Mayes, Edgar on behalf of Duncan, Ame Tuesday, June 10, 2014 6:41 AM Pollack, Joshua; Mitchell, Ted; Runele, James FW: thanks from TICAS. Good Morning ~ 1 thought I would share the note to the Secretary below. Thanks, Edgar Bdgar Mayes Director, Correspondence and Commumication Control Unit Office of the Secretary U.S. Department of Education Washington, DC 20202 From: Lauren Asher (maito:LAsher@ticas.org] Sent: Tuesday, June 10, 2014 12:38 AM To: Lauren Asher Ce: Pauline Abernathy ‘Subject: thanks from TICAS Dear Administration Colleagues, We very much appreciate the Administration's executive actions announced today to help student loan borrowers, including expanding the targeted outreach to those likely to face repayment challenges to include those already in Gefault. | was on the phone all day telling reporters about the importance of these positive steps to help more borrowers have access to a plan with payments capped at 10% of income and forgiveness after 20 years, stay in repayment and out of default, and avoid unnecessaty forbearances. We were also excited to see that loan counseling pilots wore part of the announcement. Thanks for bringing much needed attention and action to multiple aspecis of student loan repayment. Lauren Lauren Asher, President ‘The Institute for College Access & Success 405 14th Street, 1th Floor, Oakland, CA 94612 phone: $10-318-7900, x304 fax: 510-318-7918 emast: ashen @ticas.org wewwwnticasorg ‘www projectonstudentdeht ong snn.college-insizhtorg smu sbrinfo-orgHolland, Linda ——_________ From: Leith, Wiliam Sent: Wednesday, April 30, 2014 11:19 AM To: Appel, Jeff: Runcie, James: Baker, Jeff, O'Flaherty, Sue; Kane, John; McGinnis, Coneen Subject: RE: SERVICING Issues -- WH High Prioniy Interest Attachments: servicing WH ideas (from TICAS April 2014).doox Jeff - see the attached comments to the TICAS proposal. Bill Sent: Fridey, April 25, 2014 4:24 PM To: Runcie, James; Leith, William; Baker, Jeff; O'Flaherty, Sue; Kane, John; McGinnis, Colleen Subject: SERVICING Issues -- WH High Priority Interest Importance: High [eyS) (eXS)[eerApril 24, 2014 TICAS’ Recommended Administrative Actions to Help Struggling Student Loan Borrowers Reduce the Burden of Federal Student Loan Debt for Current Borrowers # Ensure borrowers know about Income-Driven Repayment and Public Service Loan Forgiveness: © Direct OPM to do IDR/PSLF outreach to federal employees, including military, postal, etc. Could also do outreach to state and local employees including police officers and other first responders. GOOD IDEA © Direct £D to do outreach to schoo! districts for teachers to enroll in IDR/PSLF and HHS to do outreach to public health workers and Head Start workers. GOOD IDEA ‘© Direct ED to ensure borrowers are alerted to the availability of IDR as soon as they have been delinquent, in forbearance, or in economic hardship or unemployment deferment for more than 60 days, ‘THROUGH FINANCIAL LITERACY OUTREACH (SUCH AS WEBSITE)THEY CONTACT ALL BORROWERS DURING NON-DELINQUENT STAGES SUCH AS GRACE). WHEN A BORROWER BECOMES DELINQUENT ALL OPTIONS ARE MADE AVAILABLE. THIS IS NOT ‘A REQUIREMENT BUT IS ALREADY BEING DONE. © Direct ED to stop its servicers from putting borrowers in forbearance (ever or at least @ second time) without first explaining and estimating their IDR payment. OUR SERVICERS. ALREADY DO THIS. THE SERVICERS DO NOT AUTOMATICALLY PLACE BORROWERS IN FORB, THEY DO DISCUSS OPTIONS PRIOR TO FORB. IT IS NOT A REQUIREMENT BUT IT IS ALREADY BEING DONE. THIS WOULD MOST LIKELY BE A LEGISLATIVE CHANGE. «Make it easier for the lowest income student loan borrowers to enroll and remain én IDR, ‘Direct Treasury and any other relevant agencies to enable borrowers who eara too little to owe federal income tax and do not file a 1040 to electronically transfer their 1099 and/or W2 data when applying for IDR. GOOD IDEA © Eliminate the annual income verification process by reinstating the ability for borrowers to grant permission for ED to receive their IRS information for five or more years, GOOD IDEA «Provide relief to bankrupt borrowers who are elderly, destitute and/or a disabled vet: cc ED to direct its contractors not to challenge undue hardship petitions from certain bankrupt federal loan borrowers clearly facing an undue hardship by deeming repayment of a student loen debt to be an undue hardship if any of the following are applicable to the borrower: MOST OF THIS SECTION WOULD REQUIRE LEGISLATION AS THIS IS HANDLED THROUGH BANKRUPTCY LAW. THE DEBTOR WOULD NEED TO FILE AN ADVERSARY PROCEEDING. IF THE FACTS IN THE CASE MATCH THOSE BELOW, IT SEEMS LIKELY THAT WE MAY CONCEDE HARDSHIP AND THE DISCHARGE WITHOUT FORCING THE CASE TO TRIAL, BUT THEY STILL HAVE TO GO THROUGH THE COURTS. THAT IS CURRENTLY WHAT THE LAW REQUIRES. WE HAVE NO AUTHORITY TO GRANT A BANKRUPTCY DISCHARGE UNLESS THE BORROWER FILES AN ADVERSARY PROCEEDING SEEKING AN UNDUE HAROSHIP FINDING. 9 the borrower is receiving benefits under the Social Security Act; © the borrower has been determined by the VA to be unemployable due to service- connected disabllity; ISN'T THIS ALREADY COVERED UNDER TPD othe borrower receives income from retirement benefits under SSA or from a retirement fund of account and the annual household income for the borrower is less than 200 percent of the official poverty guideline;April 24, 2014 the borrower provides for the care and support of an elderly, il, or disabled household member or member of the borrower's immediate family and the annual household. income for the borrower is less than 200 percent of the official poverty guideline; or during the 5-year period before filing the petition, the average annual household income for the borrower has been less than 200 percent of the official poverty guideline. + Provide relief to borrowers in default: Direct Treasury not to gamish wages, Social Security, or EITC for borrowers who would be eligible for an IDR zero monthly payment, or limit garnishment the amount that would now be considered a Reasonable and Affordable payment in rehabilitation, or ‘exempt Social Security and EITC from garnishment entirely.? WITHOUT DOCUMENTATION FROM EITHER THE BORROWER OR THE IRS, WE CAN’T DETERMINE ‘THE IDR PAYMENT AMOUNT, MIGHT REQUIRE LEGISLATION OR IRS CODE CHANGE WE HAVE TWO DIFFERENT IDR OPTIONS FOR DEFAULTED BORROWERS: REHAB AND CONSOLIDATION, FOR REHAB, A BORROWER WiTH A ZERO DOLLAR CALCULATED. PAYMENT WOULD ACTUALLY HAVE TO MAKE 9 PAYMENTS OF $5 IN ORDER TO REHAB. FOR CONSOLIDATION, THE BORROWER COULD CONSOLIDATE MORE OR LESS IVIMEDIATELY AS A FORCED-ICR CONSOLIDATION (NO PAYMENTS). TECHNICALLY IT IS POSSIBLE TO DECERTIFY A BORROWER FROM TOP, BUT WE DO. NOT CURRENTLY HAVE ANY PROCESS FOR THIS. Direct Ed and Treasury to pilot in-house collections on a random sample of student, loans to see if it would be more cost-effective, See further explanation in our 2013, white paper {pp 66-67}. Without documentation from either the borrower or perhaps IRS you can’t determine the IDR payment amount. + Better prevent defaults and their consequences to borrowers and society: Direct ED to change its debt collection contracts to eliminate the perverse incentive for contractors to let borrowers default because they make more money this way. DON'T UNDERSTAND Direct ED to create a complaint tracking system like the CFPB and VAs have so students can get help, including both monetary and non-monetary relief. WE HAVE COMPLAINT TRACKING INTERNAL TO BUSINESS OPERATIONS AND OMBUDSMAN. WE DO NOT HAVE A WEB BASED COMPLAINT PRODUCT, SUCH AS CFPB. HOWEVER, WE COULD LOOK INTO CREATING AND STAFFING FOR ONE. Improve loan servicing and collections by directing ED to develop a plan to improve its oversight of servicers and debt collectors. WE ARE CONTINUALLY REVIEWING OUR OVERSIGHT PRACTICES AND UPDATING TO ENSURE THAT THE OVERSIGHT IS APPROPRIATE. Direct ED to increase oversight of schools where students are at the greatest rik from debt, including a high use of forbearance, inconsistent repayment, and high borrowing and default rates, or high rates of default immediately after the CDR window closes. GOOD IDEA Make it easier to pre-pay in all repayment plans (e.g. allow borrowers to direct payments to principal, including ED providing model letters to instruct servicers in this way as CFPB has done for private loan borrowers). ONCE BORROWERS SATISFY THE REGULATORY REQUIREMENT FOR PAYMENT ALLOCATION, THEY CAN DIRECT FUNDSApril 24, 2014 ‘TO BE APPLIED TO PRINCIPAL. THIS ALREADY IN PLACE. HOWEVER, THE SERVICERS DO. NOT HAVE A MEANS FOR RETAINING THE BORROWER'S WISHES AND PRESENTLY REQUIRE INSTRUCTION TO BE SENT WITH EACH PAYMENT ~ A CHANGE TO THIS WOULD BE A REQUIREMENT CHANGE, HOWEVER, MIGHT BE A CHANGE TO ALLOCATION RULES DEPENDING ON INSTRUCTIONS SO MIGHT NEED REG/LEG CHANGE, Improve Federal toan Counseling Ensure borrowers receive timely loan counseling based on their interest Direct ED to issue guidance to colleges on what they can do re: loan counseling. Currently our Making Loans Work is the only thing available and the recent Senate HELP hearing made clear schools do not understand what they can do. UNLESS LEGISLATION ALLOWS SCHOOLS TO HOLD DISBURSEMENTS, WOULD BE DIFFICULT FOR EDTODO. Direct ED to issue guidance to colleges re: what constitutes default management and What constitutes COR manipulation. GOOD IDEA Improve federal loan counseling by directing ED to: Implement another round of revisions to improve online loan counseling tools based on the comments they received last year. For example, the counseling tools should more strongly encourage students to exhaust federal loan eligibility before turning to private loans, encourage students to ask their school to initially disburse a srvaller amount and to hold the rest of the loan funds until the student indicates that they want more, and better integrate information about income-driven repayment alongside other repayment options. WE ARE PROBABLY DOING SOME OF THIS AND MAY JUST NEED TO. STRENGTHEN LANGUAGE. WE ALREADY REMIND STUDENTS TO NOT OBTAIN PRIVATE LOANS. NEED TO CHECK CASH MANAGEMENT RULES ON ABILITY FOR SCHOOL TO HOLD DISBURSEMENTS Conduct consumer testing of entrance and exit counseling. WE DO THIS THROUGH USABILITY TESTING ~ SLIGHTLY DIFFERENT Conduct research to evaluate effectiveness of loan counseling, including using random ‘assignment to measure and isolate the impact of different approaches on borrower behavior. * Test changing the exit counseling and outreach for borrowers who did not complete and are therefore at highest risk of default to learn what helps prevent defautt Requiring entrance counseling before disbursement by changing the federal master promissory note to include loan counseling or by at least encouraging all college to do this through Dear Colleague Letters and other means. ALREADY REQUIRED. Provide Relief for Defrauded Students Direct DO! to negotiate with the Career Education Corp. for millions of dollars of relief for students in the other 49 states similar to what its NY students received under its settlement with the NY AG. Gan mandatory arbitration clauses in enrollment and loan agreements with institutions that receive Title IV funds. LEGISLATIVE?April 24, 2014 + Reduce the Burden of Private Loan Debt * Ease repayment for borrowers struggling with private loans by directing ED to ensure borrowers know that their private loans count in determining the repayment period for a Direct, consolidation loan. For example, a borrower with a $39,000 Direct consolidation loan (and no ‘other federal loans} would qualify for 2 20-year repayment period. if she also had $21,000 or ‘more in private loans, she could qualify to repay her consolidation loan over 30 years {for more see http://loanconsolidation.ed.gov/examples/repyperiod html). IN DIRECT CONSOLIDATION TODAY, PRIVATE LOAN PAYMENTS ARE TAKEN INTO CONSIDERATION WHEN DETERMINING THE AMOUNT AND TERM OF THE REPAYMENT. WE ALREADY ALLOW FOR THE INCLUSION OF PRIVATE DEBT AMOUNTS FOR THE STANDARD AND GRADUATED PLANS + Encourage private loan refinancing by directing Treasury to report on what it can do in a budget neutral way to promote refinancing and improve market efficiency, with a particular focus on promoting refinancing for borrowers with high private loan debt in proportion to their income. ‘+ Prevent unnecessary private loan borrowing: © Direct ED to require or encourage schools to notify students of untapped federal aid eligibility when schools receive a private loan certification request. BELIEVE THIS IS ALREADY REQUIRED. PRIVATE LOANS ARE REQUIRED TO BE SIGNED OFF BY SCHOOLS FOR EXPRESSLY THIS PURPOSE ‘© Direct ED to include in the fedleral loan counseling information about the need to ‘maximize federal loans first before considering private loans, and to encourage schools using other counseling tools to do the same, BELIEVE WE ALREADY DO THIS, MIGHT NEED TO BE STRENGTHEND?Holland, Linda Leith, William Tuesday, April 29, 2014 9:30 AM : Runcie, James; McGinnis, Colleen Subject: FW: SERVICING Issues -- WH High Priority Interest Attachments: servicing WH ideas (from TICAS Apri! 2014).docx See the attached for comments to TICAS paper. Jeff's traveling today so it will be difficult to discuss any of this with him. How should we handle? From: Hermandes, Jana Sent: Tuesday, April 29, 2014 8:06 AM. To: Leith, William; O'Flaherty, Sue; Kane, John Subject: RE: SERVICING Issues ~ WH High Priority Interest A FEW TWEAKS, VETTED WITH SUE Original Message- From: Leith, Wiliam Sent: Tuesday, April 29, 2014 7:18 AM To: O'Flaherty, Sue; Hernandles, Jana; Kane, John Subject: RE: SERVICING Issues — WH High Priority interest I think this is great. If final | will forward to Jim, Any changes? From: O'Flaherty, Sue Sent: Monday, April 28, 2014 3:42 PM To: Hernandes, Jana; Kane, Joha; Leith, Witliam Subject: RE: SERVICING Issues -- WH High Priority interest Hi... this is combined. ‘The first section are comments to the cover email. Jana is in red, | added a few in black but discussed those earlier today. For the attachment: Jana... believe it or not, we were both pretty close in our respanses AND aur color coding! However, | changed the color coding to uppercase bold for our comments, From: Hemandes, Jana Sent: Monday, April 28, 2014 3:44 PM To: O'Flaherty, Sue; Kane, John; Leith, William Subject: RE: SERVICING tssues - WH High Priority Interest thanks From: O'Flaherty, Sue Sent: Monday, Aprit 28, 2014 3:14 PM To: Hernandes, Jana; Kane, John; Leith, William Subject: RE: SERVICING Issues -- WH High Priority InterestFok with you Jana... Ill put the two together. From: Hernandes, Jana Sent: Monday, April 28, 2014 3:02 PM. To: Kane, John; Leith, William; O'Flaherty, Sue Subject: RE: SERVICING Issues -- WH High Priority interest attached are my comments on the cover email and on the document that was part of the email | think itis salf- explanatory | didn't want to forward to everyone on the call earlier yet, depending on your thoughts about my suggestions.April 24, 2014 TICAS’ Recommended Administrative Actions to Help Struggling Student Loan Borrowers Reduce the Burden of Federal Student Loan Debt jor Current Borrowers + Ensure borrowers know about Income-Driven Repayment and Public Service Loan Forgiveness © Direct OPM to do IDR/PSLF outreach to federal employees, including military, postal, etc. Could also do outreach to state and local employees including police officers and other first responders. GOOD IDEA Direct ED to do outreach to school districts for teachers to enroll in IDR/PSLF and HHS to do outreach to public health workers and Head Start workers. GOOD IDEA © Direct ED to ensure borrowers are alerted to tie availablity of IDR as soon as they have been delinquent, in forbearance, or in economic hardship or unemployment deferment for more than 60 days THROUGH FINANCIAL LITERACY OUTREACH (SUCH AS WEBSITE)THEY CONTACT ALL BORROWERS DURING NON-DELINQUENT STAGES SUCH AS GRACE). WHEN A. BORROWER BECOMES DELINQUENT ALL OPTIONS ARE MADE AVAILABLE. THIS IS NOT ‘A REQUIREMENT BUT IS ALREADY BEING DONE. © Direct ED to stop its servicers from putting borrowers in forbearance (ever or atleast a second time) without first explaining and estimating their IDR payment. OUR SERVICERS, ALREADY DO THIS. THE SERVICERS DO NOT AUTOMATICALLY PLACE BORROWERS IN FORB, THEY DO DISCUSS OPTIONS PRIOR TO FORB. IT IS NOT A REQUIREMENT BUT IT IS ALREADY BEING DONE, THIS WOULD MOST LIKELY BE A LEGISLATIVE CHANGE. ‘+ Make it easier for the lowest income student loan borrowers to enroll and remain in IDR: © Direct Treasury and any other relevant agencies to enable borrowers who earn too little to owe federal income tax and do not fle a 1040 to electronically transfer their 2099 and/or W2 data when applying for IDR. GOOD IDEA Eliminate the annual income verification process by reinstating the ability for borrowers to grant permission for ED to receive thetr IRS information for five or more years. GOOD IDEA ‘+ Provide relief to bankrupt borrowers who are elderly, destitute and/or a disabled vet: Direct ED to direct its contractors not to challenge undue hardship petitions from certain bankrupt federal loan borrowers clearly facing an undue hardship by deeming repayment of a student loan debt tobe an undue hardship if any of the following are applicable to the borrower: MOST OF THIS SECTION WOULD REQUIRE LEGISLATION AS THIS IS HANDLED THROUGH BANKRUPTCY LAW. THE DEBTOR WOULD NEED TO FILE AN ADVERSARY PROCEEDING. IF THE FACTS IN THE CASE MATCH THOSE BELOW, IT SEEMS LIKELY THAT WE IMAY CONCEDE HARDSHIP AND THE DISCHARGE WITHOUT FORCING THE CASE TO TRIAL, BUT THEY STILL HAVE TO GO THROUGH THE COURTS. THATIS ‘CURRENTLY WHAT THE LAW REQUIRES. WE HAVE NO AUTHORITY TO GRANT A BANKRUPTCY DISCHARGE UNLESS THE BORROWER FILES AN ADVERSARY PROCEEDING SEEKING AN UNDUE HARDSHIP FINDING. © the borrower is receiving benefits under the Social Security Act; ‘© the borrower has been determined by the VA to be unemployable due to service- connected disability; ISN'T THIS ALREADY COVERED UNDER TPD © the borrower receives income from retirement benefits under SSA ar from a retirement, fund or account and the annual household income for the borrower is less then 200 percent of the official poverty guideline;April 24, 2014 the borrower provides for the care and support of an elderly, ill or disabled household member or member of the borrower's immediate family and the annual household income for the borrower is less than 200 percent of the official poverty guideline; or during the 5-year period before filing the petition, the average annual household income for the borrower has been less than 200 percent of the official poverty guideline. + Provide relief to borrowers in default: ° Direct Treasury not to garnish wages, Social Security, or EITC for borrowers who would be eligible for an iDR zero monthly payment, or limit garnishment the amount that would now be considered a Reasonable and Affordable payment in rehabilitation, or exempt Social Security and EITC from garnishment entirely.? WITHOUT DOCUMENTATION FROM EITHER THE BORROWER OR THE IRS, WE CAN'T DETERMINE THE IDR PAYMENT AMOUNT. MIGHT REQUIRE LEGISLATION OR IRS CODE CHANGE WE HAVE TWO DIFFERENT IDR OPTIONS FOR DEFAULTED BORROWERS: REHAB AND CONSOLIDATION. FOR REHAB, A BORROWER WITH A ZERO DOLLAR CALCULATED PAYMENT WOULD ACTUALLY HAVE TO MAKE 9 PAYMENTS OF $5 IN ORDER