THE STATE EDUCATION DEPARTMENT/THE UNIVERSITY OF THE STATE OF NEW YORK/ALBANY, NY 12234 DEPUTY COMMISSIONER Office of Higher Education Office of the Professions August 4, 2006 Dr. Joni E. Finney, Vice President The National Center for Public Policy and Higher Education 152 North Third Street, Suite 705 San Jose, CA 95112 Dear Dr. Finney: Thank you for sending your July 14, 2006 request for our review of preliminary data for your September release of Measuring Up, 2006. We applaud your organization’s mission to bring critical information on higher education to the public’s attention. In New York State, the Statewide Plan for Higher Education, which can be found on the Department’s Web site at www.highered.nysed.gov/Quality_Assurance/, is a comprehensive, data driven analysis of the strengths and weaknesses of New York State’s higher education system, developed in conjunction with all four sectors of higher education in New York. We recognize the value of accurate data for policymakers and the public. We would like to recommend some adjustments and corrections in your analysis to more accurately reflect education in New York State. PREPARATION: TEACHER QUALITY. The draft measures teacher quality as the percent of teachers in grades 7 through 12 who have a major in the subject they are teaching as reported by a national sample of teachers over six years ago (1999-2000). The data from 1999-2000 does not reflect the improvements states have made in response to the No Child Left Behind Act of 2001 and other reform efforts. We recommend that you instead use more recent survey data where available to reflect that progress. For example, all states reported more recent data on the percent of core classes being taught by highly qualified teachers in elementary and middle/secondary schools to the U.S. Department of Education in March 2004, as part of their Consolidates State Performance Reports for the No Child Left Behind Act. Estimates based on the samples have measurable standard errors that reveal whether the estimate is close to the actual number in the population or it only a point estimate within a wide range of what could actually be true for the population. We suggest that you report standard errors around sample estimates, or only use estimates that meet a test of having a narrow confidence interval that you specify in your report. AFFORDABILITY: FAMILY ABILITY TO PAY. The indicator of a family’s ability to pay is defined as the percent of income needed to pay for college expenses minus financial aid in each sector of higher education (public community colleges, public 4-year colleges and universities and private 4-year colleges and universities) and for each of five income groups ranging from low income to high income (quintiles). As explained in the technical guide for the indicators dates September 2004, the net cost indicator for each sector is computed as follows: Average tuition and fees in the sector + Average room and board in the sector = Subtotal of college expenses - Average Federal financial aid in the sector (average Pell grant per full-time equivalent student) - Average State financial aid in the sector (average State need-based and non-need-based grant aid per full-time equivalent student) - Average institutional aid in the sector (enrollment weighted averages of average awards) = Sector net cost The sector net cost is adjusted to get net costs for each income quintile in order to reflect targeting of aid to the lower income quintiles. Your report indicates that the adjustments are made using national estimates of how aid is targeted to income quintiles. As noted in the technical guide, “These calculations assume that students receive the same percentage of aid available in every state, but the actual amount of financial aid for students in each income quintile will vary by state because of the size of average awards varies by state.” The technical guide states that the estimates for each state’s higher education sectors and income quintiles are estimates based on available data and are not necessarily accurate. Publishing this data, even with this caveat in a separate technical guide, could mislead students and families about the affordability of public higher education in New York. For example, for over 30 years New York’s Tuition Assistance Program (TAP) has been a major entitlement program that covers the full cost of tuition for students whose families are in the lowest income quintile. Since the report card does not reflect this financial aid program, which provides more then a half of a billion dollars to students, it inaccurately reflects the affordability in New York State. We and other leaders in New York State’s higher education community have brought this omission to the attention of the National Center since the first report card was issued in 2000. Given the importance of this report, we urge you to incorporate this information into the report for 