Should Part-Time Students Have Their Borrowing Limited?

One of the key higher education policy interests of Senate Health, Education, Labor, and Pensions chairman Lamar Alexander (R-TN) has been to limit student borrowing in an effort to help reduce rising student loan debt. I’ve written in the past about how “overborrowing” is not as big of a concern as students not borrowing enough for college, but there is one group of students that may actually benefit from not being able to take out the maximum allowed amount in student loans.

Currently, students who attend college part-time can borrow the same amount as full-time students as long as there is space in their financial aid package. This can be a concern for students, as it means that they can run out of federal loan eligibility before they complete a bachelor’s degree. Current federal loan limits are the following:

Year in college Dependent student Independent student
First $5,500 $9,500
Second $6,500 $10,500
Third $7,500 $12,500
Fourth and beyond $7,500 $12,500
Lifetime $31,000 $57,500


This equates to about four and a half years of borrowing at the maximum for dependent students and five years for independent students. Given that a sizable percentage of students complete a bachelor’s degree in more than five years, running out of loan eligibility before graduation can be a real concern for students. This is particularly true among students who begin at a community college, where tuition is relatively low compared to at a four-year college. If a student reasonably expects to take six years to complete a bachelor’s degree, then she and her financial aid office should have a conversation about how to best preserve her loan eligibility for when she needs it the most.

A fairly straightforward way to reduce the number of students who exhaust their loan eligibility would be to allow students to get a certain amount of money per credit hour. Students can currently receive a Pell Grant for up to 12 full-time equivalent semesters, with full-time defined as taking at least 12 credits. The current loan limit could be divided by 12 (roughly $2,600 per semester), or this could be done on a per-credit basis (perhaps $200 per credit) to recognize that students who take more classes need to work less.

A completely different proposal would allow students to use their student loan eligibility in any way they see fit. For example, dependent students could use their $31,000 in two years if desired—as long as they had space in their aid package. This idea of an education line of credit was raised by Jeb Bush in his short-lived presidential campaign, but it is unclear what Senator Alexander thinks of this proposal. At this point, it seems like the idea of limiting borrowing for part-time students at an individual college’s discretion is the most likely policy outcome.

How Much Did A Coding Error Affect Student Loan Repayment Rates?

Mistakes happen. I should know—I make more than my fair share of them (including on this blog). But some mistakes are a little more noticeable than others, such as when your mistake has been viewed more than a million times. That is what happened to the U.S. Department of Education recently, when they found a coding error in the popular College Scorecard website and dataset.

Here is a description of the coding error from the Department of Education’s announcement:

“Repayment rates measure the percentage of undergraduate borrowers who have not defaulted and who have repaid at least one dollar of their principal balance over a certain period of time (1, 3, 5, or 7 years after entering repayment). An error in the original college scorecard coding to calculate repayment rates led to the undercounting of some borrowers who had not reduced their loan balances by at least one dollar, and therefore inflated repayment rates for most institutions. The relative difference—that is, whether an institution fell above, about, or below average—was modest.  Over 90 percent of institutions on the College Scorecard tool did not change categories (i.e., above, about, or below average) from the previously published rates. However, in some cases, the nominal differences were significant.”

As soon as I learned about the error, I immediately started digging in to see how much it affected loan repayment rates. After both my trusty computer and I made a lot of noise trying to process the large files in a short period of time, I was able to come up with some top-level results. It turns out that the changes in loan repayment rates are very large. Three-year repayment rates fell from 61% to 41%, five-year repayment rates fell from 61% to 47%, and seven-year repayment rates fell from 66% to 57%. These changes were quite similar across sectors.


