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entitled 'Postsecondary Education: Many States Collect Graduates' 
Employment Information, but Clearer Guidance on Student Privacy 
Requirements Is Needed' which was released on September 27, 2010. 

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Report to Congressional Committees: 

United States Government Accountability Office:
GAO: 

September 2010: 

Postsecondary Education: 

Many States Collect Graduates' Employment Information, but Clearer 
Guidance on Student Privacy Requirements Is Needed: 

GAO-10-927: 

GAO Highlights: 

Highlights of GAO-10-927, a report to congressional committees. 

Why GAO Did This Study: 

Postsecondary education plays an important role in producing a skilled 
workforce able to compete in the global economy. Some stakeholders 
have suggested that collecting information on graduates’ employment 
outcomes—whether they are employed in their field of study, for 
example—will provide better information to help assess the impact of a 
postsecondary education. The Higher Education Opportunity Act directed 
GAO to study the information that states have on the employment 
outcomes of postsecondary graduates. This report describes (1) the 
extent and purposes for which states collect employment-related 
information and the challenges they faced in doing so, (2) potential 
approaches to expanding states’ collection efforts across states and 
nationwide, and (3) how selected states and schools collaborate with 
employers to align education and workforce needs. To address these 
objectives, GAO reviewed relevant research and interviewed officials 
from the U.S. Departments of Education (Education) and Labor, as well 
as postsecondary institutions, state agencies, and employers in seven 
states and two countries selected based on their data collection 
capabilities. 

What GAO Found: 

Twenty-six states collect some employment-related data, such as data 
on salary and industry, on individual postsecondary graduates by 
linking student databases with states’ labor data, according to a 
national 2010 study of state education databases. Officials in seven 
states GAO contacted reported using graduates’ employment data for a 
variety of purposes, including economic development and institutional 
feedback. For example, one state reported using the data to compile 
information on the educational level of the local workforce to 
accommodate an out-of-state employer interested in opening offices in 
that area. However, some stakeholders cautioned against potentially 
inappropriate uses of the data, such as holding institutions 
accountable for the employment outcomes of graduates, noting that such 
outcomes are often beyond schools’ control. Additionally, some state 
officials said that they faced challenges in their data collection 
efforts, including the means by which they can appropriately link 
student and employment data and comply with the Family Educational 
Rights and Privacy Act (FERPA), which prohibits disclosing a student’s 
education records without written consent. Education officials 
acknowledged that confusion exists among some states and said they are 
planning to provide further guidance through various means, but as of 
September 2010, these plans had not been implemented. 

A review of relevant literature and interviews with state officials 
and experts helped identify three potential approaches for expanding 
the collection of graduates’ employment data, but many stakeholders 
emphasized the need to decide upon the specific purposes of the system 
prior to creating it. Possible approaches include expanding direct 
state-to-state data sharing, using a third party to expand interstate 
data sharing, and expanding existing national education-related 
surveys. An advantage of state-to-state data sharing is to follow 
individual students who go to school in one state and get a job in 
another. However, many stakeholders noted that sharing student data 
across states raises privacy concerns under FERPA, much like sharing 
data across different agencies within the state. In Australia and the 
United Kingdom, postsecondary institutions conduct national surveys of 
all recent graduates to obtain employment and other outcome 
information. 

States and schools that GAO contacted collaborate with employers to 
align education and workforce needs in several ways, including through 
workforce investment boards, advisory committees, and employer 
surveys. The extent of school efforts to partner with employers varied 
depending on the mission and goals of the institution, with community 
colleges and vocational schools—with their emphasis on career and 
technical training—making greater use than 4-year schools of advisory 
committees. For example, a private, nonprofit technical school in one 
state has an advisory committee for each program that drives the 
curriculum for that program. On the basis of employer input, the 
school discontinued its auto body program because of a lack of 
opportunities and began networking with employers to identify programs 
in new areas. 

What GAO Recommends: 

GAO recommends that Education clarify means by which states can 
collect and share graduates’ employment information under the Family 
Educational Rights and Privacy Act and establish a time frame for 
doing so. Education agreed with the recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-10-927] or key 
components. For more information, contact Katherine Iritani, 202-512-
7215, iritanik@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

About Half of States Collect Employment-Related Information on 
Graduates for a Variety of Purposes, but Compliance with Student 
Privacy Requirements Presents Challenges: 

Several Potential Approaches Exist for Expanding the Collection of 
Graduates' Employment Data: 

States and Schools Collaborate with Employers in Several Ways to Align 
Education and Workforce Needs: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Selected Characteristics of States' Postsecondary Student 
Unit Record Data Systems: 

Appendix III: Examples of Selected National Surveys of Postsecondary 
Education Students: 

Appendix IV: Structure of Postsecondary Education in Australia and 
United Kingdom and Data Collection Methods: 

Appendix V: Comments from the Department of Education: 

Appendix VI: GAO Contacts and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Data Capabilities of Selected States and Extent to Which 
These States' Postsecondary Data Systems Collect Certain Education and 
Employment Data on Graduates: 

Table 2: Description of Selected Possible Approaches to Expand the 
Collection of Graduates' Employment Information: 

Figure: 

Figure 1: States Maintaining Postsecondary SUR Databases That Capture 
Employment-Related Data from Unemployment Insurance Wage Records: 

Abbreviations: 

B&B: Baccalaureate and Beyond: 

BPS: Beginning Postsecondary Students: 

ELS: Education Longitudinal Study: 

FERPA: Family Educational Rights and Privacy Act: 

HEOA: Higher Education Opportunity Act: 

K-12: kindergarten through 12th grade: 

SHEEO: State Higher Education Executive Officers: 

SUR: student unit record: 

TAFE: Training and Further Education: 

UI: unemployment insurance: 

WRIS: Wage Record Interchange System: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

September 27, 2010: 

The Honorable Tom Harkin:
Chairman:
The Honorable Michael B. Enzi:
Ranking Member:
Committee on Health, Education, Labor and Pensions:
United States Senate: 

The Honorable George Miller:
Chairman:
The Honorable John Kline:
Ranking Member:
Committee on Education and Labor:
House of Representatives: 

While individuals may pursue postsecondary education for multiple 
reasons, one of the key reasons for doing so is to obtain employment. 
[Footnote 1] Postsecondary education plays an important role in 
producing a skilled workforce able to compete in the global economy. 
To this end, the U.S. Department of Education (Education) provided 
more than $110 billion in financial aid in fiscal year 2009 to help 
students finance the cost of a postsecondary education. In today's 
economic climate, and because of the escalating costs of postsecondary 
education, policymakers and consumers have noted the need for reliable 
information about what happens to students after they graduate. For 
instance, questions about college graduates from different programs 
arise. Among them are the following: Are the graduates employed? Are 
they working in their field of study? Are they working in another 
state? To follow students' progress from postsecondary education to 
the workforce over time and across state lines, there is growing 
interest in examining the employment information states currently are 
collecting, and the feasibility of collecting data across states to 
address student mobility. 

Section 1102 of the Higher Education Opportunity Act (HEOA) directed 
GAO to study the information that states have on employment of 
postsecondary education graduates.[Footnote 2] Essentially, the 
mandate requires a study of the availability of information at the 
state level regarding postsecondary graduates' employment, possible 
options for collecting and displaying such data, and how industry 
evaluates postsecondary education programs. This report addresses the 
following questions: (1) To what extent and for what purposes are 
states collecting employment-related information on postsecondary 
graduates, and what challenges have they faced in doing so? (2) What 
are the potential approaches and challenges to expanding the 
collection of graduates' employment information across states and 
nationwide? (3) How do selected states and postsecondary institutions 
collaborate with employers to align education and workforce needs? 

To determine the extent to which states collect employment information 
on postsecondary graduates and the methods used to collect such 
information, we reviewed relevant research and studies, and consulted 
with subject matter experts. We reviewed information from a 2007 
report by the Lumina Foundation[Footnote 3] and a 2010 report by the 
State Higher Education Executive Officers (SHEEO),[Footnote 4] to 
obtain information on the extent to which states are collecting 
employment-related and other outcome information on postsecondary 
education graduates, and how states obtain such information. In 
addition, to further understand how states collect, use, and display 
graduates' employment-related information, we selected seven states--
Colorado, Connecticut, Florida, Indiana, Michigan, North Dakota, and 
Washington--for a combination of site visits and telephone interviews. 
These states were selected to reflect a geographically diverse set of 
states with a range of abilities to collect student and employment 
information. Within each selected state, we interviewed officials from 
the departments of higher education and labor; representatives from 
selected public, private, and for-profit postsecondary institutions, 
such as 2-year and 4-year colleges; and one or more employers. Our 
findings from these states are for illustrative purposes only and are 
not generalizable nationally. Additionally, while we asked states 
about what they did to validate the data they collect on students, we 
did not use data collected by states to substantiate any of our 
findings. 

To identify the potential approaches and challenges for expanding 
efforts to collect graduates' employment information, we focused on 
the states' efforts to share data both internally and with other 
states.[Footnote 5] We also interviewed officials from federal and 
state education and labor departments, experts in the areas of state 
student data systems and postsecondary education, as well as 
representatives from postsecondary education organizations and 
institutions. We also examined postsecondary data collection systems 
of two selected countries--Australia and the United Kingdom--to obtain 
an international perspective (see appendix IV). We selected these 
countries primarily on the basis of expert recommendations about 
countries known to be active in collecting outcome data on 
postsecondary graduates and preparing graduates for the workforce. In 
addition, we reviewed the Family Educational Rights and Privacy Act 
(FERPA), which includes requirements related to the use and disclosure 
of data on individual students.[Footnote 6] To determine how selected 
states, schools, and employers identify and address workforce needs, 
we interviewed subject matter experts and officials in our seven 
selected states, including members of local workforce organizations 
and employers, and reviewed relevant provisions of the Workforce 
Investment Act of 1998.[Footnote 7] 

We conducted this performance audit from July 2009 to September 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. Appendix I 
discusses our scope and methodology in further detail. 

Background: 

A growing number of states are recognizing the potential of collecting 
data at the state level to inform changes in policy and practice that 
can lead to improved educational outcomes for students. State-level 
student unit record (SUR) data systems are one example of how 
individual students can be tracked over time--often called 
longitudinal data systems--as they move through the education system. 
In each state, a number of separate SUR data systems containing 
individually identified student data may exist at all levels of the 
education system. For example, a state may have multiple SUR systems 
that capture information on each student's educational data from 
kindergarten through 12th grade (K-12), with each school or school 
district maintaining its own SUR database, and other SUR systems that 
capture information on students at postsecondary institutions. Other 
state data systems capture information on people employed in the 
state. However, these systems historically have not been integrated 
with each other and therefore have not allowed for the tracking of 
students as they progress from one education level to the next and 
finally into the workforce. Furthermore, there is considerable 
variation across data systems with respect to the data elements 
collected. The focus of this report is on state-level SUR data systems 
containing postsecondary data that other research has found are 
generally maintained by the state's department of higher education or 
a similar agency that coordinates postsecondary education efforts. 

The types of student data maintained in postsecondary SUR data systems 
include the following: 

* basic demographic and enrollment data such as name, gender, 
ethnicity, major, degree granted, and academic history and: 

* financial aid information such as family income, expected family 
contribution, and financial assistance from state, federal, and other 
sources. 

