Our overarching concerns in the implementation of this requirement are to make certain that the data are completely accurate and verifiable. When this happens the reputation of institutions of higher education suffers unfairly. In addition, we want institutions to be able to verify the data on which the calculations are based to avoid the release of erroneous information that harms a school's reputation. All of our comments are designed to ensure that the data that are collected and published are accurate and verifiable. The Final Guide will impose a substantial administrative burden on colleges and universities.
Many schools graduate thousands of prospective teachers each year.
The regulatory burden imposed on colleges comes with a cost. We ask that the federal government provide a more accurate assessment of the regulatory burden that it seeks to impose and that all reasonable steps be taken to minimize this burden. We recognize the difficulty in developing a common set of reporting requirements applicable to 50 state systems of education and commend the Department of Education in its effort to clarify many points that were imprecise and misleading in the original Draft Manual. However, there are several issues of concern that should be addressed before the Final Guide is published. First, the draft guidelines require each state to develop its own set of procedures for collecting testing data, calculating the necessary pass rates, and ensuring institutional verification of the information.