Difference between corrected and previous loan repayment rates (pct).
Corrected Previous Difference N
All colleges
  3-year 41.0 61.0 -20.0 6,090
  5-year 47.1 61.1 -14.0 5,842
  7-year 56.7 66.3 -9.6 5,621
  3-year 46.6 66.8 -20.2 1,646
  5-year 54.2 68.9 -14.7 1,600
  7-year 62.1 72.1 -10.0 1,565
Private nonprofit
  3-year 57.7 77.5 -19.8 1,386
  5-year 63.7 77.3 -13.6 1,375
  7-year 70.4 79.3 -8.9 1,338
  3-year 30.5 50.4 -19.9 3,058
  5-year 35.0 48.9 -13.9 2,850
  7-year 46.9 56.5 -9.6 2,700
Source: College Scorecard.


For those who wish to dig into individual colleges’ repayment rates, here is a spreadsheet of the new and old 3, 5, and 7-year repayment rates.

Fixing the coding error made a big difference in the percentage of students who are making at least some progress repaying their loans. (And ED’s announcement yesterday that it will create a public microdata file from the National Student Loan Data System will help make these errors less likely in the future as researchers spot discrepancies.) This change is likely to get a lot of discussion in coming days, particularly as the new Congress and the incoming Trump administration get ready to consider potential changes to the federal student loan system.

How Much Do For-Profit Colleges Rely on Federal Funds?

Note: This post initially appeared on the Brookings Institution’s Brown Center Chalkboard blog.

The outgoing Obama administration placed for-profit colleges under a great deal of scrutiny. This includes gainful employment regulations that will require graduates of vocationally-oriented programs to meet debt-to-earnings requirements and borrower defense to repayment rules (which will likely be quickly abandoned by the Trump administration) designed to help students who feel they were defrauded by their college.

But special federal scrutiny of the for-profit sector has been around for decades, with one rule shaping the behavior of many colleges. This post explores the extent to which for-profit colleges rely on federal funds. It turns out that many rely heavily on these funds, although it’s not always clear what the implications are for the public.

In the 1992 Higher Education Act reauthorization, Congress included a provision that only applied to for-profit colleges, limiting the percentage of total revenue that for-profits could receive from federal grant, loan, and work-study programs to 85%. (This notably excludes veterans’ benefits, which are a large source of revenue for some colleges.) This percentage was increased to 90% in the 1998 reauthorization, which led to the rule being commonly referred to as “90/10.”

For-profit colleges that exceed 90% of their revenue from federal financial aid in two consecutive years can lose access to federal aid for the following two years. Some Democrats have tried to move back to the 85/15 rule or include veterans’ benefits in the federal financial aid portion of revenue, but these efforts will likely be unsuccessful given the support Republicans have received from for-profit colleges. Notably, some for-profits get a sizable portion of their revenue from veterans’ benefits.

I examined data from the Department of Education between the 2007-08 and 2014-15 academic years to look at how many for-profit colleges are close to the 90% threshold. As the table below shows, a sizable percentage of for-profit colleges get between 80% and 90% of their revenue from federal financial aid. In 2007-08 (the last year before the Great Recession), 23% of colleges were in this category. This rose to 35% in 2009-10 and 38% in 2011-12—the beginning of a sizable enrollment decline in the for-profit sector. As the for-profit sector contracted, the percentage of colleges receiving 80% and 90% of their revenue from federal aid fell to 29% in 2014-15. Yet very few colleges have crossed over the 90% threshold, and just two small colleges lost federal aid eligibility this year for going over 90% in two consecutive years.

Distribution of for-profit colleges’ reliance on federal financial aid dollars by year.
  Pct of total revenue from Title IV funds (number of colleges) Number of colleges
Year 0-70 70-75 75-80 80-85 85-90 90-100
2007-2008 56.9 9.1 11.2 12.5 10.3 0.1 1,831
2008-2009 46.2 12.0 13.2 15.1 13.1 0.4 1,798
2009-2010 37.5 10.9 15.8 19.8 15.5 0.5 1,884
2010-2011 39.5 11.4 14.2 17.5 16.6 0.7 1,976
2011-2012 36.5 10.7 13.6 17.6 20.2 1.4 1,999
2012-2013 37.7 11.9 14.2 15.2 19.5 1.4 1,888
2013-2014 40.5 11.7 14.4 15.1 17.6 0.7 1,888
2014-2015 45.2 12.1 12.8 15.1 13.9 0.9 1,838
Source: Office of Federal Student Aid, U.S. Department of Education.
Note: Institutions based outside the 50 United States and Washington, DC are excluded from the analyses.


