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.

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What New Gainful Employment and Borrower Defense Rules May Look Like

President Trump is fond of negotiating, as can be evidenced through his long business career and many promises to renegotiate a whole host of international agreements. Federal higher education policy is also fond of negotiation, thanks to a process called negotiated rulemaking that brings a range of stakeholders together for an arduous series of negotiations regarding key changes to federal policies. Notably, if stakeholders do not come to an agreement, the Department of Education can write its own rules—something that the Obama administration did on multiple occasions. (For more on the nitty-gritty of negotiated rulemaking, I highly recommend Rebecca Natow’s new book on the topic.)

In a long-expected announcement, the Department of Education announced Wednesday morning that it would be renegotiating two key higher education regulations (gainful employment and borrower defense to repayment) that were initially negotiated during the Obama administration, with the first meetings beginning next month. To get an idea of how expected these announcements were, here are the stock prices for Adtalem (DeVry) and Capella right after the announcement (which began to break around 11:30 AM ET). Note the fairly small movement in share prices, suggesting that changes were baked into stock prices pretty well.

It is extremely likely that the negotiated rulemaking committees won’t be able to come to an agreement (again), so the new rules will reflect the Trump administration’s higher education priorities. Here is my take on what the two rules might look like.

Gainful Employment

The Obama administration first announced its intention to tie federal financial aid eligibility for select vocational programs (disproportionately at for-profit colleges) in 2009 and entered negotiated rulemaking in 2009-10. The first rules, released in 2011, were struck down in 2012 due a lack of a “reasoned basis” for the criteria used. The second attempt entered negotiated rulemaking in 2013, survived legal challenges in 2015, and began to take effect with the first data release in early 2017. Nearly all of the programs that failed in the first year were at for-profit colleges, but this also led to Harvard shutting down a failing graduate theater program. No colleges have lost aid eligibility yet, as two failing years are required before a college is at risk of losing funds.

The Trump administration is likely to take one of three paths in changing gainful employment regulations:

Path 1: Expand the rules to cover everyone. One of the common critiques against the current regulations is that they only cover nondegree programs at nonprofit colleges in addition to nearly all programs at for-profit colleges. For example, doctoral programs in education at Capella University are covered by gainful employment, while my program at Seton Hall University is not. Requiring all programs to be covered by gainful employment would both preserve the goals of the original regulations while silencing some of the concerns. But this would face intense pressure from colleges that are not currently covered (particularly private nonprofits).

Path 2: Restrict the rules to cover only the most at-risk programs. It is possible that gainful employment metrics could be used along other risk factors (such as heightened cash monitoring status or high student loan default rates) to determine federal loan eligibility. If written a certain way, this would free nearly all programs from the rules without completely unwinding the regulations.

Path 3: Make the rates for informational purposes instead of accountability purposes. This is the most likely outcome in my view. The Trump administration can provide useful consumer information without tying federal funds (a difficult thing to actually do, anyway). In this case, I could see all programs being included since the data will be somewhat lower-stakes.

Borrower Defense to Repayment

Unlike gainful employment, borrower defense to repayment regulations were set to affect for-profit and nonprofit colleges relatively equally. Here is what I wrote back in October about the regulations when they were announced.

These wide-ranging regulations, which will take effect on July 1, 2017 (a summary is available here) allow individuals with student loans to get relief if there is a breach of contract or court decision affecting that college or if there is “a substantial misrepresentation by the school about the nature of the educational program, the nature of financial changes, or the employability of graduates.” The language regarding “substantial misrepresentation” could have the largest impact for both for-profit and nonprofit colleges, as students will have six years to bring lawsuits if loans are made after July 1, 2017.

These regulations have been halted and will not take effect until a new round of negotiated rulemaking takes place. They were generally unpopular among colleges, as evidenced by a strong lobbying effort from historically black colleges that were worried about the vague definition of “misrepresentation.” The outcome of this negotiated rulemaking session is likely to be a significant rollback of the scope to cover only the most egregious examples of fraud.

Although these two sets of negotiated rulemaking sessions are likely to mainly be for show due to the Department of Education’s final ability to write rules when the committee deadlocks, they will provide insight into how various portions of the higher education community view the federal role in accountability under the Trump administration. The Department of Education doesn’t livestream these meetings (a real shame), but I’ll be following along on Twitter with great interest. Pass the popcorn, please?

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Which States Search for FAFSA Information the Most?

In advance of this week’s National Spelling Bee finals, Google released data on the word that people located in each state searched “how to spell” on a regular basis. (Kudos to South Dakota for being so interested in how to spell “college!”) I used the Google Trends tool to search for how often people in each state searched for information on the FAFSA over the last five years and one year, as well as how often they searched for the “FASFA”—a pronunciation that is like fingernails on the chalkboard for many folks in higher education.

