Case Against
Opponents of the administrative criteria approach suggest that, while each of the proposed requirements may sound good in theory, the challenge comes in the practical implementation. They note each additional administrative criterion would require federal, state, local government, and/or accreditation agencies to develop new regulations, procedures, data collection, reports, and forms to comply with them. They suggest one should then imagine all the time and effort it would take from thousands of government and accreditation agency workers to execute the administrative processes once they’ve been put in place.
More importantly, opponents suggest, imagine program administrators and teachers who are already busy and stretched thin. First, they would need to complete all the steps to apply for their program. If successful, they would then need to continue to collect data and file reports to stay eligible. Opponents observe even some early Short-Term Pell supporters who helped craft the initial bills introduced several years ago now express concern over the number and complexity of criteria that have been added. They worry fewer programs are going to apply than we want if all or most of the additional criteria are adopted, well-intentioned as they may be.
Opponents also argue some of the criteria are redundant. For example, they suggest the requirement a program be on the ETPL (#2) and the requirement of an additional administrative determination that the program provides training for high-skill, high-wage jobs found in the area (#3) are duplicative.
Finally, opponents suggest this approach leads to a heavy administrative burden for institutions even though the input criteria are only indirect indicators that cannot guarantee quality outcomes for students. Better, they suggest, to directly measure the desired outcomes like graduation rates, job placement rates, and earnings increases.