Does This Explain Opposition to Market-Based Interest Rates?

As of this writing, it appears that the U.S. Senate has finally reached an agreement on student loan interest rates after subsidized Stafford rates doubled from 3.4% to 6.8% on July 1. The general terms of the agreement are similar to what President Obama proposed in his FY 2014 budget and what the House of Representatives agreed to back in June, with some compromises on each side.

The big difference between current law and the Senate agreement is that interest rates for nearly all student loans will be tied to the 10-year Treasury rate, which currently sits at about 2.5%.  (Undergraduates would pay a 2.05% premium above the Treasury rate on Stafford loans to account for program costs and the risk of offering the loans.) However, the Treasury rate is expected to increase to 5.6% by 2016, pushing the interest rate for undergraduates to 7.65% from less than 5%. The plan includes a cap at 8.25%, which may be reached according to the CBO report.

The Senate agreement is not without its critics, particularly on the political Left. Senator Bernie Sanders, a Vermont independent and a self-described “socialist,” criticized the plan as “dangerous” in an article in The Hill. His criticism lies in the fact that interest rates can rise well above the current 6.8% over time, a very real concern given the interest rate projections. While the plan is expected to pass the Senate (and the House), some other Senate Democrats will likely vote no as well.

At this point in the great interest rate debate, I have to wonder if there is another reason some politicians oppose market-based interest rates. Tying student loan interest rates to the 10-year Treasury note directly connects students’ future payments to the cost of federal borrowing. And that cost of federal borrowing is influenced by the federal government’s fiscal policy.

This connection between federal borrowing and student loan rates could potentially have the following repercussions. If loans are tied to Treasury notes—and there is no way to fix the rate as has been done for the past seven years—students should have an incentive to push for federal policies which lower the federal government’s cost of borrowing. (With the decline in home ownership rates among younger adults, fewer 20- and 30-somethings have mortgages, which are affected by federal borrowing costs.)

The policy that best reduces the cost of borrowing is a balanced budget, which reduces the need for additional borrowing. The passage of the Omnibus Budget Reconciliation Act of 1993, which reduced the budget deficit through a combination of tax hikes and spending cuts, had the effect of driving down long-term interest rates. (For more on this, I highly recommend reading Bob Woodward’s Maestro about Alan Greenspan’s role in the policy discussions.)

My question to readers is whether you think that some politicians may oppose market-based interest rates because more young adults may place pressure on Congress to find some legislative solution to balance the budget—although the solutions certainly vary by political persuasion. Say it’s 2016 and undergraduate Stafford rates are 7.5%, with hitting the 8.25% cap becoming more likely. Could we see student advocacy organizations pushing for a balanced budget to bring down interest rates? I don’t know how many people will think this way, but it’s something to consider.

The Great Student Loan Interest Rate Debate

As I write this post, the House of Representatives is currently debating the future of student loan interest rates. Under current law, the rates on subsidized Stafford loans for undergraduates (the rates which get the most attention) will double on July 1 from 3.4% to 6.8% without Congressional action. The same debate was held last year under the same parameters, but Congress and the President agreed to extend interest rates for an additional year.

There have been a wide range of proposals put forth regarding plans to address the interest rate cliff, an outstanding summary of which was written by Libby Nelson in Inside Higher Ed. (In addition to the plans listed in that article, some Senate Democrats have supported a two-year extension to current law in order to allow for the Higher Education Act to be reauthorized.) Most proposals move to tie interest rates to the market—represented here by borrowing costs for the federal government—but the plans vary widely in their ideas of what the relevant market should be.

Proposals put forth by the Obama Administration and House and Senate Republicans all tie interest rates to long-term Treasury bills, but vary in their other features. (I’ve previously written on the Obama Administration’s proposal.) While the President has threatened to veto the common House GOP proposal over certain aspects, there is enough common ground here to reach an agreement.

However, proposals put forth by certain Democratic senators, particular Sen. Elizabeth Warren from Massachusetts, confuse long-term lending risks with short-term credit markets. She has proposed tying student loan interest rates (which are repaid for at least ten years once a student leaves college) to the interest rate the Federal Reserve charges banks for very short-term borrowing. Jason Delisle of the New America Foundation, hardly a bastion of conservatism, crushes her argument in a great piece of writing. He notes the confusion between short-term and long-term rates, as well as accounting for the probability of default. I would also note that if Congress wishes to help make college more affordable, it’s a better idea to give the funds upfront to students than to lower interest rates later on–long after the enrollment decisions have been made.