Because most SUR databases historically have contained only education 
information, states must use other sources to capture wage and other 
employment-related information. One such source is the unemployment 
insurance (UI) database, which contains wage records on certain 
workers in the state and is maintained by all states as part of their 
administration of the federal unemployment insurance program. States' 
UI wage records generally include employees' wages, industry, and 
Social Security number. States compile UI wage records from data 
submitted each quarter by employers. Although UI wage records contain 
basic wage information for the majority of workers, certain categories 
of employees are excluded, such as self-employed persons, independent 
contractors, federal employees, and military personnel.[Footnote 8] 

At the time of our review, several federal initiatives were under way 
that promoted the linkage of education to employment databases. One 
such initiative is Education's Grant Program for Statewide 
Longitudinal Data Systems (SLDS), authorized by the Educational 
Technical Assistance Act of 2002,[Footnote 9] through which Education 
awards competitive grants to states for the development of 
longitudinal data systems based on individual student records. While 
the grants initially focused on integrating the various K-12 systems 
maintained by schools and school districts, the focus has recently 
shifted to following students from prekindergarten through 
postsecondary education and into the workforce. In fiscal year 2010, 
Education awarded $250 million in SLDS grants to 20 states. Another 
initiative is the Department of Labor's (Labor) Workforce Data Quality 
Initiative, which supports the development of longitudinal data 
systems that integrate education and workforce data using funds 
provided under the Consolidated Appropriations Act, 2010.[Footnote 10] 
Labor announced the availability of approximately $12.2 million to 
fund these competitive grants, for which applications were due by 
August 2010. 

In establishing data linkages among agencies and sharing data from a 
student's education records, entities must be aware of and comply with 
FERPA, which generally affords parents and eligible students access to 
student education records while limiting the disclosure of those 
records to third parties.[Footnote 11] Specifically, FERPA requires 
educational agencies and institutions that receive Education funds-- 
such as schools, school districts, colleges, and universities--to 
provide parents and eligible students with access to education records 
and generally prohibits the disclosure of personally identifiable 
information from education records without the prior written consent 
of the parent or eligible student, unless an exception to the FERPA 
general consent requirement applies. One exception to the general 
consent requirement in FERPA permits educational agencies and 
institutions to disclose, without consent, personally identifiable 
information from students' education records to state and local 
educational authorities for the purpose of an audit or evaluation of 
federal-or state-supported education programs, or for the enforcement 
of or compliance with federal legal requirements that relate to those 
programs.[Footnote 12] Representatives of state and local educational 
authorities--such as a state educational agency--may nonconsensually 
redisclose personally identifiable information from students' 
education records on behalf of the educational agency or institution 
in accordance with the redisclosure requirements of FERPA.[Footnote 
13] That is, the redisclosure must meet the statutory and regulatory 
exceptions to consent in FERPA. Accordingly, Education has interpreted 
FERPA to permit an educational authority to redisclose personally 
identifiable information from education records to another educational 
authority if the latter entity has the legal authority to audit or 
evaluate the federal-or state-supported education program of the 
educational agency or institution that disclosed the education records 
in the first place.[Footnote 14] 

About Half of States Collect Employment-Related Information on 
Graduates for a Variety of Purposes, but Compliance with Student 
Privacy Requirements Presents Challenges: 

About half of all states collect employment-related information on 
postsecondary graduates. This is usually accomplished by linking the 
state's postsecondary data system with labor data, such as UI wage 
records maintained by state labor agencies. According to the 2010 
study on postsecondary data systems conducted by SHEEO, 45 states, 
including the District of Columbia, have at least one postsecondary 
data system[Footnote 15] (see app. II for a list of states with 
postsecondary systems and their characteristics). Of these states, 26 
have the capacity to capture employment information by linking their 
SUR data system with other state-level labor/workforce data, such as 
UI wage records (see figure 1). 

Figure 1: States Maintaining Postsecondary SUR Databases That Capture 
Employment-Related Data from Unemployment Insurance Wage Records: 

[Refer to PDF for image: illustrated U.S. map] 

State has no postsecondary SUR data system: 
Delaware: 
Idaho: 
Iowa: 
Michigan: 
Nebraska: 
New Hampshire: 

State has a postsecondary SUR data system: 
Alabama: 
Arizona: 
Arkansas: 
Colorado: 
Connecticut: 
District of Columbia: 
Hawaii: 
Illinois: 
Louisiana: 
Massachusetts: 
New Jersey: 
New York: 
Pennsylvania: 
South Carolina: 
South Dakota: 
Tennessee: 
Vermont: 
Wisconsin: 
Wyoming: 

State has a postsecondary SUR data system and links it with UI data: 
Alaska: 
California: 
Florida: 
Georgia: 
Indiana: 
Kansas: 
Kentucky: 
Maine: 
Maryland: 
Minnesota: 
Mississippi: 
Missouri: 
Montana: 
Nevada: 
New Mexico: 
North Carolina: 
North Dakota: 
Ohio: 
Oklahoma: 
Oregon: 
Rhode Island: 
Texas: 
Utah: 
Virginia: 
Washington: 
West Virginia: 

Sources: SHEEO Report: Strong Foundations: The State of State 
Postsecondary Data Systems,State Higher Education Executive Officers 
(July 2010); Art Explosion (map). 

Note: According to SHEEO, Iowa had limitations to its data system and 
enrollment numbers that precluded it from being included in the report. 

[End of figure] 

Further, according to the SHEEO report, most of the state 
postsecondary data systems include information on public institutions 
within the state.[Footnote 16] Of the 26 states with postsecondary 
data systems that linked to employment data, 24 collect data from both 
public 2-and 4-year institutions and the other 2 states collect data 
only from public 4-year institutions. Furthermore, 8 of the 26 states 
collect data from independent, nonprofit institutions, and 5 collect 
data from for-profit institutions. 

The types of employment-related data collected by the 26 states that 
link student data with labor data include the following: 

* whether graduates were employed in-state, 

* wages earned, 

* employer name, and: 

* industry of employment. 

Of the 7 states we selected for review, 6 have one or more SUR data 
systems containing postsecondary data, and 4 states linked those data 
systems to labor data to capture employment information on graduates. 
Florida state education officials reported that they also link their 
postsecondary data system to federal databases such as those 
maintained by the U.S. Postal Service, Office of Personnel Management, 
and Department of Defense to obtain employment data on federal 
employees. Since UI wage records do not capture information for 
federal employees, this capability allows Florida officials to obtain 
employment information on postsecondary graduates who are employed by 
the federal government. 

Some of the specific education and employment data elements collected 
on postsecondary graduates by the selected states include individual 
students' courses of study during college, job obtained within a 
particular industry, their salary once they were employed, and the 
type of financial assistance they received while in college (see table 
1). 

Table 1: Data Capabilities of Selected States and Extent to Which 
These States' Postsecondary Data Systems Collect Certain Education and 
Employment Data on Graduates: 

Characteristics of selected states' postsecondary data systems: Has 
postsecondary data system; 
Selected states: Colorado: [Check]; 
Selected states: Connecticut[A]: [Check]; 
Selected states: Florida: [Check]; 
Selected states: Indiana: [Check]; 
Selected states: Michigan: [Empty]; 
Selected states: North Dakota: [Check]; 
Selected states: Washington: [Check]. 

Characteristics of selected states' postsecondary data systems: Links 
postsecondary data system to labor data; 
Selected states: Colorado: [Empty]; 
Selected states: Connecticut[A]: [Empty]; 
Selected states: Florida: [Check]; 
Selected states: Indiana: [Check]; 
Selected states: Michigan: [Empty]; 
Selected states: North Dakota: [Check]; 
Selected states: Washington: [Check]. 

Data elements collected: Course of study; 
Selected states: Colorado: [Check]; 
Selected states: Connecticut[A]: [Check]; 
Selected states: Florida: [Check]; 
Selected states: Indiana: [Check]; 
Selected states: Michigan: [Empty]; 
Selected states: North Dakota: [Check]; 
Selected states: Washington: [Check]. 

Data elements collected: Job obtained within employer's industry; 
Selected states: Colorado: [Empty]; 
Selected states: Connecticut[A]: [Check]; 
Selected states: Florida: [Check]; 
Selected states: Indiana: [Check]; 
Selected states: Michigan: [Empty]; 
Selected states: North Dakota: [Check]; 
Selected states: Washington: [Check]. 

Data elements collected: Whether job is related to course of study; 
Selected states: Colorado: [Empty]; 
Selected states: Connecticut[A]: [Empty]; 
Selected states: Florida: [Empty]; 
Selected states: Indiana: [Empty]; 
Selected states: Michigan: [Empty]; 
Selected states: North Dakota: [Empty]; 
Selected states: Washington: [Empty]. 

Data elements collected: Salary; 
Selected states: Colorado: [Empty]; 
Selected states: Connecticut[A]: [Check]; 
Selected states: Florida: [Check]; 
Selected states: Indiana: [Check]; 
Selected states: Michigan: [Empty]; 
Selected states: North Dakota: [Check]; 
Selected states: Washington: [Check]. 

Data elements collected: Student satisfaction with job preparation; 
Selected states: Colorado: [Empty]; 
Selected states: Connecticut[A]: [Empty]; 
Selected states: Florida: [Empty]; 
Selected states: Indiana: [Empty]; 
Selected states: Michigan: [Empty]; 
Selected states: North Dakota: [Empty]; 
Selected states: Washington: [Empty]. 

Data elements collected: Financial aid received; 
Selected states: Colorado: [Check]; 
Selected states: Connecticut[A]: [Check]; 
Selected states: Florida: [Check]; 
Selected states: Indiana: [Check]; 
Selected states: Michigan: [Empty]; 
Selected states: North Dakota: [Check]; 
Selected states: Washington: [Check]. 

Source: GAO analysis of data capabilities of selected states and the 
following data elements specified in HEOA mandate: type of job 
obtained, whether job was related to course of study, starting salary, 
student's satisfaction with his or her preparation for job, guidance 
provided with respect to securing job, and type of assistance received 
for recipients of federal student aid. 

[A] While Connecticut does not link its postsecondary SUR data system 
to UI wage records, a state labor official said that the state has 
linked postsecondary data provided directly from public postsecondary 
institutions to UI wage data to capture certain labor elements 
required for annual reporting requirements. 

[End of table] 

In contrast, we found that occupational information was generally not 
available in states' labor systems, in part because their UI wage 
records often do not capture this information. Such information can 
indicate whether an individual got a job in a field related to his or 
her course of study during school. The UI wage records maintained by 
states commonly contain data that identify the industry--such as 
health care or retail--that employed individuals, but according to 
Labor, state labor agencies generally do not require employers to 
identify occupations in a way that would reflect the type of job--such 
as nurse or cashier. An industry code would indicate, for example, 
that a graduate with a nursing degree or certificate is employed in 
the health care industry but not whether the graduate is employed as a 
nurse or an administrative assistant. Several state officials and 
experts we spoke with believed that collecting the occupation code 
from employers would be valuable. However, some also acknowledged that 
this would require burdensome and costly system changes for both 
states and employers. One official in Connecticut estimated that it 
would initially cost the state approximately $800,000 to add 
occupation codes to its unemployment insurance data system, and about 
$400,000 each year thereafter. 

Our selected states also reported that they were not able to use their 
data systems to gauge students' satisfaction with the preparation they 
received for the job obtained. Instead, student satisfaction 
information was usually collected through surveys administered by 
postsecondary institutions. For example, state officials and 
representatives at some institutions we interviewed said that student 
satisfaction surveys were typically conducted by for-profit 
institutions and certain professional programs at 4-year universities 
in the state because these schools were required to collect outcome 
information, such as placement rates, in order to satisfy national 
accreditation requirements. 

Federal grant funds could result in further changes to states' systems 
for capturing employment information on graduates. All 7 states we 
contacted had received federal SLDS grants from Education, and some 
have used or planned to use these grants in part to develop student 
data systems, or expand their efforts to capture employment data using 
existing SUR data systems, according to state officials. For example, 
Colorado, which had a SUR data system containing postsecondary data 
but was not capturing any employment data from its UI wage record 
system, had established in 2009 a Government Data Advisory Board to 
oversee, among other things, the development of a comprehensive data 
system that would allow data to be collected on students from 
prekindergarten through their entry into the workforce. According to 
officials in Michigan, which had no postsecondary SUR database in 
place, the state planned to use the grant to develop a data system 
that linked K-12, postsecondary, and workforce data. 

