August 31, 2015 the Honorable Arne

Home , Ann Weaver Hart, Arne Duncan, Jane Close Conoley, Jay Gogue, Steven Leath

August 31, 2015

The Honorable Arne Duncan U.S. Department of Education 400 Maryland Avenue, SW Washington, DC 20202

Dear Secretary Duncan:

As college and university leaders, we appreciate the U.S. Department of Education’s responsiveness to concerns from the higher education community about a post-secondary rating system. Moreover, we support the Department’s recent announcement that it is instead focusing on the development of consumer-focused tools with newly available data. This effort could benefit students and their families, policymakers, and the public by providing them with new comparison tools and additional information on post-secondary institutions. That is why we are writing you about the Student Achievement Measure (SAM), a voluntary web-based tool that allows institutions to show the progress and graduation of significantly more students than the federal graduation rate.

We know you share our belief that the most accurate data available should be used in order for these new tools to be effective and meaningful. Federal graduation rates as reported through the Integrated Postsecondary Education Data System (IPEDS) are a key piece of data likely under consideration for the new reporting tool. However, the commonly used federal graduation rate is limited to the success of first-time, full-time college students who graduate from their original institution. This has led to a misrepresentation of institutional performance because the federal rate does not account for the success of all students – particularly those students who attend multiple institutions.

This month a report from the National Student Clearinghouse revealed that more than one- third of the 3.8 million first-time, full-time students who entered college in 2008 transferred at least once within six years and nearly half of those students changed institutions multiple times. The pathways through which students attend college have evolved, but the method for calculating the federal graduation rate hasn’t fully evolved to reflect student behavior. Even with the collection of additional outcomes data within IPEDS this fall, the ultimate graduation of a student who transfers cannot be recognized as a successful outcome by his or her original institution, and the school to which that student transfers doesn’t receive credit for their contributions to the student’s successful completion.

Using data from the National Student Clearinghouse, SAM is able to track the progress and completion of transfer students, part-time students, full-time students, and the outcomes of students who enroll in multiple institutions. Launched just two years ago, SAM has 575

The Student Achievement Measure (SAM) is a collaboration among the American Association of Community Colleges (AACC), the American Association of State Colleges and Universities (AASCU), the American Council on Education (ACE), the Association of American Universities (AAU), the Association of Public and Land-grant Universities (APLU), and the National Association of Independent Colleges and Universities (NAICU). APLU serves as the fiduciary agent.

participating institutions across all sectors of higher education. To date, the program is already reporting the progress and completion of over 570,000 students more than the federal government. Given the shortcomings of the federal graduation rate and the advantages of SAM, we were pleased that the Department publically indicated that it might allow institutions to include data from SAM within the proposed Postsecondary Institutional Rating System when it released the detailed framework in December.

We understand that the Department is now working through how SAM information can be included as a supplemental resource within the new transparency tools. We strongly support and encourage the inclusion of a dedicated link within the new tools that would allow institutions the option to link to their SAM data and provide additional information on the success of their students. Doing so would help ensure the integrity and reliability of the new consumer information and tools.

Thank you again for your work on this critical initiative. We are pleased to serve as a resource to you and the Department as you further develop this new and valuable tool for students and families.

Sincerely, SAM Presidents and Chancellors

Timothy P. White, Chancellor William McRaven, Chancellor California State University System The University of Texas System

Michael McRobbie, President David Lassner, President Indiana University System University of Hawaii System

Michael W. Klein Timothy L. Killeen, President New Jersey Association of State Colleges and University of Illinois System Universities Ray Cross, President Mark R. Hagerott, Chancellor University of Wisconsin System North Dakota University System Gwendolyn E. Boyd, President Daniel J. Hurley, Presidents Council Alabama State University State Universities of Michigan Michael Crow, President Randy J. Dunn, President Arizona State University Southern Illinois University System Jay Gogue, President Nancy L. Zimpher Auburn University Chancellor, State University of New York

Paul W. Ferguson, President Thomas J. Hynes Jr, President Ball State University Clayton State University

Larry C. Skogen, President James Clements, President Bismarck State College Clemson University

Robert W. Kustra, President Ronald Berkman, President Boise State University Cleveland State University

Mary Ellen Mazey, President Glenn McConnell, President Bowling Green State University College of Charleston

Jeffrey D. Armstrong, President William J. Fritz, President California Polytechnic State University College of Staten Island, CUNY

Jane Close Conoley, President Taylor Reveley, III, President California State University Long Beach College of William & Mary

Dianne Harrison, President Harry L. Williams, President California State University Northridge Delaware State University

Karen S. Haynes, President, Rev. Dennis H. Holtschneider, C.M., President, California State University San Marcos DePaul University

Mildred García, President Steve Ballard, Chancellor California State University, Fullerton East Carolina University