The federal government should move toward some sort of a market-based strategy for interest rates with certain student protections. This would allow for the costs of student loans to be more adequately reflected in the federal budget. (And if interest rates get too high, maybe it’s a reminder for Congress and the President to produce a balanced budget!) With that being said, I would still expect to see a short-term extension of the current interest rates as Congress may end up deadlocked on this issue until the Higher Education Act is reauthorized.

Why Expanding Student Loan Interest Deductions is Unwise

The United States Congress has rarely met a change to the tax code that it doesn’t like. Since 2011, Congress has made nearly 5,000 changes to the tax code, making the tax code even more Byzantine and causing many Americans headaches each spring. While the exact levels and types of taxes preferred by the public tend to differ by political and economic ideologies, a general consensus exists among economists that a stable, predictable, relatively simple tax code achieves revenue goals at a reasonable cost.

Yet Congress is constantly faced with pressure to change the tax code to allow more credits and deductions to incentivize certain activities. We have certainly seen incentives in the tax code to increase educational attainment through the use of credits and deductions. These incentives have a difficult time being effective in inducing students to obtain more education because students and their families do not receive a financial benefit until well after the enrollment decision has been made, and awareness of these programs is uneven at best.

The deduction for student loan interest payments is designed to help student be able to repay their educational debt; currently, students can receive a $2,500 deduction on their taxes (if they itemize) in a given year and their income is less than $75,000 per year if single or $150,000 per year if married filing jointly. It is hard to imagine that such a program, which does not provide a financial benefit to students until after they have left college, will help increase educational attainment.

Yet Congressman Charles Rangel (D-NY), who is well-known for his 2012 censure over failing to pay taxes, has introduced the Student Loan Interest Deduction Act, which would double the tax deduction for student loan interest and get rid of the income cap for receiving the deduction. This bill has picked up the support of many higher education associations, including the American Council on Education and the National Association of Student Financial Aid Administrators, but it is an example of inefficient and misguided public policy.

Here are a few reasons why the proposed bill is poor public policy:

(1)    Students get the tax deduction years after beginning college. Yes, students with perfect information about the deduction (and who believe the policy will remain in place) will adjust their total cost of college down. But that requires a large amount of information and a low discount rate, neither of which can be assumed.

(2)    Increasing the deduction cap allows students to benefit more if they took out more debt. This can provide an additional incentive for colleges to raise their price and capture additional revenue if they think students will pay.

(3)    Getting rid of the income cap shifts the benefits more toward higher-income families, who are more likely to itemize deductions and be able to use the deduction. Advocates on the left should be particularly steamed by this point.

(4)    This acts as an additional tax on saving for college relative to borrowing, and can place families who chose not to borrow at a disadvantage.

I would prefer to see all interest deductions removed from the tax code and replaced with more efficient upfront payments. Instead of forgoing billions of dollars in revenue through tax credits and deductions, I would rather see the money used in grant programs, lowering the interest rates for federal loans, or used toward other educational improvements. Rangel’s bill just complicates the status quo and does little to actually help students afford college.

Something Old, Something New: The FY 2014 Obama Budget

Even though I know that it has no chance of being passed in anything resembling its current form, I am excited to get my hands on President Obama’s long-delayed budget for Fiscal Year 2014 (short version, long version, six-page summary of the education portion). The funding request for the Department of Education is for $71.2 billion in discretionary spending, 4.6% higher than this year’s (pre-sequester) budget; ED is unlikely to see an increase of greater than inflation this year given the current political climate.

I tweeted my way (follow me!) through some of the key points relating to higher education yesterday, and am now back with a more detailed summary of the budget. (I also recommend Libby Nelson’s excellent summary in today’s Inside Higher Ed.)This year’s theme is “something old, something new,” as many of the proposals are recycled from last year—but with one key difference that will affect millions of students.

First of all, not much changes with respect to the Pell Grant. The President proposes a $140 increase in the maximum Pell Grant to $5,785, while the program is on more solid financial footing for the next few years. He is again trying to get a higher education version of Race to the Top passed this year, which will look similar to the plan from last year. Again, there is a strong focus in the STEM fields and for program evaluation (the latter of which is welcome from my perspective). The biggest program boost I could find was to FIPSE (the Fund for the Improvement of Postsecondary Education), going from under $2.4 million to $260 million. Although it is unlikely to be adopted, it does show a commitment to demonstration projects in K-12 and higher education.