TO. REHAB. FOR CONSOLIDATION, THE BORROWER COULD CONSOLIDATE MORE OR LESS IMIMEDIATELY AS A FORCED-ICR CONSOLIDATION {NO PAYMENTS). TECHNICALLY IT IS POSSIBLE TO DECERTIFY A BORROWER FROM TOP, BUT WE DO. NOT CURRENTLY HAVE ANY PROCESS FOR THIS. Direct Ed and Treasury to pilot in-house collections on a random sample of student loans to see if it would be more cost-effective. See further explanation in our 2013 white paper (pp 66-67). Without documentation from elther the borcower or perhaps IRS you can’t determine the IDR payment amount. + Better prevent defaults and their consequences to borrowers and society: Direct ED to change its debt collection contracts to eliminate the perverse incentive for contractors to let borrowers default because they make more money this way, DON'T UNDERSTAND Direct ED to create a complaint tracking system like the CFPB and VAs have so students can get help, including both monetary and non-monetary relief. WE HAVE COMPLAINT ‘TRACKING INTERNAL TO BUSINESS OPERATIONS AND OMBUDSMAN. WE DO NOT HAVE A WEB BASED COMPLAINT PRODUCT, SUCH AS CFPB. HOWEVER, WE COULD LOOK INTO CREATING AND STAFFING FOR ONE, Improve loan servicing and collections by directing €D to develop a plan to improve its oversight of servicers and debt collectors. WE ARE CONTINUALLY REVIEWING OUR OVERSIGHT PRACTICES AND UPDATING TO ENSURE THAT THE OVERSIGHT IS APPROPRIATE. Direct ED to increase oversight of schools where students are at the greatest risk from debs, including a high use of forbearance, inconsistent repayment, and high borrowing and default rates, or high rates of default immediately after the CDR window closes. GOOD IDEA Make it easier to pre-pay in all repayment plans (e.g. allow borrowers to direct payments to principal, including EO providing model letters to instruct servicers in this way as CFPB has done for private [oan borrowers). ONCE BORROWERS SATISFY THE REGULATORY REQUIREMENT FOR PAYMENT ALLOCATION, THEY CAN DIRECT FUNDSApril 24, 2014 ‘TO BE APPLIED TO PRINCIPAL. THIS ALREADY IN PLACE, HOWEVER, THE SERVICERS DO NOT HAVE A MEANS FOR RETAINING THE BORROWER'S WISHES AND PRESENTLY REQUIRE INSTRUCTION TO BE SENT WITH EACH PAYMENT ~ & CHANGE TO THIS WOULD BE A REQUIREMENT CHANGE, HOWEVER, MIGHT BE A CHANGE TO ALLOCATION RULES DEPENDING ON INSTRUCTIONS SO MIGHT NEED REG/LEG CHANGE, Improve Federal Loon Counseling Ensure borrowers receive timely loan counseling based on their interests: Direct ED to issue guidance to colleges on what they can do re: joan counseling. Currently our Making Loans Work is the only thing available and the recent Senate HELP hearing made clear schools do not understand what they can do. UNLESS LEGISLATION ALLOWS SCHOOLS TO HOLD DISBURSEMENTS, WOULD BE DIFFICULT FOR ED TODO, Direct ED to issue guidance to colleges re: what constitutes default management and what constitutes CDR manipulation, GOOD IDEA Improve federal loan counseling by directing ED to: Implement another round of revisions to improve online loan counseling tools based on the comments they received last year. For example, the counseling tools should more strongly encourage students to exhaust federal loan eligibility before turning to private loans, encourage students to ask their school to initially disburse a smaller amount and to hold the rest of the loan funds until the student indicates that they want more, and better integrate information about income-driven repayment alongside other repayment options. WE ARE PROBABLY DOING SOME OF THIS AND MAY JUST NEED TO STRENGTHEN LANGUAGE. WE ALREADY REMIND STUDENTS TO NOT OBTAIN PRIVATE LOANS. NEED TO CHECK CASH MANAGEMENT RULES ON ABILITY FOR SCHOOL TO HOLD DISBURSEMENTS: Conduct consumer testing of entrance and exit counseling, WE DO THIS THROUGH USABILITY TESTING ~ SLIGHTLY DIFFERENT Conduct research to evaluate effectiveness of loan counseling, including using random assignment to measure and isolate the impact of different approaches on borrower behavior. ‘+ Test changing the exit counseling and outreach for borrowers who did not complete and are therefore at highest risk of default to learn what helps prevent default, Requiring entrance counseling before disbursement by changing the federal master promissory note to include loan counseling or by at least encauraging all college to do this through Dear Colleague Letters and other means. ALREADY REQUIRED. Provide Relief for Defrauded Students Direct DO! to negotiate with the Career Education Corp. for millions of dollars of relief for students in the other 49 states similar to what its NY students received under its settlement with the NY AG. 8an mandatory arbitration clauses in enrollment and loan agreements with institutions that receive Title IV funds. LEGISLATIVE?April 24, 2014 + Reduce the Burden of Private Loan Debt * Ease repayment for borrowers struggling with private loans by directing ED to ensure borrowers know that their private loans count in determining the repayment period for a Direct consolidation loan. For example, a borrower with a $39,000 Direct consolidation loan {and no other federal loans) would qualify for a 20-year repayment period. If she also had $21,000 or more in private loans, she could qualify to repay her consolidation loan over 30 years {for more see Atip://loanconsolidation.ed,gov/examples/repyperiod. html). IN DIRECT CONSOLIDATION TODAY, PRIVATE LOAN PAYMENTS ARE TAKEN INTO CONSIDERATION WHEN DETERMINING ‘THE AMOUNT AND TERM OF THE REPAYMENT. WE ALREADY ALLOW FOR THE INCLUSION OF PRIVATE DEBT AMOUNTS FOR THE STANDARD AND GRADUATED PLANS + Encourage private loan refinancing by directing Treasury to report on what it can do in a budget neutral way to promote refinancing and improve market efficiency, with a particular focus on promoting refinancing for borrowers with high private loan debt in proportion to their income. + Prevent unnecessary private loan borrowing: © Direct ED to require or encourage schools to notify students of untapped federal aid eligibility when schools receive a private loan certification request. BELIEVE THIS IS ALREADY REQUIRED. PRIVATE LOANS ARE REQUIRED TO BE SIGNED OFF BY SCHOOLS FOR EXPRESSLY THIS PURPOSE © Direct ED to include in the federal loan counseling information about the need to maximize federal loans first before considering private loans, and to encourage schools using other counseling tools to do the same, BELIEVE WE ALREADY DO THIS, MIGHT NEED TO BE STRENGTHEND?Holland, Linda From: Appel, Jett Sent: Saturday, April 26, 2014 10:53 PM To: Leith, Wiliam; Runcie, James, Baker, Jeff; O'Flaherty, Sue; Kane, John; McGinnis, Coleen Subject: RE: SERVICING Issues -- WH High Priority interest Thank you Bill. This is helpful. From: Leith, William Sent: 4/26/2014 9:58 AM To: Appel, Jeff; Runcie, James; Baker, Jeff; O'Flaherty, Sue; Kane, lehn; MeGinnis, Colleen Subject: RE: SERVICING issues -- WH High Priority Interest [(eNS) From: Appel, leit Sent; Friday, April 25, 2014 3:24 PM To: Runcie, James; Leith, William; Baker, Jeff, O'Fiaherty, Sue; Kane, Jobin; MeGinnis, Colleen Subject: SERVICING Issues ~ WH High Priority Interest fexey(eerHolland, Linda Fron Leith, witiar Sent: Saturday, April 26, 2014 12:59 PM To: Appel, Jeff; Runcie, James; Baker, Jett: OFFlaherty, Sue; Kane, John; McGionis, Colleen Subject: RE: SERVICING Issues —- WH High Priority interest ‘Thanks Jeff. A few thoughts. WET From: Appel, Jeff Sent: Friday, April 25, 2014 3:24 PM. To: Runcie, James; Leith, William; Baker, Jeff; O'Flaherty, Sue; Kane, John; McGinnis, Colleen ‘Subject: SERVICING Issues ~ WH High Priority InterestfexsyHolland, Linda Appel, Jett Friday, April 25, 2014 4:24 PM Runcie, Jamas; Leith, Wiliam; Baker, Joff: O'Flaherty, Sue; Kane, John, MeGinnis, Colleen SERVICING Issues -- WH High Priority Interest. Recommended Administrative Actions (rom TICAS April 2014) docx Importance: High [(evS) [eyGaTICAS’ Recommended Administrative Act April 24, 2014 ns to Help Struggling Student Loan Borrowers Reduce the Burden of Federal Student Loan Debt for Current Borrowers ‘+ Ensure borrowers know about Income-Driven Repayment and Public Service Loan Forgiveness: Direct OPM to do |DR/PSLF outreach to federal employees, including military, postal, etc. Could also do outreach to state and local employees including police officers and other first responders, Direct ED to do outreach to school districts for teachers to enroll in IDR/PSLE and HHS to do outreach to public health workers and Head Start workers Direct £D to ensure borrowers are alerted to the availability of IDR as soon as they have heen delinquent, in forbearance, or in economic hardship or unemployment deferment for more than 60 days. Direct ED to stop its servicers from putting borrowers in forbearance {ever or at least 3 second time) without first explaining and estimating their IDR payment. + Make it easier for the lowest income student ioan borrowers to enroll and remain in !OR: Direct Treasury and any other relevant agencies to enable borrowers who eam too little to owe federal income tax and do nat file a 1040 to electronically transfer their 1099 and/or W2 data when applying for IDR, Eliminate the anaual income verification process by reinstating the ability for borrowers ‘to grant permission for ED to receive their IRS information for five or more years. ‘+ Provide relief to bankrupt borrowers who are elderly, destitute and/or a disabled vet: Direct ED to direct its contractors aot to challenge undue hardship petitions from certain bankrupt federal loan borrowers clearly facing an undue hardship by deeming repayment of a student loan debt to be an undue hardship if any of the following are applicable to the borrower: + the borrower is receiving benefits under the Social Security Act; + the horrower has been determined by the VA to be unemployable due to service-connected disabil + the borrower receives income from retirement benefits under SSA ar from a retirement fund or account and the annual household income for the borrower is less than 200 percent of the official poverty guideline; + the borrower provides for the care and support ofan elderly, il, or disabled household member or member of the borrower's immediate family and the annual household income for the borrower is less than 200 percent of the official poverty guideline; or * during the 5-year period before filing the petition, the average annual househoid income for the borrower has been less than 200 percent of the official poverty guideline + Provide relief to borrowers in default: Direct Treasury not to garnish wages, Social Security, or EITC for borrowers who would be eligibie for an IDR zero monthly payment, or limit garnishment the amount that ‘would now be considered a Reasonable and Affordable payment in rehabilitation, or ‘exempt Social Security and EITC from garnishment entirely. Direct Ed and Treasury to pilot in-house collections on a random sample of student loans to see ifit would be more cost-effective. See further explanation in our 2013 white paper (pp 66-67) + Better prevent defaults and their consequences ta borrowers and society:April 24, 2014 Direct ED to change its debt collection contracts to eliminate the perverse incentive for contractors to let borrowers default because they make more money this way. Direct ED to create a complaint tracking system like the CFPB and VAs have so students can get help, including both monetary and non-monetary relief, Improve loan servicing and collections by directing ED to develop a plan to improve its ‘oversight of servicers and debt collectors. Direct ED to increase oversight of schools where students are at the greatest risk from debs, including a high use of forbearance, inconsistent repayment, and high borrowing and default rates, or high rates of default immediately after the CDR window closes. ‘+ Moke it easier to pre-pay in all repayment plans (e.g. allow borrowers to direct payments to principal, including €D providing model letters to instruct servicers in this way as CFP has done for private loan borrowers}. improve Federal Loon Counseling + Ensure borrowers receive timely loan counseling based on their interests: Direct ED to issue guidance to colleges on what they can do re: loan counseling. Currently our Making Loans Work is the only thing available and the recent Senate HELP hearing made clear schools do not understand what they can do. Direct ED to issue guidance to colleges re: what constitutes default management and what constitutes COR manipulation. * Improve federal loan counseling by directing ED to: lonplement another round of revisions to improve online loan counseling tools based on ‘the comments they received last year. For example, the counseling toals should more strongly encourage students to exhaust federal ioan eligibility before turning to private loans, encourage students to ask their schoo! to initially disburse a smaller amount and to hold the rest of the loan funds until the student indicates that they want more, and better integrate information about income-driven repayment alongside other repayment options. ‘Conduct consumer testing of entrance and exit counseling, Conduct research to evaluate effectiveness of loan counseling, including using random assignment to measure and isolate the impact of different approaches on borrower behavior. * Test changing the exit counseling and outreach for borrowers who did not complete and are therefore at highest risk of default to learn what helps prevent default Requiring entrance counseling before disbursement by changing the federal master promissory note to include loan counseling or by at feast encouraging all college to do this through Dear Colleague Letters and other means. Provide Retief for Defrouded Students + Direct DOS to negotiate with the Career Education Corp. for millions of dollars of relief for students in the other 49 states similar to what its NY students received under its settlement with the NY AG. + Ban mandatory arbitration clauses in enrollment and loan agreements with institutions that receive Title IV funds,April 24, 2014 Reduce the Burden of Private Loan Debt ‘+ Fase repayment for borrowers struggling with private loans by directing ED to ensure borrowers know that their private loans count in determining the repayment period for a Direct consolidation loan. For example, a borrower with a $39,000 Direct consolidation loan (and no ‘other federal loans} would qualify for a 20-year repayment period. If she also had $21,000 or more in private loans, she could qualify to repay her consolidation loan aver 30 years (for more see http://loanconsolidation.ed gov/examples/repyoeriod. html). + Encourage private loan refinancing by directing Treasury to report on what it can do in a budget neutral way to promote refinancing and improve market efficiency, with a particular focus on promoting cefinancing for borrowers with high private loan debt in proportion to their income. + Prevent unnecessary private loan borrowing: Direct ED to require or encourage schools to notify students of untapped federal aid eligibility when schools receive a private loan certification request. Direct ED to include in the federal loan counseling information about the need to maximize federal loans first before considering private loans, and to encourage schools using other counseling tools to do the same.Holland, Linda From: McGinnis, Colleen ‘Tuesday, February 04, 2014 9:41 AM Runcie, James; Manning, James; Baker, Jeff, Leith, Willa FW: Letter to the President signed by more than 50 organizations urging @ stronger gainful employment regulation Coalition tetter to President in support of GE sent Feb 4 2014.pat pabernathy@ticas.org] ‘Sent: Tuesday, February 04, 2014 9:36 AM To: Douglas_3_Kramer@who.eop.gov; Duncan, Ame; cmunoz@who.cop.gov; asperling@who.cop.gov; Syvia_M._Burwell@omb,eop.gov; Jason_L_Furman@cea.eop.gov Cc: james_R._kveal@who.eop.gov; Coven, Martha B.; Studley, Jamie; Lachman, Sherry; beuguste@who.eop.gov; sbaker@ovp.eop.gov; Appel, Jeff; Danialle_C_Gray@who.cop.gov ‘Subject: Letter to the President signed by more than 50 organizations urging a stronger gainful employment regulation On behalf of the coalition, attached and below is a letter to President Obama urging the Administration to promptly issue a strong and effective proposed gainful employment regulation so it can be finalized by November 1, 2014, and go into effect by July 1, 2015. The letter is signed by more than 50 organizations that work on behalf of students, college access, consumers, veterans, servicemembers, and civil rights The letter states that, at a minimum, the regulation should include the following five elements: 1. Arepayment rate or another metric to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding. 2, Ameaningful approval process to weed out programs that will not prepare students for gainful employment in the specified occupations before they harm students. 3. Borrower relief that is fair and provides a greater incentive to improve weak programs. 4. Meaningful debt-to-earnings standards. 5. Protection for schools offering low-cost programs in which most students do not borrow. Coalition members are also submitting requests for meetings with the Administration to discuss our views and answer any questions, consistent with Executive Order 12866. We thank the Obama Administration for its efforts to protect students and taxpayers from fraud and abuse in career education programs. The coalition stands ready to assist you in strengthening protections for taxpayers and students, including veterans and servicemembers who risked their lives to defend our country. Thank you. February 4, 2014 ‘The Honorable Barack Obama President of the United States 1600 Pennsylvania Avenue Washington, DC 20500 Dear Mr, President:Our organizations—which work on behalf of students and college access, veterans, consumers, and civil rights—were heartened by your remarks last August when you so effectively summed up the problems in the for-profit college industry: [T}here have been some schools that are notorious for getting students in, getting @ bunch of grant money, having those students take out a lot of loans, making big profits, but having really low graduation rates. Students aren't getting what they need to be prepared for a particular field. They get out of these for-profit schools loaded down with cnormous debt. They can’t find ajob. They default, The texpayer ends up holding the bag. Their credit is ruined, and the for- profit institution is making out like a bandit. That's a problem. ‘Your administration now has an opportunity to better protect taxpayers and students, including our nation's veterans, service members and their families, from predatory carcer education programs. The Education Department is developing draft regulations to enforce the statutory requirement that all career education programs that receive federal funding, whether at for-profit, public or nonprofit colleges, “prepare students for gainful employment in a recognized occupation.” The negotialed rulemaking panel convened last year by the Department to develop the draft regulations was unable to reach consensus, Even after the Department made multiple changes requested by the for-profit college industry representatives that dramatically weakened the draft regulation, the for-profit college industry representatives objected to it. The changes would have made the regulation so weak on predatory colleges and so hard on low-cost, high-performing colleges that not a single negotiator voiced support for the Department’s last proposal. We urge the Administration to issue promptly a stronger, more effective proposed regulation so that the urgently needed rules can be finalized by November J, 2014, and go into effect by Tuly 1, 2015. Ata minimum, we believe the regulation should include the following five elements: 1, A repayment rate or another metric to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding. A low completion rate is one of the way’ that proprams can fail to prepare students for gainful employment, particularly when they leave school with substantial debt. But programs where 99% of the students drop out with heavy debt that they are unable to pay dowa could still pass the Department's most recent proposal. A prograni-level cohort default rate (pCDR) was the only metric in that proposal to assess the outcomes of students who do not complete a program. However, a PCDR alone is not sufficient for at least two reasons, First, the well-documented manipulation of cohort default rates by some for-profit college corporations undermines their meaning. Second, default is an extreme situation, measuring whether borrowers have failed to make any required payments in at least 270 days and does not measure whether students are able to pay down their loans. To be clear, we believe that a strong repayment rate or other metric addressing programs with high borrowing and high dropout rates, shouid be a separate requirement that gaiafill employment programs must pass, in addition to the other tests, in order to retain eligibility. 