I then looked at the reliance on federal aid among the eleven for-profit colleges with at least $600 million in overall revenue in the 2013-14 academic year (as 2014-15 revenue data were incomplete as of this analysis). Most of these colleges became slightly less reliant on federal funds between 2010-11 and 2014-15, highlighted by DeVry’s drop from 81% to 66%. DeVry has notably pledged to voluntarily abide by the 85/15 rule across all of its colleges (including veterans’ benefits), so its declining reliance on federal aid is not surprising. ITT Tech saw a 20% increase in its share of revenues coming from financial aid before its closure, while Ashford, Kaplan, and Phoenix consistently remained at or above 80% across the five years. The American Public University System, which focuses on veterans, got less than half of its revenue from federal financial aid.



In December, the Department of Education worked with the Department of Defense and Department of Veterans Affairs to produce a dataset that included colleges’ revenue from various military and veterans’ benefits programs. A key finding of the departments is that an estimated 200 for-profit colleges would get more than 90% of their revenue from federal sources if all federal funds were counted, up from 17 under the current version of the 90/10 rule. In other words, roughly 200 for-profit colleges are almost entirely funded by the federal government, although some of this funding is returned to the government when students repay their loans. Yet this fact is obscured when military and veterans’ benefits are excluded from the calculations.

Below is a summary of the approximate revenue percentages from Department of Education and military sources for the eleven largest for-profits in the 2013-14 academic year.


Five of these top eleven colleges exceed the 90/10 rule once all federal sources are included. All for-profit colleges are estimated to have at least 70% of revenue come from federal sources.  However, this calculation may be several percent off due to differences in how each source calculates an academic year (as evidenced by ITT Tech’s 103% of revenue coming from the federal government).

The data suggest that American Public University gets more revenue from military sources than the Department of Education, while four other for-profits (Ashford, ITT Tech, Phoenix, and Strayer) got at least ten percent. From this table, it is clear that some for-profits consider military benefits as an important revenue source (others, such as DeVry and Argosy, do not).

Is it a problem that for-profit colleges generate such a large portion of their revenues from federal funds? To me, the answer is not entirely clear. A concern with many for-profit colleges’ heavy reliance on federal funds is that it signals a lack of interest from employers in these colleges’ programs. Given that many for-profit colleges were founded to train employees for specific jobs, the lack of private funding is a concern. The post-college outcomes of many for-profit colleges also deserve additional scrutiny, particularly as newly released gainful employment data show that for-profit colleges are the vast majority of institutions that failed both performance metrics.


On the other hand, the heavy reliance on federal funds also reflects the reality that for-profit colleges serve a large percentage of financially needy students. Many of these students are unable to attend college without some sort of financial assistance, whether it be the Pell Grant, student loans, or state appropriations that help to lower the price tag for college. A sizable percentage of public and private nonprofit colleges get a majority of their revenue from the federal or state governments, but they do not face the same level of public scrutiny as for-profit colleges.

Finally, it would be helpful if the Department of Education provided data on how much revenue all colleges received from military sources in addition to federal financial aid dollars. This could be used to highlight colleges that rely heavily on government funding, but it could also be used to showcase colleges that serve a particularly large percentage of active-duty military members and veterans.

Highlights from the Gainful Employment Data Release

In one of the Obama administration’s final education policy actions, the U.S. Department of Education released a long-awaited dataset of earnings and debt burdens under the gainful employment accountability regulations. These regulations, which survived several legal challenges from the for-profit college sector, require programs that are defined to be vocationally-oriented in nature (the majority of programs at for-profit colleges and a small subset of nondegree programs at public and private nonprofit colleges) to meet one of two debt-to-earnings metrics in order to continue receiving federal financial aid.

