What Public Commenters Said About a Low-Financial-Value College Programs List

What Public Commenters Said About a Low-Financial-Value College Programs List

What Public Commenters Said About a Low Financial Value College Programs List

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In early January, the US Department of Education (Department) phoned a friend: How, the agency asked in an official request for information (RFI), might it go about identifying and increasing public transparency around low-financial-value postsecondary programs?

Measuring higher education’s value is an increasingly urgent but often loaded question. The Department addressed this tension upfront, clarifying that it was seeking input specifically on economic value—programs “for which total costs exceed the financial benefits provided to students”—while acknowledging that “some higher education programs promote goals other than financial returns for students.”

The concept of a “watch list” of the lowest-value college programs was first floated by the Biden-Harris Administration as part of its debt cancellation announcement last summer, and the RFI reflects a next step in bringing that proposal to fruition. Nearly 130 commenters responded to the Department’s call for feedback, representing a diverse set of organizations and associations, colleges and universities, members of Congress, researchers, and individuals with viewpoints on how such a list could be constructed, what metrics should be included, and how it can most effectively be presented to the public.

The good news? There’s a surprising amount of agreement across the submitted comments as to what measures of value matter most and how the Department could approach this effort. The better news? We read all 128 comments so that you don’t have to. Below, we unpack four top takeaways:


  1. Transparency is the ticket.
  2. Gainful employment metrics are gaining steam.
  3. Meet students where they are.
  4. Don’t stop at disclosures.

1. Transparency Is the Ticket

If there is a single red thread that emerges from this set of public comments, it’s that greater transparency is an end goal shared by all constituencies. Those in favor of creating a low-financial-value programs list emphasized the need for more data, better disaggregated data, and data that allow for apples-to-apples comparisons for users. Commenters also broadly agreed that when it comes to equipping students with the right information to make decisions about where to attend college, getting as granular as possible at the program-level (while safeguarding student privacy) makes data more actionable. And even commenters opposed to the very concept of the list—notably institutional associations, which typically want to prevent provisions that stand to impact any of their member schools negatively—devoted space to acknowledging the value of greater transparency for the higher education community writ large. In a joint comment led by the American Council on Education, two dozen organizations noted that:

“Comprehensive and reliable data on the outcomes of students in postsecondary programs would have tremendous value to students, policymakers, and the public. For students, such information could inform choices not just of a particular field to enter, but also the relative merits of specific programs. For institutions, these data may help determine where resources could and should be allocated among their academic offerings. And for policymakers, an ability to meaningfully compare outcomes would help them identify areas of concern that require greater scrutiny.” –American Council on Education

The Council of Graduate Schools likewise wrote that despite their concerns about the proposed list, it is critical that “Before prospective graduate students start a degree program, they should have access to important information on the cost of the degree program, time to degree completion, degree completion rates, potential career pathways, and career outcomes.” The American Association of Community Colleges (AACC) and Association of Community College Trustees (ACCT) in turn oppose the list idea but “enthusiastically endorse efforts to provide more complete information to consumers of higher education than what is currently available, and to place that information in a relevant and easily understandable context.”

Current and former students who submitted public comments resoundingly supported the creation of a list identifying low-financial-value programs, and many emphasized that such a tool would have impacted their own college choices for the better:

“This is something we NEED. If this was available when I first went to college, I would not have attended the college I did.” –Alicia Rohm

“The department of education should be protecting people from schools that are savvy in their sales and presentation, but [sic] an inadequate focus on actual education.” –Ellen Ross

“The average person has no reason to question the validity of an educational program because nothing has been done to alert them of the possibility that they could be scammed by these so called institutions. If the public was properly informed there would be far fewer predatory schools out there because people would know what questions to ask and how to spot the ‘Red flags’ before becoming a victim.” –Anonymous 

“My school was sued for fraud during my time of enrollment and they lied about placement statistics. This information was out there but it wasn’t readily available to me. Had I known about its actual reputation and statistics, I would have had the opportunity to go to a reputable institution where my degree would hold value in the market and where I wouldn’t have been left in insurmountable debt for a fraudulent education. … Please make it easier for students to receive accurate information and red flag these institutions so that students can make informed decisions regarding their education and finances.” –Ami Schneider

