HESA

Higher Education Strategy Associates

Category Archives: U.S.

February 18

Performance-Based Funding (Part 2)

So, as we noted yesterday, there are two schools of thought in the US about performance-based funding (where, it should be noted, about 30 states have some kind of PBF criteria built into their overall funding system, or are planning to do so).  Basically, one side says they work, and the other says they don’t.

Let’s start with the “don’t” camp, led by Nicholas Hillman and David Tandberg, whose key paper can be found here.  To determine whether PBFs affect institutional outcomes, they look mostly at a single output – degree completion.  This makes a certain amount of sense since it’s the one most states try to incentivize, and they use a nice little quasi-experimental research design showing changes in completion rates in states with PBF and those without.  Their findings, briefly, are: 1) no systematic benefits to PBF – in some places, results were better than in non-PBF systems, in other places they were worse; and, 2) where PBF is correlated with positive results, said results can take several years to kick-in.

Given the methodology, there’s no real arguing with the findings here.  Where Hillman & Tandberg can be knocked, however, is that their methodology assumes that all PBF schemes are the same, and are thus assumed to be the same “treatment”.  But as we noted yesterday, the existence of PBF is only one dimension of the issue.  The extent of PBF funding, and the extent to which it drives overall funding, must matter as well.  On this, Hillman and Tandberg are silent.

The HCM paper does in fact give this issue some space.  Turns out that in the 26 states examined, 18 have PBF systems, which account for less than 5% of overall public funding.  Throw in tuition and other revenues, and the amount of total institutional revenue accounted by PBF drops by 50% or more, which suggests there are a lot of PBF states where it would simply be unrealistic to expect much in the way of effects.  Of the remainder, three are under 10%, and then there are five huge outliers: Mississippi at just under 55%, Ohio at just under 70%, Tennessee at 85%, Nevada at 96%, and North Dakota at 100% (note: Nevada essentially has one public university and North Dakota has two: clearly, whatever PBF arrangements are there likely aren’t changing the distribution of funds very much).  The authors then point to a number of advances made in some of these states on a variety of metrics, such as “learning gains” (unclear what that means), greater persistence for at-risk students, shorter times-to-completion, and so forth.

But while the HCM report has a good summary of sensible design principles for performance-based funding, there is little that is scientific about it when it comes to linking policy to outcomes. There’s nothing like Hillman and Tandberg’s experimental design at work here; instead, what you have is an unscientific group of anecdotes about positive things that have occurred in places with PBF.  So as far as advancing the debate about what works in performance-based funding, it’s not up to much.

So what should we believe here?  The Hillman/Tandberg result is solid enough – but if most American PBF systems don’t change funding patterns much, then it shouldn’t be a surprise to anyone that institutional outcomes don’t change much either.  What we need is a much narrower focus on systems where a lot of institutional money is in fact at risk, to see if increasing incentives actually does matter.

Such places do exist – but oddly enough neither of these reports actually looks at them.  That’s because they’re not in the United States, they’re in Europe.  More on that tomorrow.

January 13

Packaging Student Aid

One of the things about student aid that makes it such great fun as a policy area is that it’s as much about framing as it is about actual policy.  For instance, which of the following two policies would you like to have?

a)      A policy where students are asked to bear a huge amount of debt – over $100,000 in some cases for an undergraduate degree – over 25 years, and where three-quarters of students will never repay their loans in full; or:

b)      A policy where graduates are asked to pay a 9% surtax for 25 years, up to a maximum of about $100,000, but much less (possibly even $0) if their earnings are low.

If you’re a regular reader of the Guardian, you’ll probably recognize the first policy as being the one implemented by the Cameron government in 2012, to cover fees in English universities.  That’s the one the progressive types are always pointing at and shouting: “Look!  Students are being horribly indebted AND the government is losing lots of money through the program!  Quelle fiasco!”

But here’s the thing: that second program is also the English loan scheme.  As I’ve explained before, for the three-quarters or so of graduates not expected to pay off their loans in full, the scheme is simply a graduate tax.  It’s not explained that way, but that’s what it is.  It’s a packaging issue.

There’s something similar going on in student aid policy in the United States; namely, the interest in something called “Income Share Agreements”.  It’s been kicking around for awhile (the American Enterprise Institute wrote about it a year ago), but is getting more of a hearing these days because Florida Senator, and potential Presidential candidate, Marco Rubio is now backing it.  It’s basically a Human Capital Contract – someone gives you money today, and you agree to give them a set portion of your income for a set number of years.

