Congress – Robert Kelchen

It’s Time to Suspend Federal Student Loan Payments

It is hard to believe that higher education was essentially functioning normally just two weeks ago. Then the novel coronavirus started to make itself known, with travel being suspended, in-person classes being suspended and then moved completely online, and now all on-campus operations are quickly grinding to a complete halt. Much of the American economy is also grinding to a halt thanks to social distancing practices and restrictions on certain sectors of the economy.

This sudden recession (depression?) has placed higher education under an incredible amount of strain, although our industry is far better off in the short term than many other service industries. This has also resulted in a number of proposed economic stimulus packages and other ideas to keep the economy moving. President Trump’s current higher education-related proposal is to unilaterally waive interest on student loan payments. But since this does not actually reduce payments (instead just allowing people to pay down more principal), the economic benefits of the proposal are likely to be zero if this plan survives potential legal challenges.

If the federal government wants to provide economic relief for millions of Americans who will likely be struggling with their student loan payments (or getting into income-driven repayment) over the next several months, my recommendation is relatively straightforward. Congress should seriously consider passing legislation to suspend all federal student loan payments for a period of six to twelve months. Just like the coronavirus is freezing the economy, freezing student loan payments would give Americans a chance to recover before either resuming normal payments or going onto income-driven repayment plans. A six-month halt would also give people time to navigate the complicated income-driven repayment system, which is likely to be overwhelmed in the short term.

To explain how this would work, consider a student with $15,000 in debt and six years of payments remaining. In the case of a six-month pause, the student would still have $15,000 in debt and six years of payments six months from now. Since this plan would not directly forgive any student loans, the taxpayer burden would be relatively small in the long term. The only cost would be that more struggling borrowers would enroll in income-driven repayment plans. I also would not count this six-month pause toward the required number of payments for Public Service Loan Forgiveness, as no payments would be made.

Hitting the pause button on student loans could be a good way to get more money in the hands of Americans in the short term while not resulting in a massive forgiveness of student debt. It is an idea worth serious consideration at this point.

Twenty-Two Thoughts on House Democrats’ Higher Education Act Reauthorization Bill

House Democrats released the framework for the College Affordability Act today, which is their effort for a comprehensive reauthorization of the long-overdue Higher Education Act. This follows the release of Senator Lamar Alexander’s (R-TN) more targeted version last month. As I like to do when time allows, I live-tweeted my way through the 16-page summary document. Below are my 22 thoughts on certain parts of the bill (annotating some of my initial tweets with references) and what the bill means going forward.

(1) Gainful employment would go back in effect for the same programs covered in the Obama-era effort. (Did that policy induce programs to close? Stay tuned for a new paper on that…I’m getting back to work on it right after putting up this blog post!)

(2) In addition to lifting the student unit record ban, the bill would require data to be disaggregated based on the American Community Survey definitions of race (hopefully with a crosswalk for a couple of years).

(3) Federal Student Aid’s office would have updated performance goals, but there is no mention of a much-needed replacement of the National Student Loan Data System (decidedly unsexy and not cheap, though).

(4) Regarding the federal-state partnership, states would have access to funds to “support the adoption and expansion of evidence-based reforms and practices.” I would love to see a definition of “evidence”—is it What Works Clearinghouse standards or something less?

(5) The antiquated SEOG allocation formula would be phased out and replaced with a new formula based on unmet need and percent low-income. Without new money, this may work as well as the 1980 effort (which flopped). Here is my research on the topic.

(6) Same story for federal work-study. Grad students would still be allowed to participate, which doesn’t seem like the best use of money to me.

(7) Students would start repaying loans at 250% of the federal poverty line, up from 150%. Automatically recertifying income makes a lot of sense.

(8) There are relatively small changes to Public Service Loan Forgiveness, mainly regarding old FFEL loans and consolidation (they would benefit quite a few people). But people still have to wait ten years and hope for the best.

