What Should Count as “Financial Aid?”

Financial aid has taken center stage in federal policy discussions recently, including President Obama’s plan to provide many students with two years of tuition-free community college and changes to the Byzantine system of higher education tax credits, deductions, and tax-preferred savings plans. (I’ve written about the two topics here and here.) But these discussions hint at a broader question—what should be considered “financial aid?” In some respects, financial aid is a little bit like pornography, as everyone knows it when they see it.

But definitions of “financial aid” vary quite a bit across individuals. This is evidenced by Jordan Weissman of Slate, who tweeted his thoughts on financial aid policy:

His definition includes grants, loans, and tax credits—the broadest possible definition. Libby Nelson at Vox agreed:

But she also noted the difficulty in determining what financial aid is:

I’m a little skeptical about whether tax credits should truly be considered aid, as they come so far after the tuition bill coming due:

Others weighed in, noting that loans often aren’t considered financial aid:

It’s worth noting here that all grants, loans, and work-study are included as financial aid that students can receive up to the total cost of attendance, but only grants are included in the calculation of the net price.

So, wise readers, what would you consider to be financial aid? Take the poll below and feel free to leave additional thoughts in the comments section.

How Many Students Pay Full Price at Private Colleges?

As private nonprofit colleges in many regions of the country struggle to recruit an incoming class that meets both enrollment and revenue goals, the percentage of students paying the full sticker price has decreased significantly. This is well-explained in Jeff Selingo’s piece in the Washington Post, for which I contributed some analyses. In this blog post, I provide a few additional details behind the numbers.

I used data from the National Postsecondary Student Aid Study, a nationally representative survey of undergraduate students conducted every four years. For this analysis, I pulled data from the 1999-2000 and 2011-12 waves to look at trends in the percentage of students receiving any grant aid. (The remainder of the students are paying full price.) I cut the data by institutional selectivity, as conventional wisdom is that less-selective institutions are struggling more than elite colleges.

Percent of students at private 4-year colleges receiving any grant aid (NPSAS).
Selectivity category 1999-2000 (pct) 2011-2012 (pct)
Overall 66.8 76.3
Very selective 60.6 72.2
Moderately selective 71.6 83.6
Minimally selective 63.4 71.3
Open admission 62.2 63.8

 

While the percentage of students receiving grant aid increased in all categories of colleges but open admission institutions, the percentage with grant aid and the growth over time was largest at moderately selective institutions. These colleges and universities are squeezed financially, as they compete with very selective colleges for some students while being forced to fend off less selective colleges that are offering some of their students larger aid packages. As a result, yield rates (the percent of students accepted to a college who actually attend) have dropped to 15% at some of these institutions.

The increased competition for students and reduced ability of families to pay full price are key reasons why Standard & Poor’s just issued a negative outlook for the creditworthiness of nonprofit higher education for 2015. The big question remains how long some colleges can afford to continue operating under current business models.

Comments on President Obama’s State of the Union Higher Education Proposals

As President Obama enters the last two years of his presidency, he has made higher education one of the key points in his policy platform. The announcement of a plan to give students two years of free tuition at community colleges has gotten a great deal of attention, even though a lot of details are still lacking. (See my analysis of the plan here.) In an unusual Saturday night release, the Obama Administration laid out some details of its tax proposals that will be further elaborated in Tuesday’s State of the Union Address.

Many of the tax provisions will either directly affect higher education, or they will impact students and their families who are currently struggling to pay for college. Here is a quick overview of the provisions:

  • Expand the Earned Income Tax Credit, which goes to lower-income families with some wage income. This credit is fully refundable, meaning that families can benefit even if they don’t have a tax liability to offset with a credit (meaning that negative effective tax rates can result).
  • Expand and streamline the Child and Dependent Care Tax Credit, which is designed to offset high costs of child care. This could help the growing number of students who have children.
  • Consolidate the tuition and fees deduction and Lifetime Learning Credit into a streamlined and expanded American Opportunity Tax Credit, and making the AOTC permanent (it is set to expire in 2017). The AOTC would be set at $2,500 per year for five years and would be indexed for inflation. The AOTC would also be expanded to cover part-time students and the refundable portion would increase from $1,000 to $1,500. Finally, Pell Grant funds received would not count toward the AOTC. The AOTC expansion would be partially covered by reducing tax incentives for 529 and Coverdell savings plans.
  • Eliminate any taxes on any student loan balances forgiven after making the full 20 years of payment under income-based repayment plans. Right now, students are scheduled to be taxed on any balances—although few (if any) students have actually faced the tax burden at this point. This would partially be paid for by getting rid of the student loan interest deduction; essentially, students would lose any tax benefits for paying interest during the life of the loan, but they could benefit at the end of the payment period.

Although the exact costs of each of these proposals will not be known until the President releases his budget document later this spring, it appears that much of the revenue needed to pay for these expanded programs will come from higher taxes on higher-income individuals and large financial companies. Those tax increases are extremely unlikely to be passed by a Republican Congress, but some of the individual tax credit proposals may still be considered with funding coming from other sources.

Putting concerns about feasibility and funding aside, there are some things to like about the President’s proposals, while there are other things not to like. I’m generally not a fan of tax credits for higher education, as it is far less efficient to give students and their families money months after enrollment instead of when they actually need it the most. A great new National Bureau of Economic Research working paper by George Bulman and Caroline Hoxby examined the effectiveness of federal higher education tax credits and found essentially no impacts of tax credits on enrollment or persistence rates. It would be far better to give students a smaller grant at enrollment than a larger grant later on, but that is unlikely to ever happen due to the political popularity of tax credits on both sides of the aisle.

