Mount Ida College’s April 2018 announcement that it would close the following month triggered a state government effort to prevent students at other colleges from experiencing such profound disruption. The Massachusetts Department of Higher Education is readying draft regulations aimed at achieving that goal — but its plan is seriously flawed.
The department proposes to screen all nonprofit colleges and universities annually on “multiple financial metrics using publicly available data” to determine if they have sufficient resources to complete the current and following academic years. This timing is designed to ensure that the department can engage an institution to determine if closure is imminent and, if so, that there are teach-out agreements in which students can transfer to other schools to complete their degrees.
No one wants another precipitous closure. But despite the department’s good intentions, its proposed screening has four serious problems.
The state has said it will rely on publicly available data that colleges report to the US Department of Education to identify which colleges would be subject to intensive monitoring by a newly created Office of Student Protection. That office would then compel institutions to submit their financial records, which it would use to decide if the college has adequate financial resources. Those in danger of being unable to complete the current academic year and the next would be required to submit a thorough teach-out contingency plan for Office of Student Protection approval, and to notify students and other stakeholders of their status by Dec. 1.
The first problem: Information reported to the Education Department is generally 18-to-24 months old by the time it becomes publicly available.
Second, the Commonwealth has at best uncertain prospects for keeping the information confidential. Failing to do so could trigger the very kind of financial collapse the scheme is meant to prevent. At a recent Boston Foundation event, Simmons College president Helen Drinan said Simmons, which is doing well today, might not have survived if such a scenario were in place when she took over in 2008. Other area presidents have made similar statements.
Third, the state faces a catch-22 when it comes to choosing which colleges to monitor. The state Department of Higher Education hasn’t revealed the metrics it would use to select colleges for the intensive high-stakes monitoring that could trigger mandatory teach-out plans and Dec. 1 notifications, which prevents others from weighing in on the efficacy of such metrics, and they are unlikely to do so. Since the data are public, revealing the metrics would essentially make the results public. Few would then apply for admission to the institution, and existing students, faculty and staff would look to leave, making the college’s demise a self-fulfilling prophecy.
Finally, it is unclear that the department will get the additional resources it needs to carry out this work.
The way around this dilemma is for the Commonwealth to partner with the New England Commission of Higher Education, the regional accreditor for 218 colleges and universities in the six New England states and 11 American-style institutions in other countries. The New England Commission of Higher Education could do the financial screening and employ its “Notation,” a determination used when the commission believes an institution’s condition is serious enough to require a public signal that its accreditation “may be in jeopardy if current conditions continue or worsen.”
Involving us makes sense for all of these reasons. We can get current information directly from colleges and universities. Further, its commission includes six members who are experts in institutional finance. Since the Mount Ida closure, the commission has also adopted recommendations from the Boston Consortium — the chief financial officers of 17 Boston-area colleges and universities — to further strengthen its oversight processes. With the consortium’s help, the New England Commission of Higher Education has drawn on the expertise of higher-education experts with senior experience at the Big Four accounting firms and a major bond-rating agency. These enhancements position the commission to have the strongest means of financial oversight of any US accreditor.
Finally, when it comes to the fear that colleges could be doomed if word leaks that they are undergoing intensive monitoring, the commission operates as a private nonprofit and thus isn’t subject to Freedom of Information requests.
A public-private partnership between the commission and the Board of Higher Education can protect students, faculty, staff and the public without the risks inherent in the administration’s plan. By using a truly confidential process to provide high-level review of current data, it can avoid having a self-fulfilling prophecy lead to the closure of an otherwise viable institution.
Barbara Brittingham is president of the New England Commission of Higher Education.