(9) I’m in a Halloween mood after seeing the awesome Pumpkin Blaze festival in the Hudson Valley last night. So, on that note, Zombie Perkins returns!

The Statue of Liberty, made entirely out of pumpkins. Let HEA reauthorization ring???

(10) ED would take a key role in cost of attendance calculations, with a requirement that they create at least one method for colleges to use. Here is my research on the topic, along with a recent blog post showing colleges with very low and very high living allowances.

(11) And if that doesn’t annoy colleges, a requirement about developing particular substance abuse safety programs will. Campus safety and civil rights requirements may also irk some colleges, but will be GOP nonstarters.

(12) The bill places a larger role on accreditors and state authorizers for accountability while not really providing any support. Expect colleges to sue accreditors/states…and involve their members of Congress.

(13) Improving the cohort default rate metric is long-overdue, and a tiered approach could be promising. (More details needed.)

(14) There would be a new on-time loan repayment metric, defined as the share of borrowers who made 33 of 36 payments on time. $0 payments and educational deferments count as payments, and ED would set the threshold with waivers possible.

(15) This is an interesting metric, and I would love to see it alongside the Scorecard repayment rate broken down by IDR and non-IDR students. But if the bill improves IDR, expect the on-time rate to (hopefully!) be high.

(16) It would be great to see new IPEDS data on marketing, recruitment, advertising, and lobbying expenses. Definitions matter a lot here, and the Secretary gets to create them. These are the types of metrics that the field showed interest in when the IPEDS folks asked Tammy Kolbe and me to do a landscape analysis of higher ed finance metrics.

(17) Most of higher ed wants financial responsibility scores to be updated (see my research on this), and this would set up a negotiated rulemaking panel to work on it.

(18) There is also language about “rebalancing” who participates in neg reg. The legislative text will be fun to parse.

(19) Teach for America will be reauthorized, but it’s in a list of programs with potential changes. Democrats will watch that closely.

(20) And pour one out for the programs that were authorized in the last Higher Education Act back in 2008, but never funded. This bill wants to get rid of some of them.

(21) So what’s next? Expect this to get a committee vote fairly quickly, but other events might swamp it (pun intended) in the House. I doubt the Senate will take it up as Alexander has his preferred bill.

(22) Then why do this? It’s a good messaging tool that can keep higher ed in the spotlight. Both parties are positioning for 2021, and this bill (which is moderate by Dem primary standards) is a good starting place for Democrats.

Thanks for reading!

Why the Democrats’ New ‘Debt-Free’ College Plan Won’t Really Make College Debt-Free

This article was originally published at The Conversation and is co-authored with Dennis Kramer II of the University of Florida.

Rising student loan debt and concerns about college affordability got considerable attention from Democrats in the 2016 presidential campaign. Those issues are bound to get renewed attention since House Democrats recently introduced the Aim Higher Act – an effort to update the Higher Education Act, the federal law that governs federal higher education programs.

The bill promises “debt-free” college to students. As scholars who focus on higher education finance and student aid, we believe the bill actually falls well short of that promise.

What ‘free’ really means

In its current form, the bill guarantees two years of tuition-free community college to students. However, the Democratic bill does not address the fact that tuition is only about one-fifth of the total cost of attending community college. Rent, food, books and transportation make up the rest of the cost of attendance and are not covered by this plan.

The “debt-free” label is problematic for other reasons. For instance, the maximum Pell Grant – $6,095 for the 2018-2019 school year – already covers community college tuition in nearly all states. This means the neediest students likely already have access to federal grant funds to cover tuition. Although the bill would increase Pell awards by $500 each year and reduce debt somewhat for the neediest students, many needy students will still need to take out loans to attend college.

