Episode 8, Part 2: Academic Admissions Standards – What Is Ability-to-Benefit and Is It a Good Policy?

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In this episode, the Faculty of the Mace explains the meaning of ability-to-benefit, examines how it affects both recruitment and retention, and makes free-market, policy recommendations.

TRANSCRIPT:

[Music, Voiceover] You're watching the Faculty of the Mace Show, where faculty authority is promoted and protected in the academy of the twenty-first century.

[Eugene Murray, Lead Moderator, FOTM] If ATB is, in fact, so flawed, then how do we explain its existence? Its existence can be explained by our old friend, the "magic" headcount formula which we discussed in Faculty of The Mace Episode 5. To review, let's put that formula up on the screen, again. As you can see, the "magic" headcount formula states that the ending headcount, at the end of a period, n, is equal to the beginning headcount, at the beginning of that same period, plus adds, minus the sum of losses plus grads. Also, remember our simplifying assumptions: adds is equal to starts plus reentries, and losses is equal to non-returns plus drops.

ATB is simply a mechanism for a school to boost its starts in short run, creating the appearance of growth. However, in the long run, this creates a tremendous pressure that increases the number of drops. In turn, this can result in pressure on courseware developers to decrease the rigorousness of the curriculum and on faculty, by the use of faculty incentive compensation -- which we will discuss in Episode 9 -- and by other means, to pass students inappropriately. Because of these problems, the Faculty of The Mace makes the following free-market and regulatory recommendations:

If you are a regulator --

• State licensing boards, as well as programmatic accreditors, should require a valid high school diploma without substitution.
• State education regulators should consider restricting ATB at the state level.

If you are a student --

• If you have a high school diploma or GED, you should consider an institution that offers ATB to others only as a last choice. Your educational experience will be seriously compromised by the other unprepared students that you will encounter.
• If you do not have a valid high school diploma, consider completing your high school studies or obtaining a GED. It will be much cheaper for you to do this at the secondary level than by paying college tuition. Do not consider attending any institution that offers an ATB scheme. Seriously, if you were not prepared to complete high school, why are you now suddenly able to learn at the college level? People who do not pose this hard truth to you do not have your best interests at heart.

If you're an educator or staff member --

• You should accept employment at an institution that offers an ATB scheme only as a last resort.
• If you currently work at such an institution, you might consider changing jobs. Remember, if you're not part of the solution, you're part of the problem.

If you are a C-level executive or mid-level manager --

• If you continue to refuse ATB schemes, well, congratulations -- you're on the right side of history. You know that many successful and profitable schools also do as you do and your positive reputation in the industry and in the community is well earned.
• For those who participate in such schemes, however, there may be some social, short selling in your future by Steven Eisman and Manuel P. Asensio. Don't say I didn't warn you!

The Faculty of The Mace recommends that post-secondary institutions develop relationships with both secondary institutions and other GED providers and actively encourage potential students to complete their secondary educations before attempting to begin college studies.

By adopting this practice voluntarily, you will create a tremendous amount of goodwill in your target community and a reservoir of potential students who will likely turn to you when they are ready to begin their studies with the best chance for success. In the long run, the effect on your recruitment and retention efforts will be positive.

Also, your marketing efforts will be enhanced at no cost. The reputation you earn by voluntarily doing the right thing is a pearl beyond price. By adopting this recommended practice, you will actually have a story to tell -- something, in fact, to market. Not just a vague feel-good message. You will also out-compete those in your market segment who do not adopt this practice.

Finally, the Faculty of The Mace must sadly note the complete absence of attention to this issue by national and regional accrediting bodies. Surely, this issue must fall within your due diligence responsibilities as accreditors.