Robert S. Nelsen, President Marcia G. Welsh, President California State University, Sacramento East Stroudsburg University

Tomás D. Morales, President Kim Schatzel, Interim President California State University, San Bernardino Eastern Michigan University

Geraldine M. Jones, Interim President Julie E. Wollman, President California University of Pennsylvania Edinboro University

John M. McArthur, President David L. Eisler, President Cameron University Ferris State University

John W. Miller, President Mark B. Rosenberg, President Central Connecticut State University Florida International University

Cynthia Jackson Hammond, President John Thrasher, President Central State University Florida State University

F. Javier Cevallos, President Beverly J. Warren, President Framingham State University Kent State University

Luther F. Carter, President Raymond M. Burse, President Francis Marion University Kentucky State University

Thomas L. Bowling, Interim President Doug Darling, President Frostburg State University Lake Region State College

Angel Cabrera, President Manuel J. Cabral, Chancellor George Mason University Leeward Community College

Mark Becker, President F. King Alexander, President Georgia State University Louisiana State University

Elaine P. Maimon, President Philip C. Williams, President Governors State University McNeese State University

Willie D. Larkin, President Stephen M. Jordan, President Grambling State University Metropolitan State University of Denver

Noreen R. Yamane, Chancellor David Hodge, President Hawaii Community College Miami University

Arthur C. Vailas, President Glenn Mroz, President Idaho State University Michigan Technological University

Steven Leath, President John M. Anderson, President Iowa State University Millersville University of Pennsylvania

Jonathan Alger, President Mark E. Keenum, President James Madison University Mississippi State University

Kirk H. Schulz, President Jim Borsig, President Kansas State University Mississippi University for Women

Leon Richards, Chancellor William B. Bynum, Jr., President Kapi'olani Community College-University of Mississippi Valley State University Hawaii Cheryl B. Schrader, Chancellor Helen A Cox, Chancellor Missouri University of Science and Technology Kauai Community College Robert Vartabedian, President Anne E. Huot, President Missouri Western State University Keene State College

Mark Nook, Chancellor William M. B. Fleming, Jr., President Montana State University Billings Palm Beach Atlantic University

Donald M. Blackketter, Chancellor Francis Achampong, Chancellor Montana Tech of the University of Montana Penn State Mont Alto

Susan A. Cole, President Eric J. Barron, President Montclair State University Pennsylvania State University

Daniel M. Asquino, President Donald L. Birx, President Mount Wachusett Community College Plymouth State University

Rosalie M. Mirenda, President Wim Wiewel, President Neumann University Portland State University

Garrey Carruthers, President Mitch Daniels, President New Mexico State University Purdue University

Randy Woodson, Chancellor Richard L. Edwards, Chancellor North Carolina State University Rutgers, The State University of New Jersey

Dean Bresciani, President Dana G. Hoyt, President North Dakota State University Sam Houston State University

Steve Turner, President Elliot Hirshman, President Northeastern State University San Diego State University

Rita Hartung Cheng, President Leslie E. Wong, President Northern Arizona University San Francisco State University

President Douglas Baker, President David L. Chicoine, President Northern Illinois University South Dakota State University

Geoffrey S. Mearns, President John L. Crain, President Northern Kentucky University Southeastern Louisiana University

George Hynd, President Earl H. Potter III, President Oakland University St. Cloud State University

Roderick J. McDavis, President Baker Pattillo, President Ohio University Stephen F. Austin State University

Edward J. Ray, President Harvey Kesselman, President Oregon State University Stockton University

Samuel L. Stanley Jr., President Robert A. Altenkirch, President Stony Brook University The University of Alabama in Huntsville

Harvey Stenger, President Ann Weaver Hart, President SUNY Binghamton The University of Arizona

Erik J. Bitterbaum, President Morris H. Stocks, Chancellor SUNY Cortland (State University of New York) The University of Mississippi

Merodie A. Hancock, President Dana Dunn, Acting Chancellor SUNY Empire State College The University of North Carolina at Greensboro

Denise A. Battles, President Rodney D. Bennett, President SUNY Geneseo The University of Southern Mississippi

Kristine Young, President Greg Fenves, President SUNY Orange The University of Texas at Austin

John Ettling, President Hobson Wildenthal, Interim President SUNY Plattsburgh The University of Texas at Dallas

Kristin G. Esterberg, President Donna Price Henry, Chancellor SUNY Potsdam The University of Virginia's College at Wise

Neil Theobald, President Jose V. "Zito" Sartarelli, Chancellor Temple University University of North Carolina Wilmington

Michael Young, President Ray L. Watts, President Texas A&M University - College Station University of Alabama at Birmingham

Denise M. Trauth, President Brian Rogers, Chancellor Texas State University University of Alaska Fairbanks