The most controversial part of the President’s budget is the proposed shift to market-based interest rates. A day after Republican Senators Coburn, Burr, and Alexander introduced a bill to tie all interest rates to the ten-year Treasury rate (currently 1.8%) plus three percentage points, the President’s budget also proposed tying interest rates to the same measure. His plan is more nuanced, with different loans having different premiums over the Treasury rate (see p. 344-350):

Subsidized Stafford: Treasury plus 0.93% (about 2.75% currently)

Unsubsidized Stafford and Perkins: Treasury plus 2.93% (about 4.75%)

PLUS: Treasury plus 3.93% (about 5.75%)

GOP plan: All loans are Treasury plus 3% (about 4.8%)

These rates are far lower than the current rates (3.4% for subsidized Stafford, 6.8% for unsubsidized Stafford, and over 8% for graduate unsubsidized loans), but do shift risk onto students as the rate for new loans would change each year. There would also be no interest rate cap, which is lamented by many advocates. (Income-based repayment provides another alternative, however.)

If either of these plans is adopted, the interest rate cliff would be eliminated as students would no longer have to wait on Congress to know their rates. However, students are likely to see rates rise as Treasury yields return toward their historical norm. The Congressional Budget Office predicts that 10-year Treasury notes will yield 5.2% by 2018, which would put unsubsidized loans just over 8%. (This is still lower than the recent rate for unsubsidized graduate loans, with which I am quite familiar.) If rates go higher than that, I expect Congress to enact an interest rate cap in several years.

The federal budget process does not move quickly, especially with a divided Congress. While I do not expect large increases in the Department of Education’s budget, I am optimistic that a market-based solution to interest rates will be adopted in order to provide more certainty in the short run and to bring graduate loan rates closer to what the private market would otherwise offer.

Should Campuses be Able to Limit Student Loans?

The National Association of Student Financial Aid Administrators jumped into the financial aid reform debate this week with the release of their policy paper as a part of the Gates Foundation’s Reimagining Aid Delivery and Design (RADD) project. Many of the recommendations are similar to other papers in the panel (including proposals to increase the maximum Pell Grant for certain students and providing more information for students and their families to make better college decisions)—and an additional recommendation of exploring an early commitment program for Pell recipients is informed by some of my research, which is pretty nifty.

The NASFAA report does make one recommendation which will likely prove to be highly controversial—limiting eligibility for student loans for certain groups of students in a clear effort to reduce student loan default rates. First, NASFAA suggests that students who do not meet a baseline level of academic preparation (perhaps a combination of ACT/SAT scores and high school GPA) would not be initially eligible to take out federal student loans. This proposal would be similar to the academic eligibility index used by the NCAA to determine student-athletes’ ability to play college sports. This proposal could have the effect of ending the open-access institution as we know it, depending on exactly where the cutoff is set. While it is true that students with lower standardized test scores are less likely to complete college, I’m very hesitant to place a substantial barrier to college entry—especially for students who did not enroll in college directly after completing high school.

The report also contains a recommendation allowing colleges to restrict groups of students’ ability to borrow if the financial aid officer feels that the loan funds are not needed or risky. For example, education majors’ loans may be limited compared to business majors because of their lower annual earnings (and reduced repayment abilities). Restricting access to loans by program characteristics (instead of individual characteristics) reduces the burden on financial aid officers, but also fails to take individual characteristics into account unless a student appeals for professional judgment.

The proposal to limit student loans will penalize students who cannot pay for college by any other means—especially for dependent students who cannot get parental support to pay for their expected family contribution. Additionally, many students cannot borrow the maximum amount of loans under current rules, which base eligibility in part on the estimated cost of attendance. Research suggests that this posted cost of attendance may be much lower than the actual cost of attending college, as institutions have an incentive to make the college look as affordable as possible.

While I am concerned about these particular portions of NASFAA’s proposal, they raise concerns that are of genuine merit and concern in the financial aid and policy communities. I would be surprised if they become a part of federal rules in any meaningful way, but this does show the diversity of opinions within the RADD group and the importance of listening to as many stakeholders as possible before redesigning the financial aid system.

Predicting Student Loan Default Rates

Regular readers of this blog know that there are several concerns to using outcome measures in a higher education accountability system. One of my primary concerns is that outcomes must be adjusted to reflect a college’s inputs—in non-economist language, this means that colleges need to be assessed based on how well they do given their available resources.  I have done quite a bit of work in this area with respect to graduation rates, but this same principle can be applied to many other areas in higher education.

The Education Sector also shares this concern, as evidenced by their recent blog post on the importance of input-adjusted graduation measures. In this post (at the Quick and the Ed), Andrew Gillen examines four-year colleges’ performance in student loan default rates. He adjusts for the percentage of Pell Grant recipients, the percentage of part-time students, and the average student loan size to get a measure of student default rate performance.

