Examining Average Student Loan Balances by State

In a blog post last month, I used newly-available data from the U.S. Department of Education’s Office of Federal Student Aid to look at the amount of student loan dollars in income-driven repayment plans by amount of debt. In that post, I showed that students with more debt were far more likely to use IDR than students with less debt, with students having over $60,000 in debt being about twice as likely to use IDR as those with between $20,000 and $40,000 in debt.

In this post, I want to highlight some other new data that provides interesting insights into the federal student aid portfolio. I looked at state-level data (based on current residence, not where they went to college) that shows outstanding balances and the number of borrowers for both all Direct Loans (the vast majority of federal student loans at this point) and for those enrolled in income-driven plans. I then estimated the average loan value by dividing the two. The data are summarized in the table below.

 All Direct Loans  Loans in IDR plans
State  Balance ($bil) Borrowers (1000s)  Avg loan  Balance ($bil) Borrowers (1000s)  Avg loan
AL 15.9 522.2        30,400 5.4 100.0        54,000
AK 1.7 59.9        28,400 0.6 10.3        58,300
AZ 21.2 711.9        29,800 7.7 137.1        56,200
AR 8.5 312.9        27,200 3.0 62.0        48,400
CA 102.8 3307.3        31,100 36.7 600.2        61,100
CO 20.4 662.1        30,800 7.7 133.6        57,600
CT 12.1 414.6        29,200 3.4 59.6        57,000
DE 3.1 101.2        30,600 1.0 17.4        57,500
DC 5.0 102.2        48,900 2.4 25.7        93,400
FL 65.7 2063.1        31,800 26.4 473.1        55,800
GA 45.8 1350.2        33,900 16.6 279.2        59,500
HI 3.1 104.5        29,700 1.1 18.2        60,400
ID 5.3 191.7        27,600 2.1 41.6        50,500
IL 45.7 1439.7        31,700 14.9 247.9        60,100
IN 21.6 794.7        27,200 7.3 152.3        47,900
IA 10.4 405.8        25,600 3.3 67.8        48,700
KS 9.2 339.5        27,100 2.9 57.6        50,300
KY 13.8 507.1        27,200 4.9 102.6        47,800
LA 14.1 499.1        28,300 4.9 95.2        51,500
ME 4.4 158.8        27,700 1.5 30.0        50,000
MD 25.1 707.2        35,500 8.3 123.5        67,200
MA 23.1 783.7        29,500 7.0 114.3        61,200
MI 37.9 1262.4        30,000 13.2 243.4        54,200
MN 19.9 709.9        28,000 6.7 124.4        53,900
MS 10.6 360.7        29,400 3.8 75.2        50,500
MO 21.0 707.2        29,700 7.6 143.5        53,000
MT 3.0 106.5        28,200 1.2 23.1        51,900
NE 5.7 216.9        26,300 1.9 37.8        50,300
NV 7.5 262.9        28,500 2.8 51.6        54,300
NH 4.7 165.2        28,500 1.4 26.2        53,400
NJ 29.7 999.5        29,700 8.4 145.1        57,900
NM 5.3 189.3        28,000 2.1 39.7        52,900
NY 67.9 2113.1        32,100 24.0 387.8        61,900
NC 32.7 1065.5        30,700 11.8 213.6        55,200
ND 1.8 75.1        24,000 0.6 12.0        50,000
OH 45.4 1577.1        28,800 16.0 313.8        51,000
OK 10.3 383.0        26,900 3.6 71.5        50,300
OR 14.9 475.8        31,300 6.1 107.7        56,600
PA 46.1 1539.3        29,900 15.1 275.3        54,800
RI 3.3 119.6        27,600 1.0 18.8        53,200
SC 18.2 584.7        31,100 6.8 123.5        55,100
SD 2.6 98.9        26,300 0.9 17.9        50,300
TN 21.3 700.7        30,400 7.8 146.0        53,400
TX 76.5 2772.1        27,600 26.1 516.4        50,500
UT 6.9 256.8        26,900 2.7 47.3        57,100
VT 2.1 66.4        31,600 0.8 13.1        61,100
VA 29.9 913.8        32,700 10.1 166.0        60,800
WA 20.1 674.8        29,800 7.4 128.0        57,800
WV 5.4 200.3        27,000 1.8 37.0        48,600
WI 17.0 646.6        26,300 5.7 114.5        49,800
WY 1.2 45.3        26,500 0.4 8.0        50,000