But I do like the part of the proposal that cuts the student loan interest deduction and directs the savings toward addressing the ticking time bomb of the loan forgiveness tax. The interest deduction is complicated, making it less likely to be claimed by lower-income households. Additionally, making interest partially tax-deductible could be seen as encouraging students to borrow more, potentially putting upward pressures on tuition. That is a difficult claim to verify empirically, but it is something that is often mentioned in discussions about college prices.

Regardless of whether any of these proposals become law, it is exciting to see so much discussion of higher education finance and policy at this point. Hopefully, there will be additional proposals coming from both sides of the political aisle that will help students access and complete high-quality higher education.

Thoughts on President Obama’s “Free Community College” Proposal

(NOTE: Updated 1/9/15 11 AM ET with discussion of state performance-based funding and maintenance of effort requirements.)

Two weeks in advance of the State of the Union Address, President Obama unveiled a proposal for tuition-free community college that is getting a great deal of attention. The plan, which was influenced by a “Free Two-Year College Option” paper by Sara Goldrick-Rab and Nancy Kendall, calls for the federal government to fund three-fourths of the cost of tuition and fees while states fund the remainder. The student is then responsible for covering other costs that go along with college attendance, such as books and living expenses.

This is an ambitious and complicated proposal that requires a fiscal outlay and Congressional approval. As a researcher at the intersection of financial aid and accountability policies, there are some things to like about the proposal, but there are also some significant concerns. Below, I list some of the pros and cons of the tuition-free community college proposal, as well as some potential items that can best be classified as “mixed” at this point:

Pros:

  • This sends a clear message that community college is an affordable option for all students. Even though tuition and fees make up a small portion of the total cost of attendance—and it is unclear if all students will see additional savings from this plan—telling students early on that tuition will be free may induce more to prepare for college and eventually enroll.
  • This could potentially encourage students to switch from expensive for-profit colleges to less-expensive community colleges for an associate’s degree. This would reduce their debt burden and maybe encourage them to pursue further education if desired.
  • This program will likely be targeted toward middle-income families who do not qualify for the Pell Grant, but cannot readily afford to pay several thousand dollars out of pocket each year for college. This group is key in building public support for higher education. (I don’t think it would affect the college choices of high-income families, who typically chose four-year institutions.)
  • Covering half-time students in addition to full-time students is a plus, although it remains to be seen whether half-time students would be eligible for additional years at a lower enrollment intensity.

Cons

  • The neediest students may not benefit as much from this plan as a straightforward increase to the Pell Grant, as some funds will go to students without financial need. At this point, it sounds like the proposal is NOT a last-dollar scholarship, meaning that all students will get at least some money. But while this is less efficient than increasing the Pell, the broad-based nature of the plan could gain additional political support.
  • If enough students switch from private to public colleges, the additional demand would force states and localities to undertake expensive capital building projects. This could also place additional strain on state financial aid programs.
  • The promise to cover three-fourths of tuition could encourage states and colleges to raise their tuition in order to qualify for more funds. Ideally, the legislation will have some sort of mechanism to prevent outright gaming, but community colleges in high-tuition states will effectively get more money than those in low-tuition states (often with a better history of state and local support). The state/federal/institutional interactions deserve careful scrutiny.
  • In order to qualify for the funds, states must allocate at least some appropriations based on performance instead of enrollment. This sounds like a good thing, but there are two problems. First, measuring performance is difficult–even with respect to graduation rates at community college. Second, as shown in research by Nick Hillman and David Tandberg, it is far from clear that performance-based funding policies improve student outcomes.

Mixed or unclear

  • Students must enroll half-time and earn at least a 2.5 GPA in order to qualify for free tuition. That is a step up from current rules for satisfactory academic progress for the Pell Grant, which typically requires a 2.0 GPA. It may help students be more serious about their studies, but it could also cut off struggling students who need additional support.
  • Requiring the state to fund the remaining cost of tuition could cut out the role of the local community college district. While some states have centralized funding structures for community colleges, others rely on local districts to fund their own college. Moving to a system of state-funded community colleges could help reduce massive funding inequities across districts, but it could reduce taxpayer support for higher education if they do not want their funds going elsewhere.
  • The plan calls for community colleges to work on transfer agreements with public four-year colleges and universities, which is a good thing. But I’d like to see the plan encourage collaboration with other regionally accredited institutions, including reputable private nonprofit and for-profit colleges.
  • The requirement that states maintain their effort for other sectors of higher education may induce some states to not participate. Additionally, if students shift from the four-year sector to two-year colleges, it’s not clear how “effort” should be defined.

We don’t know all of the details about the plan yet, but it is certain to generate a great deal of discussion in Washington and around the country. I’m looking forward to the conversation!

Analyzing the New Cohort Default Rate Data

The U.S. Department of Education today released cohort default rates (CDR) by college, which reflects the percentage of students who default on their loans within three years of entering repayment. This is a big deal for colleges, as any college that had a CDR of more than 30% for three consecutive years could lose its federal financial aid eligibility. I analyzed what we can learn from CDRs—a limited amount—in a blog post earlier this week.

