Mr. Rick Jerue Vice President, Governmental Relations and Corporate Development Education Management Corporation
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Vice President, Government Relations and Corporate Development
Education Management Corporation
Kansas City, Missouri
March 7, 2003
Assistant Secretary Stroup, Deputy Assistant Secretaries Andrade and Bryant:
Thanks for giving me the opportunity to present my views at this hearing.
My name is Richard Jerue. I am Vice President for Government Relations and Corporate Development at Education Management Corporation. EDMC is a publicly traded company that is among the largest providers of post-secondary education in North America. We have 43 primary campus locations in 26 major cities, with a student population of more than 41,000 students. Our 29 Art Institutes offer masters, bachelors, associates and non-degree programs in the areas of design, media arts, fashion and culinary arts. Our 14 Argosy Education Group primary campuses provide graduate and undergraduate degree programs in various fields, including psychology, counseling, education, business, law, and health services. Our company has offered career oriented education for 40 years, and our education institutions have more than 150,000 alumni.
Prior to assuming my current job with EDMC this past September, I served as President of one of its campuses, the New England Institute of Art & Communications in Boston. And prior to my employment with EDMC, I served on the staff of both the House and Senate Education Committees of the U.S. Congress. So I've had first hand experience with the issues you have asked me to address today, both as a president of a postsecondary education institution and a Congressional staffer. And as we begin to prepare for the reauthorization of the Higher Education Act, these issues of quality and accountability which you have asked me to address today are the right ones to address and focus on.
You've asked me to discuss the twin issues of quality and accountability. To me, these two issues are inseparable and, in many ways, indistinguishable. Quality to me is what an institution claims that it will do and do well. And accountability is demonstrating that it has actually done what it says it intends to do. And it really doesn't matter what the mission or type of institution involved is. What really matters is what the institution has determined its mission to be, how it discloses that mission to its various constituencies, whether they be students, parents, policymakers, accreditors, investors, or other financial supporters, and then how it shows those constituencies that it is actually doing what it says it intends to do. Essential to this is providing the necessary resources, both human and fiscal, to the task at hand. Without applying these resources, an institution won't be able to demonstrate that it is doing an effective job.
And all of this goes to the heart of federal policy making. We are blessed with a governmental support system for higher education that allows parents and students to have significant choice in selecting the type of postsecondary education that is best suited for them. An important foundation of this support system is the federal student financial assistance programs. Those programs make higher education accessible and affordable to every student with the desire and ability to pursue a postsecondary degree, diploma or certificate. Yet if we are going to maintain taxpayer support for federal higher education programs, I believe we must provide taxpayers with the confidence that their tax dollars are being well spent. Quality and accountability are the ways to assure that.
There are already in place a number of ways to address these twin issues. As a college president, my institution addressed them regularly through an on-going process of institutional effectiveness and peer review. My school had an institutional effectiveness committee, which regularly reviewed what we were doing, what we said we wanted to do, and detailed where we were in accomplishing what we said we wanted to do. We did this in my 3 years as a college president through an institutional self-study process in preparation for regional accreditation and through comprehensive internal reviews to support expansion to a baccalaureate level institution from an associate level institution. These self studies enabled us to look at ourselves carefully and critically, to define our strengths and our weaknesses, and to establish a plan of action to address those areas where we needed improvement. I think most schools follow a similar process. It's something our accrediting bodies encourage and require. And it is extremely helpful in making sure that we continue to improve what we're doing, and that we actually do what we say we'll do.
Yet even though self-study and institutional effectiveness are pursued at most institutions, they in themselves are not enough. They certainly help in making sure that each institution is doing all that it can to be the best that it can, but unless there is some mechanism to evaluate all of this and report this information to the various concerned and interested constituencies, that information like so many other reports and publications will stay on a library shelf, oftentimes unused. Requiring each institution to report those elements that constitute institutional quality and effectiveness to all concerned and affected constituencies is a proper and important aspect of federal policy. It is a role that is sensitive to institutional autonomy and academic freedom, but yet requires institution to share vital consumer information with all interested constituencies. It's a simple proposition: every institution should be able and willing to be measured by what it claims to the public are its strengths and selling points. And the federal government should make sure this happens if an institution desires to participate in federal student assistance programs. We already do this somewhat through Student Right to Know reporting. But I think we can provide better and more useful information, and in so doing we may conclude that we can fulfill the purposes of the Student Right to Know Act more effectively through a new mechanism.