I repeat this estimate using the most recent loan default data (through 2009-10) and IPEDS data for the above characteristics for the 2009-10 academic year. This simple model does a fair job predicting loan default rates, with a R-squared value of 0.422. Figure 1 below shows actual vs. predicted loan default rates for 1876 four-year institutions with complete data:

figure1_jan17

The Education Sector analysis did not break down student default rate performance by important institutional characteristics, such as type of control (public, private not-for-profit, or for-profit) or the cost of attendance. Figures 2 and 3 below the performance between public universities and their private non-profit and for-profit peers:

figure2_jan17figure3_jan17

Note: A positive differential means that default rates are higher than predicted. Negative numbers are good.

The default rate performances of public and private not-for profit colleges do not differ in a meaningful way, but a significant number of for-profit colleges have substantially higher than predicted default rates. This difference is obscured when all colleges’ performances are combined.

Finally, Figure 4 compares default rate performance by the net price of attendance (the sticker cost of attendance less grant aid) and finds no relationship between the net price and loan default rates:

figure4_jan17

Certainly, more work needs to be done before adopting input-adjusted student loan default rates as an accountability tool. But it does appear that a certain group of colleges tend to have a higher percentage of former students default, which is worth additional investigation.

Am I On the Wrong Job Market?

In light of being on the academic job market this year, I was amused to get the following mailing from the local branch of Globe University. (Even though the mailing was addressed to me, it was also addressed to “Or Current Resident.”)

Globe Ad

The message is quite simple: graduates of this university get jobs. The mailing advertises that 100% of graduates with a bachelor’s degree in business administration get employment, although the fine print does mention that “employment is not guaranteed.” However, not much can be said about the graduation rates of students attending any of the Globe campuses, both because very few students attending Globe are first-time, full-time students (which are the only students counted in federal graduation rate calculations) and because many campuses (including Madison) have not been open long enough to have a graduation rate cohort.

To get an idea of graduation rates, I looked at the oldest Globe campus, in Brooklyn Center, MN. The reported graduation rate is 23%, with an overall career placement rate of 72%. Meanwhile, tuition is over $5,000 per quarter before mandatory course fees. I’m not saying that Globe University is a bad bet for students, but some students are likely to benefit more by attending the local technical college.

Moral of the story: Don’t believe colleges which imply that everyone gets a job. This isn’t even true at the most prestigious colleges, let alone for relatively unknown for-profit institutions. (Now, I do hope that my UW-Madison PhD helps me get a great job!)

Paying It Forward: A Different Take on Income-Based Repayment

In prior blog posts, I have been less than charitable toward the federal government’s changes to the income-based repayment policies for student loans. (As a reminder, these changes provide large subsidies to students who attend expensive colleges and particularly those who earn good salaries after having attended law or medical school.) My criticism of the federal government’s way of implementing the program does not mean that I am not open to a better way of income-based repayment. With this in mind, I look at a proposal from the Economic Opportunity Institute, a liberal think tank from Washington State, which suggests an income-based repayment program for students attending that state’s public colleges and universities.

The EOI’s proposal, called “Pay It Forward,” would charge students no tuition or fees upfront and would require students to sign a contract stating that they would pay a certain percentage of their adjusted gross income per year (possibly one percent per year in college) for 25 years after leaving college. It appears that the state would rely on the IRS to enforce payment in order to capture part of the earnings of those who leave the state of Washington. This would be tricky to enforce in theory, given the IRS’s general reticence to step into state-level policies.

I am by no means convinced by the group’s crude simulations regarding the feasibility of the program. This is currently short on details and would also require a large one-time investment to get off the ground and enroll an initial cohort of students. Additionally, it is not clear whether the authors of the report accounted for part-time enrollment patterns in their cost estimates. I also urge caution with this program, as this sort of an income-based repayment program decouples the cost of attendance from what students actually pay. Colleges suddenly have a strong incentive to raise their posted tuition substantially in order to capture this additional revenue.

With all of these caveats, the Pay It Forward program does have the potential to serve as a simple income-based repayment program once analysts do more cost-effectiveness analyses. But this will only work if policymakers keep a close eye on the cost of college in order to result in a revenue-neutral program. My gut feeling is that the group’s estimates understate the cost of college under current rules and don’t consider the possibility of the incentives that will increase cost.

A November Surprise in Student Loans

A few weeks ago, I co-authored a piece in The Chronicle of Higher Education on the federal government’s authority to relax income-based repayment requirements for student loans. To summarize the proposal, the federal government was granted the authority (starting in 2014) to allow students to repay student loans using only ten percent of their discretionary income for 20 years, down from 15 percent for 25 years. Our argument in the Chronicle piece is that the program represents an enormous subsidy for students attending expensive colleges and particularly professional schools. We were not the only people with those concerns; the left-leaning New America Foundation put out a similar set of concerns.

