financial responsibility – Robert Kelchen

An Updated Look at Financial Responsibility Scores and College Closures

The topic of college closures has gotten even more attention since the beginning of the coronavirus pandemic last spring. Even though the number of private nonprofit colleges closing remained around recent norms in 2020 (approximately ten degree-granting institutions), many colleges have absorbed sizable losses during the pandemic and will continue to do so in coming years. In a recent working paper that I wrote with Dubravka Ritter of the Federal Reserve Bank of Philadelphia and Doug Webber of Temple University, we estimate that colleges and universities may lose approximately $100 billion in revenue over the next five years. This means that colleges are still going to face financial challenges going forward.

One of the federal government’s main tools to identify colleges at risk of closure is financial responsibility scores. Private nonprofit and for-profit colleges are scored on a scale of -1.0 to 3.0 based on three measures: a primary reserve ratio, a net income ratio, and an equity ratio. Colleges that score at 1.5 or above pass, while colleges that score between 1.0 and 1.4 are in an oversight zone and colleges that score at 0.9 or below fail. Colleges that fail must submit a letter of credit in order to keep receiving federal financial aid, and colleges that are in the oversight zone or fail are subject to additional financial monitoring.

The financial responsibility scores for fiscal years ending in 2018-19 were recently released by Federal Student Aid, and this represents the final pre-pandemic look at colleges’ finances. The distribution of listed scores by sector is below. The vast majority of colleges in both sectors passed, but a larger number of for-profit colleges failed than in the private nonprofit sector.

Outcome	For-profit	Nonprofit
Pass	1,517	1,479
Zone	51	51
Fail	123	49
Total	1,691	1,579

Four years ago, I looked at the financial responsibility scores of private nonprofit colleges that closed in 2016. Of the 12 colleges with available data, four colleges passed, two were in the oversight zone, three failed, and the final three institutions were placed on heightened cash monitoring for financial responsibility score issues without assigning a score.

I repeated this exercise for twelve private nonprofit colleges that closed or merged in 2020 or 2021 and had available data. As shown below, not a single college that closed received a failing financial responsibility score. Three were in the oversight zone, three were instead placed on heightened cash monitoring for financial responsibility concerns, and the other six all passed. Holy Family College in Wisconsin, which closed in 2020, had a perfect score.

Name	Financial responsibility score
Judson College	2.1 (pass)
Becker College	Placed on HCM1
Concordia College (NY)	Placed on HCM1
Marlboro College	1.8 (pass)
Wesley College (DE)	Placed on HCM1
Pine Manor College	1.0 (zone)
Holy Family College (WI)	3.0 (pass)
Urbana University	2.9 (pass)
MacMurray College	2.6 (pass)
Robert Morris University (IL)	1.3 (zone)
Concordia University (OR)	1.1 (zone)
Watkins College of Art	2.2 (pass)

Next year’s release of financial responsibility scores will begin to show the effects of the pandemic at colleges which had their fiscal years end after the pandemic began. The 2020-21 IPEDS data collection cycle also includes for the first time values for each component of the financial responsibility score so analysts have more information about colleges’ financial positions.

Which Colleges Failed the Latest Financial Responsibility Test?

Every year, the U.S. Department of Education is required to issue a financial responsibility score for private nonprofit and for-profit colleges, which serves as a crude measure of an institution’s financial health. Colleges are scored on a scale from -1.0 to 3.0, with colleges scoring 0.9 or below failing the test (and having to put up a letter of credit) and colleges scoring between 1.0 and 1.4 being placed in a zone of additional oversight.

Ever since I first learned of the existence of this metric five or six years ago, I have been bizarrely fascinated by its mechanics and how colleges respond to the score as an accountability pressure. I have previously written about how these scores are only loosely correlated with college closures in the past and also wrote an article about how colleges do not appear to change their fiscal priorities as a result of receiving a low score.