2. A meaningful approval process to weed out programs that will not prepare students for gainful employment in the specified occupations before they harm students. Programs that lack the programmatic accreditation or other attributes needed for graduates to be hired in the field should not be eligible to receive taxpayer funds, yet the Department's most recent proposal would allow funding to continue to flow to these programs. For example, federal funding should not be available for dental assisting and other medical programs whose graduates are ineligible for the licensing exam required to work in that field. Subsidizing such programs misieads students, who trust the federal government to fund only worthwhile programs and is clearly inconsistent with the statutory requirement that all career edueation programs receiving federa! funding “prepare students for gainful employment in a recognized occupal3. Borrower relief that is fair and provides a greater incentive to improve weak programs. The Department proposed partia/ relief —at no cost to taxpayers—for some students who enroll in programs that the Department ultimately determines systematically and consistently fail to prepare students for gainful employment in the specified occupations. We believe students should not be responsible for any loans they received to attend such programs. Providing full relief to all such students is not only fair, it also provides 2 more effective incentive for schools to improve their programs so they never have to provide such relief. 4. Meaningful debt-to-carnings standards. The cebi-to-carnings standards in the Department's last proposal ‘were so weak that literally thousands of programs with median and mean debt levels that exceed their graduates" entire discretionary incomes would not fail the standards, This is clearly too low a Standard, Students and taxpayers deserve better. 3. Protection for schools offering low-cost programs in which most students do not borrow. The final 2011 gainful employment regulation automatically passed all low-cost programs where the majority of graduates do not borrow. The federal district court reviewing the regulations upheld this provision, which recognized that such programs do not consistently leave students with unaifordable debts. The new draft regulation should also. In contrast, the Department’s last proposal would unintentionally jeopardize funding for many of these low-cost programs because the metries would consider only students receiving Title IV finnding, which in many cases are a small, unrepresentative share of the program's students. These proposals would incentivize more schools to Jeave the Federal student foan program, lead to the voluntary or involuntary closure of effective, low-cost programs, and is at odds with related statutory precedent which acknowledges the importance of the share of students borrowing in applying default rate sanctions We believe these five elements are essential, but there are other areas in which thoughtful proposals were submitted by negotiators that merit further consideration, Several of the negotiated rulemaking pane! working groups and individual negotiators developed detailed proposals to strengthen the regulation in important ways while reducing its burden on high-performing, low-cost colleges. For example, the Department's proposals do nothing to increase the accuracy or compatability of the job placement rates that schools advertise to students. As the commissioner of the National Center for Education Statisties told the negotiated rulemaking panel in September, the exclusion of deceased students is just about the only thing that the many current definitions of job placement have in common, In light of this lack of comparability and the increasing evidence of widespread manipulation and inflation of job placement rates in the for-profit college industry, the proposals by the working group on job placement are timely, thoughtful, and practical. We applaud the Members of Congress who recently sent a letter to Secretary Duncan urging the Administration to move decisively towards issuing a final regulation. We thank you for your leadership in seeking to improve higher education and cateer opportunities for all Americans, We and our members and supporters stand with you and look forward to the prompt issuance a strengthened gainful employment rule and other urgently needed Steps to enforce current laws to better protect students, taxpayers, and our nation’s economy. Sincerely, APL-CIO The Ametican Association of State Colleges and Universities (AASCU) American Association of University Professors (AAUP) American Association of University Women (AAUW) ‘American Federation of Teachers (AFT) Americans for Financial Reform Association of the United States Navy (AUSN) ‘Center for Law and Sacial Poliey Center for Public interest Law Center for Responsible Lending.Children’s Advocacy Institute Consumer Action Consumers Union Consumer Federation of California Council for Opportunity in Education Crittenton Women’s Union East Bay Community Law Center Generation Progress Initiative to Protect Student Veterans The Education Trust The Institute for College Access & Success Institute for Higher Education Policy (HEP) Iraq and Afghanistan Veterans of America (IAVA) ‘The Leadership Conference on Civil and Human Rights League of United Latin American Citizens MALDEF Mississippi Center for Justice National Association for Black Veterans, Inc. (NABVETS) National Association for College Admission Counseling National Consumer Law Center (on behalf of its low-income clients) National Consumers League ‘National Education Association ‘The National Guard Association of the United States (NGAUS) National Women Veterans Association of America New Economy Project (formerly NEDAP) NYPIRG. Paralyzed Veterans of America Public Advocates Inc. Public Higher Education Network of Massachusetts (PHENOM) Public Citizen Rebuild the Dream Service Employees International Union Student Veterans of America United States Student Association US. PIRG ‘Veteran Student Loan Relief Fund Veterans Education Success Veterans for Common Sense Vetlobs VersFirst, 2 program of United Spinal Association Vietnam Veterans of America Young Invincibles ce: Hon, Arne Dunean, Secretary of Educ Hon. Cecilia Muioz, Director, White House Domestic Policy Council Hon. Gene Sperling, Director, White House National Economie Counicil Hon. Sylvia Mathews Burwell, Director, Office of Management and Budget, Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 www.ticas.org and www.projectonstudentdebt.orgFebruary 4, 2014 ‘The Honorable Barack Obama President of the United States 1600 Pennsylvania Avenue Washington, DC 20500 Dear Mr. President: Our organizations—which work on behalf of stadents and college access, veterans, consumers, and civil rights—were heartened by your remarks last August when you so effectively summed up the prablems in the foreprofit college industry: [Jhere have been some schools that are notorious for getting students in, getting a bunch of grant money, having those students take out a lot af loans. making big profits, but having really low graduation rates. Students aten’t getting what they need to be prepared for a particular field, They get out of these for-profit schools loaded down with enormous debt. They can't find a job. ‘They default. ‘The texpayer ends up holding the bag. Their credit is ruined, and the for-profit institution is making out like a bandit, ‘That's a problem, ‘Your administration now has an opportunity to better protect taxpayers and students, including our nation’s veterans, service members and their families, from predatory career education programs. The Education Department is developing draft regulations (o enforce the statutory requirement that all career education programs that reeeive federal funding, whether at for-profit, public or nonprofit colleges, “prepare students for gainful employment in a recognized occupation.” ‘The negotiated rulemaking panel convened last year by the Department to develop the draft regulations was unable to reach consensus. Even after the Department made multiple changes requested by the for-profit college industry representatives that dramatically weakened the draft regulation, the for-profit college industry representatives objected to it. The changes would have made the regulation so weak on predatory colleges and so hard on low-cost, high-performing colleges that not a single negotiator voiced support for the Departments last proposal We urge the Administration to issue promptly a stronger, more effective proposed regulation so that the urgently needed rules can be finalized by November I, 2014, and go into effect by July 1, 2015, Ata ‘minimum, we believe the regulation should include the following five elements: 1. A repayment rate or another metrie to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding. A iow completion rate is one of the ways that programs can fail to prepare students for gainful employment, particularly when they leave school with substantial debt. But programs where 99% of the students drop out with heavy debt that they are unable to pay down could still pass the Department’s most recent proposal. A program-levet cohort default rate (pCDR) was the only metric in that proposal to assess the outcomes of students ‘who do not complete a program, However, a pCDR alone is not sufficient for at least two reasons. First, the well-documented manipulation of cohort default rates by some for-profit college corporations undermines their meaning. Second, default is an extreme situation, measuring whetherborrowers have failed to make any required payments in at least 270 days and does not measure whether students are able to pay down their loans. To be clear, we believe that a strong repayment rate or other metric addressing programs with high borrowing and high dropout rates should be a separate requirement that gainful employment programs must pass, in addition to the other tests, in order to retain eligibitity. 2. A meaningful approval process to weed out progranis that will not prepare students for gainful employment in the specified occupations before they harm studenis. Programs that lack the Programmatic accreditation or other attributes needed for graduates to be hired in the field should not be eligible to receive taxpayer funds, yet the Department's most recent proposal would allow funding to continue to flow to these progrems. For example, federal funding should not be available for dental assisting and other medical programs whose graduates are ineligible for the licensing exam required to work in thal field. Subsidizing such programs mistcads students, who trust the {edcrat government to fund only worthwhile programs and is clearly inconsistent with the statutory requirement that all career education programs receiving federal funding “prepare students for gainful employment in a recognized occupation.” 3. Borrower relief that is fair and provides a greater incentive to improve weak programs. The Department proposed partial relief—at no cost to taxpayers—for some students who enroll in programs that the Department ultimately determines systematically and consistently fail to prepare students for gainful employment in the specified occupations. We believe students should not be responsible for any loans they received to attend such programs. Providing full relief to all such students is not only fair, it also provides a more effective incentive for schools to imprave their programs so they never have to provide such relief. 4, Meaningful debt-to-earnings standards, The debt-to-eamnings standards in the Department's last Proposal were so weak that literally thousands of programs with median and mean debt levels that exceed their graduates’ entire discretionary incomes would not fail the stardards. This is clearly too low a standard. Students and taxpayers deserve better. 5. Protection for schools offering low-cost programs in which most students do not borrow. The final 2011 gainful employment regulation automatically passed all low-cost programs where the majority of graduates do not borrow, The federal district court reviewing the regulations upheld this provision, which recognized that such programs do not consistently leave students with unaffordable debts. The new draft regulation should also. In contrast, the Department's last proposal would unintentionally jeopardize funding for many of these low-cost programs because the metrics would consider only students receiving Title IV funding, which in many cases are a small, unrepresentative share of the programs students. These proposals would incentivize more schools to leave the Federal student loan program, lead to the voluntary or involuntary closure of effective, low-cost programs, and is at odds with related statutory precedent which acknowledges the importance of the share of students borrowing in applying default rate sanctions. We believe these five elements are essential, but there are other areas in which thoughtful proposals were submitted by negotiators that merit further consideration. Several of the negotiated rulemaking panel working groups and individual negotiators developed detailed proposals to strengthen the regulation in important ways while reducing its burden on high-performing, low-cost colleges. Forexample, the Department's proposals do nothing to increase the accuracy or comparability of the job placement rates that schools advertise to students, As the commissioner of the National Center for Education Statistics told the negotiated rulemaking panel in September, the exclusion of deceased students is just about the only thing that the many current definitions of job placement have in common. Jn light of this lack of comparability and the increasing evidence of widespread manipulation and inflation of job placement rates in the for-profit college industry, the proposals by the working group on Job placement are timely, thoughtful, and practical We applaud the Members of Congress who recently sent a fetter to Secretary Duncan urging the Administration to move decisively towards issuing a final regulation, We thank you for your leadership in secking to improve higher education and career opportunities for all Americans. We and our members and supporters stand with you and look forward to the prompt issuance a strengthened gainful employment rule and other urgently needed steps to enforce current laws to better protect students, taxpayers, and our nation’s economy. Sincerely, AFL-CIO The American Association of State Colleges and Universities (AASCU) American Association of University Professors (AAUP) American Association of University Women (AAUW) American Federation of Teachers (AFT) Americans tor Financial Reform Association of the United States Navy (AUSN) Center for Law and Social Policy Center for Public Interest Law Center for Responsible Lending Children's Advocacy Institute Consumer Action Consumers Union Consumer Federation of California Couneil for Opportunity in Education Crittenton Women’s Union East Bay Community Law Center Generation Progress Initiative to Protect Student Veterans ‘The Education Trust The Institute for College Access & Success Institute for Higher Education Policy (HEP) lrag and Afghanistan Veterans of America (Ava) ‘The Leadership Conference on Civil and Human Rights Mississippi Center for Justice National Association for Black Veterans, Inc. (NABVETS) National Association for College Admission Counseling National Consumer Law Center (on bebalf of its low-income clients) National Consumers League ‘National Education Association ‘The National Guard Association of the United States (NGAUS) National Women Veterans Association of America New Economy Project (formerly NEDAP) NYPIRG Paralyzed Veterans of America Public Advocates Ine. Public Higher Education Network of Massachusetts (PHENOM) Public Citizen Rebuild the Dream Service Employees International Union Student Veterans of America United States Student Association US. PIRG Veteran Student Loan Relief Fund, Veterans Education Success Veterans for Common Sense Veilobs VetsFirst, a program of United Spinal AssociationLeague of United Latin American Citizens Vietnam Veterans of America MALDEF, Young Invincibles ce: Hon, Arne Duncan, Secretary of Education Hon. Cecilia Muftoz, Director, White House Domestic Policy Council Hon. Gene Sperling, Director, White House National Economic Council Hon, Syivia Mathews Burwell, Director, Office of Management and BudgetPauline Abernathy ‘Tuesday, February 04, 2074 9:26 AM Douglas_J_Kramer@who.eop.gov; Duncan, Ame; cmunez@who.eop.9ov, gsperiing@who.eop.cov, Sylvia_M._Burwell@omd eop.gov, Jason_L_Furman@cea.eop gov ce: James_R._kvaal@who.cop.gov, Coven, Martha B.; Studley, Jamie; Lachman, Sherry: bauguste@who.eop gov; sbaker@ovp.eop gov; Appel, Jeff; Danielle C_Gray@whe.cop.cov Subject: Letter to the President signed by more than £0 organizations urging @ stronger gainful employment regulation Attachments: Coalition teter to President in support of GE sent Feb 4 2014 paf On behalf of the coalition, attached and below is a letter to President Obama urging the Administration to promptly issue a strong and effective proposed gainful employment regulation so it can be finalized by November 1, 2014, and go into effect by July 1, 2015. The letter is signed by more than 50 organizations that work on behalf of students, college access, consumers, veterans, servicemembers, and civil rights. The letter states that, at a minimum, the regulation should include the following five elements: 1. A repayment rate or another metric to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding, 2. A meaningful approval process to weed out programs that will not prepare students for gainful employment in the specified occupations before they harm students. 