Why is it So Difficult to Sanction Colleges for Poor Performance?

The U.S. Department of Education has the ability to sanction colleges for poor performance in several ways. A few weeks ago, I wrote about ED’s most recent release of financial responsibility scores, which require colleges deemed financially unstable to post a bond with the federal government before receiving financial aid dollars. ED can also strip a college’s federal financial aid eligibility if too high of a percentage of students default on their federal loans, if data are not provided on key measures such as graduation rates, or if laws such as Title IX (prohibiting discrimination based on sex) are not followed.

The Department of Education can also sanction colleges by placing them on Heightened Cash Monitoring (HCM), requiring additional documentation and a hold on funds before student financial aid dollars are released. Corinthian Colleges, which partially collapsed last summer, blames suddenly imposed HCM requirements for its collapse as they were left short on cash. Notably, ED has the authority to determine which colleges should face HCM without relying upon a fixed and transparent formula.

In spite of the power of the HCM designation, ED has previously refused to release a list of which colleges are subject to HCM. The outstanding Michael Stratford at Inside Higher Ed tried to get the list for nearly a year through a Freedom of Information Act request (which was mainly denied due to concerns about hurting colleges’ market positions), finally making this dispute public in an article last week. This sunlight proved to be a powerful disinfectant, as ED relinquished late Friday and will publish a list of the names this week.

The concerns about releasing HCM scores is but one of many difficulties the Department of Education has had in sanctioning colleges for poor performance across different dimensions. Last fall, the cohort default rate measures were tweaked at the last minute, which had the effect of allowing more colleges to pass and retain access to federal aid. Financial responsibility scores have been challenged over concerns that ED’s calculations are incorrect. Gainful employment metrics are still tied up in court, and tying any federal aid dollars to college ratings appears to have no chance of passing Congress at this point. Notably, these sanctions are rarely due to direct concerns about academics, as academic matters are left to accreditors.

Why is it so difficult to sanction poorly-performing colleges, and why is the Department of Education so hesitant to release performance data? I suggest three reasons below, and I would love to hear your thoughts in the comments section.

(1) The first reason is the classic political science axiom of concentrated benefits (to colleges) and diffuse costs (to students and the general public). Since there is a college in every Congressional district (Andrew Kelly at AEI shows the median district had 11 colleges in 2011-12), colleges and their professional associations can put forth a fight whenever they feel threatened.

(2) Some of these accountability measures are either all-or-nothing in nature (such as default rates) or incredibly costly for financially struggling colleges (HCM or posting a letter of credit for a low financial responsibility score). More nuanced systems with a sliding scale might make some sanctions possible, and this is a possible reform under Higher Education Act reauthorization.

(3) The complex relationship between accrediting bodies and the Department of Education leaves ED unable to directly sanction colleges for poor academic performance. A 2014 GAO report suggested accrediting bodies also focus more on finances than academics and called for a greater federal role in accreditation, something that will not sit well with colleges.

I look forward to seeing the list of colleges facing Heightened Cash Monitoring be released later this week (please, not Friday afternoon!) and will share my thoughts on the list in a future piece.

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The 2015 Net Price Madness Bracket

Every year, I take the 68 teams in the 2015 NCAA Division I men’s basketball tournament and fill out a bracket based on colleges with the lowest net price of attendance (defined as the total cost of attendance less all grant aid received). My 2014 and 2013 brackets are preserved for posterity, with Louisiana-Lafayette and North Carolina A&T emerging victorious for having the lowest net price without having won a single game.

In 2015, the final four teams standing (based on net price) are:

MIDWEST REGION: Wichita State [WINNER] (net price of $9,039*, 46% graduation rate, 36% Pell)

WEST REGION: North Carolina (net price of $11,994, 90% graduation rate, 21% Pell)

[An earlier version of this post incorrectly had BYU beating North Carolina. My apologies for that error, which has been corrected.]

