Is Administrative Bloat Really a Big Problem?

I usually begin talks on my book Higher Education Accountability with a discussion of why accountability pressures now are stronger than ever for much of nonprofit higher education. Not surprisingly, one of the key reasons that I discuss is the rising price tag of a college education. I usually get at least one question from audience members in every talk about the extent to which administrative bloat in higher education is driving up college prices. I have written before about how difficult it is to pin the rising cost of providing a college education on any given factor, but I am diving in deeper on the administrative bloat concern in this post.

First, let’s take a look at trends in administrative expenditures and staffing over the last decade or two. Here are charts on inflation-adjusted per-FTE expenditures for instruction, academic support, institutional support, and student services between 2003 and 2013 (courtesy of Delta Cost Project analyses). The charts show that spending on student services and academic support increased faster than both inflation and instructional expenditures, while institutional support expenditures (the IPEDS expenditure category most closely associated with administration) increased about as fast as instructional expenditures.

Turning to staffing trends, I again use Delta Cost Project data to look at the ratios of full-time faculty, part-time faculty, administrators, and staff per 1,000 FTE students. In general, the ratio of full-time faculty and administrators per 1,000 students held fairly constant across time in most sections of higher education. However, the ratio of part-time faculty and professional staff members (lower-level administrators) increased markedly across higher education.

The data suggest that there has not been a massive explosion of high-level administrators, but there has been substantial growth in low- to mid-level academic support and student services staff members. What might be behind that growth in professional staff members? I offer two potential explanations below.

Explanation 1: Students need/want more services than in the past. As most colleges have enrolled increasingly diverse student bodies and institutions respond to pressures to graduate more students, it’s not surprising that colleges have hired additional staff members to assist with academic and social engagement. Students have also demanded additional services, such as more staff members to support campus diversity initiatives. (Lazy rivers and climbing walls could factor in here, but there are limited to such a small segment of higher education that they’re likely to be a rounding error in the grand scheme of things.)

Explanation 2: Staff members are doing tasks that faculty members used to do, which may not necessarily be a bad thing. A good example here is academic advising. Decades ago, it was far more common for faculty members to advise undergraduate students from their first year on. But over the years, professional academic advisers have taken on these responsibilities at many campuses, leaving faculty members to advise juniors and seniors within a major. To me, it seems logical to allow lower-paid professional advisers to work with first-year and second-year students, freeing up the time of higher-paid faculty members to do something else such as teach or do research. (I also have a strong hunch that professional advisers are better at helping students through general education requirements than faculty members, but I’d love to see more research on that point.)

In summary, there are lots of gripes coming from both faculty members and the public about the number of assistant and associate deans on college campuses. But most of the growth in non-faculty employees is among lower-level student and academic affairs staff members, not among highly-paid deans. There is still room for a robust debate about the right number of staff members and administrators, but claims of massive administrative bloat are not well-supported across all of higher education.

It’s hard to believe that a faculty member is writing this, but I do feel that most administrators do serve a useful purpose. As I told The Chronicle of Higher Education in a recent interview (conducted via e-mail while I was waiting for a meeting with an associate dean—I kid you not!), “Faculty do complain about all of the assistant and associate deans out there, but this workload would otherwise fall on faculty. And given the research, teaching, and service expectations that we face, we can’t take on those roles.”

Why Accountability Efforts in Higher Education Often Fail

This article was originally published at The Conversation.

As the price tag of a college education continues to rise along with questions about academic quality, skepticism about the value of a four-year college degree has grown among the American public.

This has led both the federal government and many state governments to propose new accountability measures that seek to spur colleges to improve their performance.

This is one of the key goals of the PROSPER Act, a House bill to reauthorize the federal Higher Education Act, which is the most important law affecting American colleges and universities. For example, one provision in the act would end access to federal student loans for students who major in subjects with low loan repayment rates.

Accountability is also one of the key goals of efforts in many state legislatures to tie funding for colleges and universities to their performance.

As a researcher who studies higher education accountability – and also just wrote a book on the topic – I have examined why policies that have the best of intentions often fail to produce their desired results. Two examples in particular stand out.

Federal and state failures

The first is a federal policy that is designed to end colleges’ access to federal grants and loans if too many students default on their loans. Only 11 colleges have lost federal funding since 1999, even though nearly 600 colleges have fewer than 25 percent of their students paying down any principal on their loans five years after leaving college, according to my analysis of data available on the federal College Scorecard. This shows that although students may be avoiding defaulting on their loans, they will be struggling to repay their loans for years to come.

The second is state performance funding policies, which have encouraged colleges to make much-needed improvements to academic advising but have not resulted in meaningful increases in the number of graduates.

Based on my research, here are four of the main reasons why many accountability efforts fall short.

1. Competing initiatives

Colleges face many pressures that provide conflicting incentives, which in turn makes any individual accountability policy less effective. In addition to the federal government and state governments, colleges face strong pressures from other stakeholders. Accrediting agencies require colleges to meet certain standards. Faculty and student governments have their own visions for the future of their college. And private sector organizations, such as college rankings providers, have their own visions for what colleges should prioritize. (In the interest of full disclosure, I am the methodologist for Washington Monthly magazine’s college rankings, which ranks colleges on social mobility, research and service.)

