Why sameness, not teaching, is the goal

The Transfer Industrial Complex

The battle is finally forming: professors versus metrics. Faculty are finally standing up to institutional demands to check boxes rather than actually teach students. No professor wants to be a worker on a generic education assembly line any more.

Read Paul Schofield’s “Why Pedagogy Experts Are Wrong” if you can, which has awoken professors across the country who have spent years feeling alienated from their own profession, biting their tongues in workshops, nodding through PowerPoints on scaffolding and active learning, sitting through community-care days with blankets and coloring books, shouting “Yes!” There is no such thing as generic “good teaching” or “good writing.” You cannot apply “general standards of excellence” to disciplines focused on specific methods and approaches. The evidence-based practices the centers peddle — learning styles, flipped classrooms, instructional scaffolding — keep failing to replicate, and the centers keep peddling them anyway. As Schofield points out:

No one thinks there's such a thing as ‘playing sports’ generically. There’s just playing football, gymnastics, golf, wrestling, and shotput, each with standards of excellence particular to it. This is why we don't establish generic-sports coaching centers staffed by noncoaching staff, tasked with developing workshops targeted at once to wrestling, rowing, and water-polo coaches.

Read the whole thing. Twice. Send it to friends.

But then listen up. Most professors — even Schofield — don’t yet see why it will be impossible for faculty to simply “reclaim” the work they have outsourced, because those centers are not “simply” offering “guidance.” They are downstream of what I am calling the Transfer Industrial Complex. Why are there 1,200 of them, as Schofield notes? Because these centers are the local delivery mechanism for learning outcomes and assessment rubrics, which exist because credits have to be portable across institutions, as the majority of states mandate, and the federal government is about to tie Title IV funding to program-level earnings data. The Bates Center for Inclusive Teaching and Learning is up front about this, naming “evidence-based approaches, assessments, and technologies” as its first goal. Assessment and “course design” are not about you, lovely faculty. They’re about sameness. Even if you stopped attending the workshops, ignored the jargon, and refused the trainings, the centers will remain because they generate data, and not just about who visits them. Schofield is 100% right about the pain the assessment machinery causes faculty. Will the pain push professors to reach across institutions and across party lines?

I was thrilled to see two conservatives moaning about the same thing in a Law & Liberty podcast conversation “Conservatism’s Lamentable Drift,” between University of Tennessee’s James Patterson and Baylor’s Elizabeth Corey. The high drama was Christopher F. Rufo lashing out on X against conservative faculty who think their job is teaching instead of “owning the libs.” Indeed the conservative critique of higher ed has been ineffective because it’s been aimed at liberal faculty, not the metrics bureaucracy. And indeed, Corey and Patterson, like Schofield, are sick of the bureaucracy. Corey laments “learning objectives” mandates: “We have no idea what the learning objectives are for reading Dante or for Plato. We hope that we’re giving them... this culture to them such that it becomes theirs and they can enjoy it.” Corey quoted a student who used to love reading novels for pleasure. “And around middle school, it became something that I just didn’t enjoy anymore because I was always asked to regurgitate on a worksheet what I had just read.” James Patterson sighed to listeners:

“if you don’t know what we’re talking about listening to this, believe me, you don’t want to know. It’s the behind the scenes work that so many faculty have to do….in 10 years, that student will also still be reading and you will never see that and that will never be on the accreditation file.”

The battle against assessment and metrics can unite left and right, especially in the AI era where human teaching is becoming more valuable.

Against what? Read today’s “Higher Ed’s Data Problem” piece by Sara Custer, editor-in-chief of Inside Higher Ed, describing a whole different planet from the one Schofield, Patterson, Corey, and even Rufo are standing on. Custer is reporting on ASU+GSV, the annual ed-tech summit co-founded by Michael Crow’s ASU and a Silicon Valley investment group, called the “Davos of Education,” where vendors and foundations and consulting firms gather to sell the next generation of education infrastructure to each other. Their concern is not what you are doing in the classroom but “Bad data in + bad data out = bad decisions all around.”

