Not long ago, one of the authors of a recent Inside Higher Ed Views article, “Aid for Students, Not for Banks,” proposed the creation of “State/Federal Partnerships for College Access and Completion Rates,” arguing that there are “too few programs addressing” these issues.
If the Obama administration’s budget proposal to eliminate the Federal Family Education Loan Program succeeds, there’ll be even fewer. That the author of is unaware of the extraordinary work done by guaranty agencies and lenders in the areas of college awareness and access speaks volumes of the quality of the debate around the administration’s proposal – and the need for more careful examination.
Clearly, battle lines have been drawn. Advocates for the proposal have quite effectively stoked populist rage against the organizations that make and service student loans. But just as any fair-minded person should be wary of claims that are “too good to be true,” they should be equally wary of charges that are “too bad to be true.” It should count for something that the picture being painted is unrecognizable to the overwhelming majority of the nation’s financial aid administrators and student loan borrowers.
Finally, does anyone seriously think the lives of borrowers will improve with the government not only becoming the (only) banker, but also needing to make large profits on loans in order to fund the proposed Pell Grant expansion?
As Congress moves forward with abbreviated consideration of the proposal under budget reconciliation, the student loan community implores policymakers to weigh two questions:
Are the projected cost savings from eliminating FFELP real? The short answer is No.
The Office of Management and Budget claims that the proposal will save $46 billion over 10 years; the Congressional Budget Office, $94 billion.
That the government’s budget agencies produced such divergent estimates ought to be reason enough for healthy skepticism.
But real grounds for skepticism exist. This year OMB revised its cost estimate of about 10 years' worth of FFELP loans. It said it was $18 billion too high. Since 2004 FFELP’s costs have been chopped by $23 billion.
Did the Direct Loan program get cheaper? Nope. OMB has revised its cost estimates upward by $12 billion. That amounts to a $30 billion swing.
In other words, the cost savings projected could very well vanish. Congress could wind up eliminating the more cost effective program.
Finally, the government’s cost estimates are problematic in other ways. For example, the department’s growing costs for administering direct loans would not be counted. These and other flaws have been well documented by the CBO, OMB, Congressional Research Service, and PricewaterhouseCoopers, among others.
Healthy skepticism is warranted for another reason. “Subsidy costs are estimates about an uncertain future and could be manipulated,” a 2004 OMB memo explained. “There is pressure on occasion to manipulate the estimates.”
Apart from whether the savings are real is what they actually represent: The government profiting on its low, low borrowing costs (close to 0 percent), while the borrower rate is as high as 6.8 percent.
The second question that should be weighed is, “Are there elements of today’s FFELP that are worth preserving?”
One of its greatest strengths is its accessibility: wherever Americans with dreams of going to college live, whether it’s on the plains of Nebraska, in the mountains of West Virginia or on the bayous of Louisiana, there’s almost always a nearby lender, bank or credit union that makes federal student loans.
And, almost always, the guaranty agency that serves the community sponsors college nights and other college awareness programs, as well as financial aid workshops. These programs have helped countless numbers of low-income and first-generation college students.
Another strength is the program’s default prevention activities, which have given FFELP lower lifetime default rates. Beyond the numbers is the personal aspect: the thousands of men and women who work for guaranty agencies really care about doing a good job -- and that job is to help borrowers manage repayment and avoid default.
A third strength is the program’s continuous innovation. Lenders have invested millions of dollars in developing more convenient processes, such as eSignature, and improving customer service. Consider this: almost every major processes and convenience used by the Direct Loan program was invented by FFELP’s private sector participants.
Finally, FFELP has to be one of the government’s most small “d” democratic programs. Not only do schools get to choose which program to participate in, students get to choose their lenders. With respect to schools, they’ve always preferred FFELP by overwhelming majorities – even today after years of budget cuts and during the current credit crisis.
The administration’s proposal is not a win-win for college access. There will be losers. College awareness and default prevention services will vanish. It will cost jobs and eliminate choice and competition. It will add a trillion dollars to the national debt within a dozen years.