Officials in Selected States Report Using Graduates' Employment Data 
to Promote Economic Development, Provide Institutional Feedback, and 
Raise Consumer Awareness: 

Selected states reported using graduates' employment-related data for 
a variety of purposes: 

* Promote economic development. One official in Florida mentioned that 
the state workforce agency used the data to compile information on the 
educational level of the local workforce population at the request of 
an out-of-state employer that was interested in opening offices in 
that area. State workforce officials in Indiana also said that they 
use the student unit record database to inform prospective employers 
about the educational attainment of local postsecondary graduates, 
their geographic location within the state, and whether these 
graduates are still seeking employment. Officials in North Dakota's 
Department of Commerce said that they combine graduates' employment 
information with labor market information to determine the extent to 
which graduates are prepared for employment in high-growth industries. 

* Provide institutional feedback. North Dakota used the database to 
provide feedback to institutions. Using the data, the state compiled 
reports on the total number of degrees awarded, by institution, and 
whether graduates who earned those degrees were employed in-state. 
Indiana used its database to approve a master of liberal arts program 
at a particular campus. To do so, the state analyzed employment 
outcomes of graduates of a similar liberal arts program at other 
campuses and determined that these individuals were more likely to be 
employed in-state and have higher earnings after completing their 
degree. 

* Raise consumer awareness. To better inform prospective students, 
some states that collect employment information reported that they 
make aggregate data and annual reports on graduates' employment 
publicly available, generally through their state Web site. For 
example, according to a state education official in Florida, the state 
higher education agency publishes an annual outcomes report that 
provides information on numbers of graduates, average salary, and 
whether they are working in-state. This report provides aggregate 
employment information on graduates and is publicly available on the 
state's Web site. Furthermore, some institutions we contacted, 
including for-profit and 4-year schools, also reported providing 
outcome information on the school's or state's Web site such as 
placement rates and average salary. 

[Side bar: 

How Australia and the United Kingdom Use and Display Graduates’ 
Employment Information: 

Government officials we spoke with in Australia reported using 
education and employment information—collected through their 
Australian Graduate Survey—in a variety of ways. One way is to use the 
information as an accountability tool for overseeing universities that 
receive monetary incentives through a performance fund that is partly 
based on survey results. Australia also collects employment-related 
information on vocational education graduates and uses data collected 
at the time of enrollment and completion to determine how many 
students are trained in specific occupations, evaluate performance of 
training providers, and allocate funding, among other purposes. In the 
United Kingdom, employment information is also obtained through 
surveys of university and college graduates, which are used to help 
rank these institutions. Both countries make survey results publicly 
available through the Web sites of agencies that administer the 
surveys. For example, Australia publishes five annual reports based on 
information collected through the graduate surveys and made available 
online through the agency’s Web site. These reports provide 
information on graduates such as earnings and course experiences. 
Prospective students can also use an online tool to view employment 
information on vocational schools, and can query the data through this 
tool to customize the data to their needs. End of side bar] 

However, some stakeholders cautioned against what they considered to 
be potentially inappropriate uses of the data. Stakeholders raised 
concerns that employment outcomes that are beyond a school's control 
should not be used as a basis for assessing the quality of the 
education provided by the school or adequacy of preparing students for 
employment. For example, several postsecondary institution 
representatives in Michigan mentioned that many external factors such 
as the local economy are not captured by data systems even though they 
might influence whether graduates can successfully obtain employment. 
In addition, stakeholders were also concerned that employment outcome 
data may not be comparable from one institution to another, depending 
on how specific data elements are defined, such as job placement rate. 
Finally, representatives from several 4-year institutions and higher 
education associations noted that there are other reasons students 
choose to go to college besides employment, including enhancing skills 
and engaging in lifelong learning. 

Selected States Faced Challenges in Their Data Collection Efforts, 
Particularly Understanding Requirements for Protecting Student Privacy: 

One challenge cited by several state officials we interviewed was how 
to link postsecondary graduate student and employment data without 
violating student privacy requirements under FERPA. Linking student 
and employment data could entail sharing student records with entities 
outside education agencies, such as labor agencies, which in turn 
could violate FERPA. While FERPA may allow for the nonconsensual 
disclosure of personally identifiable information from student records 
with state educational agencies, as long as it is for a purpose 
permitted under one of FERPA's exceptions, such as for program 
evaluation to improve instruction,[Footnote 17] it does not explicitly 
address the nonconsensual disclosure of personally identifiable 
information from education records to a state department of labor for 
the purpose of linking student and employment records or how these 
linkages could be performed. Consequently, some states have been 
unwilling to link their education data systems to labor data. 
Officials in Colorado and Michigan--states not linking education data 
to UI wage records--cited FERPA as a roadblock to their states' 
efforts to develop a comprehensive database that follows students 
after graduation. Moreover, the SHEEO report found that over half of 
states cited FERPA as a barrier to linking postsecondary data systems 
with labor data. 

The means by which state education agencies can link or share student 
data consistent with FERPA can be complicated. According to 
stakeholders, how a state captures, maintains, and uses SUR data can 
depend on the individual state's laws, systems, or databases, and 
state educational agencies may need to take certain steps, such as 
establishing data use agreements among state agencies that share data 
in order to comply with FERPA and applicable state laws. States such 
as Florida and Indiana have established systems whereby educational 
data are not shared with the labor agency;[Footnote 18] rather, the 
labor agency provides data to the educational agency, which then 
performs the linking function in-house within an education agency or 
state university system.[Footnote 19] 

Some state officials and other stakeholders we interviewed said that 
states' varying interpretations of FERPA have caused confusion, with 
one national stakeholder adding that the stakeholder has called upon 
Education to clarify FERPA so that states understand how they can link 
education and employment data. Education officials acknowledged that 
despite the agency's issuance of FERPA regulations in December 9, 
2008, confusion remains among states in how to interpret FERPA's 
redisclosure provisions for sharing education data with noneducation 
entities.[Footnote 20] Education officials said that they were taking 
steps to clarify how states can develop and use data in statewide 
longitudinal data systems consistent with FERPA. As previously 
discussed, many states are developing or enhancing statewide systems 
under Education's Grant Program for Statewide Longitudinal Data 
Systems, which supports data integration including education and 
workforce information. Education officials specifically said they were 
planning to improve the guidance and technical assistance available to 
education data stakeholders through activities that include issuing a 
Notice of Proposed Rulemaking; creating a Chief Privacy Officer 
position within Education; releasing technical briefs related to data 
security, confidentiality, and privacy; and launching a Privacy 
Technical Assistance Center. As of September 2010, Education said it 
was engaged in implementing these actions, with a timeline for 
completion expected to occur during fall 2010 and early winter 2011. 
At the time of this report, Education had not provided information on 
whether its guidance would specifically address linking education and 
employment data. 

In addition, several state officials we spoke with were also 
challenged by trying to collect information on graduates who obtain 
employment outside of their state. Specifically, some state officials 
reported that existing postsecondary data systems are able to track 
students within the boundaries of a given state, but they have been 
rarely used to track students across state lines, in part based on the 
lack of common data elements, standardized definitions, and 
interoperable data systems. 

Several Potential Approaches Exist for Expanding the Collection of 
Graduates' Employment Data: 

On the basis of our review of relevant literature and interviews with 
numerous state officials and subject matter experts, we identified 
several potential approaches for expanding the collection of 
postsecondary graduates' employment information on a broad level, such 
as across states or nationwide. These include direct state-to-state or 
regional data-sharing arrangements, using third parties to assist 
state efforts in a variety of ways, and expanded national surveys that 
collect employment-related data.[Footnote 21] Each approach presents 
challenges. Regardless of how collection efforts might expand, many 
state officials and other stakeholders we spoke to emphasized the 
importance of having a clear understanding of the specific policy 
questions that the data system should address prior to creating it. 
For example, state officials in Colorado noted that when the policy 
questions are known, it makes determining the required data elements 
needed to answer those questions easier and can decrease unnecessary 
data collection and costs. 

Expanding Direct State-to-State Data Sharing: 

One approach to expanding collection efforts is for states to directly 
share postsecondary graduates' employment data with each other, which 
can be done through data-sharing agreements. This approach allows 
states to expand their data on graduates' subsequent employment and 
allows analysis at the individual student or postsecondary institution 
level.[Footnote 22] One example of the use of this approach is the 
data-sharing agreement between the Washington State Board for 
Community and Technical Colleges and Oregon's labor agency to provide 
UI wage data from the latter state. Board officials said this 
agreement allows the board to follow the employment progress of 
students who graduate from community and technical colleges in 
Washington and find a job in Oregon. This additional employment 
information has enabled Washington to better evaluate the education 
students received, since it has more data to determine whether 
Washington community college graduates are working in the field in 
which they were trained. The SHEEO report noted that only three 
statewide postsecondary data systems shared data with other states. 

Several key challenges that affect interstate data-sharing agreements 
are similar to those associated with sharing data across agencies in 
the same state, including privacy concerns under FERPA, the lack of 
standardization of certain data elements, and coordinating ownership 
and allowable uses of the data, as well as other matters, sometimes 
referred to generally as governance issues. However, these challenges 
can be more complex when they arise across different states rather 
than within the same state. Education's current FERPA regulations do 
not explicitly address linking data between agencies of different 
states, so state officials told us they lack sufficient guidance on 
how data can be shared between states in a way that is consistent with 
the requirements of FERPA. Further, according to one stakeholder, many 
states have their own privacy laws in addition to FERPA, and this can 
create additional challenges for sharing data across states. 
Nonetheless, several national postsecondary education organizations 
have indicated that interstate data exchanges could be handled 
consistent with the requirements of FERPA if certain guidelines are 
followed, such as having state legislatures specifically authorize 
state agencies to create the exchanges. A second challenge is the lack 
of standard data elements among states that may use a different coding 
system: Even when a state's own agencies have agreed on what data to 
share with each other and how to standardize the coding, those same 
kinds of issues must be resolved again by agencies sharing data across 
states. Another challenge to sharing data across states involves 
governance issues such as who owns the data, who has the right to use 
them, and how data quality is managed and assured. 

Washington's approach to complying with FERPA--in seeking information 
on the employment of college graduates that had moved to a neighboring 
state, Oregon--entailed close supervision of the data and data-linking 
process. To maintain complete control over the student records and 
matching process, a staff member from one of the educational 
authorities in Washington will drive to the Oregon Employment Security 
Department and personally oversee the match and deliver the data back 
to the Washington board, according to a Washington state board 
official. The official said that the current agreement would comply 
with FERPA requirements. The official also noted that Washington will 
no longer obtain data from Idaho and Montana, as it had through 
separate agreements in the past, because it would take too much time 
to drive to those locations to conduct the match and the current 
procedure requires personal oversight of the matching process. 

Using a Third Party to Help Expand Interstate Data Sharing: 

A second potential approach for expanding data collection may be to 
have third parties help, by coordinating interstate data sharing, or 
by warehousing the relevant data from institutions or states. This 
involves having states select one or more unrelated entities to serve 
various functions such as facilitating data-sharing agreements and 
analyzing or warehousing data. Similar to the first approach, this 
approach allows states to follow students across state lines and 
analyze outcomes at student and institution levels; however, it also 
presents FERPA and other challenges.[Footnote 23] In 2007, Kentucky, 
Ohio, Tennessee, and West Virginia used the National Center for Higher 
Education Management Systems, a private nonprofit organization, to 
facilitate a data exchange designed to help the states examine 
postsecondary student mobility across their borders.[Footnote 24] 
Serving as a third party "broker," the center created exchange 
agreements with each state individually to resolve governance issues 
such as how the data would be shared and used. The states also used an 
independent "administrator" that received data from each state, 
matched data across states, and constructed database tables based on 
the designated data elements. A third party, according to officials 
from the center, can also develop standard data-sharing methodology 
that can be applied to multiple states. 