Nationwide, the average outstanding Direct Loan balance was right at $30,000, with significant variation across states (ranging from $24,000 in North Dakota to $48,900 in Washington, DC). The average outstanding balance in IDR was $55,800, which suggests that many borrowers in IDR attended graduate school in order to accumulate that amount of debt. State-level average IDR balances ranged from $47,800 in Kentucky to an impressive $93,400 in Washington, DC. California, Hawaii, Illinois, Maryland, Massachusetts, New York, Vermont, and Virginia all had average balances over $60,000—and they are all high cost of living states with high percentages of adults obtaining graduate or professional degrees.

Once again, kudos to the Department of Education for slowly releasing more data on the federal student loan portfolio. But there are still quite a few important data points (such as school-level data or anything on PLUS loans) that still aren’t available to the public.

Who Uses Income-Driven Repayment Plans?

Over the last two years, the U.S. Department of Education’s Office of Federal Student Aid has quietly released additional data on the federal government’s portfolio of nearly $1.4 trillion in student loans. I was on the FSA website today looking up the most recent data on Public Service Loan Forgiveness employment certification forms (up to 740,000 filed as of September 30) for a paper I am currently drafting when a new set of spreadsheets on the income-driven repayment (IDR) programs caught my eye.

Overall, just over $375 billion of the $1.05 trillion in federal Direct Loans is now enrolled across the various types of IDR programs. (The rest of the federal loan portfolio is in the old FFEL program, which does not make new loans.) This is up from $269 billion of loans in IDRs when I last wrote about the topic on my blog in mid-2016, which has implications for both students and taxpayers alike. Here, I summarize some of the new data on the types of borrowers who use IDR, as well as some of the other data elements that would be helpful to have going forward.

It is not surprising that students with more debt are more interested in income-driven repayment plans, as many borrowers with less debt could manage payments under the standard ten-year repayment plan. But I was surprised by how much of the debt is held by a small percentage of borrowers. About 1.9 million of the 35.3 million borrowers (or five percent) have more than $100,000 in debt—and this is primarily due to graduate school attendance (since undergraduates cannot borrow more than $57,500 without resorting to PLUS loans). Yet these borrowers hold $325 billion in Direct Loans, or about 30% of all loans outstanding. About $173 billion of this amount is enrolled in IDR plans—53% of all debt held by those with six-figure debts. On the other hand, less than one-fourth of all debt of borrowers with less than $40,000 outstanding is enrolled in IDR. The table and figure below show the amount of Direct Loans outstanding and the amount enrolled in IDR by debt burden.

(UPDATE 2/1/18: As a commenter noted below, there is a small percentage of loans from the old FFEL program in income-driven repayment plans. But as far as I can tell from the data, this only slightly overstates the percentage of Direct Loans in IDR. I’m confident that the general trends still hold, though.)

Table 1: Direct Loan and IDR volumes by debt burden.
Amount of debt All Direct Loans ($bil) IDR ($bil) Pct of loans in IDR
Less than $5k 16.9 0.9 5.3%
$5k-$10k 45.6 4.0 8.8%
$10k-$20k 110.7 16.7 15.1%
$20k-$40k 220.6 52.9 24.0%
$40k-$60k 154.6 50.9 32.9%
$60k-$80k 110.5 48.2 43.6%
$80k-$100k 71.3 30.3 42.5%
$100k-$200k 191.7 90.5 47.2%
More than $200k 133.5 82.3 61.6%
Total 1055.4 376.7 35.7%

I also examined new FSA data on Direct Loan and IDR volumes by age (Table 2 below) and institution type (Table 3). The data show that younger borrowers (between ages 25 and 49) have a higher percentage of dollars in IDR than older borrowers and that students who attended private nonprofit and for-profit colleges rely on IDR more heavily than students who went to public colleges. The finding by sector matches general patterns in tuition and fees, but it does not suggest that for-profit college students disproportionately turn to IDR to manage their loan burdens.