2006. Omitting this student resource from your methodology incorrectly yields a failing grade to a state whose targeted Tuition Assistance Program consistently yields one of the highest college participation rates in the nation among low income high school graduates, as reported in Postsecondary Education Opportunity, January 2006 (page 10). For the lowest income students with a family income of $12,000 (an estimated median income for 2005-2006, based on the $11, 000 median for 2004-2004 used in Measuring Up 2004), we compared the actual percentage of income needed to attend college in New York State to the percentage in Measuring Up 2006 for public community colleges in the State University of New York. Your estimate of 84 percent is 34 percentage points higher than the actual percentage for financially dependent students not living at home. For the large portion of community college students who are financially dependent and living at home, the percentage is zero, and there is even a surplus of $735. SUNY Community Colleges ACTUAL 2005-2006 Not Living Living At Home At Home 2005-2006 Tuition and fees $ 3,315 $ 3,315 + 2005-2006 Other expenses $ 9,700 $ 3,000* = Subtotal: Expenses $ 13,015 $ 6,315 - Pell Grant $ 4,050 $ 4,050 - TAP Award $ 3,000 $ 3,000 - Institutional grant aid $ 0 $ 0 = Net cost: Expenses minus aid $ 5,965 $ -735 Net cost as a percent of income = 50% 0% _______ _______ ($5,965/$12,000) MEASURING UP 2006 Net cost as a percent of income = 84% * Data source is 2005-06 IPEDS and is an estimate for SUNY community colleges AFFORDABILITY: SHARE OF INCOME THAT POOREST FAMILIES NEED TO PAY FOR TUITION AT LOWEST-PRICE COLLEGES. For this measure, your report divides annual community college tuition and gee charges by the income level for the lowest income group among five income groups (quintiles). This portion of the Center’s report needs to be corrected. As shown by the illustrative comparison for The City University of New York community colleges and an estimated low income of $12,000, there is a 26 percentage point difference between the actual share of income (3 percent) and the share of income reported in Measuring Up 2006 (29 percent). CUNY Community Colleges ACTUAL 2005-2006 Average tuition and fees net of Tuition Assistance Program entitlement $ 300 Average family income in lowest quintile $12,000 Share of income paid = 3% _______ Measuring Up 2006 Share of income paid = 29% _______ AFFORDABILITY: RELIANCE ON LOANS. Average student loan amount can be useful data. We recommend however, that your report also note that the percent of students with loans, the gamily income of the students, and the cost of sector of the institutions attended (rather than aggregating students with different family incomes attending institutions with different costs) are relevant to interpreting average loan size. PARTICIPATION: HIGH SCHOOL FRESHMEN ENROLLING IN COLLEGE WITHIN 4 YEARS. You report a score of 37 percent for New York State. Our latest review and “cleaning” of the IPEDS residence data, which is the key data source for this measure, indicates that 50 percent of New York State’s 9th grade students enrolled in college 4 years later. PERSISTENCE AND COMPLETION. Your rates for persistence and awards per 100 undergraduates are consistent with rates we calculate from our data. However, your draft report inaccurately reflects that the 2004 graduation rate within 6 years for baccalaureate programs is 57 percent while we calculate a rate of 61 percent. For both of the items mentioned above, the differences appear to be related to the reliability of the IPEDS data used. More thorough “cleaning up” of the missing and erroneous data would probably eliminate the differences. As the magnitude of the problem and the direction of the errors would probably differ considerably by state, improving the data quality would likely make very significant differences in state-by-state comparisons. I hope these comments and corrections will be incorporated in your final report and would welcome the opportunity to discuss them with you in greater detail in order to improve the value of Measuring Up for policymakers and the public. The New York State Education Department shares the National Center’s commitment to promoting the quality and affordability of higher education for all students. Your report is an opportunity to provide important information to prospective students and we look forward to working with you to ensure the accuracy of the data included in the report. Sincerely, Johanna Duncan-Poitier cc: Board of Directors of the National Center for Public Policy and Higher Education Richard P. Mills, Commissioner of Education, New York State John R. Ryan, Chancellor, State University of New York Matthew Goldstein, Chancellor, The City University of New York Abraham M. Lackman, President, Commission of Independent Colleges and Universities Ellen Hollander, President, Association of Proprietary Colleges