3. Borrower relief that is fair and provides a greater incentive to improve weak programs. Meaningful debt-to-earnings standards. 5. Protection for schools offering low-cost programs in which most students do not borrow. Coalition members are also submitting requests for meetings with the Administration to discuss our views and answer any questions, consistent with Executive Order 12866. We thank the Obama Administration for its efforts to protect students and taxpayers from fraud and abuse in career education programs. The coalition stands ready to assist you in strengthening protections for taxpayers and students, including veterans and servicemembers who risked their lives to defend our country. Thank you. February 4, 2014 The Honorable Barack Obama President of the United States 1600 Pennsylvania Avenue Washington, DC 20500 Dear Mr. President: Our organizations—which work on behalf of students and college access, veterans, consumers, and civil rights—were heartened by your remarks fast August when you so effectively summed up the problems in the for-profit college industry: [Tyhere have been some schools that are notorious for getting students in, getting a bunch of grant money, having those students take out a lot of loans, making big profits, but having really low graduation rates. Students aren’t getting what they need to be prepared for a particular field. They get out of these for-profit schools loaded down with enormous debt. They ean’t find 1ajob. They default. The taxpayer ends up holding the bag. Their credit is ruined, and the for- profit institution is making out like a bandit. That's a problem. ‘Your administration now has an opportunity to better protect taxpayers and students, including our nation's veterans, service members and their families, from predatory career education programs. The Education Department is developing drati regulations to enforce the statutory requirement that all career education programs that receive federal funding, whether at for-profit, public or nonprofit colleges, “prepare students for gainful employment in a recognized occupation.” The negotiated rulemaking panel convened last year by the Department to develop the draft regulations was unable to reach consensus, Even after the Department made multiple changes requested by the for-profit college industry representatives that dramatically weakened the draft regulation, the for-profit college industry representatives abjected to it, ‘The changes would have made the regulation s0 weak on predatory colleges and so hard on low-cost, high-performing colleges that not a single negotiator Voiced support for the Departments last proposal. We urge the Administration to issue promptly a stronger, more effective proposed regulation so that the urgently needed rules can be finalized by November 1, 2014, and go into effect by July 1, 2015, Ata minimum, we believe the regulation should include the following five elements: 1. A repayment rate or another metric to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding. A low completion rate is one of the ways that programs can fail to prepare students for gainful employment, particularly when they leave school with substantial debt. But programs where 99% of the students drop out with heavy debt that they are unable to pay dawn could still pass the Department’s most recent proposal. A program-level cohort default rate (pCDR) was the only metric in that proposal to assess the outcomes of students who do not complete a program. However, a PCDR alone is not sufficient for at least two reasons. First, the well-documented manipulation of cohort default rates by some for-profit college corporations undermines their meaning, Second, defeult is an extreme situation, measuring whether borrowers have failed to make any required payments in at least 270 days and does not measure whether students are able to pay down their loans, To be clear, we believe that strong repayment rate or other mettic addressing programs with high borrowing and high dropout rates should be a separate requirement that gainful employment programs must pass, in addition to the other tests, in order to retain eligibility, 2, A meaningful approval process to weed out programs that will not prepare students for gainful employment in the specified occupations before they harm students. Programs that lack the programmatic accreditation or other attributes needed for geaduates to be hired in the field should not be eligible to receive taxpayer funds, yet the Department's most recent proposal would allow funding to continue to flow to these programs. For example, federal funding should not be available for dental assisting and other medical programs whose graduates are ineligible for the licensing exam required to work in that field. Subsidizing such programs misleads students, who trust the federal government to fund only worthwhile programs and is clearly inconsistent with the statutory requirement that all career education programs receiving federal funding “prepare students for gainful employment in a tecognized occupiti 3. Borrower relief that is fair and provides a greater incentive to improve weak programs. The Department proposed partial relief—at no cost to taxpayers—for some students who enroll in programs that the Department ultimately determines systematically and consistently fail to prepare students for gainful ‘employment in the specified occupations. We belicve students should not be responsible for any loans they received to attend such programs. Providing full relief to all such students is not only fair, it also provides a more effective incentive for schools to improve their progranis so they never have to provide such relief, 4. Meaningful debt-to-earnings standards. The debt-to-earnings standards in the Department's last proposal were so weak that literally thousands of programs with median and mean debt levels that exceed their 2graduates’ entire discretionary incomes would not fail the standards. This is clearly too low a standard. Students and taxpayers deserve better. 5. Protection for schools offering low-cost programs in which most students do not borrow. The final 2011 gainfut employment regulation automatically passed all iow-cost programs where the majority of graduates do not borrow. The federal district court reviewing the regulations upheld this provision, which recognized that such programs do not consistently leave students with unaffordable debts, ‘The new draft regulation should also. In contrast, the Department's last proposal would unintentionally jeopardize funding for many of these low-cost programs because the metrics would consider only students receiving Title IV fimding, which in many cases are a small, unrepresentative share of the program's students. These proposals would ineentivize more schools to Ieave the Federal student loan program, lead to the voluntary or involuntary closure of effective. low-cost programs, and is at odds with related statutory precedent which acknowledges the importance of the share of students borrowing in applying default rate sanctions. We believe these five elements are essential, but there are other areas in which thoughtful proposals were submitted by negotiators that merit further consideration, Several of the negotiated rulemaking panel working groups and individual negotiators developed detailed proposals to strengthen the regulation in important ways while reducing its burden on high-performing, low-cost colleges. For example, the Department's proposals do nothing to increase the accuracy or comparability of the job placcment rates that schools advertise to students. As the commissioner of the National Center for Education Statistics told the negotiated ralemaking panel in September, the exclusion of deceased students is just about the only thing that the many current definitions of job placement have in common. In light of this lack of comparability and the inereasing evidence of widespread manipulation and inflation of job placement rates in the for-prolit college industry, the proposals by the working group on job placement are timely, thoughtful, and practical. We applaud the Members of Congress who recently sent a letter to Secretary Duncan urging the Administration to move decisively towards issuing a final regulation. We thank you for your leadership in seeking to improve higher education and career opportunities for all Americans. We and our members and supporters stand with you and look forward to the prompt issuance a strengthened gainful employment rule and other urgently necded steps to enforce current laws to better protect students, taxpayers, and our nation’s economy. Sincerely, AFL-CIO The American Association of State Colleges and Universities (AASCU) American Association of University Professors (AAUP) American Association of University Women (AAUW) American Federation of Teachers (AFT) Americans for Financial Reform Association of the United States Navy (AUSN) Center for Law and Social Policy Center for Public Interest Law Center for Responsible Lending, Children's Advocacy Institute Consumer Action Consumers Union Consumer Federation of California Council for Opportunity in Education Crittenton Women’s Union East Bay Community Law Center Generation Progress Initiative to Protect Student Veterans The Education Trust‘The institute for College Access & Success Institute for Higher Education Policy (IHEP) Iraq and Afghanistan Veterans of America (JAVA) ‘The Leadership Conference on Civil and Human Rights, League of United Latin American Citizens MALDBE Mississippi Center for Justice ‘National Association for Black Veterans, Inc. (NABVETS) National Association for College Admission Counseling National Consumer Law Center (on behalf ofits low-income clients) National Consumers League National Education Association The National Guard Association of the United States (NGAUS) National Women Veterans Association of America New Economy Project (formerly NEDAP) NYPIRG Paralyzed Veterans of America Public Advocates Inc. Public Higher Education Network of Massachasetts (PHENOM) Public Citizen Rebuild the Dream Service Employees International Union Student Veterans of America United States Student Association U.S. PIRG ‘Veteran Student Loan Retief Fund Veterans Education Success Veterans for Common Sense Vetlobs VetsFirst, « program of United Spinal Association Vietnaim Veterans of America ‘Young Invincibles co: Hon, Ame Duncan, Secretary of Education Hon. Cecilia Muitoz, Director, White House Domestic Policy Council Hon. Gene Sperling, Director, White House National Economie Council Hon, Sylvia Mathews Burwell, Director, Office of Management and Budget Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 www ticas.org and www.projectonstudentdebt.orgFebruary 4, 2014 ‘The Honorable Barack Obama President of the United States 1600 Pennsylvania Avenue Washington, DC 20500 Dear Mr. President ‘Our organizations—which work on behalf of students and college access, veterans, consumers, and civil rights —were heartened by your remarks last August when you so effectively summed up the problems in the for-profit college industry: [T]here have been some schools that are notorious for getting students in, getting a bunch of grant money, having those students take out a lot of loans, making big pro{its, but having really low graduation rates. Students aren’t getting what they need to be prepared for a particular field. They get out of these for-profit schools ioaded down with enormous debt. They can’t find 2 job. They default, The taxpayer ends up holding the bag. Their credit is ruined, and the for-profit institution is making out like a bandit. That's a problem. ‘Your administration now has an opportunity to better protect taxpayers and students, including our nation’s vetcrans, service members and their famities, from predatory career education programs. ‘The Education Department is developing draft regulations to enfaree the statutory requirement that all eareer education programs that receive federal finding, whether at for-profit, pubtic or nonprofit colleges, “prepare stucents for gainful employment in a recognized occupation.” ‘The negotiated rulemaking, panel convened last year by the Department to develop the draft regulations was unable to reach consensus. Even after the Department made multiple changes requested by the for-profit college industry representatives that dramatically weakened the draft regulation, the for-profit college industry representatives objected to it, The changes would have made the regulation so weak on predatory colleges and so hard on low-cost, high-performing colleges that not a single negotiator voiced support for the Department's last proposal. We urge the Administration to issue promptly a stronger, more effective proposed regulation so that the urgently needed rules can be finalized by November I, 2014, and go into effect by July 1, 2015. Ata minimum, we believe the regulation should inchide the following five elements |. A repayment rate or another metric to effectively prevent programs with high borrowing and high dropout rates from receiving federal funding. A low completion rate is one of the ways that programs can fail to prepare students for gainful employment, particularly when they leave scliool vith substantial debt. But programs where 99% of the students drop out with heavy debt that they are unable to pay down could still pass the Department's most recent proposal. A program-level cohort default rate (pCDR) was the only metric in that proposal to assess the outcomes of students who do not complete a program. However, a pCDR alone is not sufficient for at least two reasons. First, the well-documented manipulation of cohort default rates by some for-profit college corporations undermines their meaning, Second, default is an extreme situation, measuring whetherborrowers have failed to make any required payrnents in at least 270 days and does not measure whether students are able to pay down their loans, To be clear, we believe that a strong repayment rate or other metric addressing programs with high borrowing and high dropout rates should be a separate requirement that gainful employment programs must pass, in addition to the other tests, in ‘order fo retain eligibi 2. A meaningful approval process to weed out programs that will not prepare students for gainful ‘employment in the specified occupations before they harm students. Programs that lack the programmatic acereditation or other attributes needed for graduates to be hired in the field should not be eligible to receive taxpayer funds, yet the Department's most recent proposal would allow. fanding to continue to flow to these programs. For example, federal funding should not be available for dental assisting and other medical programs whose graduates are ineligible for the licensing exam required to work in that field. Subsidizing sach programs misleads students, who trust the federal government to fund only worthwhile programs and is clearly inconsistent with the statutory requirement that all career education programs receiving lederal funding “prepare students for ‘gainful employment in a recognized occupation.” Borrower relief that is fair and provides a greater incentive to improve weak programs. The Department proposed partial relief—at no cost to taxpayers-—for some students who entoll in programs that the Department ultimately determines systematically and consistently fail to prepare students for gainful employment in the specified occupations. We believe students should not be responsible for any loans they teceived to attend such programs. Providing full relief to all such students is not only fair, it also provides a more effective incentive for schools to improve their programs so they never have to provide such relief, 4, Meaningful debt-to-earnings standards, ‘The debt-to-earnings standards in the Department's last proposal were so weak that literally thousands of programs with median and mean debt leveis that ‘exceed their graduates" entire discretionary incomes would not fail the standards. This is clearly too lowa standard, Students and taxpayers deserve better. 5. Protection for schools offering low-cost programs in which most students do not borrow, The final 201 { gainful employment regulation automatically passed all low-cost programs where the majority of graduates do not borrow. ‘The federal district court reviewing the regulations upheld this provision, which recognized that such programs do not consistently leave students with unaffordable debts. The new draft regulation should also. In contrast, the Department's last proposal would unintentionally jeopardize funding for many of these low-cost programs because the metries would consider only students receiving Title LV funding, which in many cases area small, unrepresentative share of the program’s students, ‘These proposals would incentivize more schools to leave the Federal student Joan program, lead to the voluntary or involuntary closure of effective, fow-cost programs, and is at odds with related statutory precedent which acknowledges the importance of the share of students borrowing in applying default rate sanctions. We believe these five elements are essential, but thete are other areas in which thoughtful proposals were submitted by negotiators that merit further consideration. Several of the negotiated rulemaking panel working groups and individual negotiators developed detailed proposals to strengthen the regulation in important ways while reducing its burden on high-performing, low-cost colleges, Forexample, the Department's proposals do nothing to increase the accuracy or comparability of the job placentent rates that schools advertise to students. As the commissioner of the National Center for Education Statistics tald the negotiated rulemaking panel in September, the exclusion of deceased students is just about the only thing that the many current definitions of job placement have in common, Jn light of this lack of comparability and the increasing evidence of widespread manipulation and inflation of job placement rates in the for-profit colfege industry, the proposals by the working group on Job placement are timely, thoughtful, and practical. We applaud the Members of Congress who recently sent a letter to Secretary Duncan urging the Administration to move decisively towards issuing a final regulation. We thank you for your leadership in seeking to improve higher education and career opportunities for all Americans. We and our members and supporters stand with you and look forward to the prompt issuance a strengthened gainful employment rule and other urgently needed steps to enforce current laws to better protect students, taxpayers, and our nation’s economy. Sincerely, APL-C1O ‘The American Association of State Colleges and Universities (AASCU) American Association of University Professors (AAUP) American Association of University Women (AAUW) American Federation of Teachers (AFT) Americans for Financial Reform Association of the United States Navy (AUSN) Center for Law and Social Policy Center for Public Interest Law Center for Responsible