Table 2: Direct Loan and IDR volumes by age of borrower.
Age All Direct Loans ($bil) IDR ($bil) Pct of loans in IDR
24 or younger 128 9.2 7.2%
25-34 418.3 177.4 42.4%
35-49 337.9 139.8 41.4%
50-61 140.5 39 27.8%
62 or older 30.6 11.3 36.9%
Total 1055.3 376.7 35.7%

 

Table 3: Direct Loan and IDR volumes by institutional type.
Sector All Direct Loans ($bil) IDR ($bil) Pct of loans in IDR
Public 464.2 143.3 30.9%
Private nonprofit 337 126.5 37.5%
For-profit 176.6 63.6 36.0%
Total 977.8 333.4 34.1%

There are two additional data elements that would be extremely useful in considering the implications of income-driven repayment plans. Ideally, data on IDR takeup would be available at the institutional level (as I have politely requested in the past). But at the very least, a breakdown by undergraduate/graduate student status would be useful information.

And one final request of any journalists or qualitative researchers who may be reading this blog—I would love to know more about how the PSLF approval process is going now that some borrowers have made the 120 monthly payments necessary to qualify for forgiveness. It’s been strange not to hear anything about that process after applications could be submitted as early as October 2017.

A Poor Way to Tie the Pell Grant to Performance

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

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

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

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

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

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

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

Is There Evidence of the Bennett Hypothesis in Legal Education?

“If anything, increases in financial aid in recent years have enabled colleges and universities blithely to raise their tuitions, confident that Federal loan subsidies would help cushion the increase…Federal student aid policies do not cause college price inflation, but there is little doubt that they help make it possible.”

In what year was the above quote first printed in The New York Times? Given concerns about college affordability and the ever-rising price tag of a college education, it’s reasonable to assume that the quote comes from the last few years. Yet this quote came from William Bennett (who was President Reagan’s Secretary of Education) way back in 1987. Bennett is now a conservative commentator and occasional advisor to the Trump administration, and his higher education views likely get traction in key federal policy circles.

Since 1987, what came to be known as the Bennett Hypothesis has been vigorously debated in the research and policy communities. As I detailed in two previous blog posts, the evidence to support the Bennett Hypothesis is generally modest among undergraduate students—with stronger evidence at private nonprofit and for-profit colleges than community colleges. However, prior research often looks at small changes in student loan borrowing limits or Pell Grant award amounts since there have been no large-scale changes in financial aid for undergraduate students over the past several decades.

Many graduate and professional students, on the other hand, saw a large increase in their federal student loan limits in 2006 (from $18,500 per year up to the full cost of attendance) due to the creation of the Grad PLUS loan program. This increase, which could be in the tens of thousands of dollars for students, provides a rare opportunity to test how colleges responded to a large change in potential federal revenue. This is particularly salient for students in master’s and professional degree programs, as institutional financial aid is far less common than in PhD programs.

Thanks to support from the AccessLex Institute and the Association for Institutional Research, I have spent much of the last year examining whether professional programs responded to the creation of the Grad PLUS program and the following expansion of income-driven repayment programs by increasing tuition and fees and/or living allowances. I also looked at whether student debt burdens of graduates increased. Today, I am releasing a SSRN working paper examining these questions for law schools, with additional analyses for business and medical schools to come at some point in the future.