“I support red flagging low value educational programs because low performing, high cost schools operate without ANY warning to the students about the reality that the education received is not likely to provide enough benefit to justify the outrageous personal and financial cost.” –Jessica Wilkeson 

As to be expected, there’s plenty of constructive disagreement among stakeholders about how to get from A to B, but submitted comments leave no doubt that improving data quality and strengthening transparency are goalposts the higher education community wants to work toward. To that end, AACC and ACCT also specifically called out the data challenges posed by the lack of a national student unit record system—an issue that would be fixed by the bipartisan College Transparency Act, with calls for the bill’s passage echoed in comments from the Association of Public and Land-grant Universities and the Center for Higher Education Policy and Practice at Southern New Hampshire University.

2. Gainful Employment Metrics Are Gaining Steam

Several comments recommended that the Department align the metrics it uses to identify low-financial-value programs with those it will be proposing for the gainful employment (GE) regulation this spring. The forthcoming GE rule, which applies to career education programs, will use a debt-to-earnings rate and an earnings threshold to assess compliance and demonstrate program value. Roughly one-third of all comments—over 40 unique submissions—recommended that the Department use the same metrics it establishes for GE to create this list or that it include either a debt-to-earnings rate or a measure of post-program earnings in its low-financial-value calculations.

These comments spanned two primary rationales—the merits of the metrics and the benefits of consistency across federal disclosures. Many underscored the useful and clear insights that debt-to-earnings rates and earnings thresholds offer to students and institutions:

“The ultimate test of whether a program has value is whether completers obtain employment and how much they earn. Potential students want jobs and earnings that will allow them to pay back their student loans. Gainful employment, if appropriately implemented, will provide students with the information they need to assess potential outcomes and, in turn, an ability to parse between low- and high-value postsecondary programs. For this reason, ED should align the program-level data and metrics expectations it establishes based on what is collected for this RFI on low-value programs with those it identifies for gainful employment.” –Higher Learning Advocates

“If the Department proceeds with a watchlist or other information disclosure beyond the proposed gainful employment regulations, I suggest that the metrics used be consistent with it. In particular, I strongly support the use of debt-to-earnings rates and an earnings threshold, as the Department proposed in the 2022 negotiated rulemaking. ... Debt-to-earnings rates have served as the basis of GE for a decade. … An earnings threshold is an intuitive, equitable, and theoretically-justified approach to assessing value in higher education. It offers a straightforward measure of value for students and taxpayers. At the same time, it generates positive incentives for institutions and is difficult for institutions to game.” -Stephanie Cellini, professor of public policy and economics, George Washington University

“D/E was effective in identifying overpriced, ineffective programs that left students worse off than when they started and improved value for students. Motivated by the GE rule, colleges worked to improve the value they offered students – cutting tuition prices, increasing access to scholarships, and even introducing free trial periods. This history demonstrates the effectiveness of instituting such a ratio and the effectiveness of a D/E measure as a tool to hold low-quality programs accountable for the outcomes of their students. In this context, the D/E metric could work as an additional disclosure that provides vital information to students as they decide where to enroll. ... Since D/E is an existing measure used to assess low quality programs in the career education space, adopting this metric would be feasible for the Department to implement for identifying low-value programs.” –The Center for American Progress

“Although the sanctions of GE statutorily only apply to certain programs, they are a useful measure for determining low-value programs overall and thus should be used to determine the list of low-financial-value programs. … An earnings threshold is needed because not all students borrow for their programs, but they still may use federal financial aid, not to mention their own time and money, to complete programs.” –New America Higher Education Program

Others point out that maintaining consistency with the GE rule will promote alignment across postsecondary policies, lessen reporting burdens on institutions, and make information easier to interpret for students:

