Remember this: In education you can’t regulate your way to excellence. The same environment that encourages innovation and quality also, unfortunately, opens the door to some people who do not carry high standards for their work. At the same time, however, if you regulate to eliminate the “bad actors,” using metrics that cut across important institutional and learner characteristics, you create exactly the opposite environment, emphasizing compliance over quality. If ever there was an example of “managing to the average,” the consequences of the proposed “Gainful employment” rule — all 845 pages of it — would be Exhibit A.
What is really depressing about this issue is that we should have already learned our lesson. When “No Child Left Behind” was finally evaluated in the field, there was one glaring problem with it which guaranteed its failure. Its underlying logic was organized around learning standards based on grade level, requiring all children to “perform” at certain levels at certain ages. This is the educational equivalent of requiring all 6th graders to high jump four feet before proceeding to 7th grade.
The federal government is about to make the same mistake again as it proposes evaluating some community colleges and proprietary colleges for compliance with its emerging “gainful employment” rule, using ham-handed metrics that discriminate against institutions by type and students demographically. As an editorial in the Washington Post pointed out, the proposed rule will have exactly the opposite effect from what was intended.
So what can we do to identify poor-performing institutions when it comes to academic success and financial well-being after completion? First, include all institutions, regardless of governance structure, in the survey. Second, identify common characteristics that “bucket” institutions, not by governance, but by the characteristics of the students they serve. Third, gather evidence of educational success — successful completion and employment — that illustrates within each bucket the high-, average-, and low-performing institutions. In other words, hold them accountable for what they do: educate students and prepare them for work.
If emergency rooms in hospitals located in low income rural or urban areas were evaluated on their “success” rates compared to those in other, more affluent areas, they might well be recommended for closure. Doesn’t make much sense does it? Why should it be any different for the very colleges that serve historically low-access and marginalized learners?
Collect evidence, yes. But remember: You can’t regulate your way to excellence. And managing the average doesn’t work.