If that sounds like a Graduate Tax, that’s because it’s exactly how a graduate tax works – the difference in this case simply being that you’re not giving that money to government, but rather to an individual who has chosen to “invest” in you.  The beneficiary is different, but the flow of funds is precisely the same.  But that difference is enough to get the idea some love from a Tea Party favourite.

And that is to say nothing of our experience in Canada where the CFS, which absolutely hates income-contingent loans, and has done so for years, applauded the introduction of the Repayment Assistance Program (RAP) – which basically makes the Canada Student Loans Program fully income-contingent – because the government simply chose not to call the program “income contingent”.

This all goes to show: in student aid, few people actually look at substance.  The real debate is about the packaging.

January 12

That Obama Free Community College Proposal

I was going to start on a series about growth in non-academic staff numbers today, but the news out of Washington late last week was too spectacular, so I’m bumping it.  Did Obama really say he wanted to make community college free?

Well, yes he did.  But he might not have meant it the way we all heard it.  And whatever happens, it’s unlikely to occur any time soon.

Let’s start with what he actually said (White House fact sheet, here).  He said he would make tuition free for “responsible students” (read: on course to graduate on-time, with a 2.5 GPA) attending community colleges and taking courses towards a 4-year degree, or an occupational training course in an “in-demand” field.  But there were some catches.  Only institutions that adopt “promising and evidence-based” programs to improve graduation rates will qualify.  States also have to agree to participate, kick-in 25% (or thereabouts) of the funding without cutting any other higher education programs, plus adopt a new outcome-based formula-funding system that funds completions rather than enrolments.  It’s not clear how many states will agree to this (nor, indeed, is there much likelihood that a republican congress would agree to those kind of state spending mandates).

There are obviously a whole bunch of questions that weren’t answered in the initial announcement.  The main one was whether Obama meant “free”, or if he actually meant “government would cover the cost”.  That makes a big difference; Pell grants already cover the cost of tuition for nearly half of all community college students.  If that were the standard, it would imply that all of the new money would be going to students currently considered wealthy enough not to need grants.  That would make the new program very similar in distributional consequences to the notionally universal $1,500 refundable tax credit that Bill Clinton introduced in his second term, but which in fact was only available to those receiving less than $1,500 in Pell.

Another question, not raised much in the US, is: if the initiative is in fact successful at increasing the number of students at 2-year institutions (some of whom, to be fair, could simply be people switching from 4-year to 2-year), where are they all going to study?  In many states – California, for example – the systems are already at breaking point.  Who funds the growth required to make this system successful?

A lot of people seem to think that the President really did mean “free tuition” (i.e. no displacement of Pell grants, which are income-based), based on a comment made last week by his spokesman.  But on the other hand, the spokesman also said the program had been costed at $60/billion over ten years, or $6 billion per year, or about $666 per community college student.  Given that average tuition is about $3,800, it’s hard to see how this plan makes sense unless the administration: a) doesn’t expect most states to participate; b) doesn’t think many students will qualify; and, c) doesn’t in fact mean free tuition, but rather just “cover the cost”.  Or maybe the administration threw together a bunch of nonsense numbers that don’t matter.  Regardless, the likelihood of this becoming policy anytime soon is pretty low; it’s value is mainly rhetorical and as a marker for future policy initiatives by future Presidents.

As I said a last year, free tuition in community colleges makes a fair bit of sense.  The main rationale for fees is that: a) there are substantial private benefits, and, b) the clientele is mainly better-off and don’t need all the subsidies.  But those don’t hold true in community colleges the way they do in universities.   So while there might be some better ways to use that amount of money, this is still a generally worthwhile and positive initiative.  Would that a Canadian government could be so bold.

December 10

The History of the Smorgasbord

One of the things that clouds mutual understanding of higher education systems across the Atlantic is the nature of the Arts curriculum.  And in particular, the degree to which they actually have them in Europe, and don’t over here.

When students enroll in a higher education program in Europe, they have a pretty good idea of the classes they’ll be taking for the next three years.  Electives are rare; when you enter a program, the required classes are in large part already laid out.  Departments simply don’t think very much in terms of individual courses – they think in terms of whole programs, and share the teaching duties required to get students through the necessary sequence of courses.