And then things got interesting in Washington. The Department of Education put out a release yesterday noting that some students with loans from multiple servicers (known as “split servicers”) were current on some loans and defaulting on others. In this release, ED noted that the split servicer students were being dropped from CDRs over the last three years—but only if a college was close to the eligibility threshold. This led many to question whether ED was serious about using CDRs as an accountability tool, as well as trying to glean implications for the upcoming college ratings system.

The summary data for cohort default rates by year and sector is available here, and shows a decline from a 14.7% default rate in Fiscal Year 2010 to 13.7% in FY 2011. Default rates in each major sector of higher education also fell, led by a decline from 21.8% to 19.1% in the for-profit sector. However, a comparison of the FY 2009 and 2010 data in this release with the FY 2009 and 2010 data in last year’s release shows no changes from last year–before the split servicer change was adopted. Something doesn’t seem to be right there.

Twenty-one colleges are subject to sanctions under the new CDRs, all but one of which (Ventura Adult and Continuing Education) are for-profit. Most of the colleges subject to sanctions are small beauty or cosmetology institutions and reflect a very small percentage of total enrollment. We don’t know how many other colleges would have crossed over 30%, if not for the split servicer changes.

This year’s data show some very fortunate colleges. Among colleges with a sufficiently high participation rate, six institutions had CDRs of between 29 and 29.9 percent after being over 30% in the previous two years. They are led by Paris Junior College, with a 29.9% CDR in FY 2011 after being over 40% in the previous years. Other colleges weren’t so lucky. For example, the Aviation Institute of Maintenance was at 38.9% in FY 2009, 36.1% in FY 2010, and improved to 31.1% to 2011—but is still subject to sanctions.

FY 2011 CDRs, FY 2009 & 2010 above 30%
Name FY 2011 FY 2010 FY 2009
SEARCY BEAUTY COLLEGE 9.3 30.7 38.2
NEW CONCEPT MASSAGE AND BEAUTY SCHOOL 9.7 30.1 35.2
UNIVERSITY OF ANTELOPE VALLEY 12 31.8 30.6
PAUL MITCHELL THE SCHOOL ESCANABA 12.1 40 68.7
SAFFORD COLLEGE OF BEAUTY CULTURE 13.1 36.8 36.3
COMMUNITY CHRISTIAN COLLEGE 13.9 33.3 38.8
UNIVERSITY OF SOUTHERNMOST FLORIDA 14.6 30.8 35.1
SOUTHWEST UNIVERSITY AT EL PASO 15.5 36.1 37.5
CENTRO DE ESTUDIOS MULTIDISCIPLINARIOS 15.6 39.2 50.9
VALLEY COLLEGE 17.2 36.9 32.7
AMERICAN BROADCASTING SCHOOL 17.5 30.8 44.6
SUMMIT COLLEGE 17.6 30.9 30.5
VALLEY COLLEGE 19.4 56.5 37.5
AMERICAN UNIVERSITY OF PUERTO RICO 21 31.2 36.6
BRYAN UNIVERSITY 21.1 30.2 30.4
SOUTH CENTRAL CAREER CENTER 22 32.6 35.1
PAUL MITCHELL THE SCHOOL ARKANSAS 22 37.5 30
D-JAY’S SCHOOL OF BEAUTY, ARTS & SCIENCES 22.2 37.5 41.9
PAUL MITCHELL THE SCHOOL GREAT LAKES 22.2 34.6 33.9
KILGORE COLLEGE 22.7 30.2 33.5
ANTONELLI COLLEGE 22.8 33 35.1
OLD TOWN BARBER COLLEGE 23 37.7 40
OZARKA COLLEGE 23.1 41.8 35
TESST COLLEGE OF TECHNOLOGY 23.4 33.7 32
CENTURA COLLEGE 23.7 32 35
RUST COLLEGE 23.7 32 31.6
CARSON CITY BEAUTY ACADEMY 23.8 31.8 43.3
BACONE COLLEGE 24.1 32 30
KAPLAN CAREER INSTITUTE 24.1 32.5 33.6
TECHNICAL CAREER INSTITUTES 24.3 38.8 34.9
VICTOR VALLEY COMMUNITY COLLEGE 24.6 32.6 31
SOUTHWESTERN CHRISTIAN COLLEGE 24.6 32.7 43.1
AMERICAN BEAUTY ACADEMY 24.8 35.7 34.6
CENTURA COLLEGE 24.8 31.5 34.7
DENMARK TECHNICAL COLLEGE 25 30.8 31.6
MILAN INSTITUTE OF COSMETOLOGY 25 32.4 41.5
TREND BARBER COLLEGE 25 43.5 60.5
JACKSONVILLE BEAUTY INSTITUTE 25.2 33.3 41.7
CONCEPT COLLEGE OF COSMETOLOGY 25.3 41.5 34.2
EASTERN OKLAHOMA STATE COLLEGE 25.4 31.8 30
OTERO JUNIOR COLLEGE 25.5 34.2 38.2
LANGSTON UNIVERSITY 25.5 32.5 32.9
COLLEGEAMERICA DENVER 25.5 34.8 38.3
AVIATION INSTITUTE OF MAINTENANCE 25.8 36.9 39.6
EMPLOYMENT SOLUTIONS 26 38.5 30
SANFORD-BROWN COLLEGE 26.2 31.6 31.5
CAMBRIDGE INSTITUTE OF ALLIED HEALTH AND TECHNOLOGY 26.6 33.3 35
ANTELOPE VALLEY COLLEGE 26.9 32.6 33.2
UNIVERSITY OF ARKANSAS COMMUNITY COLLEGE AT BATESVILLE 26.9 30.6 31.6
CC’S COSMETOLOGY COLLEGE 27.4 40.3 35.9
MILWAUKEE CAREER COLLEGE 27.6 34.1 32.7
NTMA TRAINING CENTERS OF SOUTHERN CALIFORNIA 27.8 32.1 34.2
CONCORDIA COLLEGE ALABAMA 27.9 31.4 37.5
NORTH AMERICAN TRADE SCHOOLS 28 31 31.1
AVIATION INSTITUTE OF MAINTENANCE 28.1 37.9 39.8
MEDIATECH INSTITUTE 28.4 33.3 33.3
SEBRING CAREER SCHOOLS 29 54.1 57.5
MOHAVE COMMUNITY COLLEGE 29.3 32.7 36.7
CHERYL FELL’S SCHOOL OF BUSINESS 29.4 38 31.2
AVIATION INSTITUTE OF MAINTENANCE 29.4 36.1 38.9
KLAMATH COMMUNITY COLLEGE 29.4 33 31.7
PARIS JUNIOR COLLEGE 29.9 40.7 41.5
STYLEMASTERS COLLEGE OF HAIR DESIGN 30.6 46.6 37
LASSEN COLLEGE 30.8 37.1 37.7
AVIATION INSTITUTE OF MAINTENANCE 31.1 37.5 32.2
CHARLESTON SCHOOL OF BEAUTY CULTURE 31.7 37.5 34
PALLADIUM TECHNICAL ACADEMY 33 39.4 46.2
L T INTERNATIONAL BEAUTY SCHOOL 38.1 37.7 38
TIDEWATER TECH 38.6 42.7 55
JAY’S TECHNICAL INSTITUTE 40.6 53.8 51.5
OHIO STATE COLLEGE OF BARBER STYLING 41.1 37.8 32.9
MEMPHIS INSTITUTE OF BARBERING 44.7 47.2 44.4
FLORIDA BARBER ACADEMY 46.5 41.7 32.5
SAN DIEGO COLLEGE 49.3 34 35.7

