Like a beautiful but inattentive date, the Obama Administration’s recent proposals to improve college affordability and completion mean well, but in a moment of passion end up calling you by the wrong name. Suffice it to say, the date does not lead to the desired result.

Alongside a major expansion of the Perkins Loan program, the Administration is proposing that universities provide “scorecards” for use in comparing institutions to one another as well as “shopping sheets” that would be provided to prospective students. If you’ve bought a new car recently, you’re familiar with the concept: the mileage stickers now required by the EPA. As the mileage stickers have proven relatively popular, and as the Occupy movement caused college affordability to leap to the top of the higher education agenda last fall, it’s a good idea to slap a sticker on every college, right?

With the EPA new car stickers, mileage is well understood and measurable. In fact, the only reported definitional controversy around the stickers concerned all-electric cars like the Chevy Volt. How to calculate miles per gallon for an all-electric vehicle?

In contrast, here is the data that college scorecards and shopping sheets would provide:

1. List tuition relative to other institutions
2. Net price, after grants and scholarships relative to other institutions
3. Retention rate relative to other institutions
4. Graduation rate relative to other institutions
5. Average student debt relative to other institutions
6. Loan repayment rates relative to other institutions
7. Employment potential relative to other institutions

Although they do come in various models and years, colleges are not cars. So the Administration ought to recognize that of the above list, perhaps the only data that are clear and measurable are list tuition and net price – and only on an absolute basis. Rating an institution’s performance relative to other institutions requires definition of the relevant comps. And there is no consensus on this question or even on a methodology for answering this question.

More important, the same can be said for the other five proposed metrics. The Department of Education’s data system (Integrated Postsecondary Education Data System, or IPEDS) is based on aggregated data reported by institutions for traditional full-time students only. IPEDS graduation rate data do not include the part-time or transfer students who constitute a majority of all students enrolled in higher education.

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As we have argued previously in this letter, the key to unleashing improved performance in higher education in the form of improved affordability and student outcomes is to define the relevant data and deploy effective reporting and verification systems. Once we do that, performance is measurable and accountability for performance becomes possible. Unfortunately, the Obama Administration ignores this fundamental question or assumes the answer. Whichever it is, the proposed scorecards will be discarded or disregarded.

It’s likely that one reason for this is the K-12-centricity of the Department of Education’s leadership. Here’s what Secretary Duncan said as he proposed the scorecards:

“Colleges aren't too dissimilar to high schools. Some have done a great job building cultures around completion and attainment and some haven't,” Duncan said.

He went on to say that his focus is on tracking graduation rates because, when he served as CEO of the Chicago Public Schools, he noticed that some universities were graduating his students at rates of 75% or more, while others were graduating them at a small fraction of that.

As noted, colleges are quite dissimilar from high schools, which employ a full-time model for a less heterogeneous demographic (in terms of age, stage of life). We can only conclude that Secretary Duncan has a very traditional view of higher education, namely that our nation’s colleges consist of newly minted high school graduates who barrel through their chosen institution as quickly as they can. This is no longer the reality and may emit a whiff of snobbery, which could explain recent attacks from Republican Presidential candidate Rick Santorum (i.e., asserting that the President is a snob for wanting all kids to go to college). Hyperbole aside, as Stan Jones, President of Complete College America, says: “We shouldn’t make policy based on the image of students going straight from high school to college, living on campus, and graduating four years later, when the majority of college students don’t do that.”

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There are two observations worth noting here. First, one would think the Administration would be aware of the critical data and definitional challenges facing higher education following the imbroglio over gainful employment, including multiple releases of data that proved to be inaccurate. (Wise observers have noted that that gainful employment’s fundamental misstep was putting the regulatory cart before the data horse. Reportedly, a scheduled release of draft CDRs to for-profits last week was delayed due to concerns about data accuracy.) And second, a much more productive approach was ready-at-hand: the Administration’s greatest success story in education, K-12’s “Race to the Top.”

Not only was it ready-at-hand, Race to the Top actually made it into the affordability proposals. Specifically, the Administration wants to create of a $1 billion grant competition for states that keep college costs down, as well as a $55 million competitive grant for individual institutions.

The point of Race to the Top was to encourage states to adopt best practices that data had shown were likely to improve school performance. The Department of Education defined best practices and states were evaluated and rewarded based on how closely their newly adopted rules hewed to them. In higher education what’s missing are the best practices. And to figure out best practices, we first need the data. So rather than a mechanistic application of the Race to the top Concept, what’s required is a creative application: create a Race to the Top competition for states to properly define the relevant data and deploy an effective reporting and verification system. This is a very complicated problem and allowing 50 flowers to bloom (or even 10) would be extremely valuable in helping us arrive at the right metrics and systems.

Some lawmakers have arrived at this result. On February 9, Senator Ron Wyden, D. OR, introduced a bill called the “Student Right to Know Before You Go Act.” (California Republican Duncan Hunter introduced its companion bill in the House.) The proposed bill focuses on the key issue: defining the right data and establishing the right mechanisms for collecting and policing data quality. One provision of the bill provides support for states to create new data systems for their postsecondary institutions, including all the data that the Obama Administration assumes are already clear and available.

Race to the Top is a perfect funding model for this effort, in part because in 2006 Congress barred the federal government from creating and managing a reporting system with student-level data. So the breakthrough will have to come at the state level. Already, without federal prompting, a number of states have taken some action for state-funded institutions only. Tennessee is furthest ahead, having designed an outcomes-based funding formula consisting of 13 measures, including persistence of transfer students and part-time students, remedial success (full- and part-time students who were enrolled in any remedial or developmental course who then successfully completed college-level courses within 3 years of their initial enrollment), and ensuring that data for subpopulations of adult learners and low-income students are available for every metric. The Illinois Board of Higher Education has formed a working group from state government, higher education and business to design metrics to be used to evaluate university performance. Mississippi, Texas, Colorado and Arkansas are following a similar path, all with a view to phasing in state funding based on outcomes. With federal support, these emerging data systems could encompass all institutions in the respective states.

We’re hopeful the Administration will listen to Senator Wyden’s ideas and implement them by making Race to the Top even more central to its affordability initiatives. It’s certainly not too late to do so. After all, if the first date doesn’t go exactly as planned, it’s time to get better data.

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