If you really want to confuse a European-trained prof just starting her/his career in Canada, ask: “what courses do you want to teach?”  This is bewildering to them, as they assume there is a set curriculum, and they’re there to teach part of it.  As often as not, they will answer: “shouldn’t you be telling me what courses to teach”?  But over here, the right to design your own courses, and have absolute sovereignty over what happens within those courses, is the very definition of academic freedom.

And it’s not just professors who have freedom.  Students do too, in that they can choose their courses to an extent absolutely unknown in Europe. Basically, we have a smorgasbord approach to Arts and Sciences (more the former than the latter) – take a bunch of courses that add up to X credits in this area, and we’ll hand you a degree.  This has huge advantages in that it makes programs flexible and infinitely customizable.  It has a disadvantage in that it’s costly and sacrifices an awful lot of – what most people would call – curricular consistency.

So why do we do this?  Because of Harvard.  Go back to the 1870s, when German universities were the envy of the world.  The top American schools were trying to figure out what was so great about them – and one of the things they found really useful was this idea called “academic freedom”.  But at Harvard, they thought they would go one better: they wouldn’t just give it to profs, they’d give it to students, too. This was the birth of the elective system.  And because Harvard did it, it had to be right, so eventually everyone else did it too.

There was a brief attempt at some of the big eastern colleges to try and put a more standard curriculum in place after World War II, so as to train their budding elites for the global leadership roles they were expected to assume.  It was meant to be a kind of Great Books/Western Civ curriculum, but profs basically circumvented these attempts by arguing for what amounted to a system of credit “baskets”.  Where the university wanted a single course on “drama and film in modern communication” (say), profs argued for giving students a choice between four or five courses on roughly that theme.  Thus, the institution could require students to take a drama/film credit, but the profs could continue to teach specialist courses on Norwegian Noir rather than suffer the indignity of having to teach a survey course (not that they made their case this way – “student choice” was the rallying call, natch).

Canadian universities absorbed almost none of this before WWII – until then, our universities were much closer to the European model.  But afterwards, with the need to get our students into American graduate schools, and so many American professors being hired thereafter (where else could we find so many qualified people to teach our burgeoning undergrad population?), Canadian universities gradually fell into line.  By the 1970s, our two systems had coalesced into their present form.

And that, friends, is how Arts faculties got their smorgasbords and, to a large extent, jettisoned a coherent curriculum.

November 21

Variation in Tuition in the United States

One of the things foreigners always get wrong about the American higher education system is tuition fees.  The external perception of tuition is driven by what’s happening at the famous private institutions, mainly in the country’s northeast.  But that’s not even close to being the whole story.

Figure 1: Tuition by Type of Institution, United States, 2014-15

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It is true that tuition at private non-profits is pretty high – $31,231, on average; though it goes much higher than that (one-sixth of these colleges charge over $45,000/year for tuition alone).  Of course, discounts are rife, and few actually pay the sticker price.  Net tuition and fees in this sector are actually only about $12,500.  And more to the point, only 2.7 million undergraduates (i.e. fewer than 20% of the total) attend schools in this sector.  In contrast, 6.6 million students attend public 4-year colleges, where the average sticker price is only $9,139 (avg. net tuition = $3,000), and 7.1 million attend public 2-year colleges (i.e. community colleges), where fees are just $3,347 (avg. net tuition = -$1,900).

But the differences aren’t simply by sector, they’re also geographic.  In-state tuition at 4-year publics varies widely from one state to another.  In Wyoming, tuition is $4,646; in Vermont, it’s $14,419.  There are some broad regional trends you can see in the data, but they aren’t quite as stark: in New England (i.e. Maine, New Hampshire, Vermont, Rhode Island, Connecticut, and Massachusetts), average tuition at public four-year institutions is $11,436; in the South and Southwest, it’s about $8,300.

This often makes people stop and think: why is it that tuition in the liberal, blue-state northeast is higher, while in the conservative red-state south and Midwest it’s cheaper?  Well, the answer is that politics in the US didn’t always break down the way it does today.  Back in the 1890s when the big Land-Grant universities were starting to grow, most of today’s low-tuition states were run by governments heavily influenced by the Populist movement.