But wait! We're not done yet. The problems with ATB are merely a symptom of a larger problem at DoE. What is that? Well, it's the systematic non-representation of faculty on negotiated-rulemaking committees. Because of this, Education's decision-making process is demonstrably biased toward corporate and administration interests. As each episode of the Faculty of The Mace demonstrates, these interests are not always aligned with the interests of faculty, and, what is even more important, not always aligned with the interests of the very students that we purport to serve. To address this issue of bias at Education, the Faculty of The Mace calls on Secretary Duncan to immediately include faculty on all negotiated-rulemaking committees. We believe that faculty should be represented at parity, that is, at a one-to-one ratio of faculty to non-faculty. This is completely reasonable, as it actually under-represents the true ratio of faculty to non-faculty in the academy.

In Episode 9, we will examine: Faculty Incentive Compensation -- You Mean It’s Not Just for Admissions Reps, Anymore?

How do you feel about the issue of ability-to-benefit students beginning college without a high school diploma? And, also, how do you feel about social, short selling; schools that offer an ATB scheme; and faculty representation on DoE negotiated-rulemaking committees?

Let us know by visiting Faculty of The Mace dot com. There, you will find many ways to join the community and leave your feedback.

Thanks for watching! I'll see you inside the next video.

[Music, Voiceover] Produced at Studio C, Colorado, USA.

[Music, Credit Roll]

Episode 8, Part 1: Academic Admissions Standards – What Is Ability-to-Benefit and Is It a Good Policy?

What did you think of this video? Let me know...

Share this video: on Facebook or on Twitter.

In this episode, the Faculty of the Mace explains the meaning of ability-to-benefit, examines how it affects both recruitment and retention, and makes free-market, policy recommendations.

TRANSCRIPT:

[Music, Voiceover] You're watching the Faculty of the Mace Show, where faculty authority is promoted and protected in the academy of the twenty-first century.

[Eugene Murray, Lead Moderator, FOTM] Welcome to Episode 8: Academic Admissions Standards -- What Is Ability-to-Benefit and Is It a Good Policy? In this episode, we examine the meaning of ability-to-benefit and examine how it affects both recruitment and retention. It’s a common-sense proposition that, in order to pursue a post-secondary education, that one needs a high school diploma, isn’t it? Well, not according to the United States Department of Education. Per DoE regulations, in order to obtain Title IV funds at an eligible institution, a potential student must have done any one of the following:

• Completed a high school diploma.
• Completed a general equivalency diploma or GED.
• Completed six credit-hours toward a degree or certificate, or
• Passed an ability-to-benefit test on basic English and math skills.

Let’s take a look at this last item, ability-to-benefit, often referred to by its initials: ATB.

ATB is a bad idea whose end-time has come. ATB schemes unnecessarily transfer risk from the secondary to the post-secondary educational sectors with no benefit to either students or faculty. In fact, it works to undermine the perceived necessity and value of a high school diploma. The Faculty of The Mace position is that ATB has absolutely no place, whatsoever, in post-secondary education leading to either an Associates or a Baccalaureate degree.

ATB suffers from the following problems: The premise behind the testing is flawed. Its target population essentially doesn’t exist. Because of the above two factors, ATB is impossible to administer honestly and effectively.

Let’s take a look at each of these issues, in turn:

First, we'll consider the premise behind the testing methodology. The Faculty of The Mace questions the very concept that a short-form test could, even possibly, adequately assess a student's readiness for college. This type of testing does not effectively measure a student's ability to think and write effectively, or to perform active problem solving. It does not evaluate work habits and study skills. It does not evaluate a student's personal readiness to begin college, as we discussed in Faculty of The Mace Episode 6 on non-academic, risk-factor screening. It is also subject to coaching and teaching to the test. As well, short answer tests are more easily subject to fraud. In short, it represents yet another lack of due diligence on the part of the colleges that administer the ATB test. We have already discussed other aspects of this lack of due diligence in Faculty of The Mace Episodes 6 and 7.

Second, let’s examine the target population of the ATB test. In essence, we are trying to identify well balanced, motivated individuals with good study skills and stability in their lives who just somehow, magically, don't happen to have a high school diploma. So, where are these people? The answer is that such persons are so few and far between that the existence of the ATB process is completely unjustified. I'm sure you are aware that even the readiness for college of students who actually possess a valid high school diploma is currently being questioned by the Community Colleges. They are noting the enormous remediation effort involved with even these students who have a high school diploma.