This is no ordinary “budget” proposal. It will affect the “going to college” process for families for years to come. Even though it’s on a legislative fast track, it’s not too late for Congress to slow this train down. As is being done with health reform, all the stakeholders should be convened to explore ways to preserve the best of the current system and build a better one for the future.
An overwhelming consensus has been developing that the Federal Family Education Loan (FFEL) Program should be ended, and all federal student loans should be made through the Direct Loan Program, where students borrow directly from the federal government. The main justification for this is that direct lending costs less than FFEL, where students borrow money from private financial organizations, typically with some federal subsidy. Proponents cite new figures indicating that the government stands to make a lot of money on the switch, money that will be used to fund more Pell grants.
As someone who likes the idea of bigger Pell grants, and thinks that the FFEL subsidies are a waste of taxpayer money, I can certainly appreciate the goals of these proponents.
But a closer look at their argument leaves me quite worried. Advocates are pointing to a figure of $94 billion that could be saved. This number is derived from the subsidy rate calculations of the loan programs produced by the Congressional Budget Office (CBO) through a process known as “scoring.” Proponents are using the CBO figures to argue that shutting down FFEL will save massive amounts of money -- a strange argument given that a former head of the CBO has explicitly warned against drawing such conclusions.
The warning appeared in "Budget-Scoring Barriers to Efficient Student Loan Policy," a paper prepared for and presumably financed by groups of lenders. The author was Douglas Holtz-Eakin, the former head of the CBO. The paper describes the reasons why the CBO subsidy rate calculations are not sufficient for making policy decisions. Such decisions should be based on a cost-benefit analysis. Though no fault of its own, the CBO has a good handle on neither of the required totals.
To begin with, the CBO does not even look at the benefits of the programs. Advocates are assuming that both programs have the exact same benefits, which is highly questionable, given what Holtz-Eakin terms “a plethora of anecdotal evidence that private sector lenders offer a portfolio of un-priced borrower benefits (fee waivers, rate reductions, etc.), credit counseling, expedited delivery, superior information technology, college access in initiatives and other enhancements and programs not offered by the [DL], but not easily quantified.” It is also possible that DL provides greater benefits. The point is that we should not assume both programs have the same benefits.
Moreover, the CBO does not look at all the relevant costs. As Holtz-Eakin summarizes, the CBO figures do “not capture the economic cost of the loan programs. This is not a secret. The [CBO] itself has acknowledged the fact” in a 2005 report stating that “the subsidy calculations … are not designed to fully capture the economic costs to the government … nor do they capture all of the effects of the programs on federal spending and revenues.”
The CBO provides some of the most authoritative, objective and accurate estimates on a wide range of budgetary issues. Thus, if you are going to take issue with their numbers, you had better have a good reason. While I am not qualified to offer a detailed critique, as the former head of the organization, Holtz-Eakin is, and he’s offered a number of reasons to doubt the usefulness of the estimates.
As he explains, these programs are required to be scored according to the Federal Credit Reform Act (FCRA). But the fact of the matter is that DL and FFEL “do not receive equal treatment under federal budget scoring rules.” While the switch to FCRA removed a bias in favor of FFEL, it instituted one in favor of DL. A few of these differences in treatment that lead to bias are explored below.
To begin with, there are risks that are not accounted for by budgetary scoring. The two big ones are interest rate risk (the uncertainty about what rate the government can borrow at) and market risk. Market risk is a broad category that accounts for uncertainty due to fluctuations of the economy. For instance, will the recession push up default rates? While these are real risks with real costs, those costs are “not captured by federal scorekeepers.” This puts FFEL at a disadvantage since they face the cost of insuring or hedging against these risks, while for DL, these risks and costs are simply ignored.
Then there is the risk of programmatic failure (DL had to shut down in 1997, and without FFEL to fall back on, students would have incurred substantial hardship) and indirect taxes (FFEL lenders pay significant corporate income taxes), neither of which is reflected in the budgetary scoring.