M. Duane Nellis, President Paul B. Beran, Chancellor Texas Tech University University of Arkansas - Fort Smith

David E. Van Zandt, President Laurence B. Alexander, Chancellor The New School University of Arkansas at Pine Bluff

Michael V. Drake, President George Blumenthal, Chancellor The Ohio State University University of California Santa Cruz

Stuart R. Bell, President Nicholas Dirks, Chancellor The University of Alabama University of California, Berkeley

Linda P.B. Katehi, Chancellor Kent Fuchs, President University of California, Davis University of Florida

Howard Gillman, Chancellor Lui K. Hokoana, Chancellor University of California, Irvine University of Hawaii Maui College

Gene D. Block, Chancellor Michael D. Amiridis, Chancellor University of California, Los Angeles University of Illinois at Chicago

Dorothy Leland, Chancellor Jean Robillard, Interim President University of California, Merced University of Iowa

Kim Wilcox, Chancellor Bernadette Gray-Little, Chancellor University of California, Riverside University of Kansas

Pradeep K. Khosla, Chancellor James R. Ramsey, President University of California, San Diego University of Louisville

Henry Yang, Chancellor Kathryn A. Foster, President University of California, Santa Barbara University of Maine at Farmington

John C. Hitt , President Juliette B. Bell, President University of Central Florida University of Maryland Eastern Shore

Charles Ambrose, President Javier Miyares, President University of Central Missouri University of Maryland University College

Don Betz, President Wallace D. Loh, President University of Central Oklahoma University of Maryland, College Park

Santa Ono, President J. Keith Motley, President University of Cincinnati University of Massachusetts Boston

Roderick Nairn, Chancellor Divina Grossman, Chancellor University of Colorado Denver University of Massachusetts Dartmouth

Philip P. DiStefano, Chancellor Jacqueline Moloney, President University of Colorado, Boulder University of Massachusetts Lowell

Susan Herbst, President M. David Rudd, President University of Connecticut University of Memphis

Patrick Harker, President Mark S. Schlissel, President University of Delaware University of Michigan

Daniel Little, Chancellor Kay Norton, President University of Michigan-Dearborn University of Northern Colorado

Lendley C Black, Chancellor Michael H. Schill, President University of Minnesota Duluth University of Oregon

Eric Kaler, President Patrick Gallagher, Chancellor University of Minnesota-Twin Cities University of Pittsburgh

R. Bowen Loftin, Chancellor David M Dooley, President University of Missouri University of Rhode Island

Leo E. Morton, Chancellor Joel Seligman, President University of Missouri-Kansas City University of Rochester

Thomas F. George, Chancellor John Feaver, President University of Missouri-St Louis University of Science & Arts of Oklahoma

Harvey S. Perlman, Chancellor Jimmy G. Cheek, Chancellor University of Nebraska-Lincoln University of Tennessee, Knoxville

Marc A. Johnson, President Vistasp M. Karbhari, President University of Nevada, Reno University of Texas at Arlington

Mark Huddleston, President Diana Natalicio, President University of New Hampshire University of Texas at El Paso

Robert G. Frank, President Sharon L. Gaber, President University of New Mexico University of Toledo

Peter J. Fos, President David W. Pershing, President University of New Orleans University of Utah

Carol Folt, Chancellor Tom Sullivan, President University of North Carolina at Chapel Hill University of Vermont

Philip L. Dubois, President Teresa A. Sullivan, President University of North Carolina at Charlotte University of Virginia

Robert O. Kelley, President Renee M. Wachter, Chancellor University of North Dakota University of Wisconsin - Superior

Ronald T. Brown, President Rebecca Blank, Chancellor University of North Texas at Dallas University of Wisconsin-Madison

Mark A. Mone, Chancellor Gary A. Ransdell, President University of Wisconsin-Milwaukee Western Kentucky University

Stan L. Albrecht, President John M. Dunn, President Utah State University Western Michigan University

Matthew S. Holland, President Rex Fuller, President Utah Valley University Western Oregon University

Cecil P. Staton, Interim President Bruce Shepard, President Valdosta State University Western Washington University

Michael Rao, President Douglas Dykstra, Chancellor Virginia Commonwealth University Windward Community College-University of Hawaii Daniel J. Bernardo, Interim President Washington State University Barry M. Maloney, President Worcester State University Christine Sobek, President Waubonsee Community College Added after 8/31/15: M. Roy Wilson, President Wayne State University James B. Milliken, Chancellor The City University of New York Charles A. Wight, President Weber State University Robert L. Caret, Chancellor University System of Maryland James Schmotter, President Western Connecticut State University

cc: Ted Mitchell, Under Secretary of Education Jamienne S. Studley, Deputy Under Secretary of Education