Populists were suspicious of universities because they served such an elite section of the population.  They wanted them opened up to the children of farmers, and to make sure that they taught “practical arts” as much as the liberal ones.  These being the days before student aid really existed, the way populists gave effect to this was to order institutions to keep tuition low, a tradition that in most states remains true today.

In fact, one way to predict state tuition levels in the US today is simply to look at vote totals from the 1896 election.  That was the “Cross of Gold” election, which pitted the Democratic/Populist William Jennings Bryan against the Republican William McKinley.  Figure 2, below, plots today’s in-state tuition rates against Bryan’s share of the vote in that election.

Figure 2: Current-Day In-State Tuition Versus William Jennings Bryan’s Vote Share in 1896

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Rather amazingly, there is still a relationship between political patterns of 120 years ago and tuition policy today.  It’s not a perfect fit, of course – South Carolina, in particular, was a Bryan stronghold, and yet now has tuition of nearly $12,000 – but the pattern is clearly there.

America is large, and contains multitudes.  Generalizations about its higher education system need to be treated with much caution.

March 17

Oregon’s “Pay It Forward” Scheme and the ICR vs. Graduate Tax Problem

You may have heard some rumblings from south of the border over the past few months with respect to a program called Pay It Forward (PIF).  The brainchild of a student group called Students for Educational Debt Reform, this idea was picked up by the Oregon assembly last summer; within a few months, over a dozen state governments were examining similar draft legislation.

The basics of the program are these: instead of paying tuition, students agree to pay a percentage of their future income (the percentages vary by state – in Oregon it’s 0.75% per year of study) for 20 years after graduation.  Some people mistook this for a version of income-contingent loans because it emphasized paying for school after-the-fact rather than up-front, and also because repayments were to be made as a function of income.  But there’s one key difference.  Loans have a limited liability: once you pay off the principal and interest, you’re done.  With PIF, there is no principal – once you start paying into a hypothecated fund, destined for the state’s higher education institutions, you keep on paying for 20 years no matter what.  This is formally known as a “graduate tax”.

Graduate taxes tend to be more progressive than income-contingent loans.  If you’re at the bottom of the income scale, you probably come out better off – you simply never pay anything.  If you’re at the top of the income scale, you’re likely going to pay a lot more because a portion of your income will go into public coffers long after you’d likely have paid off a loan.  Interestingly, the famous Yale Tuition Postponement Option of the early 1970s (designed by Nobellist James Tobin, and used by Bill Clinton when he attended law school there) went off the rails for precisely this reason – the richer students got tired of paying for the poorer ones, and started making a fuss.

One downside to a graduate tax is that it’s harder to collect than a loan.  In the US, for instance, it’s hard to imagine enforcing something like PIF, unless it was instituted nationally (if someone moved from Portland to Chicago, would Illinois be responsible for collecting the PIF contribution?).  A graduate tax was in fact examined relatively thoroughly not once but twice in England (the 1997 Dearing Report and the 2005 fee reform), and was rejected precisely because of concerns about grads evading repayment through emigration.

Another downside is: where exactly does the money come from while you’re waiting for graduates to start earning money?  If tuition is covering 40% of institutional expenditure, someone has to make that income good over the 20 or so years before the grad tax makes up the difference.  It’s not clear who that might be; if the state had money to do this, it probably wouldn’t be faffing around with ideas like PIF.  You could securitize the revenue stream, of course, but that also might get tricky.  Income-contingent loans lack graduate taxes’ most potentially progressive features, but they do have the advantage of: a) being collectable, and b) producing income for institutions in the short term.

There is of course one country that is trying very hard to merge the ideas of ICR and graduate taxes, with some really odd results.  More on the English experiment tomorrow.

October 22

Faculty Salary Data You Should Probably Ignore

Recently, the Ontario Confederation of University Faculty Associations (OCUFA) published a comparison of American and Canadian academics’ salaries.  Using Canada’s National Household Survey (NHS) and the US Occupational Employment Statistics (OES) survey (which they described as being not quite apples-to-apples, but at least Macintosh-to-Granny Smith), they noted that average salaries for the combined college-and-university instructor population (the OES cannot disaggregate below that level) were $76,000.  In Canada, the figure was $65,000.  Hence, according to them, with the dollar at par, there is a 17% gap in academic pay in favour of the Americans… and much more of a gap if PPP is taken into account.