In the seven months of tedious data compilation, coding, and cleaning that preceded any analyses (a big thanks to my sharp research assistants Joe Fresco and Olga Komissarova for their hard work!), I fully expected to find a great deal of evidence to support the Bennett Hypothesis due to the entrepreneurial nature of law schools and the sheer amount of federal student loan dollars that became available in 2006. Yet as the graphics below show, there was no immediate smoking gun in the descriptive data (focus on the red line at 2006).

But because graphics do not prove that there is (or is not) a relationship between federal student loan availability and law schools’ prices, I used two analytic strategies to try to draw causal inferences. I used an interrupted time series model that compared law schools before and after the 2006 implementation of Grad PLUS and a difference-in-differences model that looked at the difference between law schools and undergraduate institutions before and after 2006. Both of these models showed generally null or small positive coefficients, suggesting that law schools did not react by raising tuition prices or living allowances by massive amounts. (These findings generally match the conclusions from the literature at the undergraduate level, and are robust across a range of model specifications.) Below are the coefficients for tuition and fees, with the coefficients for living allowances and debt burdens available in the paper.

So why was there far less evidence for the Bennett Hypothesis than I expected to see? I offer three potential explanations.

Explanation 1: Law schools didn’t strategically increase prices in response to increased federal financial aid availability. Yes, law school tuition is expensive, and it’s certainly true that colleges have viewed law schools as potential revenue centers. But law schools may have thought that their price increases were already substantial enough to fund their operations.

Explanation 2: Any law school that increased tuition by more than their competitors may have seen a decline in applicants and/or revenue. This is somewhat similar to the classic prisoner’s dilemma in game theory, in which cooperating with other players (to raise prices) would result in a better solution than going alone. But to collude here would be price fixing—and illegal. Thus law schools stick to the norm of sizable (but not absurd) tuition increases.

Explanation 3: Students shifted from private loans to PLUS loans and thus already had access for loans up to the full cost of attendance. There is some evidence to support this logic, as 36% of law students took out private loans in 2003-04 compared to just 5% in 2011-12. Yet this would not hold for the majority of students who didn’t take out private loans.

I would love to get your comments on this working paper before it undergoes the formal peer review process in a few weeks (it’s already been informally reviewed). Send me your thoughts!

New Data on Long-Term Student Loan Default Rates

In recent years, more data have come out on how well students are able to manage repaying their loans beyond the three-year window currently used for federal accountability purposes (via cohort default rates). A great 2015 paper by Adam Looney and Constantine Yannelis used tax records merged with data from the National Student Loan Data System (NSLDS) to show longer-term trends in default in repayment. Two days later, the release of the College Scorecard provided college-level data on student loan repayment rates going out seven years (even though the repayment rates were initially calculated incorrectly).

Thanks to a lot of hard work by the data folks at the U.S. Department of Education and their contractor RTI, there are new data available on long-term student loan default rates. ED and RTI used NSLDS data going through 2015 to match records from the Beginning Postsecondary Students studies of cohorts beginning college in 1995-96 and 2003-04. This allowed a 20-year look at student loan default and payoff rates for the 1995-96 cohort and a 12-year look at the 2003-04 cohort, as detailed in this useful report from the National Center for Education Statistics.

Thanks to NCES’s wonderful PowerStats tool, I took a look at the percentage of students in the 2003-04 entering cohort (my college cohort) who had defaulted on at least one of their federal student loans within 12 years. Many of the news headlines focused on the high default rates of students at for-profit colleges (about 52%!), but this isn’t entirely a fair comparison because for-profit colleges tend to serve more economically-disadvantaged students. So in this post, I focused on racial/ethnic differences in default rates by type of college attended to give a flavor of what the data can do.

As the below chart shows, nearly half of all black students (49%) defaulted on at least one loan within 12 years—more than twice the rate of white students (20%) and more than four times the rate of Asian students (11%). The differentials are still present across sector, with more than one-third of black students defaulting across all sectors while a relatively small percentage of Asian students defaulted across all nonprofit sectors. Default rates at for-profit colleges are high for all racial/ethnic groups, with almost half of white students defaulting alongside nearly two-thirds of black students.