Between 2012 and 2016, interest in both the FAFSA (in blue) and the FASFA (in red) followed a pretty typical pattern, as shown in the first graph below. Searches picked up in frequency on January 1 (the first day to file for the new application year) before peaking around March 1 (when many state aid deadlines occur) and falling off dramatically in September. But in the 2016-17 application cycle (the second graph), searches spiked near October 1 (the new first date for filing the FAFSA) with a smaller peak around January 1 and an equal peak around March 1. This shows how the early FAFSA changes did reach students and their families.

Note: The “FAFSA” is in blue and the “FASFA” is in red.

I also looked at search intensity by state over the last year, with the most intense state receiving a value of 100. Mississippi had the highest intensity of FAFSA searches, while Oregon’s value of 42 was less than half of Mississippi’s value. Louisiana and Arkansas tied for the highest FASFA value (30), while Minnesota (7) had the lowest value. Looking at FAFSA-to-FASFA search ratios (a proxy for how commonly people searched for the wrong term), Louisiana had the lowest ratio of 3.07—indicating the highest frequency of incorrect searches. Meanwhile, Minnesotans were the least likely to type “FASFA” relative to “FAFSA,” with a ratio of 10.

FAFSA and FASFA search intensity, May 31, 2016 to May 31, 2017.

State FAFSA FASFA Ratio
Mississippi 100 28 3.57
Arkansas 95 30 3.17
Oklahoma 93 25 3.72
Louisiana 92 30 3.07
New Mexico 89 26 3.42
West Virginia 88 23 3.83
Idaho 87 18 4.83
Kentucky 87 23 3.78
Alabama 84 22 3.82
Tennessee 82 20 4.10
Indiana 80 22 3.64
Vermont 79 13 6.08
Maryland 79 18 4.39
Hawaii 78 9 8.67
South Dakota 78 14 5.57
Alaska 77 15 5.13
California 77 14 5.50
Wyoming 77 23 3.35
Utah 77 15 5.13
Montana 77 11 7.00
Arizona 76 18 4.22
Delaware 75 25 3.00
Rhode Island 74 18 4.11
Iowa 74 18 4.11
North Dakota 74 9 8.22
South Carolina 73 19 3.84
North Carolina 72 18 4.00
Virginia 72 15 4.80
Connecticut 72 16 4.50
Florida 72 18 4.00
Nebraska 72 13 5.54
Ohio 71 18 3.94
Missouri 71 20 3.55
Nevada 71 16 4.44
New Jersey 71 15 4.73
Maine 71 17 4.18
Pennsylvania 70 17 4.12
Minnesota 70 7 10.00
New Hampshire 68 15 4.53
Michigan 67 17 3.94
Washington 66 12 5.50
New York 66 15 4.40
Wisconsin 66 10 6.60
Georgia 65 18 3.61
Illinois 63 13 4.85
Massachusetts 60 12 5.00
Colorado 60 15 4.00
Texas 56 14 4.00
Kansas 54 14 3.86
District of Columbia 45 11 4.09
Oregon 42 8 5.25

Source: Google

Google search data can have the potential to provide some interesting insights about public perceptions and awareness of higher education, yet they have been used relatively infrequently. If there are any terms you would like me to dig into, let me know in the comments section!

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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.

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What Does a Professor Do During the Summer?

It’s safe to say that full-time faculty members at American colleges and universities have work schedules and expectations that are often not well understood by the general public. I often get two kinds of questions from people who are trying to figure out how I spend my time:

(1) You only teach two evenings per week. What do you do the rest of the time?

(2) You really have a three-month summer vacation? How do you fill up all of that free time?

I just finished my fourth year as an assistant professor at Seton Hall University, so right now I hear that second question quite a bit. In this post, I share some insights into what my summer looks like as a tenure-track faculty member at a university with substantial (but not extreme) research expectations. (And yes, I will take some time off this summer, as well.)

You don’t have a 12-month contract?

Like our colleagues in K-12 education, most faculty members are paid to work 9-10 months per year. This means that at least in theory, two or three months per year are completely ours. But although it’s common to say that the best three things about being a teacher are June, July, and August, faculty still have to do work outside the contract window in order to do their job well. My nine-month contract ended May 15, and there is absolutely no way I would meet the research or teaching expectations for tenure without using the summer as a way to get ahead. (Similarly, it’s hard for K-12 teachers to do course preps just within their contract period.) But service expectations grind to a halt during the summer, which does provide more time to do other work.