Third, since the ATB is a test in search of a valid purpose, it becomes effectively impossible to administer. The reason for this is that it is incorrectly testing for non-existent skills in an absent population. This means that the ATB testing process is open to continual abuse and misapplication by dishonest persons within higher education.

Let’s take a look at some of the difficulties inherent in the ATB testing process:

• Certification of ATB test administrators.
• Monitoring ATB test centers.
• Monitoring ATB test publishers.
• Assuring communication among test publishers who decertify test administrators.
• Monitoring ATB test irregularities.
• Construction and validation of tests.
• Test distribution and security.
• Accommodation for disabled test takers and, finally,
• Accommodation for ESL test takers.

Handling such complex issues comes at a tremendous cost. Just look at the size and complexity of this document. These are the final regulations regarding ATB that were published on October 29, 2010 in the Federal Register, Part II, Department of Education. They are based on a Notice of Proposed Rulemaking published on June 18, 2010 and will take effect July 1, 2011. I will put this document on the Faculty of The Mace Skydrive under Episode 8, for your examination. The ability-to-benefit material is located in this document at section 668.32(e) and Subpart J, beginning on page 66919.

Because of the difficulty and complexity involving ATB, this system is ripe for abuse. From October 2007 to August 2009, the Government Accountability Office conducted a performance audit of DoE’s policies and procedures for monitoring the administration of ability-to-benefit tests in accordance with generally accepted government auditing standards.

How did the DoE do? Let's take a look at some examples extracted from GAO report GAO-09-6000, dated August 2009. Let me put these up on the screen while I read them to you:

Here's the first example: "... in 2008 we sent two GAO analysts who posed as prospective students to a local branch of a publicly traded proprietary school to deliberately flunk an ATB test. Each analyst was sent separately to the school and on both occasions, the independent test administrator gave them and all the test takers in the room -- about 20 in total -- answers to some of the test questions. We later obtained copies of the analysts' test forms and found that they had been tampered with -- their actual answers had been crossed out and changed -- to ensure the analysts passed and would become eligible to receive Title IV funds."

And now, the second example: "... [DoE's] OIG [that is, Office of Inspector General] found personnel at a proprietary school in Louisiana had changed the failing test scores of prospective students to allow 80 individuals to pass and inappropriately qualify for federal funding."

The third example: "Likewise, in two separate New York [Department of Education] investigations in which multiple undercover operatives were sent to flunk ATB tests at local proprietary schools, test answers were changed by either the test administrator or school officials to ensure all people posing as students passed and gained access to federal aid."

Next, the fourth example: "In another case involving improper testing at a proprietary school, the Education OIG found that test administrators failed to follow test rules that govern when students can retake the test on the same form. As a result, 724 students who passed improper retests received over three million dollars in federal financial aid."

Finally, the GAO also concluded, "Weaknesses in Education's systems of controls for monitoring test publishers may not adequately guard against fraud and abuse in the ATB test program."

I will also put this document on the Faculty of The Mace Skydrive, under Episode 8, for your examination.

[Music, Voiceover] Produced at Studio C, Colorado, USA.
 
[Music, Credit Roll]

2011 AAUP Annual Conference On the State of Higher Education – Presentation Proposal Accepted

I'm pleased to let you know that my presentation proposal for the 2011 AAUP Annual Conference on the State of Higher Education has been accepted. I was notified by email on 10 December 2010 by Gewndolyn Bradley, AAUP Communications Director. I invite you to come to D.C. with your thoughts and input on the state of higher education. There has never been a more important time to do this than now.

Link to AAUP 2011 Annual Conference on the State of Higher Education: Information and Registration Page.

When: 8 - 12 June 2011

Where: Omni Shoreham Hotel in Washington, D.C.

Conference Deadlines and Fees:

May 12, 2011: Early bird registration rates end.
May 30, 2011: Online registration closes.