Another example of using a third party approach for sharing data is 
Labor's Wage Record Interchange System (WRIS). The WRIS facilitates 
the exchange of wage data among participating states for the purpose 
of assessing and reporting on employment and training under the 
Workforce Investment Act of 1998, among other purposes. States 
voluntarily participate in the WRIS, which acts like a third party by 
using the WRIS Clearinghouse to exchange wage data. According to Labor 
officials, the WRIS permits state workforce agencies to obtain wage 
data of individuals who have participated in workforce investment 
programs in one state, then subsequently taken a job in another. By 
participating in the WRIS, states can have a more robust picture of 
the effectiveness of their workforce investment programs, and are able 
to report more comprehensive outcomes against their performance 
measures, according to Labor documentation.[Footnote 25] 

In addition to performing these coordination and administrative 
functions, a third party could serve as a warehouse, maintaining all 
or some of the data content submitted by other databases, such as 
those maintained by state agencies' SUR databases or postsecondary 
institutions. Stakeholders suggested, for example, that the National 
Student Clearinghouse, a nonprofit institution that verifies student 
enrollment and other records on behalf of postsecondary institutions, 
could serve as a third party warehouse of a system that would expand 
current collection efforts.[Footnote 26] The Clearinghouse maintains 
enrollment data on over 92 percent of all postsecondary students, 
obtained directly from institutions, including public, private, and 
proprietary institutions, according to Clearinghouse officials. 
However, these data would still need to be linked to state department 
of labor wage records in order to furnish employment information on 
graduates. Clearinghouse representatives responded to this idea by 
emphasizing that all the parties, including the postsecondary 
institutions themselves, would have to agree to the arrangement, since 
local postsecondary institutions own any data that would be provided 
to the Clearinghouse. 

One challenge associated with the third party approach that some 
officials raised is how to pay for the third party, in addition to 
some of the same challenges with the state-to-state approach, 
including FERPA compliance and governance challenges, like data 
ownership. Recent data-sharing discussions among Hawaii, Idaho, 
Oregon, and Washington highlight governance issues in the third party 
context. Those states have initiated an effort to develop a 
"prototype" multistate data exchange to follow students from K-12 
through employment, according to an official from the third party 
coordinating the effort, the Western Interstate Commission for Higher 
Education.[Footnote 27] In addition to data ownership, use, and 
quality, those states have discussed other governance challenges: 

* How would the data system be organized (e.g., would the data reside 
with a third party)? 

* How can the states establish a governance board in a cost-effective 
way, who should sit that board, what kind of authority for that board 
is needed (such as individual state legislation), and what kind of 
agreements are needed? 

* How can the parties be motivated to continue working together, 
particularly in the event the shared data make some states appear 
better than others? 

Likewise, states would have to resolve how to analyze results once the 
data system is in place. The commission's report on this data exchange 
effort highlighted the magnitude of governance challenges, noting that 
the time and effort needed to establish governance rules for data 
exchange systems generally will likely be significantly greater than 
the time and effort needed to actually match the data from one state's 
database to another. 

Expanding National Surveys That Track Postsecondary Education Outcomes: 

A third potential approach for collecting more employment-related data 
on a larger number of postsecondary graduates is to expand existing 
national surveys.[Footnote 28] Several federal agencies and private 
organizations conduct national surveys to gather information on 
numerous education and workforce topics, including graduates' 
postsecondary education, employment, and other life experiences. (See 
appendix III for examples of relevant national surveys that collect 
information on postsecondary students and graduates.) For instance, 
Education's Baccalaureate and Beyond Longitudinal Study surveys a 
sample of graduating seniors to examine students' education and work 
experiences after they complete a bachelor's degree. That study 
gathers information on students' undergraduate experience and 
demographic background and follows groups of students over time to 
look at their workforce participation, income, and participation in 
graduate school programs, among other indicators. The study is 
designed to answer questions such as the following: 

* Ten years after college, what percentage of graduates work full-time 
at one job? 

* What percentage of recent graduates view their job as the start of a 
career? 

* What is the unemployment rate among college graduates 1 year after 
graduation? 

[Side bar: 

National Data Collection Approach Taken by Australia and the United 
Kingdom: 

In Australia, the primary mechanism to obtain employment outcome 
information on recent graduates of the country’s 4-year universities 
and vocational education sector is a survey of all such graduates, 
according to Australian officials. Universities administer the survey 
4 months after graduation, and information collected includes: 

* education (e.g., institution attended, degree earned, and major 
field of study), 

* satisfaction with the quality of graduates’ educational experience, 
and, 

* employment (e.g., employment status, job type, relation to course of 
study, and annual salary). 

Similarly, the United Kingdom obtains outcome information from 
graduates of universities on whether they are employed, are taking 
part in further study, or are not available for employment; the type 
of industry they are working in; and their salary. See appendix IV for 
details of the information collected in these two countries. End of 
side bar] 

Additionally, officials we interviewed at one university mentioned 
that one private survey, conducted by the National Association of 
Colleges and Employers, already provides information on average 
salaries of recent graduates and has information categorized by major 
and institution.[Footnote 29] One major advantage of surveys is that 
because students themselves provide the information, FERPA compliance 
is not an issue. However, existing surveys have limitations. For 
example, surveys that are able to bridge postsecondary education and 
employment, like the Baccalaureate and Beyond Longitudinal Study, are 
compiled infrequently: That study has followed groups of students who 
graduated in 1993 and 2000, and data collection is under way for a 
third group of 2008 graduates. Further, the Baccalaureate and Beyond 
Longitudinal Study is representative for graduating seniors nationally 
and across all majors, but is not representative of any given state or 
institution, precluding analyses at those levels.[Footnote 30] A few 
stakeholders also said that because surveys rely on self-reported 
information, they might be less reliable than other data sources. 
Other stakeholders noted that surveys sometimes have low response 
rates, and results might have significant lag time between data 
collection and data publication, and incur costs each time a survey is 
administered. (See table 2 for a summary of the various approaches.) 

Table 2: Description of Selected Possible Approaches to Expand the 
Collection of Graduates' Employment Information: 

Possible approach: State-to-state data-sharing agreements: link one or 
more states' individual SUR data to other states' data; 
Benefits of approach: 
* Follows individual students across state lines, expanding the data 
states have on graduates' employment; 
* Builds on state systems already in place; 
* Makes data available at student, institution, and state levels, 
allowing for more detailed analyses; 
* Allows for flexibility and low initial cost; 
Challenges: 
* Compliance with FERPA and differing individual state privacy laws 
across states; 
* Lack of standardization of data elements across states; 
* Coordination of governance structure, such as who controls the data 
and analyses; 
* Limited to states with SUR data systems that link graduates' 
education and employment data; 
* Limited institutional coverage of many SURs with respect to private 
and proprietary institutions; 
* Paying for states to create and follow these agreements; 
Example of approach: Washington state has a data-sharing agreement 
with Oregon to obtain employment data on its graduates. 

Possible approach: Third party intermediary: states use third parties 
to coordinate data sharing, linking, or housing graduates' employment 
data; 
Benefits of approach: 
* Follows individual students across state lines, expanding the data 
states have on graduates' employment; 
* Facilitates coordination of state agreements and analysis of data, 
according to some stakeholders; 
* Builds on state systems already in place; 
* Makes data available at student, institution, and state levels, 
allowing for more detailed analyses; 
* Could increase breadth of student information through use of the 
National Student Clearinghouse, according to some stakeholders; 
Challenges: 
* Compliance with FERPA and differing individual state privacy laws 
across states and with a third party; 
* Coordination of governance structure, including who the third party 
will be, in addition to other governance issues; 
* Lack of standardization of data elements across states; 
* Limited to states with SUR data systems that link graduates' 
education and employment data; 
* Paying for the third party assistance; 
* If using the Clearinghouse, might need postsecondary institutions' 
permission to use the data; 
Example of approach: Kentucky, Ohio, Tennessee, and West Virginia used 
a third party to help create postsecondary data sharing agreements 
among the four states, and to analyze the data. 

Possible approach: Expand existing national education-related surveys; 
Benefits of approach: 
* Provides information to policymakers to guide education and 
workforce policy; 
* Eliminates FERPA issue, since respondents themselves voluntarily 
provide information; 
* Could provide more information than could be obtained using only the 
UI wage records linked to SUR data, because UI wage records generally 
contain only whether a person is employed, the salary, employer name, 
and industry of employment; 
Challenges: 
* Low response rate and time delay between conducting survey and 
survey results can affect ability to capture current trends of overall 
population or generalize findings to all postsecondary graduates; 
* Self-reported data may be less reliable than linked SUR and UI 
information; 
* Paying for the survey, which incurs costs every time it is 
administered; 
* May not be representative at state or institution level, precluding 
analyses at that level; 
Example of approach: Other countries, specifically Australia and the 
United Kingdom, use surveys as a main source of their postsecondary 
graduates' employment information. 

Source: GAO interviews. 

[End of table] 

States and Schools Collaborate with Employers in Several Ways to Align 
Education and Workforce Needs: 

State and local workforce officials and postsecondary school 
representatives we interviewed said they collaborate with employers in 
various ways to keep abreast of workforce needs. At the state and 
local levels, these partnerships were generally facilitated through 
workforce investment boards established under the Workforce Investment 
Act of 1998,[Footnote 31] or in some cases by the state's department 
of labor, though other means were also used to cultivate ties with 
employers. 

Workforce officials in some states said that local workforce 
investment boards use the state workforce agency's labor market 
analysis to project high-growth occupations by industry in order to 
align education and training programs with employers' anticipated 
needs. For example, Michigan's No Worker Left Behind initiative uses 
labor market information to identify occupations that are in demand 
and will fund training only for those occupations. The state's 25 
local workforce investment boards then work with the business sector 
and postsecondary schools to help equip workers with skills required 
for those occupations. Similarly, Connecticut's Department of Labor 
uses labor market information to project occupational needs in the 
state and develops a profile for each industry. Local workforce 
investment areas then use this information to plan their education and 
training programs, some of which are delivered by community colleges. 
[Footnote 32] 

To promote partnerships with industry, Florida set up steering 
committees guided by local chamber of commerce and business leaders 
and embedded 13 centers--known as Banner Centers--at selected 
postsecondary institutions to promote coordination among local 
economic developers, employers, and schools. In Washington, the state 
workforce investment board, in conjunction with the state board 
representing public and private postsecondary schools, conducts an 
assessment every 2 years of the education and training credentials 
required to meet employer demand. The 2009 assessment showed that the 
largest gaps between supply and demand were in engineering, computer 
science, and the medical professions. It noted that the education 
system will need to expand in these fields to meet employer demand as 
would the number of students who are interested in and prepared for 
pursuing careers in these fields. Washington plans to survey employers 
as part of all subsequent assessments. In North Dakota, the oil and 
gas industry collaborated with the state workforce development office 
to assess the industry's workforce needs in light of a projected 
shortage of qualified workers in the state's labor pool. The 
industry's trade association partnered with the state to help identify 
skills needed--such as well drilling--and the state college designed a 
program around those skills. Another state college created a power 
plant technology program in response to industry demand for qualified 
power plant operators and hired one of the employer's retirees to head 
up the program, given his substantial experience in the industry. In 
turn, the industry contributed funding and equipment, such as 
simulators, for the classroom. North Dakota plans to conduct similar 
assessments for other industries, such as information technology and 
manufacturing, to help ensure that employers have access to a skilled 
labor pool. 