In my opinion, schools should be held accountable for doing what they say they'll do. For example, our Art Institutes are career-oriented institutions. Their fundamental mission is to prepare students for jobs related to their particular field of study. The Art Institutes should be able to demonstrate to students and parents that they do that. In our case, we publish placement rate and starting salary information on a regular basis. We report this information to accrediting bodies and investors, to students and parents. In our opinion providing that information defines our strength as an institution, and gives the public the necessary information to judge our effectiveness. I think that's appropriate. And I think it can be expanded to other types of institutions as well. If an institution claims that it prepares students for graduate school, law school, to be teachers --- they should be able to demonstrate a track record in doing just that. That track record, that fundamental information, should be available in an easily understandable format to students, parents, and policy makers. I don't think collecting that kind of information presents an unreasonable burden on postsecondary education institutions. In fact, it's the right thing to do, for it would give students and parents the information they need to determine whether a particular institution is right for them. And it would give policy makers solid information about an institution's goals and objectives and performance toward meeting those goals. And it could also serve as an early warning system that would enable policy makers to work with institutions to address issues before they become real problems.
For the past several months I've been involved in a task force established by the Career College Association to address this very issue. CCA asked members reflective of the entire CCA membership - non-degree granting schools, for-profit schools that offer degrees at the associates, bachelors, masters and doctoral level, schools that have short-term programs and schools that are on a more traditional academic calendar - to serve on this task force and come up with recommendations that would address the issues of quality and accountability. The result of this task force is a proposal to create an "Institutional Report Card". I would hope that the Department and other policy-makers would give this proposal careful consideration.
The proposed report card is based on 3 sets of accountability standards, input measures, output measures and outcome measures. It is based on the strong belief that these standards should be universal, not sector-specific. Their goal should be enhanced consumer information, since postsecondary education students and their families have significant power as consumers, because of our system of federal student assistance, to choose the institution they will attend. These standards are not meant to be inflexible eligibility criteria. Rather, they should be institutionally developed measurements, contained as part of an institution's program participation agreement, that set out what the institution intends to do and how it will measure that. And these measures should be part of a set of measurements, since no single measure will give as good a picture of institutional effectiveness as a set of measures will, and no single measure will be able to capture the uniqueness of any one institution. Let me comment a bit on the three measures proposed in the CCA report.
The first of these are input measures, such as mission statements, student body demographics, type of accreditation, faculty qualifications, faculty/student ratios - in short, factors that assess the resources and capacity to deliver educational services. These input measures are important, but they are not enough to provide the complete picture we are seeking.
The second factor in the CCA proposal is output measures. These measures, such as graduation rates, retention rates, transfer rates, attempt to assess what happens to the student while he or she is in school. How long were they there? Did the student graduate? Did he or she transfer to another institution? Again, important information, but not a complete picture.
The final factor is outcomes measures. What value-added did the student receive from the education they just paid for? Factors such as placement rates, average starting salaries, licensure information, post-undergraduate admissions rates, passage rates for competency tests or certification exams, student/alumni satisfaction surveys, employer satisfaction surveys - all examples of factors that might be included in this standard- in short, institutionally determined factors that provide student, parents and policy makers with information as to the value students received from the particular education experience. These outcome measures will necessarily be different depending on the mission of the particular institution involved. Some factors would apply to some institutions and not to others. But we should be able to arrive at outcome measures for every institution, and then make sure that the specifics as they relate to a particular institution are readily available to all interested parties.
These 3 standards - input measures, output measures, and outcome measures - would give students, parents, policymakers, and any other interested party tangible information about a particular school, its mission, goals and objectives, what it purports to do, and its success in doing that. To me, it's the type of consumer-oriented information that federal policy should encourage and support. If we want students and parents to make informed postsecondary education choices, and if we want the general public and policy makers to have confidence in federal student assistance programs, this is the type of information that should be readily available. It is not difficult to gather, but it certainly demonstrates what institutions say they intend to do, what resources they apply to that task, and what the results are. In my mind, it is the essence of quality and accountability. I have submitted a copy of the Career College Association Task Force Report for your review and consideration.
One additional point to make about the CCA recommendations. It is fundamental that these measures be applied universally, not selectively by sector or institutional governance type. These measures provide sufficient flexibility so that all institutions should be able to collect and disseminate input, output and outcomes information in a way that is appropriate to them. The CCA proposal does not proscribe what should be collected and disseminated or how it should be collected and disseminated. However, what it does do is provide examples of sets of measurements that institutions can choose from that are most appropriate to their mission and which best measure their progress toward achieving their mission. I think it's a reasonable and sensible approach to the very real issues of quality and accountability in postsecondary education, yet it is an approach that remains sensitive to institutional autonomy. It's an approach that I hope you will carefully consider. For in so doing, you will, in my opinion, enhance consumer choice and increase confidence in postsecondary education and the programs that support it.
I hope my comments today will be helpful as you begin to develop the Department's proposals for the reauthorization of the Higher Education Act. It is important work that you are about, and I offer my support and assistance in helping you in the work you have ahead.