“We strongly urge the Department to adopt the same methodology for any low-financial-value postsecondary programs list as the methodology that will be used to assess eligibility for gainful employment programs. Having two different sets of standards to assess economic value for the same program is illogical and would create unnecessary confusion for students, institutions, and taxpayers. –Career Education Colleges and Universities

“ED should primarily rely on the GE debt-to-earnings metric in this initiative to avoid an unnecessary institutional reporting burden and possible contradictions between two different measures of a program’s financial value.” –AACC and ACCT

“All metrics to be used in the gainful employment (GE) NPRM should be a disclosure for this effort.”  –ECPI University

“The more complex and unfamiliar the measure, the more time college counselors – who are in increasingly short supply – will have to spend explaining the concept and the less likely the data is to influence student decisions.” –National College Attainment Network

On balance, commenters coalesced around a recognition that measures of debt and post-program earnings represent economic outcomes that matter a great deal to higher education’s beneficiaries. “Financial value will, and should, continue to be a prominent concern for students, families, and taxpayers,” summed up Representative Frederica Wilson.

3. Meet Students Where They Are

The Department also asked for input on how best to structure a list of low-financial-value programs and how to make students aware of it. Commenters pointed out that while students are the primary intended consumers of this list, there will be other audiences for these data, including institutions, researchers, college counselors, regulatory and oversight agencies, and the Department itself. To meet the needs of such varied constituencies, many comments indicated that the Department should release a literal list of programs identified as low-financial-value but should also be intentional about meeting students where they are and embedding this information on commonly used college search and comparison platforms. Commenters were in general agreement that the “list” should in fact be multiple lists broken down by key differentiators—credential level being the most popular, mentioned in over 25 unique comments—and that the data file should be downloadable, searchable, and easily accessible on the Department and Federal Student Aid websites.

But commenters overwhelmingly agreed that a published spreadsheet alone won’t be effective in reaching students or helping them weigh college options. They stressed the need for the Department to take further steps to ensure that information on low-financial-value programs is presented in clear, user-friendly formats and housed within tools that students will realistically see and use in their college search:

“Since such a list would aim to reduce exposure to the potential negative consequences of low-value programs, the information should be structured and presented in formats that are accessible, digestible, and comparable.” –Representative Bobby Scott, House Education and Workforce Committee Ranking Member

“By providing these data where prospective students are most likely to see them, policymakers can ensure that this information has the best chance of informing students' choices." –Urban Institute researchers Sandy Baum, Matthew Chingos, Jason Cohn, Bryan Cook, and Jason Delisle

“If ED proceeds with this list or some iteration of it, the timing of information delivered is as important as its quality and format. Simply publishing a list is unlikely to catch students at the time they are ready to absorb this information. Cross-posting the information in places students are likely to visit in their postsecondary education search is the best way to ensure students get this information when it is likely to be of the most use to them.” –National Association of Student Financial Aid Administrators

The College Scorecard—the Department’s primary user-facing college comparison tool—was the most popular dissemination option, recommended by about 20 distinct commenters. Those who suggested this option highlighted that adding low-financial-value program flags to the College Scorecard would increase its usefulness for students and capitalize on a well-known and regularly updated data source. The American Association of Cosmetology Schools expressed that: "The College Scorecard is the ideal location to consolidate data about all institutions and all programs to allow for rational comparisons. College Scorecard already includes graduation rates, median earnings, median debt, repayment rates and average tuition. This information could be expanded and supplemented at the program level to allow more visibility for prospective students into key metrics at the program level for all programs.” Other dissemination options referenced by multiple commenters included the Free Application for Federal Student Aid (FAFSA), College Navigator, Federal Student Aid (FSA) Data Center, and GI Bill Comparison Tool through the Department of Veterans Affairs.