Fully 35 colleges with sufficient participation rates had CDRs between 29.0% and 29.9% in FY 2011, including a mix of small for-profit colleges, HBCUs, and community colleges. The University of Arkansas-Pine Bluff, a designated minority-serving institution, has had CDRs of 29.9%, 29.2%, and 29.8% in the last three years. Mt. San Jacinto College and Harris-Stowe State University also had CDRs just under 30% in each of the last three years. Only 19 colleges, representing a mix of institutional types, had CDRs between 30.0% and 30.9%. This includes Murray State College in Oklahoma, which was at 30.0% in FY 2011, 28.9% in FY 2010, and 31.1% in FY 2009. Forty-three colleges were between 28.0% and 28.9%.

FY 2011 CDRs between 29 and 31 percent
Name FY 2011 FY 2010 FY 2009
OHIO TECHNICAL COLLEGE 29 24.1 21.3
DAYMAR COLLEGE 29 28.9 46.2
SEBRING CAREER SCHOOLS 29 54.1 57.5
L’ESPRIT ACADEMY 29.1 0 0
BLACK RIVER TECHNICAL COLLEGE 29.1 27.9 26.6
NEW SCHOOL OF RADIO & TELEVISION 29.1 26.2 28.1
LOUISBURG COLLEGE 29.2 28.7 24.7
MOHAVE COMMUNITY COLLEGE 29.3 32.7 36.7
HARRIS SCHOOL OF BUSINESS 29.3 25.6 17.8
INTELLITEC MEDICAL INSTITUTE 29.3 27.1 24.7
GALLIPOLIS CAREER COLLEGE 29.3 33.9 29.4
CHERYL FELL’S SCHOOL OF BUSINESS 29.4 38 31.2
COLLEGE OF THE SISKIYOUS 29.4 27.7 27.1
AVIATION INSTITUTE OF MAINTENANCE 29.4 36.1 38.9
KLAMATH COMMUNITY COLLEGE 29.4 33 31.7
COLORLAB ACADEMY OF HAIR, THE 29.4 24.3 12.5
DIGRIGOLI SCHOOL OF COSMETOLOGY 29.4 21.6 23.5
VIRGINIA SCHOOL OF MASSAGE 29.4 14.8 22
WASHINGTON COUNTY COMMUNITY COLLEGE 29.5 20.5 12.7
MT. SAN JACINTO COLLEGE 29.5 29.9 26.5
WEST TENNESSEE BUSINESS COLLEGE 29.5 32.6 21.8
BRITTANY BEAUTY SCHOOL 29.5 31.9 26.4
JOHN PAOLO’S XTREME BEAUTY INSTITUTE, GOLDWELL PRODUCTS ARTISTRY 29.5 25 0
HARRIS – STOWE STATE UNIVERSITY 29.6 27.9 26.5
CARIBBEAN UNIVERSITY 29.6 29.9 29.9
GUILFORD TECHNICAL COMMUNITY COLLEGE 29.7 26 19
WARREN COUNTY CAREER CENTER 29.7 22.9 25
STARK STATE COLLEGE 29.7 24.5 17.2
STRAND COLLEGE OF HAIR DESIGN 29.7 17.9 11.1
INDEPENDENCE COLLEGE OF COSMETOLOGY 29.8 21.6 18.4
FRANK PHILLIPS COLLEGE 29.8 25.2 29.1
MEDICAL ARTS SCHOOL (THE) 29.8 21.6 13.1
NEW MEXICO JUNIOR COLLEGE 29.8 24.1 23.1
PARIS JUNIOR COLLEGE 29.9 40.7 41.5
UNIVERSITY OF ARKANSAS AT PINE BLUFF 29.9 29.2 29.8
MURRAY STATE COLLEGE 30 28.9 31.1
JARVIS CHRISTIAN COLLEGE 30 36.5 29.3
BUSINESS INDUSTRIAL RESOURCES 30.1 19.1 20.9
LONG BEACH CITY COLLEGE 30.1 24.2 19
EASTERN GATEWAY COMMUNITY COLLEGE 30.1 0 0
MARTIN UNIVERSITY 30.2 19.8 18.7
LANE COMMUNITY COLLEGE 30.2 30.6 19.5
CAREER QUEST LEARNING CENTER 30.2 24.1 16.1
NIGHTINGALE COLLEGE 30.3 25 16.6
EMPIRE BEAUTY SCHOOL 30.4 31.6 25.2
NATIONAL ACADEMY OF BEAUTY ARTS 30.4 20.6 5.6
BAR PALMA BEAUTY CAREERS ACADEMY 30.5 35.8 26.8
WEST VIRGINIA UNIVERSITY – PARKERSBURG 30.5 25.8 24.1
ENSACOLA SCHOOL OF MASSAGE THERAPY & HEALTH CAREERS 30.5 17.3 10
PROFESSIONAL MASSAGE TRAINING CENTER 30.6 14.8 13
UNIVERSAL THERAPEUTIC MASSAGE INSTITUTE 30.6 23.5 17.2
STYLEMASTERS COLLEGE OF HAIR DESIGN 30.6 46.6 37
CCI TRAINING CENTER 30.8 26.5 26.7
INSTITUTE OF AUDIO RESEARCH 30.8 29.7 17
LASSEN COLLEGE 30.8 37.1 37.7
KAPLAN CAREER INSTITUTE 30.8 34.6 29.7
TRANSFORMED BARBER AND COSMETOLOGY ACADEMY 30.9 66.6 0
MAYSVILLE COMMUNITY AND TECHNICAL COLLEGE 30.9 26.4 24.5
TRI-COUNTY TECHNICAL COLLEGE 30.9 27.2 16.1

