Today marks the start of U.S. Department of Education’s annual release of cohort default rates (CDR), which reflects the percentage of students who default on their loans within three years of entering repayment. Colleges were informed of their rates today, with a release to the public coming sometime soon. This release, tracking students who entered repayment in Fiscal Year 2011, will the third year that three-year CDRs have been collected and completes a shift from two-year to three-year CDRs for accountability purposes.
Before this year, colleges were subject to sanctions based on their two-year CDRs. Any college that had a two-year CDR of more than 40% in one year could lose its federal student loan eligibility, while any college with a two-year CDR of over 25% for three consecutive years could lose all federal financial aid eligibility. (Colleges with a very small percentage of borrowers can get an exemption.) While this was a rare occurrence (fewer than ten colleges were impacted last year), the switch to a three-year CDR has worried colleges even as the allowed CDR over three years rose from 25% to 30%.
But as the methodology changes, we need to consider what CDR data are actually good for. Colleges take cohort default rates very seriously, and the federal government is likely to use default rates as a component of the often-discussed (and frequently delayed) Postsecondary Institution Ratings System (PIRS). But should the higher education community, policymakers, or the general public take CDRs seriously? Below are some reasons why the default data are far from complete.
(1) Students are tracked over only three years, and income-based repayment makes the data less valuable. I have previously written about these two issues—and why it’s absurd that the Department of Education doesn’t track students over at least ten years. Income-based repayment means that students can be current on their payments even if their payments are zero, which is good for the student but isn’t exactly a ringing endorsement of a given college’s quality.
(2) Individual campuses are often aggregated to the system level, but this isn’t consistent. One of the biggest challenges as a researcher in higher education finance is that data on loan and grant volumes and student loan default rates come from Federal Student Aid instead of the National Center for Education Statistics. This may sound trivial, but some colleges aggregate FSA data to the system level for reporting purposes while all NCES data are at the campus level. This means that while default data on individual campuses within the University of Wisconsin System are available, data from all of the Penn State campuses are aggregated. Most for-profit systems also aggregate data, likely obscuring some individual branches that would otherwise face sanctions.
(3) Defaults are far from the only adverse outcome, but it’s the only one with reported data. Students are not counted as being in default until no payment has been made for at least 271 days, but we have no idea of delinquency rates, hardship deferments, or forbearances related to financial problems by campus. As I recently wrote in a guest post for Access to Completion, the percentage of students having repayment difficulties ranges between 17% and 51%, depending on assumptions made. But we don’t have data on delinquency rates by campus, something which a lot of stakeholders would have interest in.
Does this mean cohort default rates are good for absolutely nothing? No. They’re still useful in identifying colleges (or systems) where a large percentage of borrowers default quickly and a substantial percentage of students borrow. And very low default rates can be a sign that either students are doing well in the labor market after leaving college or that they have the knowledge to enter income-based repayment programs. But for many colleges with middling default rates, far more data are needed (that the Department of Education collects and doesn’t release) to get a better picture of performance.
When the CDR data come out, I’ll have part 2 of this post—focusing on the colleges that are subject to sanctions and what that means for current and future accountability systems.
Robert Kelchen 
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