EAST REGION: Wyoming (net price of $11,484, 54% graduation rate, 24% Pell)

SOUTH REGION: San Diego State (net price of $9,856, 66% graduation rate, 40% Pell)

netprice

All data for the bracket can be found here.

*NOTE: Wichita State has a reported net price of $9,039, but the net prices for each household income bracket are higher than $9,039. Something isn’t right here, but what would March Madness be without any controversy?

Indiana deserves special plaudits for having a net price for the lowest-income students of just $4,632—although the 19% Pell enrollment rate is quite low.

Also, thanks to Andy Saultz for catching an error in the VCU/Ohio State game. Much appreciated!

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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.

credit_rating

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.

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Why ASAP Could Harm Some Students

The City University of New York’s Accelerated Study in Associate Programs (ASAP) has gotten a great deal of positive attention in the last few years, and for good reason. The program provides much-needed additional economic, advising, and social supports to community college students from low-income families, and a new evaluation of a randomized trial from MDRC found that ASAP increased three-year associate’s degree completion rates from 22% in the control group to 40% in the treatment group. I’m glad to see that the program will be expanded to three community colleges in Ohio, as this will help address concerns about the feasibility of scaling up the program to cover more students.

But it is important to recognize that ASAP, as currently constituted, is limited to students who are able and willing to attend college full-time. Full-time students are the minority at community colleges, and full-time students tend to be more economically and socially advantaged than their part-time peers. As currently constructed, ASAP would direct a higher percentage of resources to full-time students, even though part-time students likely need support more than full-time students. (However, it’s worth noting that although part-time students count in some states’ performance-based funding systems, they are currently not counted in federal graduation rate metrics.)

Students in ASAP also get priority registration privileges, which can certainly contribute to on-time degree completion. But it is not uncommon for classes (at least at desirable times) to have waiting lists, meaning that ASAP students get access to courses while other students do not. If a part-time student cannot get access to a course that he or she needs, it could mean that the student is forced to stop out of college for a semester—a substantial risk factor for degree completion.

ASAP has many promising aspects, but further study is needed to see if the degree completion gains for full-time students are coming at the expense of part-time students. Some of the ASAP services should be extended to all students, and priority registration should be reconsidered to benefit students who are truly in need to getting into a course instead of those who are able to attend full-time.

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Why I’m Conflicted About College Athletics

As a college professor doing research in higher education finance and accountability policy, there are many times when my enjoyment of college athletics leaves me conflicted. I enjoy watching my beloved Wisconsin Badgers get the best of (most of) their Big Ten opponents on a regular basis, but I also recognize that at all but the few dozen wealthiest universities, college athletics are heavily subsidized by student fees. (Answering whether athletics programs are actually profitable is very difficult due to concerns with cost allocations, assumptions about whether students are induced to attend because of athletics, and how revenue is disbursed.)

In the past year, colleges in the “Power Five” athletic conferences (Big Ten, Big 12, Atlantic Coast, Pacific-12, and Southeastern Conferences) gained additional autonomy from the rest of the NCAA. They then voted to increase athletic scholarships by $2,000-$4,000 per year per athlete to cover the full cost of attendance, which is definitely a good thing for those athletes. Other Division I colleges can choose to also increase scholarships, but not without significant budgetary implications. For a college with 250 scholarship athletes (not an unrealistic number for a college with football), the cost could approach one million dollars per year. My concern is that those increases are likely to be funded out of the pockets of students and/or by cutting non-revenue sports like wrestling and track and field.

Other things that college athletic programs do are unambiguously bad for athletes. A recent example of this is with national letters of intent, which bind athletes to a college at the end of the recruiting process. Earlier this month, prized linebacker recruit Roquan Smith made news by accepting a football scholarship from the University of Georgia (switching from UCLA) without signing the letter of intent. Once a letter is signed, a student cannot transfer without losing eligibility unless the college decides to let the student out. In the meantime, coaches often leave for other jobs without facing any employment restrictions.