Some of the larger for-profits fared better, potentially due to split servicers. The University of Phoenix’s CDR was 19.0% in FY 2011, down from 26.0% in FY 2010 and 26.4%. DeVry University was at 18.5% in FY 2011, down from 23.4% in FY 2010 and 24.1% in FY 2009. ITT Technical Institute also improved, going from 33.3% in FY 2009 to 28.6% and then 22.4% this year. (Everest College disaggregates its data by campus, but the results are similar.)

The CDR data are not without controversy, but they are an important accountability tool going forward. It will be interesting to see whether and how these data will be used in the draft Postsecondary Institution Ratings System later this fall.

What Are Cohort Default Rates Good For?

Today marks the start of U.S. Department of Education’s annual release of cohort default rates (CDR), which reflects the percentage of students who default on their loans within three years of entering repayment. Colleges were informed of their rates today, with a release to the public coming sometime soon. This release, tracking students who entered repayment in Fiscal Year 2011, will the third year that three-year CDRs have been collected and completes a shift from two-year to three-year CDRs for accountability purposes.

Before this year, colleges were subject to sanctions based on their two-year CDRs. Any college that had a two-year CDR of more than 40% in one year could lose its federal student loan eligibility, while any college with a two-year CDR of over 25% for three consecutive years could lose all federal financial aid eligibility. (Colleges with a very small percentage of borrowers can get an exemption.) While this was a rare occurrence (fewer than ten colleges were impacted last year), the switch to a three-year CDR has worried colleges even as the allowed CDR over three years rose from 25% to 30%.

But as the methodology changes, we need to consider what CDR data are actually good for. Colleges take cohort default rates very seriously, and the federal government is likely to use default rates as a component of the often-discussed (and frequently delayed) Postsecondary Institution Ratings System (PIRS). But should the higher education community, policymakers, or the general public take CDRs seriously? Below are some reasons why the default data are far from complete.

(1) Students are tracked over only three years, and income-based repayment makes the data less valuable. I have previously written about these two issues—and why it’s absurd that the Department of Education doesn’t track students over at least ten years. Income-based repayment means that students can be current on their payments even if their payments are zero, which is good for the student but isn’t exactly a ringing endorsement of a given college’s quality.

(2) Individual campuses are often aggregated to the system level, but this isn’t consistent. One of the biggest challenges as a researcher in higher education finance is that data on loan and grant volumes and student loan default rates come from Federal Student Aid instead of the National Center for Education Statistics. This may sound trivial, but some colleges aggregate FSA data to the system level for reporting purposes while all NCES data are at the campus level. This means that while default data on individual campuses within the University of Wisconsin System are available, data from all of the Penn State campuses are aggregated. Most for-profit systems also aggregate data, likely obscuring some individual branches that would otherwise face sanctions.