The differences that have been getting the most attention are administrative and guarantee costs. These costs were generally not included in the scoring, but some estimates by the OMB and CBO indicate that these costs for FFEL are higher than previously thought. What doesn’t seem to get mentioned is that while taking these costs into account is appropriate, this is a relatively minor source of difference in program cost.
Most importantly, according to an earlier CBO report, the key way in which the programs are treated differently is that for the DL program, “principal and interest payments are discounted at a different, and generally lower, rate than the borrower pays. The result is a net budgetary gain to the federal government that does not exist in the FFEL program.” This gain reflects the fact that the government expects to borrow the money for DL at low rates (0.76 percent in 2010) and charge students 6.8 percent.
This substantial gain would be reported for any program that borrows at the Treasury rate, and lends at a higher one. But that doesn’t mean it’s a good idea. To understand why, note that the exact same logic -- that the government can borrow more cheaply than it lends -- could be used to argue that the government should take over all lending in any market.
Consider an analogy to mortgage lending. Just as with FFEL, there are private lenders that have received subsidies from the government (we’ve already provided Fannie Mae and Freddie Mac $200 billion, and are on the hook for losses on their $5.2 trillion combined portfolio). By the logic of the pro-DL advocates, this subsidization is much more expensive than if the government provided the mortgages in the first place, so why not have the government take over all mortgage lending? I don’t know of anyone who thinks the government should be the only provider of mortgages, but there seem to be quite a few who think such a policy is a good idea for student loans.
In spite of these concerns about the relevance of the CBO figures in comparing the costs of these programs, advocates of switching to DL continue to rely on them. If this is how policy is to be made, then perhaps we haven’t quite put faith based initiatives behind us after all. In the words of former CBO director Holtz-Eakin, “When the budgeted cost of a federal program fails to reflect its actual economic cost, policy decisions regarding that program are likely to be skewed. The federal student loan programs provide a case study.”
Andrew Gillen is the research director of the Center for College Affordability and Productivity.
In February 2009, at a meeting of the American Council on Education, I challenged a group of university presidents and other leaders of higher education to focus on the need for greater innovation in higher education. I encouraged those leaders to heed the lesson offered by George Romney to the auto industry in the 1970s to innovate or lose their advantage: “There is nothing more vulnerable than entrenched success,” he said. I followed up in October 2009 with an article in Newsweek entitled "The Three-Year Solution: How the reinvention of higher education benefits parents, students, and schools."
The response has been pleasantly surprising.
Over the past year and a half, a growing number of institutions of higher education came forward with proposals to offer three-year degrees to their students. Here are a few examples:
Grace College, in Winona Lake, Ind., is offering an accelerated three-year degree in each of its 50-plus major areas of study. Dr. Ronald Manahan, Grace's president, cites the cost of college as a driving force behind the decision. “We have listened to people’s concerns about [the cost of] higher education and we are answering them,” he said.
Chatham University, in Pittsburgh, Pa., is offering a three-year bachelor of interior architecture without summer classes, allowing students to get into the job market a year earlier. School officials have reconfigured the four-year degree by cutting Studio classes from 14 weeks to just seven, and when compared to similar programs, these students graduate two years earlier.
Texas Tech University, in Lubbock, Tex., is offering an accelerated three-year medical degree, rather than the usual four. The program is aimed at making it easier and more affordable for students to become family doctors.
As institutions of higher education look into the possibility of offering a three-year degree, some have run into federal policies that seem to interfere with their ability to innovate. For example, this May I received a letter from Jimmy Cheek, chancellor of the University of Tennessee-Knoxville, describing a potential obstacle to a three-year degree surrounding student loans.
Here’s the issue: Under the Higher Education Act, student loan limits are tightly set to prevent over-borrowing by students. Federal annual loan limits and lifetime loan limits establish a maximum amount one can borrow under the federal student loan program. The annual loan limits are designed to pay for two semesters per year (see chart below).