As a professor, I also worry about the increased number of televised weeknight games long distances from campus that cause athletes difficulties attending class. It’s great to get exposure for your college on national television (and get serious television dollars), but this places a burden on athletes and faculty who work with those students. But if I’m not teaching one evening and a good game is on, will I watch it? Quite possibly. Should I? No.

I’m curious to get readers’ thoughts about how they manage the pros and cons of big-time college athletics. Even when the game is going on, I can’t help think about the students and the dollar signs behind them.

[NOTE: A previous version of the post incorrectly noted that Mr. Smith was intending to enroll at UCLA instead of the University of Georgia. Thanks to Ed Kilgore for pointing out this error.]

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The FY 2016 Obama Budget: A Few Surprises

The Obama Administration released their $3.999 trillion budget proposal for Fiscal Year 2016, and the higher education portion of the budget was largely as expected. Some proposals, such as increasing research funding, providing a bonus pool of funds for colleges with high graduation rates, and reallocating the Supplemental Educational Opportunity Grant to be based on current financial need instead of an antiquated formula, were repeats from previous years. Others, such as the idea of tuition-free community college, had already been sketched out. And one controversial proposal—the plan to tax new 529 college savings plans—had already been nixed, but remained in the budget document due to a “printing deadline.”

But the budget proposal (the vast majority of which is dead on arrival in a GOP Congress thanks to differences in viewpoints and preferred budget levels) did have some surprising details. The three most interesting higher education-related details are below.

(1) “Universal” free community college isn’t exactly universal. Pages 59 and 60 of the education budget proposal noted that students with a family Adjusted Gross Income of over $200,000 would be ineligible for tuition-free community college. Although this detail was apparently decided before the program was announced, the Obama Administration for some reason chose to hide that detail from the public until Monday. As the picture shows below, only 2.7% of dependent community college students had family incomes above $200,000 in 2011-12 (data from the National Postsecondary Student Aid Study).

income

But in order to get family income, students have to file the FAFSA. Research by Lyle McKinney and Heather Novak suggests that 42% of low-income community college students didn’t file the FAFSA in 2007-08, meaning that something big needs to be done to get these students to file. Requiring the FAFSA also means that noncitizens typically would not qualify for free community college, something that is likely to upset advocates for “dreamer” students (but make many on the Right happy).

Additionally, as Susan Dynarski at the University of Michigan pointed out, the GPA requirements (a 2.5 instead of a 2.0) make a big difference. In 2011-12, 15.9% of Pell recipients had GPAs between a 2.0 and 2.49, meaning they would not qualify for free community college.

gpa

 

(2) Asset questions may be off the FAFSA. The budget document called for the following changes to the FAFSA, including the elimination of assets (thanks to Ben Miller at New America for the screenshot):

fafsa

 

Getting rid of assets won’t affect most families, as research by Susan Dynarski and Judith Scott-Clayton shows. But it does matter more to selective colleges, more of which might turn to additional financial aid forms like the CSS/PROFILE to get the information they want. Policymakers should take the benefits of FAFSA simplicity as well as the potential costs to students of additional forms into account.

(3) Mum’s the word on college ratings. After last year’s budget featured $10 million for the development of the Postsecondary Institution Ratings System (PIRS), this year’s budget had no mention. Inside Higher Ed reported that ratings will be developed using existing funds and using existing personnel. Will that slow down the development of ratings? Given the slow progress at this point, it’s hard to argue otherwise.

Finally, the budget document also contained details about the “true” default rate for student loans, using the life of the loan instead of the 3-year default window used for accountability purposes. The results aren’t pretty for undergraduate students, with default rates pushing 23% on undergraduate Stafford loans. But default rates for graduate loans hover around 6%-7%, which is roughly the interest rates many of these students face.

default

 

What are your thoughts on the President’s budget proposal for higher education? Please share them in the comments section.

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What Should Count as “Financial Aid?”

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

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

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

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

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

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

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

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

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How Many Students Pay Full Price at Private Colleges?

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

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

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

 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Pros:

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

Cons

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

Mixed or unclear

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

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

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