An advantage of the PowerStats tool is that it allows users to run regressions via NCES’s remote server. This allows interested people to analyze the relationship between long-term default rates and attending a for-profit college after controlling for other characteristics. However, PowerStats is overwhelmed by requests by my fellow higher education data nerds at this point, so I gave up on trying to run the regression after several hours of waiting. But if someone wants to run some regressions using the new loan repayment data in the BPS once the server calms down, I’m happy to feature their work on my blog!

Examining Trends in Student Loan Repayment Rates

It’s been a good week for higher education data nerds. The Department of Education released updated student loan cohort default rates on Wednesday afternoon (see my summary here), followed by an update to the massive College Scorecard dataset on Thursday morning. This is the third update to the Scorecard, with this year’s update also featuring a nice new comparison tool on the student-facing version of the site.

In this post, I focus on trends in student loan repayment rates (defined as the percentage of students who have repaid at least $1 in principal) at various periods entering loan repayment. I present data for colleges with unique six-digit Federal Student Aid OPEID numbers (to eliminate duplicate results), weighting the final estimates to reflect the total number of borrowers entering repayment. Additionally, I use the January 2017 data release for the 2012-13 Scorecard data because there appears to be an error in that year’s dataset that results in very few colleges having loan repayment rates.

I begin by show the trends in the 1-year, 3-year, 5-year, and 7-year repayment rates for each cohort of students with available data.

Repayment cohort 1-year rate (pct) 3-year rate (pct) 5-year rate (pct) 7-year rate (pct)
2006-07 61.8 63.5 64.6 66.6
2007-08 53.0 54.2 56.1 59.7
2008-09 46.1 47.9 52.0 56.0
2009-10 41.0 43.2 48.7 N/A
2010-11 36.6 40.7 46.3 N/A
2011-12 32.2 38.1 N/A N/A
2012-13 33.0 38.3 N/A N/A

There are two clear trends from this table. First, repayment rates have steadily dropped for more recent cohorts of students. The one-year repayment rate for students entering repayment in 2006-07 (before the Great Recession) was 61.8%, while the most recent cohort of students had a one-year repayment rate of just 33.0%. Much of this decline is likely due to the growth of income-driven repayment plans (which can allow students to be current on their payments while not making a dent in the overall principal). But economic circumstances also likely play a role here.

Second, repayment rates steadily rise for a given cohort as they have more time in the labor market after college. In the 2008-09 repayment cohort, the seven-year repayment rate was 56.0%, 9.9% higher than the one-year rate. These trends still suggest that it will be a long time before students repay their loans, but this is a step in the right direction.

I also show the distribution of colleges’ repayment rates for the 2008-09 cohort across all of the repayment periods by the type of college (public, private nonprofit, and for-profit). In general, private nonprofit colleges have higher repayment rates than both public and for-profit colleges (in part because private nonprofit colleges are primarily four-year institutions), but all sectors see slight improvements between the one-year and seven-year repayment rates.

Finally, a programming note: I’ll be getting the final page proofs for my book shortly and have to do final checks and put together an index during the month of October. I’ll try to write a couple of short blog posts when the new National Postsecondary Student Aid Study and full IPEDS Outcomes Measures survey come out; otherwise, stay tuned for some exciting new research that I’ll be unveiling in early November.

It’s Time to Move Beyond Cohort Default Rates

Today marked the annual release of data on cohort default rates—representing the percentage of students at a given college who default on their federal student loans within three years. The newest data show that 11.5% of students who entered repayment in Fiscal Year 2014 defaulted during this period, which is up slightly from 11.3% for those who entered repayment in Fiscal Year 2013.

Cohort default rates (CDRs) have been used for decades as an accountability metric by the federal government, with colleges posting CDRs of over 40% in a given year losing access to federal student loans for a two-year period and colleges with CDRs above 30% in three consecutive years losing access to all federal financial aid for two years. This year, six colleges posted default rates high enough to lose all Title IV aid and four more had default rates high enough to lose loan access.