Example: Scheduled Academic Year
Scheduled Academic Year 1
Fall 2010 and Spring 2011
Scheduled Academic Year 2
Fall 2011 and Spring 2012
Scheduled Academic Year 3
Fall 2012 and Spring 2013
Scheduled Academic Year 4
Fall 2013 and Spring 2014
For most institutions of higher education, and most students, this works and makes sense. But 3-year degree students often take a third semester’s worth of classes over the summer. The federal limits appear to prevent students from obtaining a loan to pay for those summer courses.
Fortunately, there is a solution. Working with the Congressional Research Service, and the staff of the U.S. Department of Education, my office has identified an option that exists under current regulations to give flexibility on these loan limits to institutions of higher education and students. Instead of following a standard “Scheduled Academic Year” as outlined above, an institution of higher education offering a three-year degree could award loans to students through a “Borrower-Based Academic Year," per the chart below:
Example: Borrower-Based Academic Year
Scheduled Academic Year 1
Fall 2010 and Spring 2011
Scheduled Academic Year 2
Summer 2011 and Fall 2011
Scheduled Academic Year 3
Spring 2012 and Summer 2012
Scheduled Academic Year 4
Fall 2012 and Spring 2013
This option would use the same annual loan limits and lifetime loan limits, but compress them to match the student’s academic schedule. Compared to the typical “Fall-Spring” academic year over each of the four years, a three-year degree program could use a “Fall-Spring, Summer-Fall, Spring-Summer” structure to allow for a compressed academic schedule.
I have been told that this “Borrower-Based Academic Year” option is currently not well used because it is administratively complicated for institutions to offer both “Scheduled Academic Year” and “Borrower-Based Academic Year” loan structures at the same time for individual students. But for an institution that offers a comprehensive three-year degree program involving a number of students, this seems to make sense as a way of helping students in that program afford the tuition and fees.
I have asked Chancellor Cheek to let me know if this option would work for the University of Tennessee, or if more flexibility needs to be added. When Congress last reauthorized the Higher Education Act in 2008, we made several changes to the Pell Grant program to allow that funding to be used on a year-round basis. There is no reason students should not have that same flexibility with their student loans.
It is my hope that more institutions will explore innovative ways to provide a high-quality postsecondary education. The three-year degree is one idea for some well-prepared students, but it is vital to our competitiveness as a nation that we develop other ideas to improve the efficiency of higher education and expand access to more Americans.
Institutions of higher education are rightly feeling pressure from parents, students, state and local leaders, the business community, Congress, and the Obama administration to do a better job of providing more Americans with a quality college education at an affordable price. That pressure will likely grow more intense every year as more jobs require higher education, advanced certificates, or technological skills from their applicants.
Some have asked whether all colleges and universities should be required to offer a three-year degree. My answer is a resounding no. Just as the hybrid car isn’t for everyone, all students and all institutions won’t want a three-year degree. The last thing we need is more federal mandates on higher education.
The strength of our higher education system is that we have 6,000 independent, autonomous institutions that compete in the marketplace for students. It is that marketplace that needs to develop the new ideas for the future -- and not become a victim of its own “entrenched success" -- so that our students, and our country, can continue to thrive.
Senator Lamar Alexander
Sen. Lamar Alexander (R-Tenn.) is chairman of the Senate Republican Conference and a member of the Senate Committee on Health, Education, Labor and Pensions. He served as U.S. secretary of education under President George H.W. Bush and as president of the University of Tennessee.
The Education Department's proposal to start charging a variable interest rate instead of a fixed, low rate to borrowers who combine multiple federal student loans into one is a "viable option for reducing federal costs" in student loan programs, the U.S. Government Accountability Office said in a February letter to Republican lawmakers, who had requested the review.
There is no such thing as an offhanded comment from a White House spokesman.
So when Trent Duffy, in explaining Friday that President Bush would seek to bolster the Pell Grant program in part by reducing the subsidies paid to lenders in the student-loan program, called the subsidies "excessive" and described the loan industry as "very profitable," the political winds surrounding the student-loan programs continued to shift.