On my solo road-trip to Orlando today for AIR Forum 2014, it occurred to me that people are still not thinking about the ratings system (PIRS) and gainful employment (GE) the way I am.

I am not convinced that PIRS is a real thing. Certainly the Department has spent a lot of time and effort to create something, including the illusion that PIRS is real.

Why? Because both GE and PIRS attempt to do the same thing – eliminate bad actors and low performing programs/institutions from Title  IV eligibility. Since we don’t have details on PIRS, the only difference we can really point to is that GE is about disqualifying programs and PIRS is about disqualifying institutions.

So, if you are a member of Congress or congressional staff working on the reauthorization of the higher education act, are you going to pick one or both? Given the nature of the lobbying and letters of support and opposition you might receive, would you consider combing the two? Especially in light of the argument that GE should apply to all programs.

If you were a lobbyist and became convinced that something would be done, would you grudgingly support program-level effects v. institution-level? Especially if student preparation is factored in to the mix with other measures than earnings and debt repayment?

Do policy-makers and law-makers want two different consumer ratings system that accomplish essentially the same thing? To me, two ratings seems to add more confusion than helping students and family.

The cynic in me wonders if PIRS is simply a way to justify GE for all programs as a reasonable compromise.