States may not cooperate

Another reason the Democrats’ “debt-free” college plan does not live up to its name is the fact that its tuition-free provision requires states to maintain their funding for public colleges in order qualify for more federal funds under the proposed bill. This approach is similar to the state-federal partnership that was part of the recent Medicaid expansion, which led 16 conservative states to decline to expand Medicaid. Many conservative-leaning states might push back against the Aim Higher Act’s tuition-free provision because it restricts states’ ability to cut higher education spending.

Slim chance of becoming law

It is unlikely that either the PROSPER Act or the Aim Higher Act become law in the near future given the lack of comprehensive support within the Republican Party and Democrats’ minority status in Congress. But there are a few parts of both bills that could get bipartisan support, such as simplifying the process for applying for federal financial aid, creating better data systems to help track students’ outcomes, and allowing Pell Grants to be used for shorter-term training programs. Although neither the Republican nor the Democratic bills appear likely to pass, expect both parties to use their proposals in the upcoming midterm elections.

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 income–driven 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.

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[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.

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.

A Poor Way to Tie the Pell Grant to Performance

“Groan” is a word that is typically used to describe something that is unpleasant or bad. But in the language of student financial aid, “groan” has a second meaning—a grant that converts to a loan if students fail to meet certain criteria. The federal TEACH Grant to prospective teachers and New York’s Excelsior Scholarship program both have these clawback requirements, and a 2015 GAO report estimated that one-third of TEACH Grants had already converted into loans for students who did not teach in high-need subjects in low-income schools for four years.

Republican Reps. Francis Rooney (FL) and Ralph Norman (SC) propose turning the Pell Grant into a groan program through their Pell for Performance Act, which would turn Pell Grants into unsubsidized loans if students fail to graduate within six years. While I understand the representatives’ concerns about students not graduating (and thus reducing—but not eliminating—the return on investment to taxpayers), I see this bill as a negative for students and taxpayers alike.

Setting aside the merits of the idea for a minute, I’m deeply skeptical that the Department of Education and student loan servicers can accurately manage such a program. With a fair amount of difficulty managing TEACH Grants and income-driven repayment plans, I would expect a sizable number of students to incorrectly have Pell Grants convert to loans (and vice versa). I appreciate these two representatives’ faith in Federal Student Aid and servicers to get everything right, but that is a difficult ask.

Moving on to the merits of the idea, I am concerned about the implications of converting Pell Grants to a loan for students who left college because they got a job. Think about this for a minute—a community college student who has completed nearly all of her coursework gets a job offer with family-sustaining wages. She now faces a tough choice: forgo a good, solid job until she completes (and hope she can get another one) or take the job and owe an additional $10,000 to the federal government? If one of the purposes of higher education is to help students move up the economic ladder, this is a bad idea.

This could also have additional negative ramifications for students who stop out of college due to family issues, the need to support a family, or simply realizing that they weren’t college ready at the time. Asking a 30-year-old adult to repay additional student loans (when he may have left in good standing) under this groan program would probably reduce the number of working adults who go back and finish their education.

If the representatives’ concern is that students make very slow progress through college and waste taxpayer funds, a better option would be to gradually ramp up the current performance requirements for satisfactory academic progress. These requirements, which are typically defined as a 2.0 GPA and completing two-thirds of attempted credits, already trip up a significant share of students. But on the other hand, research by Doug Webber of Temple University and his colleagues finds significant economic benefits to students who barely keep a 2.0 GPA and are thus able to stay in college.

Finally, although I think this proposal is shortsighted, I have to chuckle at a take going around on social media noting that one of the representatives owns a construction company that helped build residence halls. Wouldn’t that induce a member of Congress to support policies that get more students into college (and create demand for his company’s services)? It seems like he is going against his best interest if this legislation scares students away from attending college.

Comments on the Trump Higher Education Budget Proposal

The Trump administration released its first full budget proposal for Fiscal Year 2018 today, and it is safe to say that it represents a sharp break from the Obama administration’s budget proposals. The proposed discretionary budget for the Department of Education is about $69 billion, $10 billion less than the Fiscal Year 2017 budget. Below, I offer brief comments on three of the key higher education proposals within the budget, as well as my take on whether the proposals are likely to be enacted in some form by a Republican-controlled Congress that seems fairly skeptical of the Trump administration’s higher education policy ideas.