I was very surprised to learn yesterday that the Obama Administration published the final regulations for the new income-based repayment program (called “Pay as You Earn” or PAYE) in the Federal Register, which will suddenly take effect much sooner than 2014 and apparently no later than July 1, 2013. There appears to be no regulatory authority for speeding up the changes, other than the federal requirement that regulations be published by November 1 in order to take effect on July 1 of the following year. These regulations continue a disturbing trend of this administration ignoring Congressionally mandated timelines. It is my sincere hope that someone will ask the Department of Education for clarification as to how speeding up implementation is legal, especially when Congress did not agree to that timeline and there is a cost impact (more on that later).

Substantial legal issues aside, it appears that the Department of Education did not seriously consider the moral hazard concerns of people taking out more debt simply because they will not have to repay it. Buried on page 28 of the 61-page regulation document is the following nugget:

“Income-based repayment options may encourage higher borrowing and potentially introduce an unintended moral hazard, especially for borrowers enrolled at schools with high tuitions and with low expected income streams. Some commenters disagreed with the inclusion of this moral hazard statement, noting that the aspect of more generous income-based repayment plans causing increased borrowing has not been established. The Department has not found any definitive studies on the matter but since some analysts, academics, and others have suggested the possibility of this inducement effect, we wanted to address it to ensure comprehensive coverage of this issue.”

The Department of Education then never addresses the topic in the rest of the regulation document, instead focusing on the benefits for borrowers with more modest amounts of debt and household incomes of less than $60,000 per year. I side with Jason Delisle and the New America policy folks, who still note that moral hazard is a substantial concern.

The cost estimates seem way too good to be true, which is often the case in implementing new federal programs. The Department of Education (on p. 35 of the regulations) estimates that the cost will be only $2.1 billion over the next ten years, which seems to be an incredibly low number. Assuming roughly $250 million per year in additional costs over the peak years of the budget window (the last few years should not be included because they don’t include the full cohort costs) only covers $50,000 in loan forgiveness for 5,000 students. There are a lot more than 5,000 law and medical school graduates who could benefit under this program, yet it is unclear whether the Department of Education actually modeled professional school students (they mention on page 34 that graduate students were modeled, but they have much less debt on average).

Despite this change being a substantial shift in student loan policy, the education community and the media don’t seem to be too interested in the substantial cost shifting. The Chronicle had a nice article (subscription required) on the moral hazard regarding the program and Inside Higher Ed mentioned the release of the final rules, but completely missed the point. The conservative Daily Caller also mentioned the changes, but doesn’t get into the questionable legal foundation of advancing the policy before 2014 or the issue of who benefits.

It is easy to link the release of these regulations to electoral politics as usual, and I am certainly skeptical of what happens this time of year. However, given the lack of media coverage and the fact that it all hasn’t been positive, it appears that the Department of Education wanted to release the rules to have them take effect before receiving more public scrutiny. Hopefully, there will be a successful lawsuit delaying the rules on the grounds of the Obama Administration overstepping its legal authority to have the rules take effect in 2013 instead of 2014—and this will give researchers and policymakers a chance to rewrite the rules to target aid to those who truly need it instead of subsidizing expensive professional education programs.

Improving Income-Based Repayment

As regular readers of this blog know, I am keenly interested in exploring the cost-effectiveness of policies affecting the world of education. This week, the New America Foundation released a report detailing changes made by Congress and the Obama Administration to income-based repayment. Income-based repayment allows people to pay back their student loans by paying a fixed percentage of their income over a long period of time; this differs from traditional loan payments in the sense that loan payments can do down if income is low and up if income is high.

The recent actions of the good folks in Washington resulted in a system that substantially reduces the payments for people who take on a lot of debt (generally those who attend very expensive colleges or get professional degrees). Giving heavy subsidies to high-income, well-educated people isn’t the most cost-effective strategy and encourages the cost of higher education to rise even higher.

I combined with Sara Goldrick-Rab, my friendly neighborhood dissertation chair and someone who occupies a distinctly different political space from me, to write a piece for The Chronicle of Higher Education on how to improve income-based repayment. Take a read and let me know what you think. The New America people are certainly interested in considering changes to their proposal, and so am I.

As an aside, it always feels nice to get some publicity for your thoughts, especially while navigating the job market. Stay tuned for my next endeavor…coming soon!