There are three reasons why this conclusion is deeply suspect.

First, OES and NHS are not even vaguely comparable.  One is a world-class instrument, based on administrative data collected at over 200,000 places of employment; the other: a self-report from a nonrandom sample of Canadians which has been widely panned as a steaming pile of horse manure.

Second, the actual numbers seem to be slightly off.  When I go to the OES, the category for 2- and 4-year post-secondary teachers (25-1000), I get $77,600.  The Canadian NHS files show that “university professors and lecturers” (category 4011) earn $87,978 and “college and other vocational instructors” (category 4021) earn $57,275.  Together, weighted, that’s an average of $70,033.  So, a 10% gap, not a 17% one.

Third, since the two countries don’t have identical proportions of instructors in the 2- and 4-year sectors, it’s hard to tell how well these numbers reflect differences among university professors.  Neither do we have any sense of the proportion of part-timers and sessionals in the count, on either side of the border.  In other words, this comparison is based on a hodgepodge of non-comparable data, and proves absolutely nothing with respect to relative salaries of professors on either side of the 49th parallel.

More direct comparisons are possible.  Oklahoma State University has been doing an annual survey of salaries at Public and Land-grant Universities – the grouping of US institutions that look most similar to Canadian universities – for 40 years.  The figure below compares the 2012-13 OSU data with that of Canadian profs from Statistics Canada’s last UCASS study (2010-11), as published by CAUT.

Canada vs US Professors’ Salaries

 

 

 

 

 

 

 

 

 

 

 

 

One can quibble with this graph, of course.  The Canadian numbers have probably gone up another 6-7% in the intervening two years.  The US numbers don’t include the income professors get from summer research grants, which would probably add another 10% or so to their averages (see here for that calculation).  But effectively, there’s about a 15% pay gap in Canada’s favour, if dollars are counted at par, not a 17% gap the other way.

Naturally, one could get into arguments about purchasing power parity, living standards, and the like – that’s all fair game.  What’s not fair game is using a set of bad statistics when better ones are available, just because the bad data happens to better serve your cause. You’d think an association representing academics, of all people, would know that.

September 19

Cultural Determinants of Data Acquisition Costs

I saw a fascinating piece in the New York Times awhile back.  It was about a trend at American universities, asking applicants if they were gay or not.  Apparently, these institutions believe that by asking students this question, they are sending a message that they are a gay-positive environment.

Interesting.

Americans think that transparency about identity is the path to utopia.  Enrolment statistics by race?  They’ve got them.  Indeed, they are required to keep such statistics, because of a clutch of laws designed to monitor whether or not Blacks (and, to a lesser extent, Latinos and America Indians) are being discriminated against.

In Canada, the rule of thumb is simple: on forms used for administrative purposes, you can’t compel anyone to reveal data about identity, beyond what is strictly necessary to achieve the purpose for which the information is being collected.  So, on applications to universities and colleges, asking people’s names and addresses is about as far as you can go (provinces have different standards on whether you can ask gender – some say you can’t).  Asking about ethnicity, or aboriginal status?  Totally verboten.  Whereas in the US it’s mandatory.

What that means is that, in Canada, acquiring any data about students – other than raw numbers – requires voluntary surveys.  And those can get expensive: done centrally through StatsCan (and its levels of quality standards) they cost millions; even if you just get a decent-sized consortium together to do something, it will run into hundreds of thousands once you count everyone’s labour costs.  You can get it down into the tens of thousands if you go with an electronic survey, but then there are response bias issues (you can correct for them, but it requires someone to have already done a decent survey to begin with – and with the loss of the census long form, it’s not clear that we have such a survey).

Of course, even Canada is at least somewhat ahead of, say, France.  There, the local conception of nationalism means that state agencies are forbidden from classifying citizens as anything other than citizens.  Blanc, beur, noir: they’re all French according to the government, and its socially unacceptable to classify them as anything else.  A morally attractive stance, perhaps, but what it means is that the French have real trouble measuring social inequality in ways that matter.

All of this is simply to say, if you’ve ever wondered why we don’t have statistics on ethnicity the way the Americans do, it’s this: they assume racial bias exists and keep stats to measure it.  We assume that racial bias exists, and so try to mask parts of individuals’ identities to prevent it.