Public Service Loan Forgiveness would no longer be available for new borrowers. Public Service Loan Forgiveness (PSLF) was first made available in 2007 in an effort to encourage individuals to work in lower-paying nonprofit or government jobs. This plan allows students enrolled in income-driven repayment plans who annually certified their income and employment status to have any remaining balances forgiven after ten years of payments of 10% of discretionary income. However, the plan has been criticized due to its likely high price tag to taxpayers and because it provides far larger subsidies to graduate students than undergraduate students.

The Trump administration’s budget proposal would end PSLF for new borrowers as of July 1, 2018—and require all people currently on PSLF to maintain continuous enrollment in the program to remain eligible. This is likely to be a difficult hurdle for many people to clear, as a large number of students have been tripped up by annual recertification in the past. I’m glad to see that the Trump administration didn’t completely end PSLF for current students (as people reasonably relied on the program to make important life choices), but otherwise saving PSLF in the current form isn’t at the top of my priority list because of how most of the subsidy goes to reasonably well-off people with graduate degrees instead of low-paid individuals with a bachelor’s degree in early childhood education.

Prognosis of happening: Low to medium. This will generate howls of outrage in The New York Times and The Washington Post from groups such as the American Bar Association and the National Education Association, but there is a reasonable argument for at least curtailing the amount of money that can be forgiven under PSLF. A full-fledged ending of the program may not happen, but some changes are quite possible as quite a few members of Congress are upset with rising costs of loan forgiveness programs.

Subsidized loans for undergraduates would be eliminated, and income-driven loan repayment periods would change. Undergraduate students can qualify for between $3,500 and $5,500 per year in subsidized student loans (meaning interest is not charged while they are in school), with the remainder of their federal loans being unsubsidized (with interest accumulating immediately). The Trump administration would end subsidized loans, with the likely rationale that the interest subsidy is not an efficient use of resources (something that is hard to empirically confirm or deny, but is quite plausible).

The federal government currently offers students a menu of income-driven loan repayment options, and the Trump administration proposed to simplify these into one option. Undergraduates would pay up to 12.5% of the income over 15 years (from 10% over 20 years for the most popular current plan), while grad students would pay up to 12.5% for 30 years. Undergraduate students probably benefit from this change, while graduate students decidedly do not. This plan hits master’s degree programs hard, as any graduate debt would either trigger a 30-year repayment period for a potentially small amount of additional debt or push people back into a standard (non-income-driven) plan.

Prognosis of happening: Medium. There has been a great deal of support for streamlining income-driven repayment plans, but the much less-generous terms for graduate students (along with ending PSLF) would significantly affect graduate student enrollment. This will mobilize the higher education community against the proposal, particularly as many four-year colleges are seeking to grow graduate enrollment as a new revenue source. But potentially moving to a 20-year repayment period for graduate students or tying repayment length to loan debt are more politically feasible. The elimination of subsidized loans for undergraduates hits low-income students, but a more generous income-driven repayment program mainly offsets that and makes that change more realistic.

Federal work-study funds would be cut in half and the Supplemental Educational Opportunity Grant would be eliminated. The federal government provides funds for these two programs to individual colleges instead of directly to students, and colleges are required to provide matching funds. The SEOG is an additional grant available to needy undergraduates at participating colleges, while federal work-study funds can go to undergraduate or graduate students with financial need. Together, these programs provide about $1.7 billion of funding each year, with funds disproportionately going to students at selective and expensive colleges due to an antiquated funding formula. Rather than fixing the formula, the Trump administration proposed to get rid of SEOG (as being duplicative of Pell) and halve work-study funding.