ED typically releases financial responsibility scores with no fanfare, and it looks like they updated their website with new scores in late March without anyone noticing (at least based on a Google search of the term “financial responsibility score”). I was adding a link to the financial responsibility score to a paper I am writing and noticed that the newest data—for the fiscal year ending between July 1, 2016 and June 30, 2017—was out. So here is a brief summary of the data.

Of the 3,590 colleges (at the OPEID level) that were subject to the financial responsibility test in 2016-17, 269 failed, 162 were in the oversight zone, and 3,159 passed. Failure rates were higher in the for-profit sector than in the nonprofit sector, as the table below indicates.

Financial responsibility scores by institutional type, 2016-17.

	Nonprofit	For-profit	Total
Fail (-1.0 to 0.9)	82	187	269
Zone (1.0 to 1.4)	58	104	162
Pass (1.5 to 3.0)	1,559	1,600	3,159
Total	1,699	1,891	3,590

Among the 91 institutions with the absolute lowest score of -1.0, 85 were for-profit. And many of them were a part of larger chains. Education Management Corporation (17), Education Affiliates, Inc. (19), and Nemo Investor Aggregator (11) were responsible for more than half of the -1 scores. Most of the Education Affiliates (Fortis) and Nemo (Cortiva) campuses still appear to be open, but Education Management Corporation (Argosy, Art Institutes) recently suffered a spectacular collapse.

I am increasingly skeptical of financial responsibility scores as a useful measure of financial health because they are so backwards-looking. The data are already three years old, which is an eternity for a college on the brink of collapse (but perhaps not awful for a cash-strapped nonprofit college with a strong will to live on). I joined Kenny Megan from the Bipartisan Policy Center to write an op-ed for Roll Call on a better way to move forward with collecting more updated financial health measures, and I would love your thoughts on new ways to proceed!

How Financial Responsibility Scores Do Not Affect Institutional Behaviors

One of the federal government’s longstanding accountability efforts in higher education is the financial responsibility score—a metric designed to reflect a private college’s financial stability. The federal government has an interest in making sure that only stable colleges receive federal funds, as taxpayers often end up footing at least part of the bill when colleges shut down and students may struggle to resume their education elsewhere. The financial responsibility score metric ranges from -1.0 to 3.0, with colleges scoring between 1.0 and 1.4 being placed under additional oversight and those scoring below 1.0 being required to post a letter of credit with the Department of Education.

Although these scores have been released to the public since the 2006-07 academic year and there was a great deal of dissatisfaction among private colleges regarding how the scores were calculated, there had been no prior academic research on the topic before I started my work in the spring of 2014. My question was simple: did receiving a poor financial responsibility score induce colleges to shift their financial priorities (either increasing revenues or decreasing expenditures) in an effort to avoid future sanctions?

But as is often the case in academic research, the road to a published article was far from smooth and direct. Getting rejected by two different journals took nearly two years and then it took another two years for this paper to wind its way through the review, page proof, and publication process at the Journal of Education Finance. (In the meantime, I scratched my itch on the topic and put a stake in the ground by writing a few blog posts highlighting the data and teasing my findings.)

More than four and a half years after starting work on this project, I am thrilled to share that my paper, “Do Financial Responsibility Scores Affect Institutional Behaviors?” is a part of the most recent issue of the Journal of Education Finance. I examined financial responsibility score data from 2006-07 to 2013-14 in this paper, although I tried to get data going farther back since these scores have been calculated since at least 1996. I filed a Freedom of Information Act request back in 2014 for the data, and my appeal was denied in 2017 on the grounds that the request to receive data (that already existed in some format!) was “too burdensome and expensive.” At that point, the paper was already accepted at JEF, but I am obviously still a little annoyed with how that process went.

Anyway, I failed to find any clear evidence that private nonprofit or for-profit colleges changed their fiscal priorities after receiving an unfavorable financial responsibility score. To some extent, this result made sense among private nonprofit colleges; colleges tend to move fairly slowly and many of their costs are sticky (such as facilities and tenured faculty). But for-profit colleges, which generally tend to be fairly agile critters, the null findings were more surprising. There is certainly more work to do in this area (particularly given the changes in higher education that have occurred over the last five years), so I encourage more researchers to delve into this topic.