As one example of these conflicting pressures, consider a public research university in a state with a performance funding policy that ties money to the number of students who graduate. One way to meet this goal is to admit more students, including some who have modest ACT or SAT scores but are otherwise well-prepared to succeed in college. This strategy would hurt the university in the U.S. News & World Report college rankings, which judge colleges in part based on ACT/SAT scores, selectivity and academic reputation.

Research shows that students considering selective colleges are influenced by rankings, so a university may choose to focus on improving their rankings instead of broadening access in an effort to get more state funds.

2. Policies can be gamed

Colleges can satisfy some performance metrics by gaming the system, instead of actually improving their performance. The theory behind many accountability policies is that colleges are not operating in an efficient manner and that they must be given incentives in order to improve their performance. But if colleges are already operating efficiently – or if they do not want to change their practices in response to an external mandate – the only option to meet the performance goal may be to try to game the system.

An example of this practice is with the federal government’s student loan default rate measure, which tracks the percentage of borrowers who default on their loans within three years of when they are supposed to start repaying their loans. Colleges that are concerned about their default rates can encourage students to enroll in temporary deferment or forbearance plans. These plans result in students owing more money in the long run, but also they push the risk of default outside the three-year period that the federal government tracks, which essentially lets colleges off the hook.

3. Unclear connections

It’s hard to tie individual faculty members to student outcomes. The idea of evaluating teachers based on their students’ outcomes is nothing new; 38 states require student test scores to be used in K-12 teacher evaluations, and most colleges include student evaluations as a criterion of the faculty review process. Tying an individual teacher to a student’s achievement test scores has been controversial in K-12 education, but it is far easier than identifying how much an individual faculty member contributes to a student’s likelihood of graduating from college or repaying their loans.

For example, a student pursuing a bachelor’s degree will take roughly 40 courses during their course of study. That student may have 30 different professors over four or five years. And some of them may no longer be employed when the student graduates. Colleges can try to encourage all faculty to teach better, but it’s difficult to identify and motivate the worst teachers because of the elapsed time between when a student takes a class and when he or she graduates or enters the workforce.

4. Politics as usual

Even when a college should be held accountable, politics often get in the way. Politicians may be skeptical of the value of higher education, but they will work to protect their local colleges, which are often one of the largest employers in their home states. This means that politicians often act to stop a college from losing money under an accountability system.

The ConversationTake for example Senate Majority Leader Mitch McConnell, R-Ky., who was sympathetic to the plight of a Kentucky community college with a student loan default rate that should have resulted in a loss of federal financial aid. He got a provision added to the recent federal budget agreement that allowed only that college to appeal the sanction.

Comments on Accountability and the Higher Education Act

As the Senate works on its version of a Higher Education Act reauthorization bill, the Health, Education, Labor and Pensions Committee has made accountability one of its key areas of discussion in recent hearings. Committee chairman Lamar Alexander asked the higher education community for comments regarding accountability, so I sent my comments along to the committee. They are reprinted below.

February 15, 2018

The Honorable Lamar Alexander

The Honorable Patty Murray

Senate Health, Education, Labor and Pensions (HELP) Committee

Dear Senators:

My name is Robert Kelchen and I am an assistant professor of higher education at Seton Hall University.[i] I have been closely following the Higher Education Act reauthorization hearings in the Senate HELP Committee and am pleased to see the committee beginning to work on writing a comprehensive, bipartisan piece of legislation. Accountability is a crucial issue for both protecting students and taxpayers alike, and is such it is essential to design a system that encourages institutional improvement while discourages colleges from trying to game the system to remain eligible to receive federal Title IV financial aid dollars.

I have spent the last several years researching higher education accountability in all of its forms, including efforts by the federal government, state governments, accrediting agencies, the private sector, and colleges themselves.[ii] In this letter, I share four key points from my research on how to design accountability systems that have the highest likelihood of success and provide the best possible information for students, their families, and policymakers.

 

Point 1: Avoid all-or-nothing accountability systems. Three key federal accountability policies—cohort default rates (CDRs), the 90/10 rule, and gainful employment—grant institutions access to federal Title IV financial aid if they pass a certain threshold. Although the gainful employment metrics are too new to actually take away programs’ financial aid, it is clear from CDRs and the 90/10 rule that very few colleges are affected. In the most recent year of data, only ten small colleges faced the loss of either federal student loans or all Title IV aid for high CDRs and no colleges were subject to the loss of federal student aid for failing the 90/10 rule in two consecutive years.[iii]

Setting minimum performance floors sounds like an appealing idea, and the idea of ‘bright line’ standards has been proposed with respect to recognizing accreditors.[iv] But actually following through and pulling the plug on the lowest-performing colleges by denying them access to federal financial aid is a much more difficult task. As the majority staff’s white paper notes, just eleven colleges have lost access to Title IV funds due to high CDRs since 1999—even though approximately ten colleges per year should have lost aid if federal laws were strictly followed. Congress and the Department of Education have shown a lack of willingness to effectively close colleges (particularly public or private nonprofit institutions), as shown by the Senate Majority Leader’s recent efforts to exempt a Kentucky technical college from losing Title IV aid and the previous administration’s alteration of CDR calculations just prior to release in 2014 that protected an unknown number of colleges.[v]