Prognosis of happening: Slim to none. Because funds disproportionately go to wealthier colleges (and go to colleges instead of students), the lobbying backlash against cutting these programs will be intense. (There is also research evidence showing that work-study funds do benefit students, which is important to note as well.) Congressional Republicans are likely to give up on changing these two programs in an effort to focus on higher-stakes changes to student loan programs.

In summary, the Trump administration is proposing some substantial changes to how students and colleges are funded. But don’t necessarily expect these changes to be implemented as proposed, even if there are plenty of concerns among conservatives about the price tag and inefficient targeting of current federal financial aid programs. It will be crucial to see the budget bill that will go up for a vote in the House of Representatives, as that is more likely to be passed into law than the president’s proposed budget.

The Importance of Negative Expected Family Contributions

The Free Application for Federal Student Aid (FAFSA) has received a great deal of attention in the past year. From a much-needed change that allowed students to file the FAFSA in October instead of January for the following academic year to the pulling of the IRS Data Retrieval Tool that made FAFSA filing easier for millions of students, the federal financial aid system has had its ups and downs. But one criticism that has been consistent for years is that the FAFSA remains an extremely blunt—and complex—financial aid allocation instrument.

After students fill out the FAFSA, they receive an expected family contribution (EFC), which determines their eligibility for federal and other types of financial aid. EFCs are currently truncated at zero for reporting purposes, which lumps together millions of students with various levels of (high) financial need into the zero EFC category. In a previous article, I showed that more than one-third of undergraduate students have a zero EFC and how that rate has generally increased over time.

Yet the underlying FAFSA data allows for negative EFCs to be calculated, and these negative EFCs can be used for two different purposes. First, they could be used to give additional Pell Grant aid to the neediest students; there have been several proposals in the past to allow EFCs to go down to -$750 in order to boost Pell Grants by up to $750. Second, the sheer number of students classified in the zero EFC category makes identifying the very neediest students difficult when there are insufficient funds to help all students from lower-income families. Reporting negative EFCs would at least allow colleges to help target their often-scarce resources in the best possible manner.

In my newest article (just published in the Journal of Student Financial Aid, which is open-access!), I used five years of student-level FAFSA data from nine colleges to show how calculating negative EFCs can help identify students with the greatest levels of financial need. The graphics below give a rough idea of what the distributions of negative EFCs could look like under various scenarios and current FAFSA filing situations. (I show dependent students here, but the same story is generally true for independent students.)

I also looked at how much it might cost the federal Pell Grant program to fund EFCs of -$750 by increasing maximum Pell Grants by an additional $750 for the neediest students. I estimated that funding negative EFCs would have increased Pell Grant expenditures by between $5 billion and $7 billion per year, depending on the specification. This is far from a trivial change for a program that spent about $31.5 billion in 2013-14, but it would roughly return Pell spending to its high point following the Great Recession. To save money, additional Pell funds could be given just to students with an automatic zero EFC—students with low family incomes who are already receiving some kind of means-tested benefit (such as free lunches in high school). That sort of limited expansion could be funded out of the current Pell surplus (assuming it doesn’t get used for other purposes, as is currently proposed).

Regardless of whether students get more money from the federal government under a negative EFC, it is a no-brainer for Congress and the Department of Education to work together to at least release the negative EFC number alongside the current number. That way, states, colleges, and private foundations can better target their funds to students with the absolute greatest need. Until the FAFSA is simplified, it makes sense to better use all of the information that is collected on students so everyone can make better decisions on allocating scarce resources.

Examining College Endowments per Pell Recipient

One of the most-discussed higher education policy proposals from President Donald Trump has been a proposal to tax the endowments of wealthy colleges that are seen as not using enough money on financial aid. Key Trump supporter Rep. Tom Reed (R-NY) has introduced legislation requiring colleges with endowments over $1 billion to spend at least 25% of all investment returns on financial aid, much to the chagrin of wealthy colleges.