Lending Children’s Advocacy Institute Consumer Action Consumers Union Consumer Federation of California Council for Opportunity in Education Crittenton Women’s Union East Bay Community Law Center Generation Progress Initiative to Protect Student Veterans The Education Trust ‘The Institute for College Access & Success Institute for Higher Education Poticy (HEP) Iraq and Afghanistan Veterans of America (AVA) ‘The Leadership Conference on Civil and Human Rights i Center for Justice ‘National Association for Black Veterans, Inc. (NABVETS) National Association for College Admi ‘Counseling National Consumer Law Center (on behalf of its low-income elients) National Consumers JLeague National Education Association ‘The National Guard Association of the United States (NGAUS) National Women Veterans Association of America New Economy Project (formerly NEDAP) NYPIRG Paralyzed Veterans of America Public Advocates Inc, Public Higher Education Network of Massachusetts (PHENOM) Public Citizen Rebuild the Dream Service Employees International Union Student Veterans of America United States Student Association USS. PIRG Veteran Student Loan Relief Fund Veterans Education Success Veterans for Common Sense Vetlobs VetsFirst, a program of United Spinal AssociationLeague of United Latin American Citizens Viemam Veterans of America MALDEF Young Invincibles Hon. Arne Duncan, Secretary of Education Hon, Cecilia Mufioz, Director, White House Domestic Policy Couneil Hon, Gene Sperling, Director, White House National Economic Council Hon. Syivia Mathews Burwell, Director, Office of Management and BudgetMeGinris, Colleen ‘Wednesday, December 18, 2013 6:54 PM Runcie, James FW; share of borrowers repaying their loans using aulomatic electronic payments maybe we can bring this up at our meeting tomorrow morning with MK? you seemed to be fine to do only DL borrowers but wanted to check with LBJ. | have the data and wit bring in ear in case you want to bring it up. Sent with Good (www, good.com) Original Message. From: Pauline Abernathy [pabemathy/@ticas.org Sent: Wednesday, December 18, 2013 01:06 PM Central Standard Time To: McGinnis, Colicen Subject: RE: share of borrowers repaying their loans using automatic electronic payments will do, thank you! From: McGinnis, Colleen (mailto:Colleen.McGinnis@ed.gov] Sent: Wednesday, December 18, 2013 1:59 PM To: Pauline Abernathy ‘Subject: RE: share of borrowers repaying their loans using automatic electronic payments My sincere apologies. Because | got the data after your deadline, | did not get sign-off on public release. Let me de that. Ping me tomorrow afternoon if you don't hear from me, please? Best, Colleen From: Pauline Abernathy [mailto:pabernathy@ticas.ora] ‘Sent: Tuesday, December 17, 2013 3:53 PM To: McGinnis, Colleen ‘Subject: RE: share of borrowers repaying their loans using automatic electronic payments Any update on this? It would still be extremely helpful. Thank you! Pauline From: Pauline Abernathy Sent: Wednesday, November 06, 2013 1:30 PM To: ‘McGinnis, Colieen’ Subject: RE: share of borrowers repaying their loans using automatic electronic payments Any luck with this? The Lumina meeting is tomorrow. Pauline From: McGinnis, Coleen [maillo:Calleen McGiinnis@ed gov) Sent: Saturday, October 26, 2013 11:07 PMTo: Pauline Abernathy Subject: FW: quick question (I hope) Pauline: Please don't think | forgot about this. Looks like we can get you something later this week. Please call if you have additional questions. Best, Colleen Sent with Good (www.good.com) --—-Original Message- From: Greene, Chris Sent: Saturday, October 26, 2013 07:50 AM Central Standard Time ‘To: McGinnis, Colleen Subject: Re: quick question (I hope) Yes, | think we'll have it later this week, Sent from my BlackBerry Wireless Device From: McGinnis, Colleen ‘Sent: Saturday, October 26, 2013 07:48 AM Eastern Standard Time To: McGinnis, Colleen; Greene, Chris Subject: RE: quick question (I hope) Hi Chris: Any update on when this request will be fulfilled? Thanks in advance, Best, Colleen From: McGinnis, Colleen Sent: Friday, October 18, 2013 12:14 PM To: Greene, Chris ‘Subject: RE: quick question (I hope) Taanks Chris. That's fine...u! think Pauline even considers that option in her request. From:Greene, Chris Sent: Friday, October 18, 2013 12:14 PM To: McGinnis, Colleen Subject: RE: quick question (I hope) Just so you know, we may only be able to get this for DL borrowers, 'll have a better idea of what's available on Monday. From:McGinnis, Cofleen Sent: Friday, October 18, 2013 11:50 AMTo: Greene, Chris; FSA Data Request Subject: RE: quick question (I hope) Many thanks Chris. | see the error of my ways......one of these days lam going to properly and timely submit a request. Now the entire board knows what's coming. | realized it when I received my own email. Ugh. Colleen From:Greene, Chris Sent Friday, October 18, 2023 11:48 AM To: FSA Data Request Ce: McGinnis, Colleen Subject: FW: quick question (I hope) Thanks Colleen, we'll ook into this. Chris From:MeGinnis, Colleen ‘Sent Friday, October 18, 2013 11:46 AM To: FSA Data Governance Board Cc: Fare, John; Greene, Chris; Filinich, Mike Subject: FW: quick question (E hope) Hi: This came in this morning. They hope to have the paper written by November 5, 2013. Possible to meet that deadline? Thanks for any information in advance. Regards, Colleen McGinnis US. Department of Education Office of the Chief Operating Officer Seniar Advisor 1830 First St. N.E, 1121 ‘Washington, DC 20202-5145 (w) 202-377-4330 Colleen McGinnis@ed.aou Student Aid.coy Federal Student Aic! | mosses snathy@lticas.or9] Sent: Friday, October 18, 2013 10:39 AM To: McGinnis, Colleen Subject: quick question (I hope) Colleen, Do you know or do you know who would know the share of borrowers repaying their loans using automatic electronic payments (ie those getting the 0.25% reduction on their interest rates), either just DL or all federal aloans? We're writing a paper for Lumina on “passive repayment systems” and it would be helpful to know if most or just a few borrowers are currently paying automatically. Thanks in advance for any help you can provide. Pauline Pauline Abernathy Vice President, The Institute for College Access & Success Direct: 202.223.6060 x603 Main: 510.318.7900 wawweticas.org and www.projectonstudentdebt.orgHolland, Linda Debbie Cochrane ‘Thursday, December 12, 2013 5:14 PM ‘Appel, Jeff, Kanter, Martha; Gomez, Gabriella; Beker, Jeff; Runcie, James; Gast, Sara Protopsaltis, Spiros; Stualey, Jamie: McGinnis, Colleen Lauren Asher; Pauline Abernathy FYI: New TICAS biog post on CDRs and PRI As you are all aware, we have long been and remain concerned that insufficient information about what CDRs mean for boti students and colleges is contributing to community colleges ieaving the federal student loan program. As you can see from our most recent blog post, posted yesterday and pasted below, there are concrete steps the Department can take that would not be burdensome for the Department to implement. As alternate financial aid negotiator Rhonda Mohr brought up at the gainful employment regulation negoti in November, this becomes an even bigger concern with the pCDRs in the draft gainful employment regulation. The gainful employment regulation presents an opportunity to improve the administration of the PRI for both institutional and program CDRs so that more commrunity colleges do not leave the foan program. As always, please reach out if we can answer questions or be of assistance. ions, Debbie Cochrane Research Director The Institute for College Access & Success 405 Lath Street, Suite 1100 Oakland, California 94612 office: (510) 318-7900 // fax: (510) 318- 7918 deochrane(@itieas.org saw ticas.org www projectonstusientdebt org www college-insiaht.ore U.S. Department of Education Strikes Out on CDRs Posted on December 11, 2013 by admin In the last three months, the U.S. Department of Education has struck out on clarifying what cohort default rates (CDRs) mean for students and colleges, prompting some colleges to stop offering federal student loans, The Department needs to provide better guidance to colleges on how to lower their CDRs while providing timely assurances to colleges with low borrowing rates so they do not needlessly pull out of the loan program, denying their students the safest way to borrow. ‘A new proposal to use proaram-level CORs only increases the urgent need for action by the Department. Strike One: A Murky Scorecard In September, the Department released new CDRs for the nation’s colleges. But once again, it failed to provide the information necessary to Interpret what the rates mean. CDRs are the primary measure of college accountability, They measure the shere of colleges’ federal student loan borrowers who default soon after entering repayment, an important measure of student outcomes. For colleges where 1‘most or alf students borrow, CDRs can tell you a lot: high CDRs are a clear sign that students who attended that college are not faring well, and suggest that the college may not be a good investment for students or taxpayers. But for colleges where only a handful of students borrow, CDRS give fewer clues about how the colleges’ students are doing, The problem is that the Department once again did not pair CDRs with colleges’ borrowing rates, as we have long asked them to do. That means that students from a particular college may appear very likely to default when, in fact, they are very unlikely to defoul because they are very unlikely to have to borrow at all. This is not helpful to students, journalists, or college leaders. Strike Two: A Confusing Rulebook Federal law acknowledges the importance of the borrowing rate in evaluating CDRs: colleges with high CDRs may lose eligibility for federal grants and toans, but colleges with few borrowers can avoid sanctions under what's called 2 “participation rate index (PRI) appeal.” Nonetheless, misunderstandings about CDRs and the PRI have snarked unnecessary fears in some colleges ~ particularly ‘community colleges — that they will be sanctioned, leading some institutions to pull out of the federal loan program entirely. This is most obvious (but certainly not only true) in California, where borrowing rates at the vast majority of community collegas are in the single digits ~ wall within the range eligible to appeal CDR sanctions, Without access to federal loans, students who need to borrow to attend college must either drop out or turn to more expensive and riskier forms of debt, including private loans or credit cards. Yet community colleges in California continue to ston offering loans, citing fears of CDR sanctions as their rationale. We have long encouraged the Department to issue public guidance to colleges describing the appeals options availabie to them, and underscoring the importance of federal foan access for students, but to date it has not done so. Strike Three: Silent Umpires ‘The type of sanction community colleges fear most is the loss of federal Pell Grants, which can occur after three consecutive CDRs at or above 30 percent. Collages subject to this sanction lose Pell Grant elighbilty immediately, but they can appeal the sanction if their borrowing rate in any one of the three consecutive cohorts is sufficiently low. However, the Department will not confirm that the colleges’ borrowing rates are low enough to appeal sanctions until the college's third consecutive high CDR, which is very late in the game. It is so late, in fact, that at that point there is no other way for the college to avoid sanctions, should its appeal be rejected, since it cannot influence default retes for years past, By year three, the college faces sanctions within mere months. With the stakes so high, it is no wonder that some colleges opt to stop offering loans fong before a third consecutive high CDR. Simply put, colleges need to understand their risks and options on an annual basis so that they can work to reduce defaults and continue to offer federal loans. The Department could easily inform colleges whether their CDRs will count towards sanctions, as we have recommended. Unfortunately, the Department has declined to do so, claiming that it would impose an “unmanageable workload” on its staff, However, the annual burden on the Department would be minimal, as few schools with borrowing rates low encugh to qualify for the PRI have CDRs that would trigger sanctions in the first place. The Department also argued that colleges have sufficient time to avoid losing Pell Grant eligibility, since they can currentiy appeal when their third high COR is in Graft, rather than final, form. But this misses the point and ignores what we already know: without the right assurancesfrom the Department earlier in the process, colleges will stop offering federal loans after their first or second year with hhigh default rates, ‘The Next At Bat: Gainful Employment While the Department has struck out when it comes to CDRs, itis still in the game, and the ongoing gainful employment ciscussions ~ which continue next week — underscore the nead for them to act. ‘The Department's latest gainful employment proposal would expand CDRs to measure program-tevel default rates (PCDRs) for career education programs, and cut off eligibility for programs where default rates are too high. Existing protections ~ ike the PRT appeal option ~ would carry aver fram CDRs to pCORS, but that is litle consolation for colleges ‘given the current confusion and concern about PRI appeals. Most career education programs are located at community colleges, where borrowing rates are low and fears of sanctions are high. The Department needs to improve the PRI process to prevent more of these colleges from exiting the loan program ~ a trend that risks pushing more students to drop out or take out private loans, and reducing affordable career education program options instead of ensuring them. = Debbie Cochrane and Matthew La Rocque Posted in California Access & Success, Federal and State Policy | Tagged Cohort Default Rates, Loan Participation, Participation Rate Index | Leave a commentHolland, Linda Gast, Sara ‘Thursday, December 12, 2013 2:45 PM ‘Menon, Ajita 7. ‘Kvael, James’; ‘Rodriguez, Roberto’ 'Lehrich, Matt ‘Careoll, Brad? Studley, Jamie; Appel, Jeff, Gomez, Gabriela; Spector, Stephen; Nolt, Dorie, Ritsch, Massie: Soo, David; Cubarrubia, Archie, Runcie, James, Greene, Chris; Bhagat, Wendy: Hendorson. Jesh, Vadehra, Emma; Valerius, Matthew, Spector, Stephen; Wall, Mary: Darnieder, Greg’ Kanter, Martha; Muenzer, Melanie Subject: RE: Materials for tomorrow's college announcements Hi ali— per our check-in call today, just wanted to flag this readout and update you on a couple of additional stories we've seen this week about the toolkit, The Michigan piece is especially good, ew federal website Grand Rapids Press The federal government has a new online "Financial Aid Toolkit" that West Michigan guidance counselors and educators hope achieves its goal of making it easier for them to guide students through the process of selecting and financing their higher education. ... Fmmaune] Armstrong, counselor coordinator and lead for parental engagement at Grand Rapids schools, is already sharing the DOE site with his colleagues. “Students rely heavily on their guidance counselors to assist them and their parents with navigating the financial aid system for college,” he said. “Our number one focus is on pushing that graduation rate up and preparing students for what comes next. It would absolutely be a plus if this new tool can improve the process.” for college College Tips: Feds introduce new financial toolkit to help navizate application process New Jersey Star-Ledger Continuing its effort to simplify the college search process, the Obama administration has introduced a Financial Aid Tooikit. a web-based service that offers help to student counselors, mentor and families understand the process. The website is being promoted as “one-stopping shopping” for everything from finding to financing a higher education U.S. Department of Education Launches Financial Aid Toolkit U.S. News University Directory (subset project of U.S. News & World Report) Students may soon pick up on a marked improvement in the quality of the assistance they receive from guidance counselors and academic advisers during their college search, That's because the U.S. Department of Education has launched its Financial Aid Toolkit - a new online resource designed to make learning about financial aid a lot easier. eSchoolNews also ran the press release. From: Gast, Sara Sent: Thursday, December 05, 2013 4:27 PM Tos "Menon, Ajita T.; 'Kvaal, James’; ‘Rodriguez, Roberto’; 'Lehrich, Matt’; ‘Carroll, Brad’ tudiey, Jemie; Appel, Jeff; Gomez, Gabriella; Spector, Stephen; Nolt, Dorie; Ritsch, Massie; Soo, David; Cubarrubia, Archie; Runcie, James; Greene, Chris; Bhagat, Wendy; Henderson, Josh; Vadehra, Emma; Valerius, Matthew; Spector, Stephen; Wall, Mary Catherine; Darnieder, Greg; Kanter, Martina; Muenzer, Melanie Subject: RE: Materials for tomorrow's college announcements. Hi team WH ~ a readout of the roliout is below. Thanks so much for your help! To make sure that we do what we said we were going to do, ie submit the ratings RFI to the FR this week, we need to have your comments back tonight so we can re-clear it through ED and get to the FR tomorrow afternoon, Can you confirm with us that that’s possible? Thanks!Sara ‘Thanks 50 much for all your help with the financial sid toolkit + ex-sites + RFI announcement, and —for many of you~ for ‘the work you are continuing to do in the coming days to push out this message and the toolkit to various counselor and consumer groups in the coming days. Here are some of the pieces we have out there so f + Press release ‘+ Blog ost, which is cross-posted on the WH blog ~ and at least a couple of follow-up blogs about the toolkit are in the works + Several tweets from @ArneDuncan @usedgov @FAFSA @FSAconf and @FLOTUS (+200 RTs) about the tootkit, and somehow it also made its way to Pinterest * The toolkit fact sheet ‘+ Ame formally announces the toolkit and the ex-sites plans in his remarks at the FSA conference (remarks will be posted online soon}, and it made its way into some stories and TV clips about his visit to Las Vegas + ADear Colleague Letter for ex-sites and IFAP notice about the toolkit also were published + The exsites Federal Register notice will publish tomorrow, and we hope to submit the ratings RFI to the Federal Register tomorrow, pending feedback from DPC * Many outreach calls, with a special thanks to Jamie, Jeff, David, Greg, Karen and Jodie for talking with some of ‘ur key groups to explain the toolkit and encourage them to share it with their networks, as well as the Wendy, Tina and Cindly for pulling all of those pieces together. Those efforts, along with the follow-up outreach from OCO, OVAE, OPE (especially among the TRIO/GEAR-UP communities}, OUS and especially FSA, we hope wil result in more amplification and spreading of this information in the coming days. We have already seen several ‘groups share our language with their networks verbatim. + If youstll need TPs, some are attached. Somewhat related, as many of you know, TICAS (which Jamie called on Tuesday evening) released its annual student debt report on Wedaesday, and the toolkit actually made it into