Commenters also offered recommendations for strengthening the pathways from high school to college by connecting with high school counselors, scholarship providers, virtual advising programs, and other community-based organizations to ensure that professionals and volunteers who support students in the college search and application process are equipped to educate students about the new data:

“Publishing and disseminating the list of low-financial-value institutions is a necessary but insufficient step in helping students make data-informed decisions about their postsecondary education. We recommend the Department leverage organizations that build and maintain trusting relationships with students to disseminate the list and integrate it into students’ decision-making processes.” –National College Attainment Network

“The Department might consider establishing a webinar series for school counselors and other secondary school professionals who advise students on post-secondary plans on the construction of the list and how they should incorporate the list into their advising.” –Katharine Meyer, Fellow, The Brookings Institution

“Along with the development of a specialized site, the Department should craft a strategic dissemination plan that targets K-12 schools, high school advisors, college access counselors, libraries, community centers, and colleges and universities—all places that students and families regularly come into contact with and where they can receive this information.” –New America Higher Education Program

Some commenters recommended mechanisms to directly notify or require attestation from students and other educational quality stakeholders like accreditors about programs designated as low financial value. Many also mentioned the need for robust consumer testing to ensure the ultimate usability of the tools used by the Department to disseminate the data:

“Students should receive notification that their program has appeared on a low-financial-value list at the same time that they receive their financial aid offer letter. If a student receives an offer from an institution but has not enrolled in a particular program, he or she should receive notification of all programs at that institution which appear on a low-financial-value list.” –Preston Cooper, Senior Fellow, The Foundation for Research on Equal Opportunity

“We further encourage USED to consider other means currently at the disposal of your Department to directly communicate the potential risks of enrolling in a low-financial-value program. Importantly, students should be required to proactively affirm that they have seen and understand these risks prior to enrollment in a particular program.” –National Association of Workforce Boards

“We suggest that the Department send direct communications to accrediting agencies and state authorizers, informing them of any covered institutions on the low financial value list. Each of these agencies should be required to acknowledge that they have seen the list and have follow-up steps once a program under their purview is deemed low value.” –The Center for American Progress

“In addition to these dissemination strategies, the Department should consider a requirement for the programs on the low-financial-value list(s) to have enrolling students attest to their awareness of the listing. Student attestations, however, should not preclude eligibility for borrower defense, closed school discharge, or other relief programs provided by law. Consistent with previous research-based recommendations, we encourage the Department to pilot and market test dissemination strategies with students from a diverse set of regions, demographic backgrounds, and policy contexts, as well as traditional-age and older prospective students.” –Joint comment of The Lawyers’ Committee for Civil Rights Under Law, The Institute for College Access & Success, and UnidosUS, joined by Hispanic Federation and National Consumer Law Center (on behalf of its low-income clients)

4. Don’t Stop at Disclosures

Many commenters applauded the Department’s proposal to establish greater public transparency through a low-financial-value programs list—while also accentuating that the effort amounts to only a first step in ensuring students receive high-value postsecondary experiences. Dozens of comments echo this “yes, and” refrain, urging the agency to yes, start here and improve transparency through disclosures about programs delivering the lowest financial returns, and don’t stop at disclosures, but go much further to strengthen institutional accountability and fulfill its intended role as a gatekeeper of taxpayer dollars.

Several commenters mentioned the forthcoming GE rule as an urgent priority to create accountability mechanisms for low-performing career education programs. Some, including Third Way, elaborated on the Department’s consideration of requiring improvement plans from schools with programs deemed as having low financial value:

“All programs have ways to improve the value they offer students, whether by increasing graduation rates, lowering prices, elevating program quality, or building stronger career pathways. Given these varied areas of improvement, any list should be part of a systemwide strategy to improve student outcomes and deliver more equitable value. For example, it should supplement ED’s concurrent efforts to strengthen higher education accountability, including issuing a strong gainful employment regulation that ensures federally funded career education programs prepare students for gainful employment in a recognized occupation. … The low-financial-value list should also be used to drive programmatic improvement, such as requiring institutions to submit plans to improve the value of programs that have the most concerning outcomes.” –The Institute for Higher Education Policy

“We also hope to see the Department follow through on its stated intent to require institutions that have many failing programs implicated on the low-financial-value program list to submit improvement plans that demonstrate how they intend to improve their value proposition to students. This should be a structured opportunity for institutions to reflect on their program offerings and affiliated tuition rates and assess their alignment with local labor market needs and students’ typical post-college earnings, as well as the supports they provide to assist students with completing their programs, finding suitable career prospects, and successfully entering repayment.” –Third Way