This proposal does not take into account the size of a college—which means that colleges with similar endowment levels can have vastly different levels of resources. For example, Vassar College and North Carolina State University had endowments just under $1 billion as of June 2015, but the sizes of the institutions are far different. Vassar has about 2,500 undergraduate students, while NC State has nearly ten times as many.

Another important factor is the financial need of students. Colleges can have similar sizes and similar endowment levels, but differ substantially in their number of Pell recipients (a proxy for low-income status). Washington State University and the University of Missouri-Columbia both have endowments around $900 million, but Washington State enrolled 3,000 more Pell recipients than Mizzou in spite of enrolling 4,000 fewer undergraduates. This means that Mizzou has the ability to target more aid to their Pell recipients should they choose to do so.

To explore this point in more detail (and thanks to Sara Goldrick-Rab for the idea), I dove into newly available finance data from the Integrated Postsecondary Education Data System (IPEDS) for the 2014-15 academic year and merged it with data on the number of Pell recipients for the same year from Federal Student Aid’s Title IV volume report datasets. After eliminating colleges that did not report endowment values or reported endowment or Pell recipient data in conjunction with other campuses, my sample consisted of 479 public four-year colleges and 909 private nonprofit colleges. You can download the spreadsheet here to see the ratios for each college with data. (Note: This was updated on February 20 to include colleges in the District of Columbia. Thanks to Patricia McGuire for calling that error to my attention!)

Most colleges have quite small endowments per Pell recipient, as shown in the graph below. The median public college had an endowment of $12,778 per Pell recipient in 2014-15, while the median private college had an endowment of $65,295. Given typical endowment spending rates of about 5% per year, this means that public colleges can spend about $640 per Pell recipient on financial aid and private colleges could spend about $3,200 per recipient. But this assumes that (1) colleges will only spend their endowment proceeds on need-based aid and (2) colleges can actually use their endowments on whatever they want instead of what donors say. This means that most colleges do not have much ability to significantly improve financial aid packages based on endowment proceeds alone.

The other thing that stands out in the graph is the number of colleges with endowments of over $1 million per Pell recipient. In 2014-15, 92 colleges were in the millionaires’ club, including 88 private nonprofit colleges and four public colleges (William and Mary, Michigan, Virginia, and Virginia Military Institute—an unusual institution). Below are the institutions with the 25 highest endowment to Pell ratios. All of these colleges have more than $4.2 million per Pell recipient—an enviable position should any of these colleges seek to increase low-income student enrollment.

Name	Undergrad enrollment	Pell enrollment	Endowment ($bil)	Endowment per Pell recipient ($mil)
Johns Hopkins University	6357	787	3.33	4.23
Grinnell College	1734	393	1.79	4.55
Claremont McKenna College	1301	152	0.73	4.83
Amherst College	1792	442	2.19	4.96
Bowdoin College	1805	278	1.39	5.01
Columbia University in the City of New York	8100	1912	9.64	5.04
Williams College	2072	403	2.27	5.62
Northwestern University	9048	1256	7.59	6.04
University of Pennsylvania	11548	1643	10.10	6.17
Pomona College	1650	326	2.10	6.44
Swarthmore College	1542	237	1.85	7.79
Dartmouth College	4289	596	4.66	7.82
Duke University	6626	925	7.30	7.89
Washington and Lee University	1890	181	1.47	8.13
Rice University	3926	620	5.57	8.99
University of Notre Dame	8448	902	8.78	9.74
Soka University of America	411	123	1.22	9.93
University of Chicago	5738	639	6.55	10.30
Washington University in St Louis	7401	571	6.89	12.10
California Institute of Technology	983	127	2.08	16.40
Massachusetts Institute of Technology	4512	806	13.50	16.70
Stanford University	7019	1106	22.20	20.10
Princeton University	5391	790	22.30	28.20
Harvard University	10338	1238	37.60	30.40
Yale University	5477	724	25.50	35.30

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.