A more effective way to hold a larger number of colleges accountable for their outcomes is to use a gradually increasing set of sanctions for lower-performing institutions. In theory, risk-sharing proposals for federal student loan repayment can provide that sort of incentive. However, the PROSPER Act’s loan repayment metric would create the same all-or-nothing incentive that would be subject to both institutional gaming and intense lobbying efforts. The Student Protection and Success Act creates a sliding scale to some extent (although retaining a minimum eligibility threshold), and academics’ risk-sharing proposals also are based on sliding scales.[vi] It is also important to note that risk-sharing proposals should include incentives for institutional improvement as well as sanctions, similar to what the ASPIRE Act would do.

 

Point 2: Both institution-level and program-level accountability policies are important. Policy conversations are rapidly moving toward holding individual programs within colleges accountable for their performance. Gainful employment regulations already seek to do that for a subset of programs, but the PROSPER Act would use program-level loan repayment rates for all institutions of higher education. This proposal makes intuitive sense, but program-level data collection efforts have some important limitations.

In general, programmatic outcomes data make the most sense when students enter a college or university with a particular field of study in mind. This is less of a concern for vocationally-oriented programs at the undergraduate level and for graduate and professional education in which students are generally admitted to study in particular programs. But not all students enter associate or baccalaureate degree programs with a declared major, and roughly one-third of first-time college students changed their declared major at least once within three years of starting college.[vii] This means that attributing student outcomes to a particular program becomes a concern. Additionally, if undeclared students are ignored for the purposes of program-level accountability metrics, colleges suddenly have an incentive to restrict when students can officially declare majors. Waiting until two years into a bachelor’s degree program to declare a major restricts the pool of students to those with a higher likelihood of success, meaning that dropouts are less likely to be counted.

Another potential option is to restrict program-level accountability only to students who graduate, as is the case with the current gainful employment regulations. But this obscures important data for students, since only 54% of students at four-year colleges and 32% of students at two-year colleges graduated from that same institution within eight years of initial enrollment.[viii] It is likely the case that reported program-level outcomes are far better for graduates than dropouts, thus providing an overly rosy picture of lower-performing programs.[ix]

Given the interest in program-level outcomes data alongside the difficulty in fully relying on program-level accountability measures in certain sectors of higher education, a more reasonable solution would be to use a combination of program-level and institution-level data for accountability purposes. It may be worthwhile to consider tougher performance measures for entire institutions than individual programs due to the difficulty in accurately measuring programmatic outcomes in non-vocational fields and due to concerns about small cell sizes for certain programs of study.

 

Point 3: Defining the loan repayment rate is perhaps the most important accountability-related issue in HEA reauthorization. Very few academics consider CDRs to be a tremendously valuable measure of institutional performance due to their ability to be manipulated by colleges, the presence of income-driven repayment programs, and their relatively short time horizon. The student loan repayment rate that was included in the 2015 release of the College Scorecard represented a more comprehensive look at how former students are managing their loans, and painted a completely different pictures than CDRs (especially after an unfortunate coding error was finally fixed in early 2017).[x]

Both the definition of student loan repayment rates in the College Scorecard and the types of loans included are decisions that have substantial accountability implications. The Scorecard definition (repaying at least $1 in principal at 1, 3, 5, and 7 years after entering repayment) includes federal subsidized and unsubsidized loans, omitting Parent and Grad PLUS loans. Approximately $21 billion of the $94 billion in federal loans during the 2016-17 academic year was in the form of PLUS loans, yet this is entirely missing from the Scorecard repayment rate (and CDRs, as well).[xi] It may be worth considering a separate loan repayment rate metric for Parent PLUS loans, but Grad PLUS loans should be included with other student loans for accountability purposes.

There are two other potential definitions of loan repayment rates that are worth considering. The first is the percentage of dollars that are repaid during a certain period of time. This is similar to the initial definition of repayment rates that was used in the 2010 negotiations regarding gainful employment.[xii] This is a more taxpayer-focused metric, as it captures overall risk of nonrepayment instead of the percentage of borrowers who are struggling to pay down principal. The second definition is the percentage of students who are on track to repay their loans within a fixed window of time. The challenge with this definition is that students can choose from a menu of loan repayment plans, with extended payment plans being particularly common among students with larger amounts of debt.

A further complicating factor is the growth of income-driven repayment plans, which now represent about 40% of all outstanding federal student loan dollars.[xiii] These plans often result in outstanding balances rising in early years of repayment (when incomes are low) before principal is paid down later. An analysis of recent bachelor’s degree recipients found that only about 25% of students in income-driven plans paid off any principal within five years of entering repayment, while about 75% of students not in income-driven repayment had repaid principal within one year of entering repayment.[xiv] How to address students in income-driven repayment plans is a key concern regarding student loan repayment rates, as the federal government could simultaneously encourage students to enroll in income-driven plans while penalizing colleges where students take up such plans.