Rufo was successful in taking down a different apparatus — DEI trainings, bias response, diversity statements — and one hopes he might see the problems with the assessment-and-compliance machinery Schofield, Corey, and Patterson are describing.

The July 1 Title IV accountability rules will require academic programs to prove their graduates out-earn a local high-school worker. Institutions need to get their “plumbing” in order before the federal government comes asking. This means faculty will spend time looking at what graduates earn instead of actually researching and teaching, even science faculty, who might better be inventing new materials to get us to Mars. Custer praises Mark Milliron at National University for spending a year on data governance and a data warehouse. She praises the Lumina Foundation for working to link federal workforce data across four agencies. The piece ends: “You can't build an AI-powered future with dirty data and broken pipes.” Missing in the piece? Anything about faculty, professors, or teaching.

All of the energy outside the classroom is about data, and not just any data but data that can be aggregated and compared across institutions, because that is the only kind of data the federal government, the state systems, the foundations, and the AI platforms can use. Comparable data requires comparable units. A sociology course at one institution has to mean the same thing as a sociology course at another, or the accountability formula breaks. A graduate of one program has to be measurable against a graduate of a different program in a different state, or the ROI calculation breaks. Which means every institution has to be doing the same thing in the same way. It is dressed up as “transfer” or “portability,” because making it easy for students to move between institutions seems like a good thing. But the infrastructure is isomorphic. Make the courses the same, make the learning outcomes the same, make the assessment rubrics the same, make the data fields the same. The Transfer Industrial Complex is about making American higher education into a single legible system, and the transfer mandate is the mechanism. Which is why it costs so much and why nobody can add up what it costs, a topic I’m writing about in my forthcoming book.

Here’s what I mean. Faculty should understand that there is no national figure for what the U.S. spends annually to ensure that college students can transfer between institutions. The Department of Education collects detailed expenditure data from every degree-granting institution through IPEDS, covering everything from instruction to grounds maintenance to institutional support, but “transfer compliance” does not appear as a reporting category. No federal agency tracks it; no state aggregates it. But there is substantial spending, as I will try to show, distributed almost invisibly across institutional budgets.

The scale of student transfer is large and growing. In the fall of 2024, approximately 1.2 million students transferred to a new institution, representing about 13% of all non-first-year undergraduates.¹ Transfer enrollment has grown for three consecutive years and is now expanding faster than re-enrollment at existing institutions.² Longitudinal data from the National Student Clearinghouse shows that 37% of students who entered college in 2008 transferred at least once within six years, and of those who transferred, nearly 45% did it more than once, which means that roughly 17% of all entering college students attend three or more institutions before completing a degree or leaving the system.³ The pattern is called “student swirl,” and it has become the baseline of American undergraduate education over the past two decades, driven by cost pressures, pandemic disruption, and state policies designed to make mobility easier.

Universities have built up a complex infrastructure to service this mobility, both to accept transfer students, to evaluate transcripts, and to support students who transfer again. Expensive curriculum-mapping software, such as EAB Starfish or Kuali (with annual licensing fees of $500,000-$1,000,000) to maintain real-time equivalency databases across hundreds of sending institutions.⁴ Faculty serve on curriculum committees that review and align course-level learning outcomes with state competency matrices, a process that typically adds eight to twelve hours of committee work per course when a state mandates common course numbering.⁵ Registrars, transfer coordinators, and academic advisors all dedicate portions of their time to managing the logistics of credit mobility. Thirty-eight states now mandate a statewide transferable core of courses, and institutions that fail to maintain their articulation grids risk losing their standing within state systems, so none of this infrastructure is optional for the campuses subject to those mandates.⁶