(3) Defaults are far from the only adverse outcome, but it’s the only one with reported data. Students are not counted as being in default until no payment has been made for at least 271 days, but we have no idea of delinquency rates, hardship deferments, or forbearances related to financial problems by campus. As I recently wrote in a guest post for Access to Completion, the percentage of students having repayment difficulties ranges between 17% and 51%, depending on assumptions made. But we don’t have data on delinquency rates by campus, something which a lot of stakeholders would have interest in.

Does this mean cohort default rates are good for absolutely nothing? No. They’re still useful in identifying colleges (or systems) where a large percentage of borrowers default quickly and a substantial percentage of students borrow. And very low default rates can be a sign that either students are doing well in the labor market after leaving college or that they have the knowledge to enter income-based repayment programs. But for many colleges with middling default rates, far more data are needed (that the Department of Education collects and doesn’t release) to get a better picture of performance.

When the CDR data come out, I’ll have part 2 of this post—focusing on the colleges that are subject to sanctions and what that means for current and future accountability systems.

Building a Better Student Loan Default Measure

Student loan default rates have been a hot political topic as of late given increased accountability pressures at the federal level. Currently, colleges can lose access to all federal financial aid (grants as well as loans) if more than 25% of students defaulted on their loans within two years of leaving college for three consecutive cohorts. Starting later this year, the measure used will be the default rate within three years of leaving college, and the cutoff for federal eligibility will rise to 30%. (Colleges can appeal this result if there are relatively few borrowers.)

But few students should ever have to default on their loans given the availability of various income-based repayment (IBR) plans. (PLUS loans typically aren’t eligible for income-based repayment, but their default rates oddly aren’t tracked and aren’t used for accountability purposes.) If a former student enrolled in IBR falls on tough times, his or her monthly payment will go down—potentially to zero if income is less than 150% of the federal poverty line. As a result, savvy colleges should be encouraging their students to enroll in IBR in order to reduce default rates.

And more students are enrolling in IBR. Jason Delisle at the New America Foundation analyzed new Federal Student Aid data out this week that showed that the number of students in IBR doubled from 950,000 to 1.9 million in the last year while outstanding loan balances went from $52.2 billion to $101.0 billion. The federal government’s total Direct Loan portfolio increased from $361.3 billion to $464.3 billion in the last year, meaning that IBR was responsible for nearly half of the increase in loan dollars.

This shift to IBR means that the federal government needs to consider new options for holding colleges accountable for their outcomes. Some options include:

(1) Using a longer default window. The “standard” loan repayment plan is ten years, but defaults are only tracked for three years. A longer window wouldn’t give an accurate picture of outcomes if more students enroll in IBR, but it would provide useful information on students who expect to do well enough after college that standard payments will be a better deal than IBR. This probably requires replacement of the creaky National Student Loan Data System, which may not be able to handle that many more data requests.

(2) Look at the percentage of students who don’t pay anything under IBR. This would measure the percentage of students making more than 150% of the poverty line, or about $23,000 per year for a former borrower with one other family member. Even with the woeful salaries in many public service jobs (such as teaching), they’ll likely have to pay something here.

(3) Look at the total amount repaid compared to the amount borrowed. If the goal is to make sure the federal government gets its money back, a measure of the percentage of funds repaid might be useful. Colleges could even be held accountable for part of the unpaid amount if desired.

As the Department of Education continues to develop draft college ratings (to come out later this fall), they are hopefully having these types of conversations when considering outcome measures. I hope this piece sparks a conversation about potential loan default or repayment measures that can improve upon the currently inadequate measure, so please offer your suggestions as comments below.

Quick Thoughts on the Ryan Higher Education Budget Discussion Draft

Representative Paul Ryan (R-WI) released a proposal called Expanding Opportunity in America this morning, which covered topics including social benefits, the Earned Income Tax Credit, education, criminal justice, and regulatory reform. My focus is on the higher education section, starting on page 44.

First of all, I’m glad to see a discussion of targeting federal funds right at the start of the higher education section. Ryan notes concerns about subsidies going to students who don’t need them (such as education tax credits going to households making up to $180,000 per year) and the large socioeconomic gaps in college completion. This is important to note for both economic efficiency and targeting middle-income voters.

The policy points are below:

  • Simplify the FAFSA. Most policymakers like this idea at this point, but the question is how to do so. The document doesn’t specify how it should be simplified, or if it should go as far as the Alexander/Bennet proposal to knock the FAFSA back to two questions. Ryan supports getting information about aid available to students in eighth grade and using tax data from two years ago (“prior prior year”) to determine aid eligibility, both of which make great sense. I’ve written papers on both early aid commitment and prior prior year.
  • Reform and modernize the Pell program. Ryan is concerned about the fiscal health of the Pell program and is looking for ways to shore up its finances. He raises the idea of using the Supplemental Educational Opportunity Grant (SEOG)—a Pell supplement distributed by campuses—to help fund Pell. I’ve written a paper about how SEOG and work-study allocations benefit very expensive private colleges over colleges that actually serve Pell recipients. It’s a great idea to consider, but parts of One Dupont just may object. Ryan also suggests allowing students to use their Pell funds however they want (effectively restoring the summer Pell Grant), something which much of the higher education community supports.
  • Cap federal loans to graduate students and parents. This will prove to be a controversial recommendation, with the possibility of interesting political bedfellows. While many are concerned about rising debt and the fiscal implications, there are different solutions. The Obama Administration has instead proposed capping forgiveness at $57,500, while letting students borrow more. I’m conflicted as to what the better path is. Is it better to shift students to the private loan market to get any additional funds, or should they get loans with lower interest rates through the federal government that may result in a fiscal train wreck if loan forgiveness isn’t capped? The Ryan proposal has the potential to help slow the growth in college costs, but potentially at the expense of some students’ goals.
  • Consider reforms to the TRIO programs. TRIO programs serve low-income, first-generation families, but Ryan notes that there isn’t a lot of evidence supporting these programs. I admittedly don’t know as much about TRIO as I should, but I like the call for additional research before judging their effectiveness.
  • Expand funding for federal Work-Study programs. The proposal increases work-study funds through allowing colleges to keep expiring Perkins Loans funds instead of returning them to the federal government. This is the wrong way to proceed because Perkins allocations (and current work-study allocations) are also correlated with the cost of attendance. I would rather see a redistribution of work-study funds based on Pell Grant receipt instead of by cost of attendance, as I’ve noted previously.
  • Build stronger partnerships with post-secondary institutions. Most of this is empty platitudes toward colleges, but the last sentence is critical: “Colleges should also have skin in the game, to further encourage their commitment to outcome-based learning.” There seems to be some support on both sides of the aisle for holding institutions accountable for their performance through methods such as partial responsibility for loan defaults, tying financial aid to outcomes, or college ratings, but an agreement looks less likely at this point.
  • Reform the accreditation process. Ryan supports Senator Lee (R-UT)’s proposal to allow accreditors to certify particular courses instead of degree programs. This is a good idea in general, but the political landscape gets much trickier due to the existence of MOOCs, for-profit colleges (and course providers), and the power of the current higher education lobby. I’ll be interested to see how this moves forward.

Overall, the tenets of the proposal seem reasonable and some parts are likely to get bipartisan support. The biggest questions remaining are whether the Senate will be okay with the House passing Higher Education Act reauthorization components piecemeal (as they are currently doing) and what funding levels will look like for particular programs. In any case, these ideas should generate useful discussions in policy and academic circles.

Should Colleges Be Able to Determine Costs of Living?

I was reading through the newest National Center for Education Statistics report with just-released federal data on the cost of college and found some interesting numbers. (The underlying data are available under the “preliminary release” tab of the IPEDS Data Center.) Table 2 of the report shows the change in inflation-adjusted costs for tuition and fees, books and supplies, room and board, and other expenses included in the cost of attendance figure between 2011-12 and 2013-14.

Tuition and fees rose between three and five percent above inflation in public and private nonprofit two-year and four-year colleges between 2011-12 and 2013-14 while slightly dipping at for-profit colleges (perhaps a response to declining enrollment in that sector). Room and board for students living on campus at four-year colleges also went up about three percent faster than inflation, which seems reasonable given the increasing quality of amenities. But the other results struck me as a little odd:

This tweet got picked up by The Chronicle of Higher Education, and led to a nice piece by Jonah Newman talking to me and a financial aid official about what could be explaining these results. In my view, there are three potential reasons why other costs included in the costs of attendance measure could be falling:

(1) Students could be under such financial stress that they’re doing everything possible to cut back on costs at least partially within their control. Given the rising cost of college, this could potentially explain part of the drop.

(2) Colleges could be trying to keep the total cost of attendance—and thus the net price of attendance, which is the cost of attendance less all grant aid received—low for accountability and public shaming purposes. In my work as methodologist for the Washington Monthly college rankings, a college’s net price factors into its score on the social mobility portion of the rankings and its position on our list of America’s Best Bang for the Buck” Colleges. A higher net price could also hurt colleges in the Obama Administration’s proposed college ratings, a draft of which is due to be released later this fall.

(3) Colleges could be trying to keep the cost of attendance low in order to limit student borrowing because students cannot borrow more than the total cost of attendance. Colleges may think that limiting student loan debt will result in lower default rates (a key accountability measure), and there is some evidence that the for-profit sector may be doing this even if it cuts off students’ access to funds needed to pay for living expenses:

Looking at each of the individual components beyond tuition, fees, and room and board, book and supplies costs staying level with inflation or slightly falling in the nonprofit sector could be reasonable. Pushes to make textbook costs more transparent could be having an impact, as could the ability of students to rent books or access online course material at a lower price than conventional material:

While room and board for students living on campus increased 3-4 percentage points faster than inflation over the last two years, the cost of living off campus (not with family) was estimated to stay constant. However, as Ben Miller at the New America Foundation pointed out to me, some colleges cut their off-campus living expenses to implausibly low values:

The “other expenses” category (such as transportation, travel costs, and some entertainment) dropped between one and five percentage points. These drops could be a function of colleges not accurately capturing what it costs to live modestly because surveying students is an expensive and time-consuming proposition for understaffed financial aid offices. But it could also be a result of pressure from administrators or trustees who want to keep the total cost (on paper) lower.

A potential solution would be to take the room and board estimates for off-campus students and the “other expenses” category out of the hands of colleges and instead use a regionally-adjusted measure of living expenses. The Department of Education could survey students at a selected number of representative colleges to get an idea of their expenses and whether they are what students need in order to be successful in college. They could use this survey to develop estimates that apply to all colleges. There is some precedent for doing this, as the cost of attendance estimates for Federal Work-Study and Supplemental Educational Opportunity Grant campus funding add a $9,975 living cost allowance and a $600 books and supplies allowance for all students. This should be adjusted for regional cost of living (and what costs actually are), but it’s something to consider going forward.

