth identify as Black in combination with another race or ethnicity, and such youth are then categorized as Multiracial. As is discussed in greater detail below, youth identifying as both Black and White represent the largest racial combination with the Multiracial category, amounting to about 1.7 million youth. This, along with Black students who also identify as Hispanic, means that there are large numbers of students who identify as Black who also identify as another race or as Hispanic.

It would very much be a mistake to view the headline data from this report and conclude that Black students are declining, full stop. Mostly by including White + Black portion of Multiracial category, you actually have a significant increase.

Some of our past assumptions and categorizations are getting in the way, and it takes some digging to get a better understanding. Surely what we are seeing is less of big changes in absolute numbers of pre-defined groups and more of an increasingly diverse population and shifting group definitions. WICHE includes most of this nuance, but you have to go beyond the media reports to get a better understanding.

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