At the school level, the vast majority of the postsecondary schools we 
contacted relied on program advisory committees or informal 
discussions to obtain employer input in designing or updating academic 
programs. Fourteen of the 25 schools also surveyed employers in part 
to determine skills sought and satisfaction with recently hired 
graduates. Such collaboration often occurred at community colleges and 
for-profit vocational schools, given their focus on career and 
technical training, compared with 4-year schools whose stated mission 
is to provide a broad, comprehensive education. Nevertheless, 
officials from one 4-year university in Colorado said that certain 
programs, such as engineering, used advisory boards to inform program 
design, while at another university, in Washington, all of its degree 
programs had advisory boards to ensure classes were relevant to 
employer needs. 

* Advisory committees. Twenty-one of 25 postsecondary schools we 
contacted reported using advisory committees, which include business 
and industry leaders, to plan and develop their programs and 
curricula.[Footnote 33] A 4-year public school in Michigan has an 
employer advisory board consisting of 15 major corporations that 
advise the entire school and not just individual academic departments. 
At a private, nonprofit technical school in Washington, there is an 
advisory committee for each program that drives the curriculum for 
that program. On the basis of employer input, for example, the school 
discontinued its auto body program because of a lack of sufficient job 
opportunities and began networking with potential new employers. A for-
profit school in Michigan meets with its advisory committees each 
year, in part to ensure that technology being used in the classroom is 
up to date. 

* Informal communication. Twelve of the 25 schools we contacted said 
they cultivated ties with employers through informal communication. 
Schools maintained open lines of communication, for example, through 
luncheons with local business leaders to solicit feedback on the 
school and its graduates. The faculty of one community college in 
Indiana has built individual relationships with local businesses and 
meets directly with them. Fostering close relationships with employers 
enabled the faculty to incorporate employer needs into the classroom 
while helping students understand how classroom learning can be 
applied to the work world. In addition, several employers we spoke 
with said they had a good working relationship with schools, enabling 
them to provide school administrators with informal feedback on the 
quality of graduates they hired and whether the curriculum needed to 
be adjusted to meet employer needs. 

* Employer and graduate surveys. Surveying employers was a commonly 
used method among schools to determine what skills employers sought 
and employers' perception of how adequately recently hired graduates 
were prepared. In Indiana, a for-profit school surveyed its graduates 
to gauge how satisfied they were with the guidance they had received 
in preparing for and obtaining employment, while a community college 
surveyed graduates on how beneficial their coursework had been in 
helping them prepare to enter the job market. A community college in 
Indiana developed a workplace readiness certificate after survey 
results showed that employers' biggest demand was that graduates 
possess soft skills--the nontechnical skills and traits needed to 
function in a job, such as punctuality, teamwork, and work ethic. A 
for-profit school also in Indiana said it offers remedial training for 
graduates if employers are dissatisfied with their skills. 

Some community college officials said that once employer input is 
obtained, the colleges can adjust their curricula and add new training 
or degree programs very quickly (e.g., anywhere from under 2 months to 
1 year) to respond to employer needs. For example, officials at a 
community college in Indiana said they developed a new industrial 
technology program that met employers' needs for courses in advanced 
manufacturing. In contrast, officials at a 4-year school said that 
faculty, particularly if they are tenured, can be resistant to 
changing their program because their focus is on teaching rather than 
on the quality of jobs their graduates obtain. 

[Side bar: 

School and Employer Partnerships in Australia and the United Kingdom: 

One university in Australia that offers vocational education 
categorizes its courses according to the specific industry. It then 
seeks input from industry representatives to inform the programs and 
to keep apprised of emerging skill needs. Another university obtains 
employer feedback on the curriculum and faculty of its biomedical and 
science programs, and also surveys employers on the quality of 
university graduates hired. An administrator at a university in the 
United Kingdom told us that 6-8 employers serve as members of the 
school’s governing committee, and as many as 120 employers participate 
in an employer group that advises the school’s career services office. 
The university also surveys employers and uses other means to gauge 
their satisfaction with graduates hired. End of side bar] 

Conclusions: 

In an era of increasing focus on educational accountability and on 
U.S. competitiveness in a global economy, there are many merits to 
collecting employment data on postsecondary graduates and expanding on 
existing state data collection efforts. For example, collecting 
employment information on students that moved out of state could help 
close a knowledge gap when they obtain employment in another state. 
Some state officials and subject matter experts agree that such 
enhanced information could provide a more comprehensive picture, 
across states, of what happens to graduates when they enter the 
workforce, shedding light on the outcomes of education programs. A 
system that provides detailed information on the percentage of a 
school's graduates that land jobs, average starting salary, and 
whether they are employed in another state could also raise consumer 
awareness about education and employment outcomes, as long as this 
information is made public, for example, by posting the information on 
the state's or school's Web site. Just over half of the states collect 
employment information on their postsecondary graduates, and while 
there could be significant advantages in expanding current data 
collection efforts, there are also several inherent challenges in 
doing so. In particular, many states are unsure about how to collect 
and share the information while still protecting student privacy under 
FERPA. Education is planning to take several steps to clarify FERPA 
guidance and provide technical assistance. These are positive steps 
toward improving guidance, but it is not clear when the guidance will 
be available and whether it will specifically address states' concerns 
regarding how to develop or broaden their existing data collection 
systems in accordance with FERPA. Developing such guidance is 
important to addressing ongoing confusion and is particularly needed 
in view of federal grants that require states to specify how they will 
link their education and employment systems. Until such guidance is in 
place, the full potential of collecting longitudinal data within and 
across multiple states, while still ensuring necessary privacy 
protections, cannot be realized. 

Recommendation for Executive Action: 

To help address states' information needs, we recommend that the 
Secretary of Education develop and disseminate guidance that clarifies 
the means by which state education agencies can share student records 
to facilitate obtaining graduates' employment information while 
ensuring appropriate privacy protection under FERPA. In addition to 
establishing a time frame for implementation, this guidance should 
include how student records could be shared with state labor agencies, 
and how states can share data with one another. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to officials at the Departments of 
Labor and Education for their review and comment. Labor had no 
comments. Education provided a response, which is included as appendix 
V of this report, and technical comments, which we incorporated as 
appropriate. In its comments, Education agreed with our recommendation 
and noted that it has started several initiatives that are in various 
stages of action. Specifically, Education intends to propose 
amendments to FERPA regulations to clarify what is permissible under 
FERPA. According to Education, these amendments, if adopted, would 
clarify how states can effectively develop and use data in statewide 
longitudinal data systems while ensuring protection of individual 
privacy under FERPA. Education also stated it was creating a Chief 
Privacy Officer position and establishing a Privacy Technical 
Assistance Center to serve as a one-stop shop for state educational 
agencies and others for questions related to protecting privacy, 
confidentiality, and data security. In addition, Education is planning 
to release a new series of technical briefs on various issues related 
to the protection of personally identifiable information in student 
education records. 

We are sending copies of this report to the Secretaries of Education 
and Labor, as well as to relevant congressional committees. In 
addition, this report will also be available at no charge on GAO's Web 
site at [hyperlink, http://www.gao.gov/]. Contact points for our 
Office of Congressional Relations and Public Affairs may be found on 
the last page of this report. Major contributors to this report are 
listed in appendix VI. 

Signed by: 

Katherine M. Iritani: 
Acting Director, Education, Workforce, and Income Security: 

[End of section] 

Appendix I: Scope and Methodology: 

To address the objectives of this study, we used a variety of methods. 
Our overall approach included a review of relevant federal laws, 
literature, studies, and reports, as well as interviews with state 
education and workforce agency officials, representatives at all types 
of postsecondary education institutions (i.e., vocational, 2-year, and 
4-year schools that were either public, private not-for-profit, or 
private for-profit), employers, and database and postsecondary 
education experts. To provide an international context for our work, 
we reviewed relevant reports and studies and obtained recommendations 
from postsecondary education experts to identify countries that 
collect significant information on postsecondary students and that may 
have strong workforce development programs in place. We judgmentally 
selected seven states and two countries--Australia and the United 
Kingdom--where we spoke with officials from relevant education and 
workforce agencies, as well as postsecondary institutions, to help us 
understand their methods of data collection and workforce development 
planning. In conducting our review of states and other countries, we 
did not conduct independent reviews of their laws, but rather relied 
on statements attributable to government officials from those states 
and countries and reliable secondary sources, such as selected 
researchers, subject matter experts, and employers. We also contacted 
two accrediting bodies for their perspectives on our work. 

To identify the extent to which and for what purposes states collect 
employment-related information on postsecondary graduates, we 
identified a sample of seven states for site visits and telephone 
interviews and, within these states, interviewed state education and 
labor officials to determine what information is available on the 
employment outcomes of college graduates and how states are capturing 
this information. We also met with selected postsecondary education 
institutions to discuss the types of outcome data they report to the 
state, any additional outcome information they collect for internal 
purposes, and the methods used to collect such information. 
Additionally, we asked state officials, postsecondary institution 
representatives, and other subject matter experts about how states and 
institutions collect graduates' employment outcome information, any 
barriers or challenges they face in doing so, how this information is 
displayed, and for what purposes the information is used. 

To select our sample of states for review, we primarily relied on 
recommendations from postsecondary education experts and information 
from an external report published in 2007 by the Lumina Foundation 
entitled Critical Connections: Linking States' Unit Record Systems to 
Track Student Progress.[Footnote 34] This report is based on the 
results of a 50-state survey completed in 2006 by the National Center 
for Higher Education Management Systems that identifies the states 
that have postsecondary student unit record databases, the ability of 
these databases to link to employment-related data systems such as 
states' unemployment insurance wage records, and other data sources 
such as military records, federal employment data, and department of 
social services data, that provide employment outcome information. On 
the basis of a review of the Lumina Foundation report's state survey 
results, we grouped the states into the following four categories 
according to their data system capabilities: 

(1) Advanced data capabilities. States in this category had an 
operational student unit record data system for postsecondary 
students, experience linking student data to unemployment insurance 
wage records, and experience linking student data to additional 
sources that provide employment outcome information. 

(2) Emerging data capabilities. States in this category had an 
operational student unit record data system for postsecondary students 
and experience linking student data to unemployment insurance wage 
records, but did not have experience linking student data to other 
additional sources that provide employment outcome information. 

(3) Minimal capability. States in this category had an operational 
student unit record data system for postsecondary students, but did 
not have experience linking to unemployment insurance wage records or 
other sources that provide employment outcome information. 

(4) No capabilities. States in this category did not have an 
operational student unit record data system. 

In selecting our sample of states, we also considered additional 
database functionality (such as including data from private and 
proprietary institutions), state participation in a regional data 
sharing agreement, and geographic and demographic diversity (e.g., 
rural, urban, and makeup of student population). On the basis of these 
considerations, we judgmentally selected seven states with a range of 
capabilities for in-depth review: Colorado, Connecticut, Florida, 
Indiana, Michigan, North Dakota, and Washington. We used the 
information gathered from these states for illustrative purposes only, 
and that information is not generalizable to a larger group of states, 
including a group of states with similar database capabilities or 
attributes. Additionally, while we asked states about what they did to 
validate the data they collect on students, we did not use data 
collected by states to substantiate any of our findings. We 
supplemented this information with findings from the July 2010 report 
by the State Higher Education Executive Officers (SHEEO), Strong 
Foundations: The State of State Postsecondary Data Systems, which 
updated and expanded similar information in the 2007 Lumina report. 
[Footnote 35] We corroborated the SHEEO report findings for the seven 
states we selected for in-depth review. However, we did not 
corroborate the findings for any other state. 