“The creation of the Department’s list is an admirable first step in enforcing greater accountability for low-value academic programs and institutions in American higher education. Simply naming these programs will not suffice, however, and so the Department of Education must be given the necessary tools to protect students and taxpayers. BPC will continue to call on lawmakers to take bipartisan legislative action to develop and strengthen systems where institutions face consequences for poor student outcomes, up to and including the loss of eligibility for federal student aid. Such reforms would direct both students and public funds toward programs that pay off.” –Bipartisan Policy Center.

Others emphasized needed reforms to the accreditation system, coordination with student loan policies, and ways to strengthen Program Participation Agreements (PPAs). Across submissions, commenters stressed that this list should be viewed in tandem with other key regulatory and legislative priorities:

“We urge the Department to exercise its existing statutory authority regarding Secretarial recognition of accrediting agencies to create real incentives and meaningful consequences for institutions that market programs generating unrepayable debt and low financial returns. Under existing statutory authority, the Department should mandate an accreditation review of such institutions. In addition, we urge regulatory changes to the recognition process to require accreditors to determine, as part of this review of low-financial-value programs, whether institutions marketing these programs are spending an adequate share of programmatic tuition revenues on instruction and support services for enrolled students.” –Veterans Education Success

“It is long past due for ED to adopt a proactive and preventative approach to the proliferation of low-value programs. … Disclosure is not enough; to protect students, ED will need to robustly fulfill its roles as a gatekeeper of Title IV funds and as a law enforcement agency. … In particular, experts on the Title IV system have pointed out that ED already has the power to set thresholds for institutional and programmatic quality measures such as completion rates and loan repayment rates through these [PPA] contracts, which serve as schools’ access point for federal aid dollars. Installing these provisions in schools’ PPAs would serve as a substantive failsafe for accountability in ways that a simple name-and-shame list—however important—could never hope to accomplish.” –The Student Borrower Protection Center

“While we share the Department’s commitment to providing high-quality and critical information with students and families to help inform their decision-making about higher education, we urge the Department not to stop there. Disclosures cannot and must not replace or supplant other quality assurance policies and oversight responsibilities over bad actors in higher education. The Department’s efforts to (1) regulate the closing of the 90/10 loophole; (2) reestablish and strengthen the Office of Federal Student Aid’s Enforcement Office; (3) process backlogged borrower defense claims; (4) issue and recoup liabilities from the institutions that engaged in misrepresentations; (5) enforce program integrity rules; and (6) exercise its full oversight responsibility over accreditation matters all must remain a top priority for the Administration. To further ensure institutions are held accountable, we support the reinstatement and strengthening of the forthcoming proposed gainful employment rule to ensure career education programs at for-profit and non-degree institutions lead to a job in a graduate’s field and allow a graduate to repay their student loan debt. We urge the Department to take immediate action to publish and implement the rule as soon as practicable to ensure harmful actors are held accountable for enrolling students into low-quality programs.” –Senators Dick Durbin, Bernie Sanders, Chris Murphy, Tina Smith, Elizabeth Warren, Richard Blumenthal, Chris Van Hollen, and Ron Wyden


Within a set of over a hundred public comments, there’s bound to be plenty of disagreement—but we also see significant overlap in priorities among stakeholders considering the Department of Education’s plans to identify and publicize low-financial-value programs. Considered together, public comments reflect a clear shared interest in better, more disaggregated data collection and greater transparency to inform student decision-making and institutional improvement. The underlying principles in the GE metrics, which consider students’ debt burden and earnings, resonate with many as vital measures of a program’s economic value. To make this effort successful, commenters broadly agree that the information needs to reach students where they are and equip their support structures with the necessary education to help guide them through what the data can mean for their postsecondary futures. And most importantly, commenters don’t want the Department of Education or the Biden Administration to stop here—they seek real accountability and continued focus on ensuring that federal student aid dollars provide access only to high-quality programs that leave students better off.

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