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!