To describe the potential approaches and challenges to expanding the 
collection of graduates' employment information, we interviewed state 
officials and subject matter experts. In conjunction with those 
stakeholders, we identified a number of nationally administered 
surveys, including surveys administered by federal agencies such as 
the U.S. Department of Education, the Bureau of Labor Statistics, the 
National Science Foundation, and others. We examined the extent to 
which these surveys include education and employment information and 
whether they could be expanded to collect certain outcome information 
on graduates. In addition, we analyzed the Family Educational Rights 
and Privacy Act. We did not examine whether these potential approaches 
are consistent with all requirements of FERPA, because such a review 
was beyond the scope of our work. 

To identify how selected states and postsecondary institutions 
collaborate with employers and use graduates' employment-related 
information to align education and workforce needs, we relied on our 
state site visits and interviews with expert stakeholders. Because the 
Workforce Investment Act is the primary vehicle for delivering 
federally funded employment and training services, we also reviewed 
relevant information and provisions of that act. In addition, we 
reviewed prior GAO work on community colleges and workforce 
development to understand coordinated efforts between postsecondary 
education and workforce systems to meet employers' needs. Within the 
selected states, we interviewed state education and labor officials, 
representatives from 25 postsecondary institutions, and 16 employers. 
We asked these stakeholders how, if at all, state and local 
governments identified workforce needs and developed partnerships 
between employers and postsecondary institutions to meet those needs. 
Our meetings with employers and postsecondary institutions also 
focused on how local postsecondary institutions have tried to serve 
the needs of employers. 

Overall, we conducted this performance audit from July 2009 to 
September 2010 in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

[End of section] 

Appendix II: Selected Characteristics of States' Postsecondary Student 
Unit Record Data Systems: 

State: Alabama; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Alaska; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Arizona; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Arkansas; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: California; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Colorado; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Connecticut; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Delaware; 
Established postsecondary student unit record database: No; 
Institutional coverage: Public, 4-year: N/A; 
Institutional coverage: Public, 2-year: N/A; 
Institutional coverage: Nonprofit private: N/A; 
Institutional coverage: For-profit proprietary: N/A; 
Links postsecondary student data to workforce data: N/A. 

State: District of Columbia; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Florida; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Georgia; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Hawaii; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Idaho; 
Established postsecondary student unit record database: No; 
Institutional coverage: Public, 4-year: N/A; 
Institutional coverage: Public, 2-year: N/A; 
Institutional coverage: Nonprofit private: N/A; 
Institutional coverage: For-profit proprietary: N/A; 
Links postsecondary student data to workforce data: N/A. 

State: Illinois; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Indiana; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Iowa; 
Established postsecondary student unit record database: No; 
Institutional coverage: Public, 4-year: N/A; 
Institutional coverage: Public, 2-year: N/A; 
Institutional coverage: Nonprofit private: N/A; 
Institutional coverage: For-profit proprietary: N/A; 
Links postsecondary student data to workforce data: N/A. 

State: Kansas; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: Yes; 
Links postsecondary student data to workforce data: Yes. 

State: Kentucky; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Louisiana; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Maine; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes ; 
Institutional coverage: Public, 2-year: No; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Maryland; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Massachusetts; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: Yes; 
Links postsecondary student data to workforce data: No. 

State: Michigan; 
Established postsecondary student unit record database: No; 
Institutional coverage: Public, 4-year: N/A; 
Institutional coverage: Public, 2-year: N/A; 
Institutional coverage: Nonprofit private: N/A; 
Institutional coverage: For-profit proprietary: N/A; 
Links postsecondary student data to workforce data: N/A. 

State: Minnesota; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: Yes; 
Links postsecondary student data to workforce data: Yes. 

State: Mississippi; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: No; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Missouri; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: Yes; 
Links postsecondary student data to workforce data: Yes. 

State: Montana; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Nebraska; 
Established postsecondary student unit record database: No; 
Institutional coverage: Public, 4-year: N/A; 
Institutional coverage: Public, 2-year: N/A; 
Institutional coverage: Nonprofit private: N/A; 
Institutional coverage: For-profit proprietary: N/A; 
Links postsecondary student data to workforce data: N/A. 

State: Nevada; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: New Hampshire; 
Established postsecondary student unit record database: No; 
Institutional coverage: Public, 4-year: N/A; 
Institutional coverage: Public, 2-year: N/A; 
Institutional coverage: Nonprofit private: N/A; 
Institutional coverage: For-profit proprietary: N/A; 
Links postsecondary student data to workforce data: N/A. 

State: New Jersey; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: New Mexico; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: New York; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: Yes; 
Links postsecondary student data to workforce data: No. 

State: North Carolina; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: North Dakota; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Ohio; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Oklahoma; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Oregon; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Pennsylvania; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Rhode Island; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: South Carolina; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: Yes; 
Links postsecondary student data to workforce data: No. 

State: South Dakota; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: No; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Tennessee; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Texas; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: Yes; 
Links postsecondary student data to workforce data: Yes. 

State: Utah; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Vermont; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Virginia; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: Yes; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Washington; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: West Virginia; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: Yes. 

State: Wisconsin; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

State: Wyoming; 
Established postsecondary student unit record database: Yes; 
Institutional coverage: Public, 4-year: Yes; 
Institutional coverage: Public, 2-year: Yes; 
Institutional coverage: Nonprofit private: No; 
Institutional coverage: For-profit proprietary: No; 
Links postsecondary student data to workforce data: No. 

Source: State profiles from the State Higher Education Executive 
Officers (SHEEO) report, Strong Foundations: The State of State 
Postsecondary Data Systems, SHEEO (July 2010), and GAO analysis. 

Note: N/A stands for Not Applicable, because the state did not have a 
postsecondary student unit record database. 

[End of table] 

[End of section] 

Appendix III: Examples of Selected National Surveys of Postsecondary 
Education Students: 

Name of survey: National Postsecondary Student Aid Study; 
Sponsoring entity: Department of Education's National Center for 
Education Statistics; 
Survey information and analysis: A recurring survey that examines how 
students and their families pay for postsecondary education. It 
includes nationally representative samples of undergraduate and 
graduate students enrolled at all types of postsecondary institutions. 
Compiles a comprehensive research dataset, based on student-level 
records, on financial aid provided by the federal government, the 
states, postsecondary institutions, employers, and private agencies, 
along with student demographic and enrollment data. 

Name of survey: Baccalaureate and Beyond Longitudinal Study (B&B); 
Sponsoring entity: Department of Education's National Center for 
Education Statistics; 
Survey information and analysis: Examines students' education and work 
experiences after they complete a bachelor's degree, with a special 
emphasis on the experiences of new elementary and secondary teachers. 
Follows several cohorts of graduating seniors over time. The most 
recent B&B study, in summer 2009, surveyed more than 17,000 bachelor's 
degree recipients from 1,100 U.S. colleges and universities, and 
collected information about these graduates' demographic background, 
postsecondary education, employment, and other life experiences since 
leaving college in 2008. In 2012, the survey will contact the same 
graduates to find out about their longer-term experiences. 

Name of survey: Beginning Postsecondary Students (BPS) Longitudinal 
Study; 
Sponsoring entity: Department of Education's National Center for 
Education Statistics; 
Survey information and analysis: Captures a national perspective of 
persistence, multiple enrollment, transfer, and attainment using 
students as the unit of analysis. This survey follows several cohorts 
of students who enrolled in postsecondary education for the first 
time. The study collects data on student persistence in and completion 
of postsecondary education programs, their transition to employment, 
demographic characteristics, and changes over time in their goals, 
marital status, income, and debt, among other indicators. BPS draws 
its initial cohorts from the National Postsecondary Student Aid Study 
and then they are surveyed through BPS 2 and 5 years after their first 
enrollment in postsecondary education. 

Name of survey: Education Longitudinal Study of 2002 (ELS); 
Sponsoring entity: Department of Education's National Center for 
Education Statistics; 
Survey information and analysis: The study is designed to monitor the 
transition of a national sample of young people as they progress from 
10th grade through high school and into postsecondary education and/or 
their careers. The ELS is a longitudinal study, which means that the 
same individuals are surveyed repeatedly over time, and the 
information is collected from multiple respondent populations that 
represent students, their parents, their teachers, their librarians, 
and their schools. As a longitudinal study, ELS 2002 follows a 
nationally representative cohort of students from the time they were 
high school sophomores through the rest of their high school careers. 
By surveying the same young people over time, it is possible to record 
the changes taking place in their lives and help to explain these 
changes--that is, to help understand the ways in which earlier 
achievements, aspirations, and experience influence what happens to 
them later. 

Name of survey: The National Survey of Recent College Graduates; 
Sponsoring entity: National Science Foundation; 
Survey information and analysis: Provides information about 
individuals who recently obtained bachelor's or master's degrees in a 
science, engineering, or health field. Represents individuals who have 
recently made the transition from school to the workplace. It also 
provides information about individuals attending graduate school. The 
survey results are used by educational planners and employers to 
understand and predict trends in employment opportunities and salaries 
in science, engineering, and health fields for recent graduates and to 
evaluate the effectiveness of equal opportunity efforts. The survey 
sample is a two-stage sample, in which a sample of institutions is 
selected at the first stage and a sample of graduates is selected at 
the second stage from lists provided by the sampled institutions. 

Name of survey: National Survey of College Graduates; 
Sponsoring entity: National Science Foundation; 
Survey information and analysis: Longitudinal survey designed to 
provide data on the number and characteristics of individuals with 
education and/or employment in science, engineering, and related 
fields in the United States. The survey provides information on 
various characteristics of college-educated individuals in the 
workforce such as salaries, whether the college-educated population 
was working in their highest degree field of study, specific 
occupations, and a gender breakdown of the workforce. 

Name of survey: Survey of Earned Doctorates; 
Sponsoring entity: National Science Foundation; 
Survey information and analysis: Annual survey, begun in 1957-1958, 
that collects data continuously on the number and characteristics of 
all individuals receiving research doctoral degrees from accredited 
U.S. institutions. The results are used to assess characteristics and 
trends in doctorate education and degrees. Each accredited U.S. 
graduate school is responsible for providing the survey to its 
graduates and then submitting completed forms to the survey contractor 
for editing and processing. 

Name of survey: Salary Survey; 
Sponsoring entity: National Association of Colleges and Employers; 
Survey information and analysis: Compiles data from career planning 
and placement offices of colleges and universities across the United 
States. The reports consist of starting salary offers made to new 
graduates by employing organizations in business, industry, 
government, and nonprofit and educational institutions. The Salary 
Survey reports base salary and the number of offers, not acceptances. 
It does not distinguish between single and multiple offers to 
individual students, and therefore offers cannot be equated with 
actual hires. 

Source: GAO analysis of surveys administered to students and graduates 
on a nationwide basis. 

[End of table] 

[End of section] 

Appendix IV: Structure of Postsecondary Education in Australia and 
United Kingdom and Data Collection Methods: 

Australia: 

Postsecondary education structure: 

Australia's postsecondary education system is made up of a university 
system that is managed and funded primarily at the Commonwealth level, 
and a vocational education and training sector that is managed and 
funded primarily by state governments. 

System size: 

The university system includes 39 universities, of which 37 are public 
and 2 are private. According to government officials, there are about 
4,000 providers of vocational education of various sizes in Australia. 
Of these providers, 85 percent of the training is provided through 
about 58 public institutions, known as Training and Further Education 
(TAFE) institutes, which are funded and operated through the state 
governments. 