 

Point 4: Free the higher education data! Students and their families are currently being asked to make one of the biggest financial decisions of their lives based on relatively little objective information. The College Scorecard was a helpful step forward, as was including part-time and Pell recipient graduation rates in the Integrated Postsecondary Education Data System in 2017. A student unit record data system would certainly be helpful in making better data available in the college choice process, but there are things that the Department of Education can do (with the support of Congress) without overturning the ban. A few of the most important data points are the following:

  • Program-level outcomes for all Title IV institutions. Regardless of how the gainful employment negotiated rulemaking panel turns out, HEA reauthorization should encourage data to be released for all programs of study (with the caveats as noted earlier in this letter). Some programmatic accreditors are starting to require institutions to release this sort of information, but ED can do so fairly easily for all students receiving federal financial aid. It would be nice to include all students attending Title IV-participating institutions, but program-level data for federal aid recipients would be a good start.
  • Separate data for undergraduate and graduate students. Although graduate and professional students represent just 17% of all federal student loan borrowers, they make up 38% of all federal student loan dollars.[xv] Yet loan repayment and debt data are not presented separately for graduate students—and current data do not even include Grad PLUS loans.
  • Include outcomes for Parent PLUS loans. Although only five percent of students had a Parent PLUS loan in the 2011-12 academic year, this is still an important financing source for families; borrowing rates are higher (13%) at HBCUs and average loan amounts among borrowers are over $12,000.[xvi] Yet the only information available on PLUS loan outcomes is a set of sector-level default rates that ED released following a negotiated rulemaking panel in 2014.[xvii] It is more difficult to envision a high-stakes accountability policy based on parent outcomes instead of student outcomes, but making institution-level data public would be a valuable service to families.
  • Provide data on incomedriven repayment plan usage by institution. Because repayment rates are affected by income-driven repayment plans, it would be helpful to provide information on the percentage of borrowers from each institution who are enrolled in income-driven repayment plans, ideally at the undergraduate and graduate level. A lower repayment rate at a college that graduates a large percentage of students into public service may be more acceptable due to income-driven repayment plans, while a similar repayment rate at a college where students are enrolled in more lucrative majors would be a greater cause for concern.[xviii]

I would like to thank the HELP Committee for holding a series of hearings on Higher Education Act reauthorization and for actively engaging with the research community throughout the process. As the committee is drafting the bill over the next few months, so I encourage Senators and staff members to continue reaching out to researchers while considering potential policy proposals and legislative text. I am more than happy to talk with any committee members during this process and I wish you all the best of luck in working on a much-needed overhaul of the Higher Education Act.

———————————————————–

[i] All views and opinions expressed in this letter are mine alone and do not necessarily reflect my employer.

[ii] See my new book Higher Education Accountability, which is now available through Johns Hopkins University Press.

[iii] Author’s calculations using Federal Student Aid data on cohort default rates (FY14 cohort) and proprietary school revenue percentages (2015-16). Additionally, I appreciate the majority staff referencing one of my blog posts on the topic—that made my day!

[iv] Lederman, D. (2017, June 21). Where winds are blowing on accreditation. Inside Higher Ed. https://www.insidehighered.com/news/2017/06/21/bright-line-indicators-student-outcomes-dominate-discussion-federal-accreditation.

[v] Douglas-Gabriel, D. (2018, February 8). McConnell attempts to protect two Kentucky colleges in budget deal. The Washington Post. https://www.washingtonpost.com/news/grade-point/wp/2018/02/08/mcconnell-attempts-to-protect-two-kentucky-colleges-in-budget-deal/?utm_term=.a5e47c2fb77e. Stratford, M. (2014, September 24). Reprieve on default rates. Inside Higher Ed. https://www.insidehighered.com/news/2014/09/24/education-dept-tweaks-default-rate-calculation-help-colleges-avoid-penalties.

[vi] Kelchen, R. (2015). Proposing a federal risk-sharing policy. Indianapolis, IN: Lumina Foundation. Webber, D. A. (2017). Risk-sharing and student loan policy: Consequences for students and institutions. Economics of Education Review, 57, 1-9.

[vii] Leu, K. (2017). Beginning college students who change their majors within 3 years of enrollment. Washington, DC: National Center for Education Statistics Report NCES 2018-434.

[viii] Ginder, S. A., Kelly-Reid, J. E., & Mann, F. B. (2017). Graduation rates for selected cohorts, 2008-13; outcome measures for cohort year 2008; student financial aid, academic year 2015-16; and admissions in postsecondary institutions, fall 2016. Washington, DC: National Center for Education Statistics Report NCES 2017-150rev.

[ix] There is an argument that students want outcomes of graduates only instead of combining graduates and dropouts, given common complaints about College Scorecard data and the common trend of students overstating their likelihood of graduation. But for an accountability system tied to federal financial aid instead of consumer information, the proper sample may differ.