To aspiring researchers and those who rely on research in their jobs—I hope this blog post provides some insights into the scholarly publication process and all of the factors that can slow down the production of research. I started this paper during my first year on faculty and it finally came out during my tenure review year (which is okay because accepted papers still count even if they are not yet in print). Many papers move more quickly than this one, but it is worth highlighting that research is a pursuit for people with a fair amount of patience.

Do Financial Responsibility Scores Predict College Closures?

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

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

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

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

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

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

Do Financial Responsibility Scores Reflect Colleges’ Financial Strength?

In spite of the vast majority of federal government operations being closed on Thursday due to snow (it’s been a rough end to winter in this part of the country), the U.S. Department of Education released financial responsibility scores for private nonprofit and for-profit colleges and universities based on 2012-2013 data. These scores are based on calculations designed to measure a college’s financial strength in three key areas: primary reserve ratio (liquidity), equity ratio (ability to borrow additional funds) and net income (profitability or excess revenue).

A college can score between -1 and 3, and colleges that score over 1.5 are considered financially responsible without any qualifications and can access federal funds. Colleges scoring between 1.0 and 1.4 are considered financially responsible and can access federal funds for up to three years, but are subject to additional Department of Education oversight of its financial aid programs. If a college does not improve its score within three years, it will not be considered financially responsible. Colleges scoring 0.9 or below are not considered financially responsible and must submit a letter of credit and be subject to additional oversight to get access to funds. A college can submit a letter of credit equal to 50% of all federal student aid funds received in the prior year and be deemed financially responsible, or it can submit a letter equal to 10% of all funds received and gain access to funds but still not be fully considered financially responsible.

As Goldie Blumenstyk (who knows more about the topic than any other journalist) and Joshua Hatch of The Chronicle of Higher Education discover in their snap analysis of the data, 158 private degree-granting colleges (108 nonprofit and 50 for-profit) failed to pass the test in 2012-13, down ten colleges from last year. Looking at all colleges eligible to receive federal financial aid, 192 failed outright in 2012-13 by scoring 0.9 or lower and an additional 128 faced additional oversight by scoring between 1.0 and 1.4.

But, as Blumenstyk and Hatch note in their piece, private colleges have repeatedly questioned how financial responsibility scores are determined and whether they are accurate measures of a college’s financial health. I’m working on an article examining whether and how colleges and other stakeholders respond to financial responsibility scores and therefore have a bunch of data at the ready to look at this topic.

Thanks to the help of my sharp research assistant Michelle Magno, I have a dataset of 270 private nonprofit colleges with financial responsibility scores and their Moody’s credit ratings in the 2010-11 academic year. (Colleges only have Moody’s ratings if they seek additional capital, which explains the smaller sample size and why few colleges with low financial responsibility scores are included.) The below scatterplot shows the relationship between Moody’s ratings and financial responsibility scores, with credit ratings observed between Caa and Aaa and financial responsibility scores observed between 1.3 and 3.0.

The correlation between the two measures of fiscal health was just 0.038, which is not significantly different from zero. Of the 57 colleges with the maximum financial responsibility score of 3.0, only three colleges (Northwestern, Stanford, and Swarthmore) had the highest possible credit rating of Aaa. Twenty-five colleges with financial responsibility scores of 3.0 had credit ratings of Baa, seven to nine grades lower than Aaa. On the other hand, six of the 15 colleges with Aaa credit ratings (including Harvard and Yale) had financial responsibility scores of 2.2, well below the maximum possible score.

This suggests that the federal government and private credit agencies measure colleges’ financial health in different ways—at least among colleges with the ability to access credit. Financial responsibility scores can certainly have the potential to affect how colleges structure their finances, but it is unclear whether they accurately reflect a college’s ability to operate going forward.