Postsecondary data collection method: 

The university and vocational systems each maintain a student 
information data system to track students while they are enrolled in 
school. According to government officials, all universities and 
vocational institutions that receive government funding must collect 
data on their students. These data systems, however, do not track 
students beyond the point of program completion, and thus provide no 
employment outcome information on graduates. To capture employment 
outcome information on graduates, each educational system conducts its 
own national graduate surveys. 

University system: 

According to officials we interviewed, the Australian Graduate Survey 
is the primary mechanism through which the Australian government 
obtains outcome information on university graduates. All of the 
universities participate in the survey. 

* Each university is responsible for administering the survey to its 
graduates 4 months after they complete an undergraduate program, and 
the responses are sent to Graduate Careers Australia, a nonprofit 
entity, for processing. 

* The institutional response rate of 70 percent is desirable and 
achievable, but data cannot be disclosed publicly or published if the 
response rate falls below 50 percent. 

* Education data collected include institution attended, degree 
earned, and major field of study, as well as satisfaction with the 
quality of graduates' educational experience. 

* Employment outcome data collected include employer name, industry of 
employment, job title, primary job tasks, annual salary, hours worked 
per week, importance of major course of study to the current 
employment, and satisfaction with course experience. 

Vocational system: 

According to government officials, the Student Outcomes Survey is the 
primary mechanism through which the Australian government obtains 
outcome information on the vocational education and training sector 
graduates. This survey is a sample survey conducted annually to assess 
the success of the vocational education and training sector in 
improving employment outcomes. 

* Australia's National Centre for Vocational Education Research 
(NCVER) is responsible for administering the survey, which is sent to 
graduates 6-9 months after they complete training programs. 

* The response rate is about 40 percent. 

* Employment outcome data collected include industry of employment, 
job title, primary job tasks, salary, relevance of training to current 
employment, and overall satisfaction with the training. 

* These data are available through the NCVER Vocational Education and 
Training Provider Collection (released on an annual basis) and the 
NCVER Apprentice and Training Statistics collection (released on a 
quarterly and annual basis). 

* Employer survey: Every 2 years, the National Centre for Vocational 
Education Research uses a contractor to survey a sample of Australian 
employers over the phone. This survey helps officials determine why 
employers do or do not use the vocational education system. 

United Kingdom: 

Postsecondary education structure: 

The United Kingdom's postsecondary system consists of a higher 
education system (universities and colleges similar to those in the 
United States) and a further education system (institutes of further 
education, similar to community colleges or vocational schools in the 
United States), according to officials from the United Kingdom 
Department for Business Innovation and Skills. Officials said that 
both parts of postsecondary education are primarily federally funded, 
though the individual countries (England, Northern Ireland, Scotland, 
and Wales), and local areas also have some control over postsecondary 
education. 

System size: 

The higher education system is composed of 165 universities and higher 
education colleges. According to the Business Innovation and Skills 
officials, there are approximately 430 further education colleges in 
the United Kingdom.[Footnote 36] 

Postsecondary data collection method: 

According to officials from the United Kingdom Department for Business 
Innovation and Skills, annual national surveys are conducted of 
postsecondary education leavers, as well as an employer satisfaction 
survey. 

Higher education system: 

The United Kingdom's Higher Education Statistics Agency conducts its 
Destinations of Leavers from Higher Education survey in two stages. 

* In the first stage, every higher education institution surveys all 
students 6 months after they graduate. Information is gathered on 
their current activity: employed, unemployed, in further study, or 
something else/not available for employment. Employment data collected 
include graduates' area of employment, occupation, salary, and whether 
the education was necessary for the job obtained, and reasons the 
student took the job. 

* In the second stage, the country's Higher Education Statistics 
Agency uses a private contractor to send a survey to a sample of 
graduates 3½ years after graduation, and collects similar employment 
outcome data. This is not an annual survey; there have been two such 
longitudinal surveys, and a third one is under way as of September 
2010, according to officials at the Department for Business Innovation 
and Skills. 

The target response rate for each institution is 80 percent for full- 
time students (and 70 percent for part-time). 

Further education system: 

According to officials from the United Kingdom Department for Business 
Innovation and Skills, the United Kingdom surveys all further 
education leavers who complete a substantial amount of learning and/or 
basic skills programs and asks them about the impact of that 
coursework. Officials said that the survey asks, for example, about 
whether leavers are continuing their education or have obtained 
employment or better employment and whether the course was essential 
to that outcome. The surveys are conducted by phone. The results of 
the survey can be used to evaluate each institution's performance, 
according to officials. 

Employer survey: 

Employment information is obtained through surveys of university and 
college graduates, and the results are publicly available through the 
Web sites of the agencies that administer the surveys. The United 
Kingdom Commission for Employment and Skills administers the National 
Employer Skills Survey, which asks, among other things, employers to 
evaluate how well prepared these postsecondary graduates are for their 
occupations. Other areas the survey asks employers about include 
recruitment difficulties and skill gaps. The results for the 2009 
National Employer Skills Survey for England were published in March 
2010. 

[End of section] 

Appendix V: Comments from the Department of Education: 

United States Department Of Education: 
Office Of Planning, Evaluation And Policy Development: 
400 Maryland Ave. SW: 
WASIUNGTON, DC 20202: 
[hyperlink: http://www.ed.gov] 

September 10, 2010: 

Ms. Katherine M. Iritani: 
Acting Director: 
Education, Workforce, and Income Security: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Ms. Iritani: 

Thank you for the opportunity to review and comment on the Government 
Accountability Office (GAO) draft report, Postsecondary Education: 
Many States Collect Graduates' Employment Information, but Lack of 
Clear Guidance on Student Privacy Requirements Could Hinder
Progress (GAO-10-927). The U.S. Department of Education (the 
Department) appreciates GAO's efforts to describe the confusion that 
States have expressed regarding how to link data
across State agencies while also adhering to the Family Educational 
Rights and Privacy Act (FERPA). The Department's response to GAO's 
recommendation follows. 

Recommendation: To help address states' information needs, we 
recommend that the Secretary of Education develop and disseminate 
guidance that clarifies the means by which state education agencies 
can share student records to facilitate obtaining graduates' 
employment information while ensuring appropriate privacy protection 
under FERPA. in addition to establishing a timeframe for 
implementation, this guidance should include how student records could 
be shared with state labor agencies, and how states can share data 
with one another. 

Response: The Department agrees with this recommendation and has 
already taken steps to increase the guidance and technical assistance 
it provides to States on protecting student privacy,
confidentiality, and data security in order to promote full awareness 
of and compliance with Federal law and best practice. We have 
undertaken several initiatives to address this need that are in 
accordance with GAO's recommendation. These activities are summarized 
below. 

The Department intends to propose amendments to the FERPA regulations 
that would respond to the frequently heard concerns from States, 
districts, and other education data stakeholders. The proposed 
regulations will address the lack of clarity around what is 
permissible under FERPA and the need to better protect student 
information. FERPA is an extremely important law intended to ensure 
student privacy is protected. However, the Department's regulations do 
not account for the evolution of data use we see today. As announced 
in the April 26, 2010. Office of Management and Budget's Unified 
Regulatory Agenda, the Department will propose changes
to the regulations that will clarify how to comply with Federal law 
and provide guidance for ensuring student data are protected as States 
develop longitudinal data systems and use data to inform decisions. To 
protect the confidentiality of our decision-making processes and policy
discussions, we are constrained in sharing details of our anticipated 
proposed changes to the FERPA regulations. However, please be assured 
that the changes we are considering, if adopted, will clarify how 
States can effectively develop and use data in Statewide longitudinal 
data systems while ensuring protection of individual privacy under 
FERPA. We plan to publish a Notice of Proposed Rulemaking (NPRM) this 
winter. When the NPRM is published, the Department will consider 
public comments to further improve the FERPA regulations and guidance. 

We are also creating a Chief Privacy Officer (CPO) position. The CPO 
will be tasked with ensuring the Department's compliance with Federal 
laws, regulations, and policies related to information privacy, 
including implementation of the Privacy Act of 1974, as amended. and 
FERPA. The CPO will be a member of the Senior Executive Service. The 
CPO will oversee the Family Policy Compliance Office (FPCO) and serve 
as senior policy advisor on overall privacy policy, including on 
regulations and nonregulatory guidance drafted by Department offices 
on issues related to or including privacy, confidentiality, and data 
security, including the new Privacy Technical Assistance Center (see 
below). The Chief Privacy Officer job announcement is posted on 
www.usajobs.gov, with applications to be accepted until September 30, 
2010. 

In addition, through the National Center for Education Statistics 
(NCES), the Department is establishing a Privacy Technical Assistance 
Center (PTAC) to serve as a one-stop shop for State educational 
agencies (SEAS), local educational agencies (LEAs), the postsecondary 
community, and other parties engaged with education data on questions 
related to protecting privacy, confidentiality, and data security. As 
States continue to develop their longitudinal data systems, PTA(' will 
develop coordinated guidance and communication about privacy, 
confidentiality, and security measures by working with various offices 
within the Department, including representatives from the Performance 
Information Management Service (PIMS), FPCO. the Office of Special 
Education and Rehabilitative Services (OSERS), the Office of the 
General Counsel (OGC). the Office of Planning, Evaluation and Policy 
Development (OPEPD), and NCES. PTAC will communicate frequently with 
education stakeholders about updated knowledge on and changes to 
privacy, confidentiality, and security requirements, practices, and 
regulations; share lessons learned about privacy protection practices 
from other government agencies and other industries; facilitate the 
sharing of lessons learned among SEAs, LEAs, and postsecondary 
institutions regarding privacy-related matters; provide virtual and 
real settings in which user communities can collaborate; provide 
technical assistance in group settings and one-on-one with States; and 
create training materials on privacy, confidentiality, and security 
issues. PTAC will refer any FERF'.A. questions, which cannot be 
addressed by existing guidance, to FPCO. FPCO will continue to serve 
as the dedicated office to answer FERPA questions and investigate 
allegations of violations. The Department anticipates having the 
contract for PTAC awarded by the end of September 2010. 

The Department, through NCES, will be releasing a new series of 
technical briefs on various issues related to the protection of 
personally identifiable information in student education records. The 
Department will solicit public comments on them and will ultimately 
incorporate, where appropriate, those comments into nonregulatory 
guidance. Planned brief topics include the following: basic concepts 
and definitions of personally identifiable information, 
confidentiality, types of disclosures, processes for making personally 
identifiable information anonymous in data being released, privacy, 
and fair information practice principles; data stewardship, including 
the establishment of clear policies and procedures that govern 
collection, storage, processing, and access to individual students' 
education records; electronic data security related to the 
transmission of data with personally identifiable information between 
different entities; statistical methods to protect the identity of 
individual students in publicly available information; recommended 
components of written agreements that permit State and local 
educational authorities to redisclose personally identifiable 
information from education records to organizations conducting studies 
pursuant to the terms of FERPA; and privacy and confidentiality 
training needs for relevant staff at the State, district, and school 
levels, including disclosure limitation procedures and internal access 
rules. NCES will create additional briefs in response to public 
requests far guidance on related topics. The briefs will be released 
as individual documents for each topic over time, starting fall 2010. 

We believe that we must remain vigilant about safeguarding data and 
protecting privacy as the reliance on using data to inform decisions 
grows and as States expand their longitudinal data systems. The above-
listed initiatives are the first steps in what will be continuous 
development and improvement of the technical assistance and guidance 
that the Department will provide to ensure that States, districts, and 
schools are safeguarding personally identifiable information in data 
systems and complying with Federal privacy laws. 

Although we agree with GAO's recommendation for executive action, 
there are several technical points of clarification needed in the 
draft report related to the Department and FERPA. Enclosed is an 
addendum outlining these points, which I trust GAO will find useful. 
Thank you for the opportunity to provide comments on the draft report. 