[x] Kelchen, R., & Li, A. Y. (2017). Institutional accountability: A comparison of the predictors of student loan repayment and default rates. The ANNALS of the American Academy of Political and Social Science, 671, 202-223.

[xi] Baum, S., Ma, J., Pender, M., & Welch, M. (2017). Trends in student aid. New York, NY: The College Board.

[xii] Belfield, C. R. (2013). Student loans and repayment rates: The role of for-profit colleges. Research in Higher Education, 54(1), 1-29.

[xiii] Author’s analysis using Federal Student Aid data.

[xiv] Conzelman, J. G., Smith, N. D., & Lacy, T. A. (2016, July 11). The tension between student loan accountability and income-driven repayment plans. Brown Center Chalkboard. https://www.brookings.edu/blog/brown-center-chalkboard/2016/07/11/the-tension-between-student-loan-accountability-and-income-driven-repayment-plans/.

[xv] Baum, S., & Steele, P. (2018). Graduate and professional school debt: How much students borrow. West Chester, PA: AccessLex Institute.

[xvi] Goldrick-Rab, S., Kelchen, R., & Houle, J. (2014). The color of student debt: Implications of federal loan program reforms for black students and historically black colleges and universities. Madison, WI: Wisconsin HOPE Lab.

[xvii] Stratford, M. (2014, April 3). Default data on Parent PLUS loans. Inside Higher Ed. https://www.insidehighered.com/news/2014/04/03/education-department-releases-default-data-controversial-parent-plus-loans.

[xviii] It would be helpful to have data on Public Service Loan Forgiveness interest by institution, but these data would be incomplete because students do not have to signal any intent to use the program until they officially apply after making 120 qualifying payments.

Who Uses Income-Driven Repayment Plans?

Over the last two years, the U.S. Department of Education’s Office of Federal Student Aid has quietly released additional data on the federal government’s portfolio of nearly $1.4 trillion in student loans. I was on the FSA website today looking up the most recent data on Public Service Loan Forgiveness employment certification forms (up to 740,000 filed as of September 30) for a paper I am currently drafting when a new set of spreadsheets on the income-driven repayment (IDR) programs caught my eye.

Overall, just over $375 billion of the $1.05 trillion in federal Direct Loans is now enrolled across the various types of IDR programs. (The rest of the federal loan portfolio is in the old FFEL program, which does not make new loans.) This is up from $269 billion of loans in IDRs when I last wrote about the topic on my blog in mid-2016, which has implications for both students and taxpayers alike. Here, I summarize some of the new data on the types of borrowers who use IDR, as well as some of the other data elements that would be helpful to have going forward.

It is not surprising that students with more debt are more interested in income-driven repayment plans, as many borrowers with less debt could manage payments under the standard ten-year repayment plan. But I was surprised by how much of the debt is held by a small percentage of borrowers. About 1.9 million of the 35.3 million borrowers (or five percent) have more than $100,000 in debt—and this is primarily due to graduate school attendance (since undergraduates cannot borrow more than $57,500 without resorting to PLUS loans). Yet these borrowers hold $325 billion in Direct Loans, or about 30% of all loans outstanding. About $173 billion of this amount is enrolled in IDR plans—53% of all debt held by those with six-figure debts. On the other hand, less than one-fourth of all debt of borrowers with less than $40,000 outstanding is enrolled in IDR. The table and figure below show the amount of Direct Loans outstanding and the amount enrolled in IDR by debt burden.

(UPDATE 2/1/18: As a commenter noted below, there is a small percentage of loans from the old FFEL program in income-driven repayment plans. But as far as I can tell from the data, this only slightly overstates the percentage of Direct Loans in IDR. I’m confident that the general trends still hold, though.)

Table 1: Direct Loan and IDR volumes by debt burden.
Amount of debt All Direct Loans ($bil) IDR ($bil) Pct of loans in IDR
Less than $5k 16.9 0.9 5.3%
$5k-$10k 45.6 4.0 8.8%
$10k-$20k 110.7 16.7 15.1%
$20k-$40k 220.6 52.9 24.0%
$40k-$60k 154.6 50.9 32.9%
$60k-$80k 110.5 48.2 43.6%
$80k-$100k 71.3 30.3 42.5%
$100k-$200k 191.7 90.5 47.2%
More than $200k 133.5 82.3 61.6%
Total 1055.4 376.7 35.7%

I also examined new FSA data on Direct Loan and IDR volumes by age (Table 2 below) and institution type (Table 3). The data show that younger borrowers (between ages 25 and 49) have a higher percentage of dollars in IDR than older borrowers and that students who attended private nonprofit and for-profit colleges rely on IDR more heavily than students who went to public colleges. The finding by sector matches general patterns in tuition and fees, but it does not suggest that for-profit college students disproportionately turn to IDR to manage their loan burdens.