The only large-scale attempt to measure the cost of regulatory compliance in higher education was a 2015 study conducted by Vanderbilt University and the Boston Consulting Group across thirteen institutions.⁷ The researchers found that compliance consumed between 3% and 11% of each institution’s non-hospital operating budget, and they extrapolated a national cost of roughly $27 billion per year for the entire sector.⁸ The difficulty with applying that number to transfer specifically is that the study measured compliance with everything—financial aid administration, Title IX, research oversight, OSHA, immigration regulations, environmental rules—and transfer articulation is one component of the higher-education-specific regulatory slice, which is itself a fraction of the total. At Vanderbilt, of $146 million in total compliance costs, only $14 million fell into the non-research, higher-education-specific category.⁹ What the study did establish, and what matters for the transfer question, is a structural fact: 70% of all compliance costs are “decentralized,” meaning they are absorbed by faculty and department-level staff rather than by centralized administrative offices.¹⁰ A chemistry professor who spends ten hours mapping her syllabus to a state equivalency grid does not bill those hours to transfer compliance. They disappear into her service load and become part of the general cost of running a department. The spending is hard to find because it has been socialized across the institution in exactly the way that prevents anyone from adding it up.

What you can do is reconstruct a rough estimate from components, and the exercise of doing so is revealing even if the result is imprecise. Start with the direct institutional overhead at a single campus: a mid-sized regional public university typically employs a full-time articulation officer and several transcript evaluators at a combined cost exceeding $200,000 in salary and benefits. Add the technology layer, which runs $100,000 to $150,000 per year for curriculum-mapping and degree-audit software licensing. Then add the faculty time, which the Vanderbilt study identified as the largest hidden compliance cost. Using AAUP salary data, the national average for a full-time professor is approximately $160,000, yielding a fully burdened hourly rate in the neighborhood of $125.¹¹ If a campus aligns 500 general education courses to a state matrix at roughly ten hours of committee review per course, the one-time faculty labor cost is $625,000, with lower but persistent annual maintenance costs after that.

A conservative estimate for the annual direct and opportunity cost of transfer-specific infrastructure at a single mid-sized campus is $500,000 to $1 million. Apply that range across roughly 3,900 degree-granting institutions—with the approximately 1,900 public institutions as the primary targets of state transfer mandates—and you arrive at somewhere between $1.5 and $2.5 billion in institutional spending dedicated specifically to making credits portable.¹² California’s AB 1111 appropriated $105 million for that state’s community college system alone to manage the transition to common course numbering.¹³ When you start adding state-level system office spending across 38 states with active transfer mandates, the combined institutional-plus-state total probably sits somewhere between $2 and $3 billion annually. The estimate is rough, yes, but the roughness is evidence of the problem. Nobody has had to defend spending on “transferability” as a discrete investment because the spending is so dispersed.

The question is whether that $2 to $3 billion is buying what it is supposed to buy. The evidence from the student side suggests that it is not, or at least not reliably. The GAO, analyzing the 2004–2009 cohort of beginning postsecondary students, found that transfer students lost an average of 43% of their previously earned credits.¹⁴ Nearly 40% of transfer students lost all of their credits and were forced to start from scratch at their new institution.¹⁵ The National College Transfer Center has estimated that this credit loss wastes roughly $6 billion per year in tuition that students pay to retake coursework they have already completed.¹⁶ A 2024 report from the Center for Higher Education Policy and Practice put finer numbers on the individual cost: an average of $13,000 in additional out-of-pocket tuition for a student transferring to a public four-year institution, plus roughly $15,400 in lost wages from a three-month delay in graduation.¹⁷ These are costs borne by the students the system was designed to protect, and they persist after decades of institutional investment in the articulation infrastructure described above.