So what does your summer look like?

My biggest project this summer is to work on a paper looking at whether law, medical, and business schools responded to substantially increased Grad PLUS loan limits after 2006 by raising tuition or living allowances. (This is a new look at the Bennett Hypothesis—and I’ve summarized the existing research here.) I received a grant from the AccessLex Institute and the Association for Institutional Research to support this work, which provides me with a month and a half of additional salary and a grad student to help me with data work for 20 hours per week this summer as well as funds to buy out a course in the fall semester. This is my first successful external grant application after eight failed attempts, so it’s good to have some additional support for the summer.

My other important project on the research front is to put the finishing touches on my forthcoming book on higher education accountability, which should be out in early 2018 through Johns Hopkins University Press. I will spend several weeks working on copy editing, putting together an index, and checking page proofs. While I will get a portion of the book’s sales when it comes out, I can safely say that writing a book isn’t a great get-rich-quick scheme. (But journal articles rarely pay any money.)

I am in a fortunate position in which I can supplement my income as a faculty member with consulting or contract work. Each year since 2012, I have compiled Washington Monthly magazine’s college rankings, which comes with a small stipend along with the more important benefit of building connections with the higher education policy community. I also have the opportunity to write occasional policy briefs or white papers on a contract basis; different organizations ask me to explore a topic of interest to them while leaving me with complete editorial freedom to approach the topic as desired. Some of these turn into well-cited papers or articles, such as a paper I wrote at the request of the American Enterprise Institute in 2015 on the landscape of competency-based education.

While I will not teach any formal classes this summer, I will work with my group of dissertation students over the summer (as they pay tuition to work with me over the summer and I get a small stipend from the university). Based on some of the experiences I had in graduate school, I am getting my students together as a group six times over the course of the summer to share their progress and workshop draft chapters. The first meeting was yesterday, and it was a lot of fun. I will also work to update my higher education finance class for the fall semester, as quite a bit has changed since the last time I taught the class (the spring 2016 syllabus is here). I have a folder of 63 potential new readings to incorporate into the class, so it’ll take me a while to narrow this down to 20-30 articles to use in place of what was the state of the art in late 2015.

Academic summers are a wonderful thing—and the flexibility these summers offer are one of the reasons why many of us like this job so much. But even though we have a lot of flexibility about when we do the work, it still needs to get done. I hope this post provides some insights into what June, July, and August look like for at least a certain type of faculty member, and I’d love to hear what summers look like for other academics in the comments section below.

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A Look at Unmet Financial Need by Family Income

One of the perks of my job is that I get to talk with journalists around the country on a regular basis—it gives me the chance to keep up on what are the hot topics in the broader community as well as build connections with some wonderful people. I recently chatted with Jeff Selingo of The Washington Post for his latest column on whether college is affordable for middle-class families. My quote in the piece was, “They are getting squeezed on both ends because they barely miss Pell Grants and they are not the types of students getting grants from colleges themselves.”

Because I’m a data person at heart, I wanted to provide some supporting evidence for my claim. I used the most recent wave of the Beginning Postsecondary Students Longitudinal Study—a nationally representative study of first-time college students in the 2011-12 academic year—to look at financial need among new students at four-year colleges by family income quintile (for dependent students, who are mainly traditional-aged). The key column in the table below is unmet financial need, which is how much money students and their families have to come up with to cover the cost of attendance after grant aid and the expected family contribution (EFC)—a rough estimate of how much the government thinks families can contribute.

Quintile Unmet need EFC Total grants Parent income
Bottom $10,000 $0 $9,318 $13,150
Second $10,637 $557 $8,550 $34,238
Middle $9,912 $5,440 $5,550 $61,388
Fourth $4,820 $14,537 $2,750 $95,763
Top $0 $31,663 $2,000 $161,361

 

Source: NPSAS 2011-12.

Note: Values presented are medians and are only for dependent students attending four-year colleges.

The key point here is that families in the middle income quintile have to come with roughly the same amount of additional money beyond the EFC to pay for a year of college as families in the bottom two quintiles. Grant aid drops off substantially after the second quintile (where Pell eligibility starts to phase out), so middle-income families certainly do have reasons to be concerned about college affordability. Federal loans and PLUS or private loans can help to bridge the gap for students, but these figures do illustrate why student debt burdens (although relatively modest from a lifetime perspective) are a mounting concern for a larger percentage of undergraduate students.

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Which Factors Affect Student Loan Repayment and Default Rates?