Regular registration (through May 30): $300
Early bird registration (before May 12): $275
Graduate student registration: $150
Onsite registration: $325

Presentation Title:

Regional Accreditation – Why is the Economic Goodwill Value So High and What Are the Effects?

Presentation Summary:

The causes and unintended consequences of the high economic valuation of regional accreditation are considered. The recent, failed acquisition and closure of Dana College in Nebraska is presented as a case study. Possible solutions are presented and examined critically.

Government fiat has created a de facto monopoly in regional accreditation. The accreditation marketplace is essentially a two-tier system: regional and national (if we neglect programmatic and faith-based accreditors).

The principle result of this is that regional accreditation has a higher valuation than it would in a presumably more diverse, free market system of accreditation. This valuation is captured in the accounting concept of goodwill, an intangible asset.

For the case of small, under-endowed institutions, as compared to their larger, more well-endowed counterparts, the super-valuation of regional accreditation means that it becomes the dominant component of:

(1) Economic goodwill and total intangible assets
(2) Net asset value

This means that such small institutions live and die by their regional accreditation which is considered to be the gold standard. In the current environment, there is no mid ground. A case study of this effect is the recent, failed acquisition and resulting closure of Dana College in Nebraska.

Smaller, rural colleges are currently under great financial stress. Workout plans for these institutions are complicated by the super-valuation of regional accreditation. A possible solution is a more varied marketplace for academic accreditation. Rather than the current two-tier market, imposed by fiat, we propose a multi-tiered market with more gradational valuation steps between the levels. It is proposed that nationally recognized faculty groups form their own accrediting agencies. This choice could be enforced by the right of voluntary association. A faculty member could simply choose to volunteer only to serve on committees and field accreditation teams of one’s chosen accreditor. This use of the right of voluntary association strengthens academic authority in general and, specifically, faculty authority. An additional benefit of this is that such an accreditor could have requirements that are salutary to academic freedom, faculty authority, shared governance, and the condition of the contingent faculty.

Some possible problems with this model are recognized: (1) Will a super-accreditor arise that is viewed as higher than a regional accreditor? (2) What groups will step forward to form new accreditors? (3) Where will the new accreditors sit in the accreditation space between national and regional accreditation? (4) What about diploma mills and accreditation mills? Is there a danger that they will gain a higher recognition in the marketplace? (5) How will this affect Title IV funds, Pell grants, etc.? Possible solutions are addressed.

Eugene Murray (aka @FacultyMace on Twitter)
Lead Moderator, Faculty of The Mace
Advancing Faculty Authority in the Academy of the 21st Century
FacultyofTheMace.com

FOTM Audio-only Feed Now Available!

Several FOTM community members have asked for an audio-only podcast feed. This is now available in the right-hand colum of each page on the FOTM video blog site. I believe that, while the majority of people prefer the video feed, it can use useful for some to have an audio-only feed.

The audio feed is avaiable at the FOTM video blog site exclusively. I am not syndicating this feed via iTunes, etc. as I don't want to confuse consumers of the HD video podcast which I consider to be the main feed.

One issue I noticed is that if you have already subscribed to the FOTM HD video feed in Miro, when you add the FOTM audio feed, Miro thinks that it is another instance of the HD video feed. In other words, you wind up with two video feeds, not one video feed and one audio feed. I'm not sure why this is. I will attempt to pass this bug on to the Miro developers. Note that both iTunes and Zune, however, appear to behave correctly, showing both the HD video feed and the audio feed as distinct, independent feeds.

Also note that the title for each episode includes the global reference "[HD VIDEO]". I have no way of stripping this out for the audio-only feed, so please disregard this notation in the tile of the audio episodes. They are, in fact, audio-only, as you would expect.

I hope you find this new distribution method useful.

Eugene Murray (aka @FacultyMace on Twitter)
Lead Moderator, Faculty of The Mace
Advancing Faculty Authority in the Academy of the 21st Century
FacultyofTheMace.com

Episode 7: Student Felony Convictions – Is “Don't Ask, Don't Tell” a Good Policy or Practice?