Option 1 (annual earnings): The average student loan payment of graduates in a program must be less than 8% of either mean or median earnings in order to pass. Payments between 8% and 12% of income puts programs “in the zone,” while payments above 12% of income result in a failure.

Option 2 (discretionary income): The average student loan payment of graduates in a program must be less than 20% of discretionary income (earnings above 150% of the federal poverty line) in order to pass. Payments between 20% and 30% of discretionary income puts programs “in the zone,” while payments above 30% of discretionary income result in a failure.

Any colleges that fail both metrics twice in a three-year period (using both mean and median earnings) or colleges in the oversight zone for four consecutive years are currently at risk of losing access to federal financial aid. However, both the Trump administration and Congressional Republicans have expressed interest in scrapping this accountability metric, meaning that colleges may not actually face sanctions in the future.

This data release covered 8,637 programs at 2,616 colleges, with about two-thirds of these programs being at for-profit institutions. Overall, 803 programs (9.3%) failed and 1,239 programs (14.4%) were in the oversight zone, with the remaining 76% of programs passing. As shown below, there were large differences in the pass rates by type of institution (note: the incorrect headers on the original post have been fixed). No public colleges failed (likely due to lower tuition levels because of state and local subsidies), and failure rates in the private nonprofit sector were also fairly low. Yet Harvard, Johns Hopkins, and the University of Southern California all had one program fail—leaving these prestigious institutions with some egg on their face. (UPDATE: Harvard suspended admissions for their graduate program in theater that failed gainful employment within one week of the data release.)

Distribution of gainful employment scores by sector and level.
Percentage of programs
Sector Fail Zone Pass N
Public, <2 year 0.0 0.7 99.3 293
Public, 2-3 year 0.0 0.3 99.7 1,898
Public, 4+ year 0.0 0.3 99.7 302
Private nonprofit, <2 year 0.0 10.3 89.7 78
Private nonprofit, 2-3 year 3.5 22.0 74.6 173
Private nonprofit, 4+ year 4.7 9.0 86.3 212
For-profit, <2 year 4.4 19.7 76.0 1,460
For-profit, 2-3 year 11.5 20.1 68.4 2,042
For-profit, 4+  year 22.5 21.4 56.1 2,174
Total 9.3 14.4 76.4 8,637
Source: U.S. Department of Education.
(1) Percentages may not add up to 100 due to rounding.
(2) The “total” row excludes five foreign colleges.


For-profit colleges that only offer shorter programs (primarily certificates) did pretty well in the gainful employment metrics, with only 4% failing and 20% in the oversight zone. The worst outcomes were by far among four-year for-profit colleges, with 23% failing and 21% in the oversight zone. These poorer outcomes are not being driven by the large for-profit chains. DeVry, Kaplan, Strayer, and Phoenix combined to have just 16 programs fail, while four colleges (Vaterott, Sanford-Brown, the Art Institute of Phoenix, and Virginia College) all had at least 19 programs fail.

I then examined how the different sectors of colleges performed on the debt-to-earnings ratios for both annual income and discretionary income, with the distributions of ratios shown on the charts below. (Red vertical lines represent the cutoffs for being in the oversight zone (left) and failing (right).) These graphs confirm that public colleges have the lowest debt-to-earnings ratios, followed by private nonprofit colleges and for-profit colleges.



There are three important drawbacks of this data release that are worth emphasizing. First, 133 programs, all at for-profit colleges, are still in the process of appealing their classification (67 that failed and 66 that are in the oversight zone). Second, this only includes a small subset of programs at public and private nonprofit colleges even as similar programs are covered at for-profit colleges. For example, for-profit law schools are included in the gainful employment regulations (and the outcomes aren’t always great). But law programs at nonprofit law schools aren’t covered by the regulations, even though the goal at the end of the program is similar and many colleges expect their law schools to generate excess revenue for their university. Third, by only covering people who completed a program, colleges with low completion rates may look good even if the quality of education induces students to leave the program in disgust.

