Last week, Senator Lamar Alexander (R-TN) released a white paper that provided his early thinking on the approach the federal government should take regarding accountability in higher education.

One thing is clear: The higher education system needs to be improved as students struggle to graduate and repay their student loans. This is especially true for low-income students and students of color, who complete college and repay their loans at lower rates than their White and more affluent peers.

The challenge, though, is determining how to best improve higher education so that it effectively serves all students, but especially low-income students and students of color. Accountability policies can be a significant lever for this improvement.

The current system does have several accountability levers, including the gainful employment rule and the 90-10 rule, which caps the percentage of revenue that for-profit schools can receive through federal financial aid sources. These rules are critically important to protect students and taxpayers from predatory for-profit colleges and universities that leave students worse off than if they had never attended college in the first place.

Senator Alexander’s white paper suggests eliminating such rules. Ed Trust disagrees with that approach. We should be building upon these rules, not eliminating them.

The white paper instead calls for a single accountability metric: holding programs responsible for students’ ability to succeed after enrolling at their college, as demonstrated by their ability to repay their student loans.

We agree that loan repayment rates based on students’ ability to make progress on paying down their loan balance is a critical piece of data. However, focusing on loan repayment is not enough to measure student success. What about access? What about completion? What about equity?

Black students and students who did not complete college struggle the most to repay their student loans, and college completion is more directly tied to what colleges and universities do than repayment rates. Additionally, Black students who graduate are more likely to default than White students who don’t. This is a reflection of systemic inequality in the broader society and within our existing stratified higher education system, where the campuses more likely to enroll Black students have the least resources.

The Alexander proposal, along with many existing proposals on accountability, will result in incentivizing institutions to enroll the students with the lowest perceived risk and exclude students of color and low-income students who graduate and repay their loans at lower rates than their White and more affluent peers. We cannot talk about accountability policy without also addressing how to reward campuses that are successfully serving low-income students and students of color. And we also must ensure campuses who are serving these students have access to resources to improve.

What the white paper proposes is wholly insufficient and would take higher education in the wrong direction, especially if equity is a priority in reauthorizing HEA. We hope Senator Alexander reconsiders this approach as Congress moves forward.