Yet CDRs suffer from two key concerns that make them almost toothless from an accountability perspective—and show the need for better accountability metrics. I discuss the two key points in brief below (and if you like this topic, you’ll love my book on higher education accountability that will come out in January!).

Point 1: Default rates are an almost meaningless indicator of student outcomes. The availability of income-driven repayment programs means that no student should ever default on their obligations (although these programs are still clunky and some students simply don’t ever want to repay their loans). But for students who are able and willing to jump through the hoops of income-driven programs and have very low incomes, they can be current on their loans while making zero payments. Many colleges also adopt default management programs that can encourage students to either enroll in income-driven plans or to defer their obligations beyond the three-year accountability window.

In a recent article (a summary is available here), Amy Li of the University of Northern Colorado and I explored the relationship between default and repayment rates (as defined as paying down at least $1 in principal over a given period of time). We showed that although reported default rates stayed low, the percentage of students failing to repay any principal—a key question for taxpayers—was far higher.

Point 2: Default rate sanctions affect almost no colleges. Ben Miller of the Center for American Progress summed up how few colleges faced the loss of federal aid:

The all-or-nothing nature of potential sanctions gives colleges a tremendous incentive to make sure they aren’t affected. In 2014, the Obama Department of Education agreed to a controversial last-minute change to CDRs that allowed some colleges to sneak just below the 30% threshold. In 2017, a provision appeared in the FY 2018 budget that would effectively void CDR sanctions for colleges in economically distressed areas:

It turns out that Senator Mitch McConnell (R-KY) inserted the provision, likely to help out Southeast Kentucky Community and Technical College—one of the six institutions that is at risk of losing all federal financial aid due to high default rates. It pays to have friends in high places, I reckon.

So what can be done to improve federal accountability policies on student loans? I offer two simple ideas to start. First, move from default rates to repayment rates in order to get a better idea of students’ post-college circumstances. Second, move from an all-or-nothing sanction system to gradual sanctions. I go into both of these points in more depth in a paper I wrote in 2015 on the idea of “risk sharing” for student loans. It is essential to move away from CDRs as quickly as possible, even though some in higher education community may prefer the CDR system that affects relatively few colleges.

The Tangled Web of Student Debt Consolidation Companies

Like seemingly most American households, the Kelchens get far more junk in the mail than actual mail of value. We get about as many credit card applications as our shredder can handle, as well as folks trying to sell us a broad array of products and services. But letters that mention student loan debt and say “Final Notice” on them always get my attention, both as a researcher of higher education finance and as a proud part-owner of my wife’s law school debt.

The letter below came last week from a company called Direct Document Solutions out of Irvine, California. It says that we may be eligible to consolidate our existing federal student loan into a lower-interest federal loan—and that we may be eligible for loan forgiveness. While the fine print says that the company is fee-based and that they are not a part of the Department of Education, it’s in much smaller font than the rest of the letter.

After looking at this letter for a while, I realized that it looked vaguely like another student loan consolidation letter we had received several months prior. I dug through my Twitter media archives and found a nearly-identical letter (presented below) from last August from a company called Certified Document Center (which operates as Document Preparation Services at the same address as Direct Document Solutions). The Better Business Bureau gave the company a C rating, with 18 complaints in the last 12 months alone.

Just before I got the letter last week, NerdWallet put out a helpful list of about 130 companies that are less-than-ideal actors in the student debt consolidation business. To get on this list, companies needed to have faced significant complaints or have a D or F rating from the Better Business Bureau. So this means that Document Preparation Services sneaks over the bar and doesn’t make the list.

But in my research of this company, I discovered it was a part of the Association for Student Loan Relief—a group of 118 companies that specialize in student loan consolidation. A number of these companies show up on NerdWallet’s watch list. These companies tend to be clustered in certain areas—for example, nine are located in Irvine, California and quite a few are located in South Florida. This, along with the multiple aliases that several companies appear to have used, suggest the possibility that a number of these companies may be run by the same people or group of people.

