March 25, 2015
The Honorable Arne Duncan
Secretary of Education
Department of Education
400 Maryland Avenue, SW
Washington, DC 20202
Dear Secretary Duncan:
Thank you for the opportunity to provide comments on the Department of Education's proposed priorities and requirements for the First in the World program. The Institute for Higher Education Policy (IHEP) is committed to ensuring that all people, regardless of background or circumstance, have the opportunity to reach their full potential by participating and succeeding in postsecondary education. As the First in the World program is aimed at improving educational outcomes and making postsecondary education more affordable for students and families, IHEP appreciates the Department's ongoing support of the program.
In addition, IHEP commends the Department's focus through the First in the World program on identifying the strategies that are most effective for addressing key barriers that prevent underrepresented students from persisting and completing, as well as supporting innovative solutions to ensure successful postsecondary outcomes for these students. To promote college persistence and completion for underrepresented students, IHEP recommends the following improvements to the proposed priorities and requirements for the First in the World grant program:
Add priority points for Institutions that Commit to Serving a Diverse Student Population and Enhancing Equal Opportunities for All Students. The First in the World program was created to allow for the development and expansion of innovative strategies aimed at addressing persistent and widespread challenges in postsecondary education, including student persistence and completion outcomes. To address these challenges, the cornerstone of the First in the World program should be initiatives that seek to achieve equality of opportunity for all students and, in particular, help low-income, minority, and other historically underrepresented populations attain postsecondary success. IHEP recommends that priority points be added to award funding to grantees that commit to serving – by both enrolling and graduating – low income, first-generation, underprepared students. This priority would show a commitment to equity and helping historically underrepresented populations reach their full potential by achieving better postsecondary outcomes.
Promote Diversity Among First in the World Grantees. In October 2014, the Department announced the awardees for the first competition under the First in the World program. Of the twenty-four colleges and universities selected for the initial year of awards, the grantees included a range of community colleges and public and private four-year institutions in seventeen states. Specifically, funding was awarded to nineteen public and private, nonprofit four-year institutions and five public and private two-year institutions, including among these grantees six that were minority serving institutions (MSIs). In Fiscal Year 2015 and future grant competitions, Proposed Priority 8 for the First in the World program would give priority to initiatives designed to improve student outcomes at MSIs. The two-tiered competition for FY15 which designates the majority of funds for validation—large scale research projects—may be most likely to be awarded to well-resourced research institutions making this attention to diversity of institutions all the more important. IHEP recommends that the Department promote diversity among First in the World grantees by ensuring that funding continues to be directed toward a range of postsecondary institutions, including two- and four-year public and private, nonprofit colleges and universities, including MSIs.
Modify the Proposed Priority to Increase the Effectiveness of Financial Aid to Ensure that Financial Resources are Focused on Students with the Greatest Need. The Department acknowledges that evidence shows that lowering the costs of a postsecondary education (as a result of student aid) can improve access and completion. Reduced costs are particularly important to students from low-income backgrounds. IHEP believes that the postsecondary institutions should be committed to making higher education more affordable specifically for the neediest students, to ensure that student success is predicated on more than family income or the ability to pay for college. While Proposed Priority 6 for the First in the World program focuses on college affordability, it does not require grantees to prioritize strategies that will have the greatest impact on students with the greatest need. IHEP recommends that the proposed priority to increase the effectiveness of financial aid ensure that financial resources and financial aid interventions be focused on students with the greatest need.
Include the Proposed Requirement for Innovations that Improve Outcomes for High-Need Students in the Fiscal Year 2015 and All Future Grant Competitions. The Department proposes to include a requirement for the First in the World program that grantees 1) must implement projects designed to improve outcomes of high-need students, or 2) must implement projects designed to improve one or more outcomes for high-need students, including persistence, academic progress, time to degree, or completion. Because addressing barriers to student success in postsecondary education, especially for historically underrepresented students, is central to the First in the World program, the Department should require that the Fiscal Year 2015 and all future grant competitions include this requirement Additionally, IHEP recommends that the Department clarify the definition of "high-need" students to ensure that these efforts target low-income, first-generation, and academically-underprepared students.
Require Evaluations to Report Information Based on Disaggregated Data. As an organization focused on the power of research to inform policy, IHEP is encouraged that the Department proposes to require First in the World grantees to conduct an Independent Evaluation and make the evaluation’s results available broadly. IHEP recommends that the Department also require grantees to report disaggregated demographic data. At a minimum, they should report disaggregated data based on outcomes for low-income and racial and ethnic minority students. Ideally, grantees also should report disaggregated data for first-generation students; adult students; students with second-language backgrounds; undocumented students; veterans; students with disabilities; and foster care, disconnected, and formerly incarcerated youth. The disaggregation of data under the First in the World grant program could inform practices and policies that may hold promise for specific groups of underrepresented students.
With the First in the World program, the Department has recognized the central role that student success efforts focused on historically underrepresented populations will play in meeting our nation's educational goals. IHEP thanks you in advance for your consideration of these comments to improve the Fiscal Year 2015 and future grant competitions for the First in the World program.
Michelle Asha Cooper, Ph.D.
Institute for Higher Education