some of those clips as well ike the Stateline wire story. Some of the additional clips from coverage so far are below. Thanks again for all your help! New federal ‘financial aid toolkit? for coltexe The Washington Post The federal government on Wednesday rolled out an online “financial aid toolkit” for guidance counselors, parents and others to help students learn about funding options for colleze, The Web site, operated by the Education Department, is onc of several Obama administration initiatives aimed at helping consumers navigate the ofien-bewildering higher education market. "By equipping counselors and mentors with financial aid information, we ean help to ensure current and potential students are getting the assistance they need to successfully navigate the process of planning and paying for a postsecondary education,” said Education Seeretary Ame Duncan in a news release. Education Dept. rolls out website to assist adults helping students with college applications The Associated Press ‘The Education Department has created an online financial aid toolkit aimed at helping guidance counselors and others who advise students with college applications. The toolkit ean be found at htip:/financialaidtoolkit.ed.gov . It has details about applying for financial aid and repaying student loans. It also has other information such as documents advisers can download and information about professional development information. It is one of the measures the Obama administration has taken to make the college application process go smoother. Education Department Launches Site Aimed at Guidance Counselors Inside Higher Ed‘The Obama administration on Wednesday unveiled a new web portal aimed at the people who help students and families prepare for college. The site aggregates a range of Education Department resources and promotional material meant to encourage students to attend college and take advantage of federal student aid programs. Guidance counselors and other mentors are able to search a database containing infographies, fact sheets, videos, and other presentation materials relating to the financial aid process. nline Toolkit’ Gathers Information About Federal Student Aid The Chronicle ‘The U.S, Department of Education on Tuesday unveiled an online Financial-Aid Toolkit that gathers information about student aid into a single database, in an effort to make it easier for guidance counselors and advisers to help students plan for college, The searchable database includes a variety of materials, including brochures, presentations, videos—and even sample tweets and Facebook posts that counselors can use to encourage students to complete the Free Application for Federal Student Aid. The documents and olher materials cover issues spanning the financial aspects of college attendance: from applying for financial aid to paying off student loans. Secretary of Education Ame Duncan said in a written statement: "By equipping counselors and mentors with financial-aid information, we can help to ensure current and potential students are getting the assistance they need to successfully navigate the process of planning and paying for a postsecondary education.” Departs Hf Education Launches Financial Aid Toolkit Website NewsOne and BlackAmericaWeb.com The U.S. Department of Education announced Wednesday the launch of a new website that will support college advisers and guidance counselors in selecting the best couse of access and affordability for prospective students. The Financial Aid Toolkit combines the vast scope of financial aid resources and other related materials into a large, searchable database. Website is a one stop shop for applying for financial aid for college WWMT Michigan A new website created by the federal government hopes to help more students get into college. The idea is to have ail the info needed in one place to make it easier for students applying to college. The Education Department has created this on-line tool kit to help guidance counselors, parents and students with college applications. It has details about applying for financial aid and repaying student loans. It also has other information such as documents advisers can download and professional development information, Education secretary stavs busy on whirlwind day in Las Vegas Las Vegas Sun USS. Education Secretary Arne Duncan was in town Wednesday to promote a wide range of education initiatives, including a new financial aid website, higher academic standards and more collaborative career- technical education, In the morning, Duncan unveiled a website to 6,000 finaneial-aid officers attending a conference at Mandalay Bay. The “Financial Aid Toolkit” website was created for high schoo! seniors and their guidance counselors. I serves as a one-stop shop for information and resources related to federal financial aid and loan repayment programs, Duncan said. Education Dept. Seeks Ideas for Experiments in Cutting College Costs Chronicle of Higher Education ‘The U.S. Department of Education on Wednesday called on higher education to submit ideas for “experimental sites” that will test innovative ways of reducing the cost of college. The sites, which wete mentioned in the college-aftordability plan President Obama introduced in August and will be outlined in a notice to be published in the Federal Register on Friday, present an opportunity to formally test the merits of a variety of ideas that have gained traction in higher education, such as competency-based learning. Targeted experimentation—on aparticular campus, say—has long been an option available to the department, which is authorized to waive certain federal financial-aid rules for such sites. U.S. Seeks Experiments on New Models of Higher Inside Higher Ed ‘The Obama administration is moving ahead with plans to waive certain federal student aid rules for a limited number of colleges that want to experiment with competency-based education and other innovative forms of higher education. Officials are soliciting suggestions on what those experiments should look like, according to a notice set to be published in the Federal Register this week. The Education Department said it is “particularly interested in experiments that are designed to improve student persistence and academic success, result in shorter time to degree, including by allowing students to advance through educational courses and programs at their own pace by demonstrating academic achievement, and reduce reliance on student loans.” CALL FOR EXPERIMENTAL SITES IDEAS FOCUSES ON COMPETENCY, DUAL ENROLLMENT, PRIOR LEARNING Politico ‘The Education Department is looking for ideas on using its experimental sites authority, which waives some financial aid requirements so that colleges can conduct observed, controlled experiments, to expand competency-based education, dual enrollment programs and prior learning assessments, among others. In a notice that will be published in Friday's Federal Register, the Education Department names those three areas as ripe for experimentation and calls for « rough outline of what regulations colleves would waive and how they would measure their results. "We are particularly interested in experiments that are designed to improve student persistence and acaclemic success, result in shorter time to degree, including by allowing students to advance ‘through educational courses and programs at their own pace by demonstrating academic achtevement, and reduce reliance on student loans,” the department writes. COLLEGES WELCOME EXPERIMENTAL SITES EXPANSION Politico At least nine colleges said Wednesday they are already designing experiments allowing more flexibility with federal financial aid rules: Brandman University, Charter Oak State College, Excelsior College, Kentucky Community and Technical College System, Lipscomb University, Southern New Hampshire University, Westminster College, University of Wisconsin-Extension and University of Maryland University College. From: Gast, Sara Sent: Wednesciay, December 04, 2013 9:38 AM Tot ‘Menon, Ajta T.'; Muenzer, Melanie; 'Kvaal, James’; ‘Rodriguez, Roberto’; ‘Lehrich, Matt’; ‘Carroll, Brad’ Ce: Studley, Jamie; Appel, Jeff; Gomez, Gabriella; Spector, Stephen; Nolt, Dorie; Ritsch, Massie; Soo, David; Cubarrubia, ‘Archie; Runcle, James; Greene, Chris; Bhaget, Wendy; Henderson, Josh; Vadehra, Emma; Valerius, Matthevr; Spector, Stephen; Wall, Mary Catherine ; Darnieder, Greg; Kanter, Martha ‘Subject: RE: Materials for tomorrow's collage announcements And sorry ~ to clarify, these materials are going out this am. (Our email had problems last night and a lot of messages got stuck sending.) We've continued to get a lot of positive feedback fram NACAC and College Board as well as ASCA. Stephen collected the clips below to give you a sense of coverage so far, Many thanks! Education Dept, rolls out website to assist adults helping students with college applications ‘The Associated PressThe Education Department has created an online financial aid toolkit aimed at helping guidance counselors and others who advise students with college applications. The toolkit can be found at hitp/financialaidtoolkited.sov . It has details about applying for financial aid and repaying student loans, It also has other information such as documents advisers can download and information about professional development information. It is one of the measures the Obama administration has taken to make the college application process go smoother. Education Department Launches Site Aimed at Guidance Counselors Inside Higher Ed ‘The Obama administration on Wednesday unveiled a new web portal aimed at the people who help students and families prepare for college. The site aggregates a range of Education Department resources and promotional material meant to encourage students to attend college and take advantage of federal student aid programs. Guidance counselors and other mentors are able to search a database containing infographies, fact sheets, videos, and other presentation materials relating to the financial aid process, POLITICO -- EDUCATION DEPARTMENT: LEND US YOUR EXPERTISE: The Education Department is submitting its request for information to the Federal Register this week, looking for experts and researchers (0 help develop its new college rating system, And it’s looking for advice on how to use its experimental sites authority — giving colleges some flexibility on financial aid regulations if they participate in controlled experiments — to spread innovation from campus to campus, The department has also created a new website to help navigate the financial aid process, aimed at counselors and others who work with students. The site: http:/financialaidtoolkit.ed.gov, Online ‘Toolkit! Gathers Information About Federal Student Ai The Chronicle The U.S. Department of Education on Tuesday unveiled an online Financial-Aid Toolkit that gathers information about student aid into a single database, in an effort to make it easier for guidance counsclors and advisers to help students plan for college. ‘The searchable database includes a variety of materials, including brochures, presentations, videos—and even sample tweets and Facebook posts that counselors ean use to encourage students to complete the Free Application for Federal Student Aid. The documents and other materials cover issues spanning the financial aspects of college attendance: from applying for financial aid to paying off student loans. Secretary of Education Ame Duncan said in a written statement: "By equipping counselors and mentors with financial-sid information, we can help to ensure current and potential students are getting the assistance they need to successfully navigate the process of planning and paying for a postsecondary education." Website is a one stop shop for applying for financial aid for college WWMT Michigan Anew website created by the federal government hopes to help more students get into college. The idea is to have all the info needed in one place to make it easier for students applying to college. The Education Department has created this on-line tool kit to help guidance counselors, parents and students with college applications. It has details about applying for financial aid and repaying student loans. Tt also has other information such as documents advisers can download and professional development information. From: Gast, Sara Sent: Wednesday, December 04, 2013 9:26 AM To: ‘Menon, Ajita T.'; Muenzer, Melanie; 'Kvaal, James’; ‘Rodriquez, Roberto’; ‘Lehrich, Matt; ‘Carroll, Brad! Cec; Studley, Jemie; Appel, Jett; Gomez, Gabriella; Spector, Stephen; Nolt, Dorie; Ritsch, Massie; Soo, David; Cubarrubia, Archie; Runcie, Jemes; Greene, Chris; Bhagat, Wendy; Henderson, Josh; Vadehra, Emma; Valerius, Matthew; Spector, 5Stephen; Wall, Mary Catherine ; Darnieder, Greg; Kanter, Martha Subject: RE: Materials for tomorrow's college announcements ‘Attached are our final press release and blog post. We'll send this out at 10 and post the blog on our site then. Matt, can flag that for you for cross-posting consideration. We'll also have the twitters going, and the First Lady's office has also offered to help with a tweet. We had some early validator calls today that were encouraging, particularly with NCAN and NASFAA (ASCA is calling us back in the morning). Stephen shared the embargoed release with the AP, Politico, Wash Post, NYT, Inside Higher Ed, the Chronicle, and Diverse Issues, so that’s fikely where this will be in the morning, ‘Thanks so much for all your help! [exerGaHolland, Linda —=_—S.?”#_ From: Gast, Sara Sent: ‘Thursday, December 05, 2013 4:27 PM To: ‘Menon, Ajta T.; 'Kvaal, James’, ‘Rodriguez, Roberto! Lehrich, Matt: ‘Carrot, Brad’ Ce: Studley, Jamie; Appet, Jeff, Gomez, Gabriela; Spector, Stephen; Nolt, Dorie; Ritsch, Massie, Soo, David; Cubarrubia, Archie; Runcie, James; Greene, Chris; Bhagat, Wendy; Henderson, Josh; Vadehra, Emma; Valerius, Matthew, Spactor, Stephen; Wall, Mary Catherine, Darnieder. Greg; Kanter, Martha; Muenzet, Melanie ‘Subject: RE: Materials for tomorrow's college announcements Hi team WH a readout of the rollout is below, Thanks so much for your help! To make sure that we do wht we said we were going to do, ie submit the ratings RFI to the FR ti's week, we need to have your coinments back tonight so we can re-clear it through ED and get to the FR tomorrow afternoon. Can you confirm with us that that’s possible? Thanks! Sara ‘Thanks so much for all your help with the financial aid toolkit + ex-sites + RFI announcement, and ~ for many of you ~ for the work you are continuing to do in the coming days to push out this message and the toolkit to various counselor and consumer groups in the coming days. Here are some of the pieces we have out there so far: © Press release * Blog post, which is cross-posted on the WH blog ~ and at least a couple of follow-up blogs about the toolkit are in the works + Several tweets from @ArneDuncan @usedgov @FAFSA @FSAconf and @FLOTUS (+200 RTs) about the toolkit, and somehow it also made its way to Pinterest, ‘The toolkit fact sheet Arne formally announced the toolkit and the ex-sites plans in his remarks at the FSA conference (remarks wil be posted online soon}, and it made its way into some stories and TV clips about his visit to Las Vegas + A Dear Colleague Letter for ex-sites and |FAP notice about the tooliit also were published + The ex:sites Federal Register notice will publish tomorrow, and we hope to submit the ratings RF! to the Federal Register tomorrow, pending feedback fram DPC ‘+ Many outreach calls, with a special thanks to Jamie, Jeff, David, Greg, Karen and Jodie for talking with some of our key groups to explain the toolkit and encourage them to share it with their networks, as well as the Wendy, Tina and Cindy for pulling all of those pieces together. Those efforts, along with the follow-up outreach from ‘0CO, OVAE, OPE (especially among the TRIO/GEAR-UP communities), OUS and especially FSA, we hope will resutt in more amplification and spreading of this information in the coming days. We have already seen several groups share our language with their networks verbatim. * Hyou still need TPs, some are attached. Somewhat related, as many of you know, TICAS (which jamie called on Tuesday evening) released its annual student debt report on Wednesday, and the toolkit actually made it into some of those clips as well ike the Stateline wire story. Some of the additional clips from coverage so far are below. Thanks again for all your help! New federal ‘financial aid toolkit’ for college ‘The Washington Post ‘The federal government on Wednesday rolled out an online “financial aid toolkit” for guidance counselors, parents and others to help students learn about funding options for college. The Web site, operated by the Education Department, is one of several Obaina administration initiatives aimed at helping consumers navigate the often-bewilderiag higher education market. “By equipping counselors and mentors with financial aid information, we can help to ensure current and potential students are getting the assistance they need to :successfully navigate the process of planning and paying for a postsecondary education,” said Education Secretary Ame Duncan in a news release. Edueation Dept. rolls out website to assist adults helping students with college applications The Associated Press ‘The Education Department has created an online financial aid toolkit aimed at helping gaidance counselors and others who advise students with college applications, The toolkit can be found at hutp/financialaidicalkived.gov . It has details about applying for financial aid and repaying student loans. It also has other information sueh as documents advisers can download and information about professional development information. It is one of the measures the Obama administration has taken to make the college application process go smoother. Education Department Launches Site Aimed at Guidance Counselors Inside Higher Ed ‘The Obama administration on Wednesday unveiled a new web portal aimed at the people who help students and families prepare for college. The site aggregates a range of Education Department resources and promotional material meant to encourage students to attend college and take advantage of federal student aid programs. Guidance counselors and other mentors are able to search a database containing infographies, fact sheets, videos, and other presentation materials relating to the financial aid process. Online Toolkit’ Gathers Information About Federal Student Aid The Chronicle The U.S, Department of Education on Tuesday unveiled an online Finaneial-Aid Toolkit that gathers formation about student aid into a single database, in an effort to make it easier for guidance counselors and advisers to help students plan for college. The searchable database includes a variety of materials, including brochures, presentations, videos—and even sample tweets and Facebook posts that counselors can use to encourage students to complete the Free Application for Federal Student Aid, The documents and other materials cover issues spanning the financial aspects of college attendance: from applying for financial aid to paying off student loans. Secretary of Education Arne Duncan said in a written statement: "By equipping counselors and mentors with financial-aid information, we