People who are struggling to repay their federal loans (or are simply seeking a better deal) should probably start by talking with their current servicer or even reaching out to their former college’s financial aid office. If an income-driven repayment plan is the best choice, there is usually little need to involve a paid consolidation company. For students who are seeking a lower interest rate, there are legitimate companies (like Earnest and SoFi) and banks that will refinance student loans. Refinancing can be a great option for people who are certain that they won’t benefit from income-driven repayment plans and have fairly high incomes, but this is a decision that should be researched before making. Read reviews, look at BBB ratings (and the number of complaints), and be very skeptical when changing anything with your student loans.

No matter what you do, don’t put your student loans in the hands of some random company sending you “Final Notice” letters even though you have no relationship with them. That’s a great way to ruin your credit and empty your bank account.

Comments on the Trump Higher Education Budget Proposal

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

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

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

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

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

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

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

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

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

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

The Challenges Facing New York’s Tuition-Free College Program

Although tuition-free public college will not become a federal policy anytime soon, more states and local communities are considering different variations of free college. There are nearly 200 active college promise or free college programs in the United States, with two states (Arkansas and New York) enacting tuition-free programs in recent weeks.

New York’s Excelsior Scholarship program has garnered quite a bit of attention because it covers students at four-year colleges (most larger programs are limited to less-expensive two-year colleges), because of the conditions attached, and because New York governor Andrew Cuomo is likely to run for president in 2020. Yet the ambitious program (the legislation text starts on page 142 of this .pdf) also has to overcome a number of challenges in order to be truly effective. I discuss three of the key challenges with this program below.

Challenge 1: Will scholarship funds be available to all qualified students? The budget includes $163 million in funding for the program, which is probably far below the amount of money needed to fund all students. Judith Scott-Clayton of Teachers College estimated that an earlier version of the program could cost about $482 million per year. Even requirements that students complete 30 credits per year and clawbacks for students who leave the state after graduation (more on that later) may not bring the cost down enough—particularly if the program is successful in increasing enrollment at public colleges. The budget has a provision that allows awards to be cut or allocated via lottery if funds run short, which is a distinct possibility if the state faces another recession. Needless to say, this would be a PR nightmare for the state.

Challenge 2: Will colleges use fees as a tuition substitute? A full-tuition scholarship sounds great, but students and their families often forget about fees. Right now, fees are a sizable portion of direct educational prices. For example, at SUNY-Albany, tuition is $6,470 and fees are $2,793, while Hostos Community College charges $4,800 in tuition per year for a full-time student alongside $406 in fees. Since the scholarship only covers tuition, the state may pressure colleges to increase fees in an effort to reduce program costs. This happened in Massachusetts for years and still happens in Georgia, both states with large merit-based grant aid programs. Over time, it is quite possible that the value of the grant fails to keep up with inflation as a result—particularly if the state shifts funding from appropriations to student aid and colleges scramble for another revenue source.

Challenge 3: Will the state be able to manage a large “groan” program? Perhaps the most controversial portion of New York’s program is the requirement that students must live and work in the state after college for the same number of years that they received the grant; if they fail to do so, the grant converts to a loan (also known as a “groan” to financial aid wonks). Many people have raised concerns about the fairness of this idea, but here I’ll touch on the logistics of the program. Can the state of New York track students after graduation and see where they both live and work? Will they feel pressures to exempt students who live out of state but work in New York and pay state income taxes? What will the terms of the converted loans look like? There are a lot of unanswered questions here, but it is clear that the state must invest in a larger student loan agency in order to manage this complex of a program.

As Governor Cuomo prepares for a likely presidential bid in 2020, he is counting on the tuition-free college proposal to be one of his signature policy ideas. Some of the biggest concerns with this legislation may take years to develop, but even a period of two or three years may be enough to see whether the program can work effectively around some of the significant concerns noted here.