Sincerely, 

Signed by: 

Carmel Martin: 
Assistant Secretary: 

Enclosure: 

[End of section] 

Appendix VI GAO Contacts and Staff Acknowledgments: 

GAO Contact: 

Katherine M. Iritani, Acting Director, (202) 512-7215 or 
iritanik@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Meeta Engle, Assistant 
Director, and Susan Chin, Analyst-in-Charge, managed all aspects of 
the assignment. Jason Holsclaw, Andrew Nelson, Nancy Purvine, and Katy 
Trenholme made significant contributions to this report in all aspects 
of the work. Kate Van Gelder contributed to writing this report. 
Ronald Fecso and Luann Moy provided technical support, and Craig 
Winslow provided legal support. Mimi Nguyen developed the graphics for 
the report. 

[End of section] 

Related GAO Products: 

Career and Technical Education: States Have Broad Flexibility in 
Implementing Perkins IV. [hyperlink, 
http://www.gao.gov/products/GAO-09-683]. Washington, D.C.: July 29, 
2009. 

Workforce Development: Community Colleges and One-Stop Centers 
Collaborate to Meet 21st Century Workforce Needs. [hyperlink, 
http://www.gao.gov/products/GAO-08-547]. Washington, D.C.: May 15, 
2008. 

Workforce Investment Act: State and Local Areas Have Developed 
Strategies to Assess Performance, but Labor Could Do More to Help. 
[hyperlink, http://www.gao.gov/products/GAO-04-657]. Washington, D.C.: 
June 1, 2004. 

Workforce Investment Act: Improvements Needed in Performance Measures 
to Provide a More Accurate Picture of WIA's Effectiveness. [hyperlink, 
http://www.gao.gov/products/GAO-02-275]. Washington, D.C.: February 1, 
2002. 

[End of section] 

Footnotes: 

[1] Postsecondary education refers to the educational level that 
follows the completion of a school providing a secondary education, 
such as high school, and is often optional. Undergraduate, 
postgraduate, and vocational schools make up the various types of 
postsecondary education. 

[2] Pub. L. No. 110-315, § 1102, 122 Stat. 3078, 3491-92 (2008). 

[3] Peter Ewell and Marianne Boeke, Critical Connections: Linking 
States' Unit Record Systems to Track Student Progress, New Agenda 
Series, Lumina Foundation for Education, National Center for Higher 
Education Management Systems (January 2007). 

[4] Tanya I. Garcia and Hans Peter L'Orange, Strong Foundations: The 
State of State Postsecondary Data Systems, State Higher Education 
Executive Officers (July 2010). 

[5] We focused on state rather than federal efforts because the HEOA 
provided generally that nothing in the Higher Education Act of 1965 
authorizes the U.S. Department of Education to create a federal unit 
record system to track individual college students. Sec. 113, § 134, 
122 Stat. 3110-11 (codified at 20 U.S.C. § 1015c). 

[6] 20 U.S.C. § 1232g. 

[7] Pub. L. No. 105-220, 112 Stat. 936 (codified in pertinent part as 
amended at 29 U.S.C. §§ 2801-2945). In addition, section 504 provided 
generally that nothing in the act was to be construed to permit the 
development of a national database of personally identifiable 
information on individuals receiving benefits under it. 112 Stat. 1245 
(codified at 20 U.S.C. § 9274(b)). 

[8] In prior reports, we found that there is a 6-to 9-month lag 
between the time employers report UI data and states update their UI 
wage records. See [hyperlink, http://www.gao.gov/products/GAO-04-657], 
Workforce Investment Act: State and Local Areas Have Developed 
Strategies to Assess Performance, but Labor Could Do More to Help 
(Washington, D.C.: June 2004), and [hyperlink, 
http://www.gao.gov/products/GAO-02-275], Workforce Investment Act: 
Improvements Needed in Performance Measures to Provide a More Accurate 
Picture of WIA's Effectiveness (Washington, D.C.: February 2002). 

[9] Pub. L. No. 107-279, § 208, 116 Stat. 1940, 1981. 

[10] Pub. L. No. 111-117, 123 Stat. 3034, 3228. 

[11] 20 U.S.C. § 1232g. In addition, the rights under FERPA, including 
the right to access student education records, transfer from the 
parent to the student when the student becomes an eligible student. An 
eligible student is a student who has turned 18 years old or attends a 
postsecondary institution at any age. 

[12] 20 U.S.C. § 1232g(b)(3). 

[13] 34 C.F.R. § 99.33 (b) (2009). 

[14] 34 C.F.R. § 99.35(a) (2009). Within certain limitations, a 
state's K-12 educational agency that nonconsensually received 
personally identifiable information from education records to conduct 
an evaluation may nonconsensually redisclose the personally 
identifiable information to the state higher education authority. Such 
disclosure may be done on behalf of the educational agency that 
provided the information, in order for the state higher education 
authority to conduct another type of evaluation, as long as that state 
higher education authority has authority to conduct the evaluation of 
the disclosing districts' federal-or state-supported education 
program. There are other exceptions to FERPA's general requirements 
that may permit the sharing of information under certain 
circumstances. 20 U.S.C. § 1232g(b). 

[15] According to SHEEO, 5 states do not have a SUR database: 
Delaware, Idaho, Michigan, Nebraska, and New Hampshire, and 1 state 
(Iowa) had limitations to its data system and enrollment numbers that 
precluded it from being included in the SHEEO report. Further, some 
states have multiple SUR databases, but for purposes of this report, 
we use states rather than individual data systems as the unit of 
analysis. 

[16] State profiles from the SHEEO report indicated that of the 45 
states with postsecondary SUR databases, 42 collect data from both 
public 2-and 4-year institutions and the other 3 states collect data 
only from public 4-year institutions. Furthermore, 19 states collect 
data from independent, nonprofit institutions, and 7 collect data from 
for-profit institutions. 

[17] 20 U.S.C. § 1232g(b)(1)(C) and (F) and (b)(3). 

[18] In Florida, this program is created by law and is referred to as 
the Florida Education and Training Placement Information Program. The 
purpose of the program is to compile, maintain, and disseminate 
information concerning the educational histories, placement and 
employment, and other measures of success of former participants in 
state educational and workforce development programs. Fla. Stat. § 
1108.39 (2009). 

[19] In connection with other types of statewide longitudinal data 
systems, Education has explained that data maintained by a workforce 
agency is not an education record, so FERPA does not apply and does 
not present a barrier to the disclosure of such data by state 
workforce agencies to educational agencies. 74 Fed. Reg. 58,436, 
58,452 (Nov 12, 2009). 

[20] 73 Fed. Reg. 74,806. Education issued these regulations, in part, 
in an attempt to clarify permissible redisclosures by state and 
federal officials without consent for audit and evaluation purposes. 
73 Fed. Reg. 74,821-22. 

[21] Education officials noted that they have not reviewed or endorsed 
the potential approaches or the specific examples used to illustrate 
how they have been implemented. 

[22] A prior GAO report noted the challenges in following the 
employment progress of students because of the lack of data sharing 
across states. GAO, Career and Technical Education: States Have Broad 
Flexibility in Implementing Perkins IV, [hyperlink, 
http://www.gao.gov/products/GAO-09-683] (Washington, D.C.: July 29, 
2009). 

[23] Using a third party administrator can also help states avoid 
giving one state access to other states' records. Accessing another 
state's records can raise FERPA issues, according to documentation 
from the National Center for Higher Education Management Systems. 
However, a third party that has education records, such as a 
contractor, must comply with FERPA with regard to any nonconsensual 
redisclosures of that information. Education had not issued any 
guidance on whether third parties may be utilized to facilitate the 
exchange of education records and employment records at the time of 
this review. 

[24] Tracking Postsecondary Students Across State Lines, National 
Center for Higher Education Management Systems, (March 2008). 

[25] The WRIS does not allow for the sharing of aggregate wage record 
results obtained through WRIS to third party entities, such as state 
education agencies. However, a proposal before the WRIS Advisory Group 
would allow states to participate in a process to share aggregate wage 
record results with education agencies to obtain information on behalf 
of workforce and economic development partner public agencies. Labor 
officials emphasized that participation by any state in such a process 
would be on an entirely voluntary basis. 

[26] The National Student Clearinghouse, established by the higher 
education community in 1993, serves as a central repository and single 
point of contact for the collection and exchange of enrollment, 
degree, diploma, and certificate records on behalf of participating 
postsecondary and secondary institutions. 

[27] Brian T. Prescott and Peter Ewell, A Framework for a Multi-State 
Human Capital Development Data System, Western Interstate Commission 
for Higher Education, 2009. While state officials met together to 
discuss these issues, states had not progressed past this initial 
discussion and, as of May 2010, were seeking funds to continue the 
work. 

[28] We also spoke with a few employers and national associations 
representing employers or for-profit institutions about surveying 
employers online to obtain information on employer satisfaction with 
graduates they hire. They said that they would be willing to complete 
this type of survey if it would provide them with benefits such as 
access to aggregated information about graduates' institutions of 
postsecondary education attended, degrees, or starting pay. However, 
one association official stated that access to this information might 
not be enough of an incentive to compel employers to complete the 
online survey. 

[29] The National Association of Colleges and Employers Salary Survey 
compiles data from career planning and placement offices of colleges 
and universities across the United States. The reports consist of 
starting salary offers made to new graduates by employing 
organizations in business, industry, and government, and by nonprofit 
and educational institutions. The figures reported are for base 
salaries only and do not include bonuses, fringe benefits, or overtime 
rates. The Salary Survey reports offers, not acceptances. It does not 
distinguish between single and multiple offers to individual students 
and, consequently, offers reported by the study cannot be equated with 
actual hires. 

[30] Additionally, the survey may not be representative of all majors 
in follow-up surveys. 

[31] This 1998 act required, in part, that states and localities unify 
federally funded employment and training programs and deliver them 
through a single service system known as the one-stop system. § 
121(a), 112 Stat. 963 (codified at 29 U.S.C. § 2841). It also required 
establishment of business-led state and local workforce investment 
boards to assist in the development of state one-stop system plans and 
set policy, respectively. §§ 111(a) and 117(a), 112 Stat. 944-46 and 
954 (codified at 29 U.S.C. §§ 2821 and 2832), respectively. 

[32] For more information on how community colleges collaborate with 
the workforce investment system to develop career and technical 
training programs that meet industry needs, see GAO, Workforce 
Development: Community Colleges and One-Stop Centers Collaborate to 
Meet 21st Century Workforce Needs, [hyperlink, 
http://www.gao.gov/products/GAO-08-547] (Washington, D.C.: May 15, 
2008). 

[33] Secondary and postsecondary career and technical programs 
establish and rely on advisory committees to meet requirements under 
the Carl D. Perkins Career and Technical Education Act of 2006 that 
involve parents, faculty, guidance counselors, local business, and 
local labor organizations in the planning, development, 
implementation, and evaluation of career and technical education 
programs in the state. Pub. L. No. 109-270, § 122(c)(5), 120 Stat. 
683, 719 (codified at 20 U.S.C. § 2342(c)(5)). 

[34] Peter Ewell and Marianne Boeke, Critical Connections: Linking 
States' Unit Record Systems to Track Student Progress, New Agenda 
Series, Lumina Foundation for Education, National Center for Higher 
Education Management Systems (January 2007). 

[35] Tanya I. Garcia and Hans Peter L'Orange, Strong Foundations: The 
State of State Postsecondary Data Systems, State Higher Education 
Executive Officers (July 2010). 

[36] According to officials from the Department for Business 
Innovation and Skills, approximately 10 percent of higher education is 
carried out within further education colleges, and generally overseen 
by a higher education institution. 

[End of section] 

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