Regardless of whether federal financial aid dollars are tied to graduates’ debt-to-earnings ratios, it is important to make more program-level outcome data available to students, their families, and the general public. There have been discussions about including program-level data in the College Scorecard, but that is far from a certainty at this point. At the very least, the incoming Trump administration should propose making comparable earnings and debt available for vocationally-focused degree programs at public and private nonprofit colleges.

How Should States Structure “Free” College?

It is safe to say that the idea of free public college has gone dormant at the national level with the election of Donald Trump and a Republican Congress. But a number of states are considering adopting free college plans in light of the Tennessee Promise’s success from both political and enrollment perspectives.1 According to the Education Commission of the States, legislation was introduced in 23 states to adopt some type of free college plans between 2014 and November 2016. These bills died in most states, but five states in addition to Tennessee (Delaware, Kentucky, Minnesota, Oregon, and Rhode Island) enacted free college plans during this period.

On the same day that Republicans officially took control of the U.S. Senate, New York’s Democratic governor Andrew Cuomo announced a proposal to make SUNY and CUNY institutions tuition-free for students with family incomes below $125,000.2  This proposal, which Cuomo introduced alongside Vermont senator Bernie Sanders, would make public colleges tuition-free as a last-dollar scholarship. This appears to be similar to the Tennessee Promise, in which additional state funds are applied only after federal, state, and private grants are used.

While President Obama’s free community college proposal would have been a first-dollar scholarship (supplementing instead of supplanting other aid), Cuomo’s plan would keep the price tag down to about $163 million per year—an important consideration given the state’s other pressing priorities. Because New York is a low-tuition, high-aid state, the neediest students already have their tuition covered by grants and would thus receive no additional funds.

Therefore, the benefits of the program would go to two groups of students. The first group is fairly obvious: middle-income and upper-middle-income families. In New York, $125,000 falls at roughly the 80th percentile of family income—an income level where families may not be able to pay tuition without borrowing, but college enrollment rates are quite high. The second group consists of lower-income students who are induced to enroll by the clear message of free tuition, even though they would have received free tuition without the program. Tennessee’s enrollment boost suggests this group is far from trivial in size.

Students attending New York public colleges currently have fairly modest debt burdens. College Scorecard data show that the median student attending public 2-year colleges graduates with about $10,000 in debt, while students at 4-year colleges graduate with about $20,000 in debt. Will the New York program (if adopted) make a sizable dent on students’ debt burdens? My expectation is that the reduction in debt will not be as much as expected. This is because tuition and fees are less than half of the total cost of attendance at four-year colleges and an even smaller fraction at community colleges. Students will still need to borrow for books and living expenses, which are not covered in Cuomo’s proposal.

This gets back to a seemingly-eternal question in the education policy realm. Given limited resources, is it better to give more money to the neediest students to help them cover living expenses or is it better to give some money to middle-income families in a state with high tax burdens?3 Most politicians seem to prefer the latter, as the message of “free” college and giving money to more students seems to be a political winner. But the former could appeal to politicians who strongly prioritize equity.

But from a researcher’s perspective, which one is better for students as a whole is less clear. (It could even be the case that giving the money to colleges to improve the educational experience while charging higher tuition could be better for students in the long run.) One great thing about America is that there are 50 laboratories of democracy. I hope that states take different pathways in student financial aid and funding colleges to see what works best.



1 It is too early to truly tell whether the program increased educational attainment levels or labor market outcomes, or whether the program has been cost-effective given additional state funding for higher education.

2 I have to gripe about the language in the press release regarding “crushing” student loan debt, particularly given how students can use income-driven repayment plans to reduce the risk of federal loans. But I’m spitting into the wind on this one, given how journalists and politicians routinely use this language that could scare students away from attending college.

3 Some may disagree with the idea that resources are limited, but former White House staffer Zakiya Smith summed it up nicely by stating that there are plenty of other good uses for available funds in any budget.