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In this episode, the Faculty of The Mace examines the question of whether we should be preparing students with felony convictions for sensitive positions in criminal justice, health care, and information security when their employment prospects in these fields are dim, and makes free-market, policy recommendations.

Felony Convictions and Nursing: from Nursing Law & Order blog by the law office of LaTonia Denise Wright, LLC.

TRANSCRIPT:

[Music, Voiceover] You're watching the Faculty of the Mace Show, where faculty authority is promoted and protected in the academy of the twenty-first century.

Welcome to Episode Seven: Student Felony Convictions -- Is "Don't Ask, Don't Tell" a Good Policy or Practice? In this episode, we examine the question of whether we should be preparing students with felony convictions for sensitive positions in criminal justice, health care, and information security when their employment prospects in these fields are dim.

The United States, higher-education establishment has a "don't ask, don't tell" issue of its own, in addition to the U.S. military. In education, "don't ask" means that a college doesn't ask whether a potential student has a prior felony. "Don't tell" means that a college does not disclose to students that prior felonies are a significant issue with regard to future employment in highly sensitive fields of study.

Anecdotal evidence suggests that a small, but significant, number of students with prior felony convictions are preparing for careers in sensitive fields. An estimate of this number is in the single-digit percentages, somewhere between 1 and 5 percent.

While these percentages are low, the number of Title IV dollars involved is actually quite large. Also, we need to consider the effect on the individual students, who may be assuming tens of thousands of dollars of debt with little likelihood of gainful employment in their field of study, due to prior felony convictions.

Clearly, "don't ask, don't tell" is neither an acceptable policy nor an acceptable practice. By policy, I mean a written policy. I would be surprised to learn that any school had a written policy of non-disclosure. However, I would not be surprised to learn that some schools have an unwritten practice not to disclose, based on the anecdotal evidence that non-trivial numbers of students with prior felonies are, in fact, pursuing education in highly sensitive areas.

An interesting question is to what extent such a policy or procedure exposes a school to liability. This is certainly an area where I lack expertise. Some questions that come to mind are:

To what extent are individuals or companies exposed to either criminal or civil liability for such non-disclosure?

Is such non-disclosure subject to a class-action proceeding?

Can such non-disclosure be subject to a False Claims Act proceeding initiated by a whistleblower?

I'd very much like to receive feedback from the Faculty of The Mace Community about these questions. I suspect that some of our listeners possess either a Juris Doctor or a Ph.D. in law.

Nonetheless, until we receive clarification on these questions, the Faculty of The Mace has both free-market and regulatory policy recommendations in this area:

First, regarding the Faculty of The Mace free-market policies, we recommend that colleges perform full, due diligence on and disclosure to prospective students in highly sensitive areas of study. First, individuals should be required to disclose, in writing, whether or not they have a prior felony conviction. Second, students should be informed that such a conviction is a significant issue in their choice of field of study. Third, colleges should perform a background check on individuals who apply to highly sensitive areas of study in order to rule out the existence of prior felony convictions.

The Faculty of The Mace regulatory recommendations are as follows: Title IV funding for students with prior felonies should be restricted for use in pursuing an education in highly sensitive areas. At a minimum, students should be required to certify that they have received full-disclosure and counseling regarding the negative impact of their prior felony conviction on their ability to obtain gainful employment in areas such as: allied health professions, information security, and criminal justice.

Whether such students either can be or should be denied the ability to spend Title IV funds in pursuit of education in highly sensitive areas of study remains a question that is open for discussion. What are your opinions about this?

In Episode 8, We will examine: Academic Admissions Standards ? What is Ability-to-Benefit and Is It a Good Policy?

How do you feel about the issue of students with felony convictions preparing for careers in highly sensitive fields that we discussed in this episode?

Let us know by visiting Faculty of The Mace.com. There, you will find many ways to join the community and leave your feedback. Thanks for watching! I'll see you inside the next video.

[Music, Voiceover] Produced at Studio C, Colorado, USA.
 
[Music, Credit Roll]