The obvious objection is that without the $2 to $3 billion in institutional spending, the student-side losses would be even larger. That objection deserves to be taken seriously. Before the seamless transfer mandates of the late 1990s and 2000s, fewer students transferred, and those who did bore the full friction individually under an equivalency model that placed the burden of proof on the student.¹⁸ The mandates succeeded at increasing the volume of student mobility—the 1.2 million annual transfers and the 37% longitudinal transfer rate are products of a system that has made movement physically easier. The question is whether per-transaction waste has improved, and the answer appears to be that it has not improved much. The GAO’s 43% credit loss figure comes from a cohort that entered college in 2004, well after most state articulation mandates were in place, and more recent data does not show dramatic improvement in credit acceptance rates despite continued growth in institutional spending on articulation infrastructure. The machinery has succeeded at making transfer more common without making it substantially more efficient for the individual student who attempts it.

State articulation grids and common course numbering systems are a kind of QR code for each course, facilitating trade, as it were. Once a course has the QR code, it doesn’t really matter to the receiving university where the course originated (a community college, a neighboring university). Not embedded in the QR code is anything about quality (or ability) of instructor or whether the student learned anything. Courses with the same QR code can be taught by an expert, a first year grad student, a harried lecturer, in a small class, a huge lecture hall, on Zoom, online asynchronously, by someone teaching one class that semester or six classes. It is all the same to the system.

love you Zero Wing...

The articulation machinery reduces all variation into a universal currency, and in doing so, devalues local distinction.¹⁹

I acknowledge I am battling the entire educational establishment with my view that the transfer cross-subsidy is not worth it. First of all, nobody will acknowledge the cost, because the infrastructure is hidden in operating budgets. If fees were charged to transferring students, that would be one thing. But the cost is spread across the entire student body.²⁰ Roughly 35% of students transfer at least once. The remaining 65% who enroll and graduate from a single institution are paying, through their tuition, for an infrastructure they will never use and which reduces their opportunity to take a truly distinctive course. Every dollar spent on curriculum-mapping software is a dollar not spent on a faculty line or a lab upgrade, and that diversion is funded equally by the student who will never transfer and the student who will transfer twice.

The economics literature on higher education administrative costs shows that this kind of overhead is “sticky,” administrative expenses grow by 0.36% for every 1% increase in revenue but decrease by only 0.12% when revenue falls, which means that even if transfer volume declined, the infrastructure built to service it would persist as a fixed charge on the budget.²¹

What the absence of a national figure ultimately conceals is a trade-off that American higher education has made without openly debating it. The system has chosen to fund portability out of general revenue, socializing the cost across all students and embedding it in institutional overhead where it cannot be seen or questioned. If institutions tracked transfer compliance as a discrete budget line—if a provost had to report annually that her campus spent $750,000 on making credits portable, and could compare that figure against the number of students who actually transferred in and the rate at which their credits were accepted—the conversation about whether that spending is justified would become unavoidable. The data would force a confrontation between the value of mobility and the cost of the infrastructure that supports it, including the cost to pedagogical depth when syllabi are reverse-engineered for universal legibility rather than designed for local intellectual purposes. All your course are belong to the bureaucracy.

1. National Student Clearinghouse Research Center, Transfer and Mobility: A National View of Student Movement in Postsecondary Institutions, Fall 2024 (Herndon, VA: National Student Clearinghouse, 2024).

2. Ibid. Transfer enrollment grew 4.4% from fall 2023 to fall 2024, compared with 2.6% growth in non-transfer re-enrollment.

3. National Student Clearinghouse Research Center, Transfer and Mobility, Signature Report No. 9 (2015), analyzing the fall 2008 entering cohort over a six-year window.

4. Campus licensing costs for degree-audit and curriculum-mapping products vary widely. Individual campus licenses for products like EAB Starfish have been reported at up to $824,000 annually. See also vendor disclosures and institutional procurement records.

5. The Syllabus Institute reports that instructors spend an average of 24.3 hours creating a new course syllabus and 6.5 hours updating it per semester. Common Course Numbering mandates, now adopted in 21 states, add an estimated 8 to 12 hours of committee review per course for alignment to state competency matrices. See Education Commission of the States, Transfer and Articulation 2022: 50-State Comparison.