can help to ensue curzent and potential students are getting the assistance they need to successfully navigate the process of planning and paying for a postsecondary education." Department Of Education Launches Financial Aid Toolkit Website NewsOne The U.S. Department of Education announced Wednesday the launch of a new website that will support college advisers and guidance counselors in selecting the best course of access and affordability for prospective students. The Financial Aid Toolkit combines the vast scope of financial aid resources and other related materials into a large, searchable database. Website isa one stop shop for applying for financial aid for college WWMT Michigan A new website created by the federal government hopes to help more students get into college. The idea is to have all the info needed in one place 10 make it easier for students applying to college. The Education Department has created this on-line tool kit to help guidance counselors, parents and students with college applications. It has details about applying for financial aid and repaying student loans. It also has other information such as documents advisers ean download and professional development information. Education secretary stays busy on whiylwind day in Las Vegas Las Vegas SunULS. Education Secretary Ame Duncan was in town Wednesday to promote a wide range of education initiatives, including a new financial aid website, higher academic standards and more collaborative career- technical education, In the morning, Duncan unveiled a website to 6,000 financial-aid officers attending a conference at Mandalay Bay. The “Financial Aid Toolkit” website was ereated for high school seniors and their ‘guidance counselors. It serves as a one-stop shop for information and resources related to federal financial aid and loan repayment programs, Duncan said Education Dept. Seeks Ideas for Experiments in Cutting College Costs Chronicle of Higher Education The U.S. Department of Education on Wednesday called on higher education to submit ideas for "experimental sites" that will test innovative ways of reducing the cost of college. The sites, which were mentioned in the college-affordability plan President Obama introduced in August and will be outlined in a notice to be published in the Federal Register on Friday, present an opportunity to formally test the merits ofa variety of ideas that have gained traction in higher education, such as competency-based learning. Targeted experimentation—on a particular campus, say-—has long been an option available to the department, which is authorized to waive certain federal financial-aid rules for such sites. S. Seeks Experiments on New Models of Higher Ed Inside Higher Ed ‘The Obama administration is moving ahead with plans to waive certain federal student aid rules for a limited number of colleges that want to experiment with competency-based education and other innovative forms of higher education, Officials are soliciting suggestions on what those experiments should look like, according to notice set to be published in the Federa? Register this week. The Education Department said it is “particularly interested in experiments that are designed to improve student persistence and academic success, result in shorter time to degree, including by allowing students to advance through educational courses and programs at their own pace by demonstrating academic achievement, and reduce reliance on student loans.” CALL FOR EXPERIMENTAL SITES IDEAS FOCUSES ON COMPETENCY, DUAL ENROLLMENT, PRIOR LEARNING Politico The Education Department is looking for ideas on using its experimental sites authority, which waives some financial aid requirements so that colleges can conduct observed, controlled experiments, to expand competeney-based education, dual enrollment programs and prior learning assessments, among others. In a notice that will be published in Friday’s Federal Register, the Education Department names those three areas as ripe for experimentation and calls for a rough outline of what regulations colleges would waive and how they ‘would measure their results, "We are particularly interested in experiments that are designed to improve student persistence and academic success, result in shorter time to degree, including by allowing students to advanec through educational courses and programs at their own pace by demonstrating academic achievement, and reduce reliance on student loans,” the department writes. COLLEGES WELCOME EXPERIMENTAL SITES EXPANSION Politico Af least nine colleges said Wednesday they are already designing experiments allowing more flexibility with federal financial aid rules: Brandman University, Charter Oak State College, Excelsior College, Kentucky Community and Technical College System, Lipscomb University, Southern New Hampshire University, Westminster College, University of Wisconsin-Extension and University of Maryland University College.From: Gast, Sara Sents Wednesday, December 04, 2013 9:38 AM To: ‘Menon, Ajita T."; Muenzer, Melanie; 'kvaal, James'; ‘Rodriguez, Roberto’; ‘Lehrich, Matt ‘Carroll, Brad Cc: Studley, Jamie; Appel, Jeff; Gomez, Gabriella; Spector, Stephen; Nolt, Dorie; Ritsch, Massie; Soo, David; Cubarrubia, Archie; Runcie, James; Greene, Chris; Bhagat, Wendy; Henderson, Josh; Vadehra, Emma; Valerius, Matthew; Spector, Stephen; Wall, Mary Catherine ; Damieder, Greg; Kanter, Martha ‘Subject: RE: Materials for tommorrow's college announcements ‘And sorry — to clarify, these materials are going out this am. (Our email had problems iast night and a lot of messages got stuck sending.) We've continued to get a lot of positive feedback from NACAC and College Board as well as ASCA, Stephen collected the clips below to give you a sense of coverage so far. Many thanks! Education Dept. rolls out website to assist adults helping students with college applications ‘The Associated Press ‘The Education Department has created an online financial aid toolkit aimed at helping guidance counselors and others who advise students with college applications. The toolkit can be found at hup:/ifinancialaidiootkit.ed.gov , It has details about applying for financial aid and repaying student loans. It also has other information such as documents advisers can download and information about professional development information. It is one of the measures the Obama administration has taken to make the college application process go smoother. Education Department Launches Site Aimed at Guidance Counselors Inside Higher Ed ‘The Obama administration on Wednesday unveiled a new web portal aimed at the people who help students and families prepare for college. The site aggregates a range of Education Department resources and promotional material meant to encourage students to attend college and take advantage of federal student aid programs Guidance counselors and other mentors are able to search a database containing infographics, fact sheets, videos, and other presentation materials relating to the financial aid process. POLITICO -- EDUCATION DEPARTMENT: LEND US YOUR EXPERTISE: The Education Department is submitting its request for information to the Federal Register this week, looking for experts and researchers to help develop its new college rating system. And it’s looking for advice on how to use its experimental sites authority — giving colleges some flexibility on financial aid regulations if they participate in controlled experiments — to spread innovation from campus fo campus, The department has also created a new website to help navigate the financial aid process, aimed at counselors and others who work with students. The ite: hUtp://financislaidtoolkited.gov. The Chronicle The U.S. Department of Education on Tuesday unveiled an online Financial-Aid Toolkit that gathers information about student aid into a single database, in an effort to make it exsier for guidance counselors and advisers to help students plan for college. The searchable database includes a variety of materials, inciuding brochures, presentations, videos—and even sample tweets and Facebook posts that counselors can use to encourage students to complete the Free Application for Federal Student Aid. The documents and other materials cover issues spanning the financial aspects of college attendance: from applying for financial aid to paying off student loans, Secretary of Education Arne Duncan said in a written statement: "By equipping counselors and mentors with financial-aid information, we can help to ensure current and potential students are getting the assistance they need to successfully navigate the process of planning and paying for a postsecondary education.” Gathers Info Website is a on for collegeWWMT Michigan A new website created by the federal goverment hopes to help more students get into college. The idea is to have all the into needed in one place to make it easier for students applying to college. The Education Department has created this on-line tool kit to help guidance counselors, parents and students with coilege applications. It has details about applying for financial aid and repaying student loans. It also has other information such as documents advisers can download and professional development information, From: Gast, Sara ‘Sent: Wednesday, December 04, 2013 9:26 AM To: ‘Menon, Ajta T."; Muenzer, Melanie; 'kvaal, James’; ‘Rodriguez, Roberto’; ‘Lehrich, Matt’; ‘Carroll, Brad’ Ce: Studley, Jamie; Appel, Jeff; Gomez, Gabriella; Spector, Stephen; Nolt, Dorie; Ritsch, Massie; Soo, David; Cubarrubia, Archie; Runcie, James; Greene, Chris; Bhagat, Wendy; Henderson, Josh; Vadehra, Emma; Valerius, Matthew; Spector, Stephen; Wall, Mary Catherine ; Darnieder, Greg; Kanter, Martha ‘Subject: RE: Materials for tomorrow's college announcements Attached are our final press release and blog post. We'll send this out at 10 and post the blog on our site then. Matt, | Can flag that for you for cross-posting consideration. We'll also have the twitters going, and the First Lady's office has also offered to help with a tweet. We had some early validator calls today that were encouraging, particularly with NCAN and NASFAA (ASCA js calling us back in the morning). Stephen shared the embargoed release with the AP, Politico, Wash Post, NYT, Inside Higher d, the Chronicle, and Diverse Issues, so that’s likely where this will be in the morning, ‘Thanks so much for all your help! [ere[eNS)Holland, Linda Kanter, Martha Sont: ‘Thursday, December 05, 2013 4:11 PM To: Gast, Sara; Brenchley, Cameron; Specter, Stephen; Wensil, Brenda; Soo, David: Runcie, James; Bhagat, Wendy; Muenzer, Melanie; Appal, Jeff, Studley, Jamie; Cubarrubia, Archie: Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Vadehra, Emma; Ritsch, Massie: Nolt, Dorie: Stratman-Krusemark, Karen; Whitman, David, Damiedor, Greg; Waldo, Eri: Merini, Tara; Henderson, Josh; Ragland, Wiliam; Fingland, Jodie; Pemberton, Tina: Protopsaltis, ‘Spiros; Gomez, Gabriella; Valerius, Matthew, Stanek, Taylor; Amore, Andrew, Wall Mary Catherine ‘Subject: Re: Wednesday toolkit + ex-sites + ratings RFI announcement Thanks for your tireless drive and support, Sarat! Sent using BlackBerry From: Gast, Sara ‘Sent: Thursday, December 05, 2013 04:00 PM Eastem Standard Time To: Brenchley, Cemeron; Spector, Stephen; Wensil, Brenda; Soo, David; Runcie, James; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Cubarubia, Archie; Greene, Chris; Gomez, Robert} Dann-Messier, Brenda; Kanter, Martha; Vadehra, Emma; Ritsch, Massie; Nolt, Dorie; Stratman-Krusemark, Karen; Whitman, David; Darnieder, Greg; Waldo, Eric; Marini, Tara; Henderson, Josh; Ragland, William; Fingland, Jodie; Pemberton, Tina; Protopsaltis, Spiros; Gomez, Gabriella; Valerius, Matthew; Stanek, Taylor; Amore, Andrew; Wall, Mary Catherine; Honeysett, Adam; Glickman, Jane; Horwich, Lloyd; Byrd-Johnson, Linda; Immerman, Suzanne; Negron, Nancy; Rogister, Colin; Cameron, Cindy; Mulford, Priscilla; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vuong, Sandra; Coogan, Elizabeth; May, Todd; Stennis, Fred; Challenger, Maisha; Essex, Adam; Copeland, James; Roberts, Kevin; Johnson, Amber; Blasen, Richard; Coates, Katherine; Winzer, Etienna; Lemmile, Christopher; Douglas, Jennifer; Grifin, Dan Subject; RE: Wednesday toolkit + ex-sites + ratings RFI announcement Hi everyone. Thanks so much for all your help with the financial aid tooikit + ex-sites + RFI announcement, and —for many of you~ for the work you are continuing to do in the coming days to push out this message and the toolkit to various counselor and consumer groups in the coming days. Here are some of the pieces we have out there so far: + Press release Blog post, which is cross-posted on the WH blog ~ and at least a couple of follow-up blogs about the toolkit are in the works ‘+ Several tweets from @AreDuncan @usedgov @FAFSA @FSAconf and @ELOTUS (+200 ATs) about the took ‘and somehow it also made its way to Pinterest + The toolkit fact sheet + Arne formally announced the toolkit and the ex-sites plans in his remarks at the FSA conference {remacks will be posted online soon}, and it made its way into some stories and TV clips about his visit to Las Vegas + A Dear Colleague Letter for ex-sites and IFAP notice about the toolkit also were published + The ex-sites Federal Register notice will publish tomorrow, and we hope to submit the ratings RF! to the Federal Register tomorrow, pending feedback from DPC ‘+ Many outreach catls, with a special thanks to Jamie, Jeff, David, Greg, Karen and Jodie for talking with some of our key groups to explain the toolkit and encourage them to share it with their networks, as well as the Wendy, Tina and Cindy for pulling all of those pieces together. Those efforts, along with the follow-up outreach from OCO, OVAE, OPE (especially among the TRIO/GEAR-UP communities), OUS and especially FSA, we hope willresult in more amplification and spreading of this information in the coming days. We have already seen several groups share our language with their networks verbatim, + IF yousstill need TPs, some are attached Somewhat related, as many of you know, TICAS (which Jamie called on Tuesday evening) released its annual student debt report on Wednesday, and the toolkit actually made it into some of those clips as well ike the Stateline wire story. Some of the additional clips from coverage so far are belaw. Thanks again for all your heip! New federal ‘finan toolkit’ for college ‘The Washington Post The federal government on Wednesday rolled out an online “financial aid toolkit” for guidance counselors, parents and others to help students learn about funding options for college, The Web site, operated by the Education Department, is one of several Obama administration initiatives aimed at helping consumers navigate the often-bewildering higher education market. “By equipping counselors and mentors with financial aid information, we can help to ensure current and potential students are getting the assistance they need to successfully navigate the process of planning and paying for a postsecondary education,” said Education Secretary Arne Duncan in a news release. Education Dept. rolls out website (o assist adults helping students with college applications The Associated Press ‘The Education Department has created an online financial aid toolkit aimed at helping guidance counselors and others who advise students with college applications. The toolkit can be found at ipu/financialaidtoolkit.ed gov . It has details about applying for financial aid and repaying student loans. It also has other information such as documents advisers can download and information about professional evelopment information. It is one of the measures the Obama administration has taken to make the college application process go smoother. Education Department Launches Site Aimed at Guidance Counselors Inside Higher Ed The Obama administration on Wednesday unveiled a new web portal aimed at the people who help students and families prepare for college. The site aggregates a range of Education Department resources and promotional ‘materia! meant to encourage students to attend college and take advantage of federal student aid programs. Guidance counselors and other mentors are able to search a database containing infographics, fact sheets, videos, and other presentation materials relating to the financial aid process, Online ‘Toolkit’ Gathers Information About Federal Student Aid ‘The Chronicle The U.S. Department of Education on Tuesday unveiled an online Financial-Aid Toolkit that gathers information about student aid into a single database, in an effort to make it easier for guidance counselors and advisers to help students plan for college. The searchable database includes a variety of materials, including brochures, presentations, videos—and even sample tweets and Facebook posts that counsclors can use to encourage students to complete the Free Application for Federal Student Aid. The documents and other materials cover issues spanning the financial aspects of college attendance: from applying for financial aid to paying off student loans. Secretary of Education Ame Duncan said in a written statement: "By equipping counselors and mentors with financial-aid information, we can help to ensure current and potential students are getting the assistance they need to successfully navigate the process of planning and paying for a postsecondary education."The U.S, Department of Education announced Wednesday the launch of a new website that will support college advisers and guidance counselors in selecting the best course of access and affordability for prospective students. The Financial Aid Toolkit combines the vast scope of financial aid resources and other related materials into a large, searchable database. Website isa one stop shop for applying for financial aid for college WWMT Michigan A new website created by the federal government hopes to help more students get into college. The idea is to have all the info needed in one place 1o make it easier for students applying to college, The Education Department has created this on-line tool kit to help guidance counselors, parents and students with college applications. It has details about applying for financial aid and repaying student (oans. It also has other information such as documents advisers can download and professional development information. Education sceretary stays busy on whirlwind day in Las Vegas Las Vegas Sun U.S. Education Secretary Ame Duncan was in town Wednesday to promote a wide range of education initiatives, including a new financial aid website, higher academic standards and more collaborative career- technical education, In the morning, Dunean unveiled a website to 6,000 financial-aid officers attending a conference at Mandalay Bay. The “Financial Aid Toolkit” website was created for high school seniors and their guidance counselors, It serves as a one-stop shop for information and resources related to federal financial aid and loan repayment programs, Duncan said Education Dept. Secks Ideas for Experiments in Cutting College Costs Chronicle of Higher Education The U.S, Department of Education on Wednesday called on higher education to submit ideas for “experimental sites" that will test innovative ways of reducing the cost of college. The sites, which were mentioned in the college-affordability