As student loan debt has surpassed $1.25 trillion, policymakers and members of the public are increasingly concerned about whether students are able to manage rising (but often still modest) loan burdens. The federal government has relied on a measure called cohort default rates—the percentage of former borrowers who defaulted on their loans within a few years of entering repayment—to deny federal financial aid access to colleges with a high percentage of struggling students. Yet default rates can be easily manipulated using strategies such as deferment and forbearance (which often don’t help students in the long run), meaning that default rates are a very weak measure of students’ post-college outcomes.

The 2015 release of the College Scorecard dataset included a new measure—student loan repayment rates, defined as the percentage of borrowers repaying any principal within a certain period of entering repayment. This gets at whether students are paying down their loans, which seems to be a more helpful indicator than relying heavily on default rates. But since repayment rates are a new measure, colleges had no incentive to manipulate repayment rates as they did default rates. This creates a research opportunity to examine whether colleges may have been acting strategically to lower default rates even as their students’ underlying financial situations did not change.

I teamed up with Amy Li, an assistant professor at the University of Northern Colorado, to examine whether the factors affecting loan repayment rates differ from those factors affecting default rates—and whether the factors affecting repayment rates varied based on the number of years after the student entered repayment. Our article on this topic is now out in the ANNALS of the American Academy of Political and Social Science, with a pre-publication version available on my personal website.

We used default and repayment data on students who entered repayment in fiscal years 2006 and 2007 so we could track repayment rates over time. Default rates at the time covered the same time period as the one-year repayment rate, while we also looked at repayment rates three, five, and seven years after entering repayment. (And we had to scramble to redo our analyses this January, as the Department of Education announced a coding error in their repayment rate data in the last week of the Obama Administration that significantly lowered loan repayment rates. If my blog post on the error was particularly scathing, trying to revise this paper during the journal editing process was why!) We then used regressions to see which institutional-level factors were associated with both default and non-repayment rates.

Our key findings were the following:

(1) Being a traditionally underrepresented student was a stronger predictor of non-repayment than default. Higher percentages of first-generation, independent, first-generation, or African-American students were much more strongly associated with not repaying loans than defaulting after controlling for other factors. This suggests that students may be avoiding default (perhaps with some help from their former colleges), but they are struggling to pay down principal soon after leaving college.

(2) For-profit colleges had higher non-repayment rates than default rates. Being a for-profit college (compared to a public college) was associated with a 1.7 percent increase in default rates, yet an 8.5% increase in non-repayment. Given the pressure colleges face to keep default rates below the threshold needed to maintain federal loan eligibility—and the political pressures for-profit colleges have faced—this result strongly suggests that colleges are engaging in default management strategies.

(3) The factors affecting repayment rates changed relatively little in importance over time. Although there were some statistically significant differences in coefficients between one-year and seven-year repayment rates, the general story is that a higher percentage of underrepresented students was associated with higher levels of non-repayment across time.

As loan repayment rates (hopefully!) continue to be reported in the College Scorecard, it will be interesting to see whether colleges try to manipulate that measure by helping students close to repaying $1 in principal get over that threshold. If the factors affecting repayment rates significantly change for students who entered repayment after 2015, that is another powerful indicator that colleges try to look good on performance metrics. On the other hand, the growth of income-driven repayment systems that allow students to be current on their loans without repaying principal, could also change the relationships. In either case, as colleges adapt to a new accountability system, policymakers would be wise to consider additional metrics in order to get a better measure of a college’s true performance.

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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.

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The Importance of Negative Expected Family Contributions

The Free Application for Federal Student Aid (FAFSA) has received a great deal of attention in the past year. From a much-needed change that allowed students to file the FAFSA in October instead of January for the following academic year to the pulling of the IRS Data Retrieval Tool that made FAFSA filing easier for millions of students, the federal financial aid system has had its ups and downs. But one criticism that has been consistent for years is that the FAFSA remains an extremely blunt—and complex—financial aid allocation instrument.

After students fill out the FAFSA, they receive an expected family contribution (EFC), which determines their eligibility for federal and other types of financial aid. EFCs are currently truncated at zero for reporting purposes, which lumps together millions of students with various levels of (high) financial need into the zero EFC category. In a previous article, I showed that more than one-third of undergraduate students have a zero EFC and how that rate has generally increased over time.

Yet the underlying FAFSA data allows for negative EFCs to be calculated, and these negative EFCs can be used for two different purposes. First, they could be used to give additional Pell Grant aid to the neediest students; there have been several proposals in the past to allow EFCs to go down to -$750 in order to boost Pell Grants by up to $750. Second, the sheer number of students classified in the zero EFC category makes identifying the very neediest students difficult when there are insufficient funds to help all students from lower-income families. Reporting negative EFCs would at least allow colleges to help target their often-scarce resources in the best possible manner.