Table 2: Direct Loan and IDR volumes by age of borrower.
Age All Direct Loans ($bil) IDR ($bil) Pct of loans in IDR
24 or younger 128 9.2 7.2%
25-34 418.3 177.4 42.4%
35-49 337.9 139.8 41.4%
50-61 140.5 39 27.8%
62 or older 30.6 11.3 36.9%
Total 1055.3 376.7 35.7%

 

Table 3: Direct Loan and IDR volumes by institutional type.
Sector All Direct Loans ($bil) IDR ($bil) Pct of loans in IDR
Public 464.2 143.3 30.9%
Private nonprofit 337 126.5 37.5%
For-profit 176.6 63.6 36.0%
Total 977.8 333.4 34.1%

There are two additional data elements that would be extremely useful in considering the implications of income-driven repayment plans. Ideally, data on IDR takeup would be available at the institutional level (as I have politely requested in the past). But at the very least, a breakdown by undergraduate/graduate student status would be useful information.

And one final request of any journalists or qualitative researchers who may be reading this blog—I would love to know more about how the PSLF approval process is going now that some borrowers have made the 120 monthly payments necessary to qualify for forgiveness. It’s been strange not to hear anything about that process after applications could be submitted as early as October 2017.

Key Takeaways from the House Higher Education Act Reauthorization Bill

Majority Republicans on the U.S. House Committee on Education and the Workforce unveiled their draft legislation today to reauthorize the Higher Education Act—the most important piece of legislation affecting American higher education. The Promoting Real Opportunity, Success, and Prosperity through Education Reform (PROSPER) Act checks in at a hefty 542 pages and touches many important aspects of higher education. I live-tweeted my first read through the bill (read the thread here), and in this blog post I am sharing some thoughts on the key themes of the legislation.

Takeaway 1: This bill would undo many Obama-era regulations and salt the earth on future regulations. It’s no secret that Republicans didn’t care for regulations such as gainful employment, borrower defense to repayment, or providing a federal definition of the credit hour. The PROSPER Act would not only undo the regulations, but prohibit the Secretary of Education from promulgating any future regulations (meaning that Congress would have to pass legislation to create any new rules). The Secretary of Education would also be prohibited from creating a federal college ratings system, even though the Obama-era effort to do so was unsuccessful.

Takeaway 2: The federal student loan system would be radically overhauled. Instead of the array of loans that are now available, there would be three flavors of a federal ONE Loan—for undergraduates, parents, and graduate students. The key details are below.

 

  Undergrad (dependent) Undergrad (independent) Parent Grad student
Annual limit (current) $5,500-$7,500 $9,500-$12,500 Cost of attendance Cost of attendance
Annual limit (PROSPER) $7,500-$11,500 $11,500-$14,500 $12,500 $28,500
Lifetime limit (current) $31,000 $57,500 Cost of attendance Cost of attendance
Lifetime limit (PROSPER) $39,000 $60,250 $56,250 $150,000

Note: Medical students have higher loan limits than what is listed above.

Undergraduate students actually have higher loan limits, but the PROSPER Act would also allow colleges to limit borrowing by student major if they feel students are unlikely to repay their obligations. Financial aid administrators have sought this authority for years, which means that students could actually see lower loan limits. Graduate students, on the other hand, would be limited to $28,500 per year and $150,000 overall in federal loans. Given that tuition alone often exceeds this number, expect students to turn to the private market (when possible) to finance their education.

The PROSPER Act also drastically changes income-driven repayment programs. Instead of the range of programs available now, future borrowers could choose between the standard ten-year payment plan or an income-driven plan that would allow them to pay 15% of their discretionary income (over 150% of the federal poverty line) for as long as necessary to repay the loan. There would be no ending date to payments, and payments for married couples would be based on both spouses’ incomes even if they file their taxes separately. (Both of these provisions differ from current law.) The Public Service Loan Forgiveness program, which was only mentioned once in passing in the entire bill, would also end. However, people in the program now would be grandfathered in.

Takeaway 3: Colleges would be held accountable for their outcomes in new ways. The cohort default rate metric (which I’m no fan of) would be replaced by a repayment rate metric. If a program (not a college) had more than 45% of its borrowers at least 90 days delinquent or in certain types of deferment for three consecutive years, it would lose access to all federal financial aid. This is a more generous definition of repayment for colleges than the College Scorecard’s definition (repaying at least $1 in principal), so I can’t say how many colleges would actually be affected.

Another interesting piece is that colleges would have to repay at least a portion of federal financial aid dollars given to students who left college during a semester. Right now, colleges can try to claw back those funds, but this proposal would limit colleges to trying to collect 10% of the amount owed back from students. This is similar to what Matt Chingos and Kristin Blagg have proposed in a policy brief.

There are so many other interesting points in this legislation, but I think these are the three most important ones that I can speak to based on my experience and research. Keep in mind that the Senate will also introduce a Higher Education Act reauthorization bill sometime in 2018, and that the two bills may differ significantly from each other.

What New Gainful Employment and Borrower Defense Rules May Look Like

President Trump is fond of negotiating, as can be evidenced through his long business career and many promises to renegotiate a whole host of international agreements. Federal higher education policy is also fond of negotiation, thanks to a process called negotiated rulemaking that brings a range of stakeholders together for an arduous series of negotiations regarding key changes to federal policies. Notably, if stakeholders do not come to an agreement, the Department of Education can write its own rules—something that the Obama administration did on multiple occasions. (For more on the nitty-gritty of negotiated rulemaking, I highly recommend Rebecca Natow’s new book on the topic.)