6. Education Commission of the States, 50-State Comparison: Transfer and Articulation Policies (2022; updated 2024). Thirty-eight states have adopted a statewide transferable core of lower-division courses.

7. Vanderbilt University and the Boston Consulting Group, The Cost of Federal Regulatory Compliance in Higher Education: A Multi-Institutional Study (Nashville: Vanderbilt University, October 2015). The study covered 13 institutions ranging from a public Tier I research university to a private liberal arts college.

8. National Association of Student Financial Aid Administrators (NASFAA), “Study: Regulatory Compliance Costs Higher Ed $27B Per Year,” October 19, 2015, summarizing the Vanderbilt/BCG findings.

9. Kellie Woodhouse, “Does Compliance Cost $11K per Student?” Inside Higher Ed, August 3, 2015. Vanderbilt’s CFO Brett Sweet confirmed that of $146 million in total compliance costs, $14 million was non-research and higher-education specific.

10. Vanderbilt/BCG (2015). The study found that only 30% of compliance costs occur in centralized offices; 70% are decentralized, absorbed by faculty and departmental staff, with faculty time comprising over half of all decentralized costs.

11. American Association of University Professors (AAUP), Annual Report on the Economic Status of the Profession, 2023–24. The national average salary for a full-time professor is approximately $160,800. The fully burdened hourly rate of approximately $125 includes an estimate for benefits and indirect costs applied to a standard annual workload.

12. National Center for Education Statistics, Digest of Education Statistics 2023, Table 317.10. As of 2022–23, there were approximately 3,900 degree-granting postsecondary institutions in the United States, of which roughly 1,900 were public.

13. California Assembly Bill 1111 (2021), subsequently funded through the state budget, appropriated $105 million to support community colleges in the transition to a common course numbering system, with specific provisions for faculty costs associated with curriculum approval and alignment.

14. U.S. Government Accountability Office, Higher Education: Students Need More Information to Help Reduce Challenges in Transferring College Credits, GAO-17-574 (Washington, DC: August 2017). Based on analysis of the 2004–2009 Beginning Postsecondary Students Longitudinal Study.

15. Ibid. The GAO found that 39.4% of transfer students were unable to transfer any of their previously earned credits.

16. National College Transfer Center estimate, reported in Jon Marcus, “When Credits Don’t Count, Transfer Students Face Debt, More Classes,” U.S. News & World Report / Hechinger Report, November 22, 2016.

17. National College Transfer Center estimate, reported in Jon Marcus, “When Credits Don’t Count, Transfer Students Face Debt, More Classes,” U.S. News & World Report / Hechinger Report, November 22, 2016.

18. The 1997 Lisbon Recognition Convention, Article VI.1, introduced the “doctrine of substantial difference,” establishing that institutions must recognize prior learning unless they can prove a material educational shortcoming. This reversed the prior equivalency model in which the transferring student bore the burden of demonstrating course-by-course equivalence. The principle migrated into North American policy through state-level seamless transfer mandates enacted primarily in the late 1990s and 2000s.

19. Friedrich A. Hayek, “The Use of Knowledge in Society,” American Economic Review 35, no. 4 (September 1945): 519–30.

20. Institutions fund articulation offices, software licensing, and faculty committee time through general operating budgets, not through fees charged to transferring students. The cross-subsidy structure is described in Robert Kelchen, Higher Education Accountability (Baltimore: Johns Hopkins University Press, 2018).

21. The asymmetric cost stickiness of administrative overhead in higher education is documented in research showing that administrative expenses grow by 0.36% for every 1% increase in revenue but decrease by only 0.12% when revenue falls. See also Richard K. Vedder, Restoring the Promise: Higher Education in America (Oakland: Independent Institute, 2019), on the broader pattern of administrative growth outpacing faculty growth.