In my newest article (just published in the Journal of Student Financial Aid, which is open-access!), I used five years of student-level FAFSA data from nine colleges to show how calculating negative EFCs can help identify students with the greatest levels of financial need. The graphics below give a rough idea of what the distributions of negative EFCs could look like under various scenarios and current FAFSA filing situations. (I show dependent students here, but the same story is generally true for independent students.)

I also looked at how much it might cost the federal Pell Grant program to fund EFCs of -$750 by increasing maximum Pell Grants by an additional $750 for the neediest students. I estimated that funding negative EFCs would have increased Pell Grant expenditures by between $5 billion and $7 billion per year, depending on the specification. This is far from a trivial change for a program that spent about $31.5 billion in 2013-14, but it would roughly return Pell spending to its high point following the Great Recession. To save money, additional Pell funds could be given just to students with an automatic zero EFC—students with low family incomes who are already receiving some kind of means-tested benefit (such as free lunches in high school). That sort of limited expansion could be funded out of the current Pell surplus (assuming it doesn’t get used for other purposes, as is currently proposed).

Regardless of whether students get more money from the federal government under a negative EFC, it is a no-brainer for Congress and the Department of Education to work together to at least release the negative EFC number alongside the current number. That way, states, colleges, and private foundations can better target their funds to students with the absolute greatest need. Until the FAFSA is simplified, it makes sense to better use all of the information that is collected on students so everyone can make better decisions on allocating scarce resources.

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How Popular Was the IRS Data Retrieval Tool?

The financial aid application season for the 2017-18 academic year started out on a high note for current and prospective students. Thanks to the adoption of “prior prior year” or “early FAFSA,” students could file the FAFSA beginning October 1 instead of the following January 1 for the 2017-18 academic year. Students took advantage of this change in large numbers, with about 5.4 million students completing the FAFSA before the previous opening date of January 1.

But FAFSA filing hit a significant roadblock in early March when the federal government quietly pulled access to the IRS Data Retrieval Tool (DRT), which allowed students to quickly and seamlessly transfer their tax records from the IRS to the FAFSA. The tool was down for nearly a week before the IRS issued a statement explaining that the site had been taken offline due to security concerns—and now it looks like the Data Retrieval Tool will be down until next fall at the earliest. Students can still complete the FAFSA by inputting information from their 2015 tax returns, but this is an extra hurdle for many students to jump.

It is possible that the DRT outage is already affecting FAFSA filing rates. Nick Hillman of the University of Wisconsin-Madison (one of the best higher ed finance researchers out there) and his sharp grad students Valerie Crespin-Trujillo and Ellie Bruckner) have been tracking FAFSA filing trends among high school students since the start of this application cycle. Their latest look at filing trends (which they update every Friday) shows the following, which suggests a possible dip due to the DRT outage.

One question that hasn’t been addressed yet is how many students were actually using the DRT when it was pulled. Unlike the great data that Federal Student Aid makes available on FAFSA filing trends, far less data are available on DRT usage. But I was able to find two data points that provide some insights about how many FAFSA filers used the DRT. The first data point came from Federal Student Aid’s 2016 annual financial report, which listed the DRT as a priority for the department. As the highlighted text below shows, about half of all applicants who filed taxes used the DRT in the 2014-15 filing season.

A tidbit of more recent data comes from a presentation that Federal Student Aid made to a conference of financial aid professionals last fall. As shown below, 56% of the 2.2 million FAFSA filers in October 2016 used the DRT. Early FAFSA filers may have different characteristics than filers across the whole application cycle, but this again shows the popularity of the DRT.

Another important group of students use the Data Retrieval Tool—students who are enrolling in income-driven repayment plans. These students have to certify their income on an annual basis (and a majority of borrowers already struggle to do this on time), which becomes more time-consuming without the DRT. It’s still possible for students to do by submitting documentation of income, but the loss of the DRT makes that a lengthier process. I was unable to find any information about DRT usage among people in income-driven repayment programs, but my gut instinct is that it’s a fairly high percentage of borrowers.

The bottom line here—the lengthy outage of the IRS Data Retrieval Tool doesn’t mean that students can’t apply for federal financial aid or income-driven student loan repayment programs. But it does create an additional roadblock for millions of students, their families, and financial aid offices to navigate. Only time will tell whether the DRT outage is associated with lower FAFSA or income-driven repayment filing rates, but a small negative effect seems plausible.

Thanks to Carlo Salerno of Strada Education for inspiring me to dig into the numbers. Twitter conversations can be useful, after all!

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