In a long-expected announcement, the Department of Education announced Wednesday morning that it would be renegotiating two key higher education regulations (gainful employment and borrower defense to repayment) that were initially negotiated during the Obama administration, with the first meetings beginning next month. To get an idea of how expected these announcements were, here are the stock prices for Adtalem (DeVry) and Capella right after the announcement (which began to break around 11:30 AM ET). Note the fairly small movement in share prices, suggesting that changes were baked into stock prices pretty well.

It is extremely likely that the negotiated rulemaking committees won’t be able to come to an agreement (again), so the new rules will reflect the Trump administration’s higher education priorities. Here is my take on what the two rules might look like.

Gainful Employment

The Obama administration first announced its intention to tie federal financial aid eligibility for select vocational programs (disproportionately at for-profit colleges) in 2009 and entered negotiated rulemaking in 2009-10. The first rules, released in 2011, were struck down in 2012 due a lack of a “reasoned basis” for the criteria used. The second attempt entered negotiated rulemaking in 2013, survived legal challenges in 2015, and began to take effect with the first data release in early 2017. Nearly all of the programs that failed in the first year were at for-profit colleges, but this also led to Harvard shutting down a failing graduate theater program. No colleges have lost aid eligibility yet, as two failing years are required before a college is at risk of losing funds.

The Trump administration is likely to take one of three paths in changing gainful employment regulations:

Path 1: Expand the rules to cover everyone. One of the common critiques against the current regulations is that they only cover nondegree programs at nonprofit colleges in addition to nearly all programs at for-profit colleges. For example, doctoral programs in education at Capella University are covered by gainful employment, while my program at Seton Hall University is not. Requiring all programs to be covered by gainful employment would both preserve the goals of the original regulations while silencing some of the concerns. But this would face intense pressure from colleges that are not currently covered (particularly private nonprofits).

Path 2: Restrict the rules to cover only the most at-risk programs. It is possible that gainful employment metrics could be used along other risk factors (such as heightened cash monitoring status or high student loan default rates) to determine federal loan eligibility. If written a certain way, this would free nearly all programs from the rules without completely unwinding the regulations.

Path 3: Make the rates for informational purposes instead of accountability purposes. This is the most likely outcome in my view. The Trump administration can provide useful consumer information without tying federal funds (a difficult thing to actually do, anyway). In this case, I could see all programs being included since the data will be somewhat lower-stakes.

Borrower Defense to Repayment

Unlike gainful employment, borrower defense to repayment regulations were set to affect for-profit and nonprofit colleges relatively equally. Here is what I wrote back in October about the regulations when they were announced.

These wide-ranging regulations, which will take effect on July 1, 2017 (a summary is available here) allow individuals with student loans to get relief if there is a breach of contract or court decision affecting that college or if there is “a substantial misrepresentation by the school about the nature of the educational program, the nature of financial changes, or the employability of graduates.” The language regarding “substantial misrepresentation” could have the largest impact for both for-profit and nonprofit colleges, as students will have six years to bring lawsuits if loans are made after July 1, 2017.

These regulations have been halted and will not take effect until a new round of negotiated rulemaking takes place. They were generally unpopular among colleges, as evidenced by a strong lobbying effort from historically black colleges that were worried about the vague definition of “misrepresentation.” The outcome of this negotiated rulemaking session is likely to be a significant rollback of the scope to cover only the most egregious examples of fraud.

Although these two sets of negotiated rulemaking sessions are likely to mainly be for show due to the Department of Education’s final ability to write rules when the committee deadlocks, they will provide insight into how various portions of the higher education community view the federal role in accountability under the Trump administration. The Department of Education doesn’t livestream these meetings (a real shame), but I’ll be following along on Twitter with great interest. Pass the popcorn, please?

Which Factors Affect Student Loan Repayment and Default Rates?

As student loan debt has surpassed $1.25 trillion, policymakers and members of the public are increasingly concerned about whether students are able to manage rising (but often still modest) loan burdens. The federal government has relied on a measure called cohort default rates—the percentage of former borrowers who defaulted on their loans within a few years of entering repayment—to deny federal financial aid access to colleges with a high percentage of struggling students. Yet default rates can be easily manipulated using strategies such as deferment and forbearance (which often don’t help students in the long run), meaning that default rates are a very weak measure of students’ post-college outcomes.

The 2015 release of the College Scorecard dataset included a new measure—student loan repayment rates, defined as the percentage of borrowers repaying any principal within a certain period of entering repayment. This gets at whether students are paying down their loans, which seems to be a more helpful indicator than relying heavily on default rates. But since repayment rates are a new measure, colleges had no incentive to manipulate repayment rates as they did default rates. This creates a research opportunity to examine whether colleges may have been acting strategically to lower default rates even as their students’ underlying financial situations did not change.

I teamed up with Amy Li, an assistant professor at the University of Northern Colorado, to examine whether the factors affecting loan repayment rates differ from those factors affecting default rates—and whether the factors affecting repayment rates varied based on the number of years after the student entered repayment. Our article on this topic is now out in the ANNALS of the American Academy of Political and Social Science, with a pre-publication version available on my personal website.

