Are we EQUIPped to spend billions on (yet) unproven programs?
April 17, 2018
In the 1940s, Russia developed a prototype of a new military advancement called the Antonov A-40. It was an ambitious, seemingly innovative leap forward that would provide battlefield support and overwhelming, agile deployment. It was also, quite literally, a flying tank. For reasons that seem obvious in retrospect—weight and inefficient transportation chief among them—it was not functional in practice and thankfully never produced at wide scale. However, the lessons learned regarding its design ultimately provided beneficial advances to future military developments.
Federal lawmakers would be wise to heed the lesson that all ideas—particularly those with billions of dollars at stake—should not be rushed into wide-scale production. Many of them seem eager to open the $130 billion per year of taxpayer funding to new ways of providing higher education instruction without any assurance that these programs provide quality outcomes to their students. It’s still too early to tell if these innovative models will turn out to be the Antonov A-40 or the (significantly more effective) Chinook helicopter of higher education, but it’s not hard to see the potential damage—for both taxpayers and students—of going into “mass production” at this early stage, without assuring that the quality, design, and outcomes of such innovative programs are well understood.
Because Congress and the Trump Administration have signaled enthusiasm to opening Federal student aid to shorter term and other nontraditional providers, it is critical to develop quality assurance models that can meet the needs of these new learning delivery methods. It isn’t clear that accreditors—the traditional arbiters of quality more focused on inputs such as course catalogs than on outcomes like employment, earnings, and aptitude—are the right fit for newer learning models that focus more on building a skill set for adults looking to gain an additional certification for their next job. The bad news is that currently, there is no consensus and little evidence for what such a quality assurance regime would look like. The good news is that a little-known Federal experiment known as EQUIP—Educational Quality through Innovative Partnerships—is in the early stages of making Federal funding available to test whether such quality assurance providers could serve as a backstop for ensuring students are getting a superior education in exchange for their taxpayer-funded Federal grants and loans. The time is ripe to enable such innovation, to evaluate whether these quality assurance models can ensure that both taxpayer and student investments would be sufficiently protected.
EducationCounsel has reviewed and summarized what is known about the early work of the Quality Assurance Entities (QAEs) who were invited to be a part of EQUIP to develop innovative approaches to assuring the quality of new higher education approaches. Our preliminary insights, takeaways, and questions for continued consideration in the memorandum are based on research and our work convening and engaging with the QAEs.
The policy environment is such that Congress is looking for real-world instances of quality assurance to serve as a basis for prospective legislation. However, our analysis affirms it is important to keep the experimental nature of EQUIP in mind. The clearest early lesson is that this work has been challenging and complex and that significant work remains before the concept of new quality assurance approaches should be taken to scale.
This experiment is in a very early stage—indeed, the first applicant was approved to distribute federal aid on April 13. There are a number of clear challenges that should be understood and addressed in any prospective legislation or Department of Education action. While there is much more to learn from this experiment (an authority that was created in the Higher Education Act for exactly these sorts of purposes), there is no evidence that these innovative approaches are ready to expand beyond the current—and recent—experimental stage. Notable, specific challenges associated with the EQUIP pilot have included:
- access to and readiness of data;
- the difficulty of defining and measuring quality in consistent ways;
- the rapidly changing and widely varying nature of innovative higher education programs; and
- engagement with emerging and existing entities and systems.
We elaborate on these points, along with more specific lessons learned and questions for consideration in our memorandum.
Despite the challenges, one point should not be lost: higher education needs new quality assurance approaches that are sufficiently innovative and programmatically tailored to meet the needs of emerging higher education delivery models.
So, we plan to continue evaluating the work of the QAEs. And as they pursue reauthorization of the Higher Education Act, we plan to continue to provide policymakers with emerging lessons of relevance. It is imperative that Congress avoid imposing requirements on providers, accreditors, and QAEs that are ill-suited for the reality of the field—or worse, take the lack of field-tested models as an excuse to omit quality assurance requirements entirely if Congress opens Federal funding to an array of new educational providers. If that happens, we may well be spending billions of dollars a year on higher education’s own flying tank.