Could Federal Ratings Be Applied to Human Service Providers?

Could draft federal ratings for colleges and universities, released by the U.S. Department of Education on December 19, become a model for human service providers?  At first glance, the sheer difficulty of the task, combined with a lack of time remaining in President Obama’s last term in office and likely pushback from organizations representing providers, suggests that the answer is no, at least not soon.

But broader consideration of parallel developments in health care, K-12 education, and Head Start, along with possible congressional work on welfare reform next year, suggests that something very similar may come much sooner than expected.

The Proposed Higher Education Ratings System

The administration’s draft federal ratings for colleges and universities are an illustrative case study.  Spurred by skyrocketing tuition and fees that have increased 231 percent in inflation-adjusted terms at public four-year colleges since 1983, President Obama announced in 2013 that his administration would issue federal ratings for colleges and universities by the start of the 2015-16 school year.

The resulting draft framework, released earlier this month, includes proposed measures in three broad categories:

  • Greater College Access: Proposed metrics include the percentage of enrolled students who receive federal Pell grants and/or the number who are the first generation in their families to attend college.
  • Affordability: Proposed metrics include the average net price of fees and tuition and average school loan debt for enrolled students.
  • Improved Educational Outcomes:  Proposed metrics include college completion rates, graduate school attendance, employment and wage outcomes, and loan repayment and default rates.

While no decision has been made on whether to combine these metrics into a single, overall rating, the administration nevertheless intends to divide colleges and universities into three groups: high-performing, low-performing, and those falling in the middle.

“Without this,” according to the draft, “there is insufficient incentive within the higher education marketplace to offer a quality education at a lower price, or for low-performing institutions to improve.”

College ratings, particularly those from U.S. News and World Report, are already driving changes in the higher education marketplace, including applications and admissions rates.  Several universities have made rising in these rankings an explicit goal.

The new federal ratings may influence (or counterbalance) these private ratings, which the administration says have “rewarded exclusivity and rising college costs.”  Beyond these indirect effects, however, the administration would also like to tie the proposed ratings to federal financial aid, possibly by providing larger Pell grants or better interest rates to students who attend better-rated schools.

In developing the standards, the administration says it has consulted with “close to 9,000 people” through a variety of open meetings, public comments, and other consultation efforts. Despite this outreach, however, the proposals have drawn significant opposition from associations representing colleges and universities.

“What we have repeatedly said is the federal government ought to provide lots of information, but not be in the position of picking winners and losers,” David L. Warren, president of the National Association of Independent Colleges and Universities, told The Washington Post.  Some Republicans on Capitol Hill agree with this view.

The administration remains undaunted. It is currently asking for comments until February 17. After that, it will finalize the ratings before the beginning of the next academic year, probably in mid- to late-summer.

Other Provider Ratings

The administration’s proposed college ratings would be of limited interest to institutions outside higher education if they were an isolated case, but they are not.

Another prominent example is in K-12 education, where individual schools have been rated according to their progress on state-level standards since President Bush signed No Child Left Behind into law in January 2002. Under the law, individual schools failing to meet requirements for Adequate Yearly Progress were deemed to be “in need of improvement.” Schools receiving Title I funding that were so designated were subject to increasingly stringent, federally mandated interventions.

While the law’s requirement that all students meet proficiency standards by the 2013-2014 school year ultimately proved unrealistic, the Department of Education has approved waivers that provide states flexibility in exchange for new accountability systems that remain rigorous and outcomes-based.

Outside education, the Department of Health and Human Services is well into a major effort to rate the nation’s health care providers, including physicians, hospitals, and organizations providing home health care. Much of this activity was prompted by the Affordable Care Act, but a separate five-star quality rating system for the nation’s 16,000 nursing homes, now being updated by the Obama administration, was first developed in 2008 during the Bush administration.

In human services, a similar performance rating system for low-performing Head Start providers was adopted by Congress in 2007. The first cohort of 130 low-performing Head Start grantees was notified in 2011 that they would be required to compete for grant renewals.  Since then, more than 200 additional providers have been designated for recompetition, with designations substantially linked to a Classroom Assessment Scoring System (CLASS) chosen by the Administration for Children and Families to assess their quality.  In all, more than 20 percent of Head Start grantees have been subject to recompetition so far.

Taken as a whole, of course, these examples may just be isolated efforts with limited applicability to human service providers not already under the ratings microscope. But there are several reasons to think otherwise.

In July, 2013, shortly before President Obama first announced the forthcoming college ratings, the White House issued a memo to federal agencies entitled “Next Steps in the Evidence and Innovation Agenda.”  The memo, which encouraged agencies to develop new evidence and innovation-focused proposals in their forthcoming budget proposals, also cited provider scorecards as an example of an “innovative strategy for harnessing data to improve results.”  The memo laid out a schedule of related internal briefings and workshops that began the following fall. This work may come to fruition in the president’s next budget proposal, expected early next year.

If the administration proposes more ratings or other outcomes-based performance standards, there may be opposition from provider groups, but this may not be enough to prevent their adoption.  The administration’s work on higher education ratings, for example, is based on existing legal authority.

The relative lack of time remaining in President Obama’s last term in office may also not be much of a barrier.  Nursing home ratings and performance standards for Head Start providers, for example, were both developed or enacted very late in President Bush’s last term and were continued under President Obama.

Finally, pressure for improved performance is not coming solely from the executive branch. While there has been some Republican opposition to federal ratings, there has been substantial Republican support for other proposals to increase performance in social service programs more generally.  The administration and Republicans in Congress have already found common ground on a bipartisan commission to promote the use of evidence in social programs. House Republicans are also expected to support a plan, dubbed “Welfare Reform 2.0,” proposed by Rep. Paul Ryan (R-WI) that would implement a number of outcomes-focused changes for human service providers and programs in the next session of Congress.

Major welfare reform legislation was last enacted by a Republican Congress and Democratic president, President Clinton, in 1996.  If congressional Republicans and President Obama take a bipartisan approach to welfare reform in 2015, it is possible that there may be more common ground between them.


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