We used default and repayment data on students who entered repayment in fiscal years 2006 and 2007 so we could track repayment rates over time. Default rates at the time covered the same time period as the one-year repayment rate, while we also looked at repayment rates three, five, and seven years after entering repayment. (And we had to scramble to redo our analyses this January, as the Department of Education announced a coding error in their repayment rate data in the last week of the Obama Administration that significantly lowered loan repayment rates. If my blog post on the error was particularly scathing, trying to revise this paper during the journal editing process was why!) We then used regressions to see which institutional-level factors were associated with both default and non-repayment rates.

Our key findings were the following:

(1) Being a traditionally underrepresented student was a stronger predictor of non-repayment than default. Higher percentages of first-generation, independent, first-generation, or African-American students were much more strongly associated with not repaying loans than defaulting after controlling for other factors. This suggests that students may be avoiding default (perhaps with some help from their former colleges), but they are struggling to pay down principal soon after leaving college.

(2) For-profit colleges had higher non-repayment rates than default rates. Being a for-profit college (compared to a public college) was associated with a 1.7 percent increase in default rates, yet an 8.5% increase in non-repayment. Given the pressure colleges face to keep default rates below the threshold needed to maintain federal loan eligibility—and the political pressures for-profit colleges have faced—this result strongly suggests that colleges are engaging in default management strategies.

(3) The factors affecting repayment rates changed relatively little in importance over time. Although there were some statistically significant differences in coefficients between one-year and seven-year repayment rates, the general story is that a higher percentage of underrepresented students was associated with higher levels of non-repayment across time.

As loan repayment rates (hopefully!) continue to be reported in the College Scorecard, it will be interesting to see whether colleges try to manipulate that measure by helping students close to repaying $1 in principal get over that threshold. If the factors affecting repayment rates significantly change for students who entered repayment after 2015, that is another powerful indicator that colleges try to look good on performance metrics. On the other hand, the growth of income-driven repayment systems that allow students to be current on their loans without repaying principal, could also change the relationships. In either case, as colleges adapt to a new accountability system, policymakers would be wise to consider additional metrics in order to get a better measure of a college’s true performance.

Do Financial Responsibility Scores Predict College Closures?

The U.S. Department of Education’s Office of Federal Student Aid quietly released data on the financial responsibility scores of private nonprofit and for-profit colleges earlier this week, something that they have done for each of the last nine years. These scores, which can range from -1.0 to 3.0, are designed to represent a college’s financial health (although some colleges dispute the value of these scores). A score of 1.5 or above represents a passing score, meaning colleges can receive federal financial aid dollars without any additional restrictions.

Colleges scoring 0.9 or below fail the financial responsibility test and must submit a letter of credit to the Department of Education and submit to additional oversight in order to receive federal funds, while colleges scoring between 1.0 and 1.4 receive additional oversight but do not have to submit a letter of credit. Colleges in the worst financial shape may not even receive a score, as the Department of Education can instead choose to place a college under heightened cash monitoring rules (similar to the penalties for failing) without even doing the calculations.

In the newly-released data for the 2014-15 fiscal year, 187 colleges failed, 139 were in the oversight zone, while 3,048 passed unconditionally. The number of failures is the lowest on record, while the number in the oversight zone is also relatively low compared to past years. But at the same time, the rate of college closures increased sharply last year. Does this mean that financial responsibility scores are identifying financially struggling colleges, or is the metric incorrectly identifying colleges at risk of closure as being financially stable?

To answer this question, I used the best existing database of college closures—from Ray Brown’s College History Garden blog. (Check it out!) I examined the fourteen accredited private nonprofit colleges that closed in 2016 to see what the college’s financial responsibility score was in the 2014-15 fiscal year. (For colleges without a score, I checked the heightened cash monitoring (HCM) list as of September 1, 2015.) The results are below.

Name Score (2014-15)
AIB College of Business  N/A
American Indian College -0.2
Barber-Scotia College  N/A
Burlington College HCM
Colorado Heights University 2.2
Crossroads College HCM
Dowling College 0.6
Kilian Community College 1.8
Northwest Institute of Literary Arts -0.9
Ohio College of Massotherapy 2.7
Saint Catharine College HCM
The Robert B. Miller College -1
Trinity Lutheran College 0.6
Wright Career College 1.1

 

Two of the 14 colleges did not show up as either having a financial responsibility score or being under HCM, while three other colleges were on HCM due to financial issues and did not receive a financial responsibility score. Of the other nine colleges, four received a passing financial responsibility score (the Ohio College of Massotherapy received the same score as Yale), two were in the additional oversight zone, and three failed. This suggests that either financial conditions changed considerably between mid-2015 and 2016 for some colleges or that financial responsibility scores are an imperfect measure of a college’s fiscal health.

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.

repay_fig1_jan17

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
Public
  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
For-profit
  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.

brookings_fig1_jan17

 

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.

brookings_fig2_jan17

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.