August 30

So, This Obama Plan, Then (Part 2)

To recap yesterday’s blog: President Obama has a plan to make colleges reduce their costs, and deliver better value for money.  It involves having the government rate institutions on Accessibility, Affordability, and Outcomes; those which rate poorly risk losing eligibility for various forms of federal student aid (which, in total, is up around $150 billion/year these days).

While there’s no question that college costs do need to be reined in, this particular solution strikes me as odd.  Here’s what you have to believe in order to think that the President’s plan will work:

1)      That there exists a set of metrics, applicable to all institutions, which can measure Accessibility, Affordability, and Outcomes.  Forget data availability, institutions juking the stats, and whether one should judge institutions based on graduate salaries – can this stuff actually be measured in an equitable manner?  Will universities be judged on affordability without reference to the amount of state aid they receive?  Will those in rich states be penalized for the number of Pell-eligible students they enrol because there are fewer of them around than in, say, Alabama?  For employment rates or salaries, do tribal colleges or HCBUs get measured on the same scale as Princeton?  And if you’re looking at university-wide comparisons, rather than program-level ones, won’t mid-tier liberal arts colleges get completely blown out of the water?  There are probably work-arounds on most of these, but they aren’t simple.  Which leads to the next issue:

2)      Assuming the answer to 1) is yes, that the government is actually capable of finding and choosing the right measures.  I’m skeptical, let’s put it that way.

3)      That the Government, at the end of the day, is prepared to take students hostage to make this work.  Does anyone really believe that the government is going to reach the point where it says to a group of students: “we’re with you, your school isn’t delivering good value.  To show you our support, we’re going to cut off your student aid”?  The words “communications nightmare” don’t even begin to cover it.

This last one really speaks to a large problem with the Obama program.  The US federal government actually doesn’t have the tools to affect affordability because it doesn’t control the appropriations process.  At the end of the day, it’s a state issue, as it would be here in Canada.

So is this just an elaborate set-up to allow Obama to use the bully pulpit to jawbone institutions into line?  Or does the White House (and it is the White House – DOE appears to have had little to do with this) actually believe that there is a workable technocratic solution here? I’d like to think the former; I’m afraid it’s the latter.

August 29

So, This Obama Plan, Then (Part 1)

Canadians have few – if any – original ideas when it comes to education.  Generally speaking, we tend to reuse American ideas a few years after the’ve gone viral down south.  But what with all these interwebs and the Twitter these days, the lag time on this is getting shorter and shorter.  That’s why it’s definitely worth paying close attention to the recent Obama initiative on college costs: there are a lot of themes in that plan which have resonance here, and it’s likely that we’ll be hearing about them from both sides of the border soon enough.

Basically, Obama wants to keep the price of higher education down.  For years, Washington has tried to do this by increasing student aid, or providing tax credits, or what have you.  And they’ve actually been largely successful in doing so, at least for lower-income students, as the data from Matt Bruenig shows, here.  But this strategy is costing the US Government loadsadough, and it has started to dawn on them that Reagan-era Education Secretary, William Bennett, might have been right when he said that student aid just ends up raising tuition (as a side note, one of the most fascinating things in the US scene over the last two years has been the conversion of all the lefty education types into believers of the Bennett hypothesis).  So they’ve moved on to bigger fry.  They don’t just want to get prices down.  They want to get costs down.

This, as Joe Biden once almost said, is a big freaking deal.  No higher education system in the western world has ever succeeded in getting its costs down.  What with the cost disease and all, the only way costs go is up.  Unless of course you start reducing the price of labour.

So, how does he plan on getting costs down?  Well, he wants more experimentation with delivery methods.  MOOCs and Competency-based learning (CBL) are clearly big parts of that.  And he’s prepared to spend a quarter of a billion to fund this kind of experimentation in order to find out what works and what doesn’t (some governments still do believe in evidence-based policy, apparently).

That’s the easy bit.  The trickier stuff involves penalizing institutions that do not provide “value-for-money”.  The US Government plans to come up with a rating system for institutions, based on: Accessibility (the percentage of its students receiving Pell Grants), Affordability (some combination of tuition, scholarships, and financial aid), and Outcomes (graduation rates, advanced degrees, and the salaries earned by graduates).  Institutions that don’t score well on this rating will see federal funding reduced via a decrease in their students’ eligibility for student aid.

Sound crazy?  It kind of is.  More on this tomorrow.

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