State Financial Aid Application Deadlines—A Lousy Rationing Tool

Financial aid reform has become a hot political topic in Washington as of late, with legislation introduced or pending from Senate Democrats, House Republicans, and the bipartisan pair of Senators Lamar Alexander (R-TN) and Michael Bennet (D-CO). (Here is a nice summary of the pieces of legislation from the National College Access Network.) All three of the proposals support the use of “prior prior year” or PPY, which would advance the financial aid application timeline by up to one year. Given the bipartisan support, this policy change may end up happening.

PPY could affect the deadlines for state financial aid applications in ways that could help some students and hurt others. (It could also affect institutional deadlines, but that’s a topic for another post.) Some state aid deadlines listed on the FAFSA are currently well before tax day on April 15, making it difficult for students to take advantage of the IRS Data Retrieval Tool that automatically populates the FAFSA with income tax data but takes up to three weeks to process. For example, five states (Illinois, Kentucky, North Carolina, Tennessee, and Vermont) recommend filing “as soon as possible” after January 1 in order to get funds before they run out. At least 15 states currently have deadlines before March 2, nearly six months before the start of the following academic year.

The below table shows the percentage of all students who filed the FAFSA in the 2012-13 academic year (the most recent year with complete data available) by March 31 and June 30 by state and dependency status. There are two notes with the table. First, it only includes states with deadlines listed on the FAFSA, as other states are either unknown or on a first-come, first-served basis. Second, application data by state are only available by quarter at this point, although the good folks at Federal Student Aid have told me they hope to release data every month in the future.

Percent of FAFSAs Filed by State, Date, and Dependency Status
Applications Filed by 3/31 Applications Filed by 6/30
State Deadline Dependent Indep. Dependent Indep.
IL 1/1 65% 39% 83% 64%
KY 1/1 63% 40% 80% 64%
NC 1/1 54% 33% 79% 61%
TN 1/1 59% 36% 81% 63%
VT 1/1 70% 39% 87% 66%
CT 2/15 66% 35% 85% 63%
ID 3/1 61% 39% 80% 65%
MD 3/1 67% 41% 83% 64%
MI 3/1 61% 35% 80% 60%
MT 3/1 62% 40% 81% 64%
OK 3/1 47% 30% 74% 59%
OR 3/1 67% 50% 82% 71%
RI 3/1 75% 50% 87% 69%
WV 3/1 72% 40% 86% 63%
CA 3/2 68% 43% 81% 65%
IN 3/10 82% 53% 89% 69%
FL 3/15 43% 30% 72% 60%
KS 4/1 57% 33% 80% 61%
MO 4/2 56% 34% 81% 63%
DE 4/15 51% 28% 82% 60%
ND 4/15 45% 30% 78% 61%
ME 5/1 72% 45% 89% 70%
MA 5/1 65% 36% 87% 66%
PA 5/1 55% 34% 86% 65%
AZ 6/1 45% 29% 73% 59%
NJ 6/1 53% 29% 83% 62%
IA 6/6 58% 32% 83% 62%
AK 6/30 51% 32% 75% 58%
DC 6/30 60% 33% 84% 62%
LA 6/30 31% 25% 74% 58%
NY 6/30 51% 30% 79% 62%
SC 6/30 43% 28% 76% 59%
MS 9/15 37% 25% 69% 56%
MN 10/1 44% 24% 77% 57%
OH 10/1 58% 34% 81% 62%

Source: Federal Student Aid data.

Among the 17 states with stated deadlines before March 31, Indiana students were the most likely to file by March 31 (with a March 10 deadline) and Florida students were the least likely to file (with a March 15 deadline). The differences (82% vs. 43% for dependent students and 53% vs. 30% for independent students) reflect the universality of Indiana’s state financial aid program compared to the much more targeted Florida program. In all states, dependents were far more likely to file by March 31 than independents, meaning that independent students were much less likely to even be considered for state financial aid programs. Students were more likely to file by March 31 in states with earlier aid deadlines, as evidenced by a correlation coefficient of about -0.55 for both independent and dependent students.

By June 30, all but three states (Mississippi, Minnesota, and Ohio) have had their state aid deadlines, but only about 81% of dependent and 63% of independent students have filed their FAFSA by that point. Some of these students may choose to enroll in college for the spring semester only, but many are still planning to enroll in the fall semester. These students can still receive federal financial aid, but will miss out on state aid. The correlation between state aid deadlines and the percent of applications received by June 30 is lower, on the order of -0.4.

So what does this mean? About 20% of dependent and 35% of independent students are likely to miss all state application deadlines under current rules, and about 60% of independent students currently miss state aid deadlines before March 31. These students are likely to have more financial need than earlier applicants, but are left out—as shown by recent research. A shift to PPY is likely to move up these state deadlines as states are unlikely to provide more money to student financial aid. The deadlines serve as a de facto rationing tool.

There are better ways to allocate these funds. Instead of using a first-come, first-served model by setting an artificially early deadline, states could give smaller awards to more students or assign grants via lottery to all students who apply before the start of the fall semester (say, August 1). Susan Dynarski made an important point regarding the current system on Twitter:

States need to consider whether their current application deadlines are shutting out students with the greatest financial need, and whether a move to PPY at the federal level will affect their plans. It is abundantly clear that the current system can be improved upon, and I hope states act to do so.