plan President Obama introduced in August and will be outlined in a notice to be published in the Federal Register on Friday, present an opportunity to formally test the merits of a variety of ideas that have gained traction in higher education, such as competency-based leaning, Targeted experimentation on a particular campus, say—has long been an option available to the department, which is authorized to waive certain federal financial-aid rules for such sites, U.S, Seeks Experiments on New Models of Higher Ed Inside Higher Ed The Obama administration is moving ahead with plans to waive certain federal student aid rules fora limited number of colleges that want to experiment with competency-based education and other innovative forms of higher education. Officials are soliciting suggestions on wiat those experiments should look ike, according to a notice set to be published in the Federal Register this week. The Education Department said it is “particularly interested in experiments that are designed to improve student persistence and academic success, result in shorter time to degree, including by allowing students to advance through educational courses and programs at their own pace by demonstrating academic achievement, and reduce reliance on student loans.” CALL FOR EXPERIMENTAL SITES IDEAS FOCUSES ON COMPETENCY, DUAL ENROLLMENT, PRIOR LEARNING Politico The Education Department is looking for ideas on using its experimental sites authority, which waives some financial aid requirements so that colleges can conduet observed, controlled experiments, o expand competency-based education, dual enrollment programs and prior learning assessments, among others. In a notice that will be published in Friday's Federal Register, the Education Department names those three ateas as ripe for experimentation and calls for a rough outline of what regulations colleges would waive and how they would measure their results, "We are particularly interested in experiments that are designed to improve student 3persistence and academic success, result in shorter time to degree, including by allowing students to advance through educational courses and progeams at their own pace by demonstrating academic achievement, and reduce reliance on student loans,” the department writes. COLLEGES WELCOME EXPERIMENTAL SITES EXPANSION Politico At least nine colleges said Wednesday they are already designing experiments allowing more flexibility with federal financial aid rules: Brandman University, Charter Oak State College, Excelsior College, Kentucky Community and Technical College System, Lipscomb University, Southern New Hampshire University, Westminster College, University of Wisconsin-Extension and University of Maryland University College. From: Gast, Sara Sent: Wednesday, December 04, 2013 3:34 PM To: Brenchley, Cameron; Spector, Stephen Cet Wensil, Brenda; Soo, David; Runcie, James; Bhagat, Wendy; Muenver, Melanie; Appel, Jeff; Studley, Jami Cubarrubia, Archie; Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Kanter, Martha; Vadehra, Emma; Ritsch, Massie; Nolt, Derle; Stratman-Krusemark, Karen; Whitman, David; Darnieder, Greg; Waldo, Eric; Marini, Tara; Henderson, Josh; Ragland, Wilism; Fingland, Jodie; Pemberton, Tina; Protopsaltis, Spiras; Gomez, Gabriella; Valerius, Matthew; Stanek, Taylor; Amore, Andrew; Wall, Mary Catherine; Honeysett, Adam; Glickman, Jane; Horwich, Lloyd: Byrd-Johnson, Unda; Immerman, Suzanne; Negron, Nancy; Rogister, Colin; Cameron, Cindy; Mulford, Priscilla; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vuong, Sandra; Coogan, Elizabeth; May, Todd; Stennis, Fred; Challenger, Maisha; Essex, Adam, Copeland, James; Roberts, Kevin; Johnson, Amber; Blasen, Richard; Coates, Katherine; Winzer, Etienna; Lemmie, Christopher; Douglas, Jennifer; Griffin, Dan Subject: RE: Wednesday toolkit + ex-sites + ratings RFI announcement Hi everyone ~ thanks so much for your helpful updates you've been sending me over the day! | appreciate how many of You have kept me posted on your conversations and outreach efforts, We have a couple of follow-up blog posts coming, along with the outreach that many of our newsietter and epubs teams will be undertaking, If you hadn't seen yet, the First Lady tweeted about the toolkit today: httosi//twitter.com/FLOTUS/status/4082860¢216560844g (+200 retweets so far), and we've sean a few other news pieces that we'll compile tomorrow and send around, including a Washington Post piece. From: Brenchley, Cameron Sent: Wednesday, December 04, 2013 9:57 AM To: Spector, Stephen’ Ce: Gast, Sara; Wensil, Brenda; Soo, David; Runcie, James; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Cubarrubia, Archie; Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Kanter, Martha; Vadehra, Emma; Ritsch, Massie; Nolt, Dorie; Stratman-Krusemark, Karen; Whitman, David; Damnieder, Greg; Waldo, Eric; Marini, Tara; Henderson, Josh; Ragland, William; Fingland, Jodie; Pemberton, Tina; Protopsaltis, Spiros; Gomez, Gabriella; Valerius, Matthew; Stanek, Taylor; Amore, Andrew; Wall, Mary Catherine; Honeysett, Adam; Glickman, Jane; Horwich, Lloyd; Byrd- Johnson, Linda; Immerman, Suzanne; Negron, Nancy; Rogister, Colin; Cameron, Cindy; Mulford, Priscila; Thares, Susan; Callahan, Nicole; Anderson, Jered; Vuong, Sendra; Coogan, Elizabeth; May, Todd; Stennis, Fred; Challenger, Maisha; Essex, Adam; Copeland, James; Roberts, Kevin; Johnson, Amber; Blasen, Richard; Coates, Katherine; Winzer, Etienna; Lemmie, Christopher; Douglas, Jennifer Subject: Re: Wednesday toolkit + ex-sites + ratings RFI announcement Good morning everyone! The blog post just went live;hitp://www.ed.gov/blog/2013/12/new-tools-to-support-students-in-preparing-for-college-and-a-call-for- inmoyative-ideas/ Cameron Brenchley Director of Digital Strategy U.S. Department of Education. On Dec 4, 2013, at 9:16 AM, "Spector, Stephen” wrote Good morning, everyone, | want zo make sure folks had an opgortunity to see some ofthe clips that appeared this merning, We wil be issuing the press release to a wider audience later this morning, Thanks, Stephen Education Dept. rolls out website to assist adults helping students with college applications The Associated Press The Education Department has created an online financial aid toolkit aimed at helping guidance counselors and others who advise students with college applications. The toolkit can be found at hiip:/finaneialaidtoolkit.ed.gov . It has details about applying for financial aid and repaying student loans. It also has other information such as documents advisers can download and information about professional development information. It is one of the measures the Obama administration has taken to make the college application process go smoother. ‘The Obama administration on Wednesday unveiled a new web portal aimed at the people who fnelp students and lies prepare for college. The site aggregates a range of Education Department resources and promotional ‘material meant to encourage students to attend college and take advantage of federal student aid programs. Guidance counselors and other mentors are able to search a database containing infographies, fact sheets, videos, and other presentation materials relating to the financial aid process. POLITICO -- EDUCATION DEPARTMENT: LEND US YOUR EXPERTISE: The Education Department is submitting its request for information to the Federal Register this week, looking for experts and researchers to help develop its new college rating system, And it's looking for advice on how to use its experimental sites authority — giving colleges some flexibility on financial aid regulations if they participate in controlled experiments — to spread innovation from campus to campus. The department has also cteated a new website to help navigate the financial aid process, aimed at counselors and others who work with students. The site: http://finaneialaidtoolkit.ed,gov. Online "Toolkit" Gathers Information About Federal Student Aid The Chronicle The U.S. Department of Education on Tuesday unveiled an ontine Financial-Aid Toolkit that gathers information about student aid into a single database, in an effort to make it easier for guidance counselors and advisers to help students plan for college. ‘The searchable database includes a variety of materials, including brochures, presentations, videos—and even sample tweets and Facebook posts that counselors can use to encourage students to complete the Free Application for Federal Student Aid. The documents and other materials cover issues spanning the financial aspects of college attendance: from applying for financial sid to paying off student loans, Secretary of Education Ame Duncan said in a written statement: "By equipping counselors and mentors with financial-aid information, we can help to ensure current and potential students aregetting the assistance they need to successfully navigate the process of planning and paying for a postsecondary education." Website is a one stop shop for appiving for financial aid for eotlege WWMT Michigan AA new website created by the federal government hopes to help more students get into college. The idea is to have all the info needed in one place to make it easier for students applying to college. The Education Department hes created this on-line tool kit to help guidance counselors, parents and students with college applications. ft has details about applying for financial aid and repaying student loans, It also has other information such as documents advisers can download and professional development information. (es)foxy From: Gast, Sara Sent: Tuesday, December 03, 2013 10:32 AM To: Wensil, Brenda; Soo, David; Runcie, James; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Gabarcubia, Archie; Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Kanter, Martha; Vadehra, Emma; Ritsch, ‘Massie; Nol, Dorie; Spector, Stephen; Stratman-Krusemark, Karen; Whitman, David; Darnieder, Greg; Waldo, Ericy erin, Tara; Henderson, Josh; Ragland, Wiliam; Fingland, Jodie; Pemberton, Tina; Brenchiey, Cameron; Protapsalts, Spiros; Gomez, Gabriela; Muenzer, Melanic; Valerius, Matthew; Stanek, Taylor; Amore, Andres; Well, Mary Catherines Honeysett, Adam Glickman, Jane; Horwich, Lloyd Dann-Messier, Brenda; Byrd-Johnson, Linda; Immerman, Suzanne: Negron, Nancy; Rogister, Colin ci Cameron, Cindy; Mulford, Priscilla; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vuong, Sandra; Coogan, Elizabeth; May, Todd; Stennis, Fred; Challenger, Maisha; Essex, Adam; Copeland, James; Roberts, Kevin: Johnson, ‘Amber; Blasen, Richard; Coates, Katherine; Winzer, Etienne; Lemmie, Christopher; Douglas, Jennifer Subject: RE: Wednesday toolkit + ex-sites + ratings RFI announcement Bye)[yey From: Gast, Sara Sent: Monday, December 02, 2013 12:13 PM To? Wensil, Brenda; Soo, David; Runcie, James; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; ‘Cuberrubia, Archie; Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Kanter, Martha; Vadehra, Emma; Ritsch, Massie; Nolt, Dorie; Spector, Stephen; Stratman-Krusemark, Karen; Whitman, David; Darnieder, Greg; Waldo, Erie, Marini, Tara; Henderson, Josh; Ragland, Witham; Fingland, Jodie; Pemberton, Tina; Brenchley, Cameron; Protopsaltis, Spiros; Gomez, Gabriella; Muenzer, Melanie; Valerius, Matthew; Stanek, Taylor; Amore, Andrew; mary.wali@ed.gov; Honeysett, Adam (Adam Honeysett@ed.gov); Glickman, Jane; Horwich, Lloyd; Dann-Messier, Brenda; Byrd-Johnson, Linda; Immerman, Suzanne; Negron, Nancy; Rogister, Colin Ce: Cameron, Cindy; Mulford, Priscila; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vuong, Sandra; Coogan, Elizabeth; May, Todd; Stennis, Fred; Challenger, Maisha; Essex, Adam; Copeland, James; Roberts, Kevin; Johnson, Amber; Blasen, Richard; Coates, Katherine; Winzer, Etienna; Lemmie, Christopher; Douglas, Jennifer Subject: Wednesday toolkit + ex-sites + ratings RFI annauncement vey[exer -Original Message- From: Gast, Sara Sent: Wednesday, November 27, 2013 11:29. AM To: Wensi, Brenda; Soo, David Runeie, James; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Cubarrubia, Archie; Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Kanter, Marta Cc: Vadehva, Emma; Ritsch, Massie; Nott, Dorie; Spector, Stephen; Stratman-krusemark, Karen; Whitman, David; Darnieder, Greg, Waldo, Eric; Marini, Tara; Henderson, Josh; Ragland, William; Fingland, Jodie; Pemberton, Tina ‘Subject: Re: Change of Piay- Holding FR Notices Gal[exer ‘Original Message —- From: Gast, Sara Sent: Tuesday, November 26, 2013 06:27 PM ‘To: Wensil, Brenda; Sco, David; Runcie, James; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Cubarrubia, Archie: Greene, Chris; Gomez, Robert ; Dann-Messler, Brenda; Kanter, Martha Ce: Vadehra, Emma; Ritsch, Massie: Nolt, Dorie; Spector, Stephen; Stratman-krusemark, Karen Subject: FW: Change of Play- Holding FR Notices [exer Original Message From: Gast, Sera Sent: Tuesday, November 26, 2013 4:19 PM To: Wensil, Brenda; Menon, Ajita 7; Soo, David; Kvaal, James; Runcie, James; Bhagat, Wendy; Lehrich, Matt; htuenzer, Melanie: Appel, Jeff; Studley, Jamie; Cubartubla, Archie; Rodriguez, Roberto /adehra, Emma; Ritsch, Massie; Nolt, Deri; Spector, Stephen Subject: RE: Change of Play- Holding FR Notices [re 10From: Wensil, Brenda Sent: Tuesday, November 26, 2023 2:54 PM. To: Menon, Alita 7; Seo, David; kvaal, James; Runcie, James; Bhagat, Wendy; Gast, Sara; Lehrich, Matt; Muenzer, Melanie; Appel, Jeff; Studley, lamie; Cubarrubia, Archie; Rodriguez, Roberto Ce: Vadehra, Emma; Ritsch, Massie Subject: RE: Change of Play- Holding FR Notices ENS) From: Menon, Ajita T. [Alita R Talwalkor@who top gov} Sent: Tuesday, November 26, 2013 11:46 AM To: Soo, David; Kvaal, James; Runcie, James; Bhagat, Wendy; Gast, Sara; Lehrich, Matt; Muenzer, Melanie; Appel, Jef; Studley, Jamie; Cubarrubia, Archie; Rodriguez, Roberto Ce: Vadehra, Emma; Ritsch, Massie; Wensil, Brenda Subject: RE: Change of Play- Holding F Notices From: Soe, David [malie:David Soo@ed pov Sent: Tuesday, November 26, 2013 12:38 PM To: Kvaal, James; Runcle, James; Bhagat, Wendy; Gast, Sara; Lehvich, Matt; Menon, Ajita T; Muenzer, Melanie; Agpel, Jeff; Studley, Jamie; Cubarrubia, Archie; Rodriguez, Roberto Ce: Vadehra, Emma Ritsch, Massie; Wensil, Brenda Subject: RE: Change of Play- Holding. FR Notices ever From: Kvaal, James (mailta:lames & Kvaal@who,eop.g0v] Sent: Menday, November 25, 2013 8:21 PM ‘Te: Runcie, James; Bhagat, Wendy; Gast, Sara; Lehrich, Matt; Menon, Ajta T.; Muenzer, Melanie; Appel, Jo; Studley, Jamie; Sco, David; Cubarcubia, Archie; Rodriguez, Roberto Ceci Vadehra, Emma; Ritsch, Massie; Wens!l, Brenda Subject: RE: Change of Play- Holding FR Notices ‘Thanks sim, really appreciate that From: Runcie, James [mailio:James,Runcie@ed gov) Sent: Monday, November 25, 2013 8:20 >M To: Kvaal, James; Bhagat, Wendy; Gast, Sara; Lehrich, Matt; Menon, Alta Tz Muenzer, Melanie; Appel, Jeff, Studley, Jamie; Soo, David; Cubartubia, Archie; Rodriguez, Roberto Ce: Vadehira, Emma; Ritsch, Massie; Wensii, Brenda Subject: RE: Change of Play- Holding FR Notices [exer From: Kvaal, JamescmailtoJames R Kvaal@who.eop gov> uwSent: 11/25/2013 7:52 PM To: Bhagat, Wendy; Gast, Saracmailto:Sara Gast@ed,gov>; Lehrich, Matt; Menon, Ajta T.; Muencer, Melaniesmailto: Melanie. Muenzer@ed.gov>; Appel, Jeff; Studley, Jamiecmailto:iamie, Stugley@ed.gov>; S00, David; Cubarrubia, Archiecmalto:Archie,Cubarrubia@ed gov>; Rodriguez, RobertocmaittoRobert_L, Rodtigver@who.cop.gov> Cc: Vaciehra, Emmacmailto:Emma,vadehra@ed.gov>; Runcie, jamescquailta:lames Runcie@ed.gov>; Ritsch, Massiecmailt: Massie, Rilschd@ed pov>; Wensil, Srendacmalte:Srenda Wensil@ec.gov> Subject: RE: Chonge of Play: Holding F8 Notices{(BVS) ba From: Bhagat, Wendy [mailto: Wendy. Rhagat@ed.cov) Sent: Monday, Novernber 25, 2013 7:50 PM To: Gast, Sara; Kvaal, James; Lehrich, Matt; Menon, Ajit T; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Seo, David; Cubarrubia, Archie; Rodriguez, Roberto Cec: Vadehre, Emma; Runcie, James; Ritsch, Massie; Wensil, Brenda Subject: RE: Change of Piay- Holding FR Notices The site should be up by noon (12 pm) on Sunday, December 2 wendy Sent from my Windows Phone From: Gast, SaracmllioiSara Gasi@ed gov> Sent: 11/25/2013 7:23 PM ‘To: kvaa!, Jamescmalltayames R_kvaal@who.eop gov>; Lehich, Matt; Menon, Ajta T.; Muenzer, Melarie; Appel, JeffemalitorleffAppel@ed.gov>; Studley, Jamiecmailto:lamig.Studley@ed.gov>; S00, David; Recrigue2, Robertocmalto:Roverta J. Rotrlpuez@who. > Cc: Vadehra, Emmacmailto:émma Vadehra@ed.gov>; Bhagat, Wendy; Runcie, JamescmalitoJames Runcie@ed.gov>; Ritsch, Masstecmailto:wassia Ritscn ed 2c Subject: RE: Change of Play- Holding FR Notices{(6)(5) [(eNS) -Original Message- From: Kvaal, James [mailto:lames R Kwasi@who.cop.cov) Sent: Monday, November 25, 2013 6:32 PM! ‘To: Gast, Sara; Lehrich, Matt; Menon, Ajita T.; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Soo, David; Cubarrubia, Archie; Rodriguez, Roberto Ce: Vadehra, Emma; Bhagat, Wendy; Runcie, James; Ritsch, Massie Subject: RE: Change of Play- Holding FR Notices [exer Original Messag From: Gast, Sara {mailto Sera.Gast@ed.gov) Sent: Monday, November 25, 2013 6:19 PM. To: Kvaal, James; Lehrich, Matt; Menon, Ajita 7; Muenzer, Melanie; Appel, Jeff, Studley, Jamie; $00, Cavid; Cubarrubla, archie; Rodriguez, Roberto Ce: Vadehra, Emma; Bhagat, Wendy; Runcte, James; Ritsch, Massie Subject: RE: Change of Play- Holding FR Notices [exer 2[exer -Original Massage- From: Kvaal, James {mailladJames &_Kveal@who.eop.20¥] Sent: Monday, November 25, 2013 6:11 PM To: Lehrich, Matt; Menon, Ajita 7.; Gast, Sara; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Seo, Oavid; Cubarrubia, Archie; Rodriguez, Roberto Ce: Vadehra, Eres Subject: RE: Change of Play- Holding FR Notices [(exS) ~-—Original Message-—— rom: Lehrich, Matt Sent; Monday, November 25, 2013 6:06 PM To: Menon, Alta T.; Gast, Sara; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Soo, Da Kvaal, James. Ce: Vadehra, Emme Subject: RE: Change of Play- Holding F& Notices Gal ; Cubarrubia, Archie; Rodriguez, Roberto; Original message. From: Menon, Alita T. Sent: Monday, November 25, 2013 6:04 PM To: Gast, Sara; Muenzer, Melanie; Appel, Jeff; Studley, Jame; Soo, David; Cubarrubia, Archie; Rodriguez, Roberto; Lehrich, Matt; kvaal, James. Ce: vadehra, Emma Subject: RE: Change of Play- Holding FR Notices Original Messag From: Gast, Sara mailto Sara. Gast@ed gov) Sent: Monday, November 25, 2013 5:44 PM Yo: Menon, Ajita 7; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Soo, David; Cubarrubia, Archie Ce: Vadlehra, Erma Subject: RE: Change of Play- Holding FR Notices BYES) -Originat Message- 3From: Gast, Sara Sent: Monday, November 25, 2013 4:06 #M To: Menon, Ajita 1. Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Soo, David; Cubarrutia, Archie Subject: RE: Change of Play- Holding FR Notices check now. Original Message- From: Menon, Ajta 7. [mailto:Alita Sent: Monday, November 25, 2013 4:02 PM To: Gast, Sara; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Soo, David Cubarrubia, Archie Subject: Re: Change of Play- Holding FR Notices Original Message —~ From: Gast, Sara (mallto:Sara,Gast@ed.gov] Sent: Monday, November 25, 2013 03:58 Pm To: Menon, Ajta T.; Muenzer, Melanie >; Appel, Jett >; Studley, Jamie >, Se, David ad Sao@ed gnu> Subject: RE: Change of Play- Holding FR Notices [(eNS) Original Message: From: Menon, Ajita T. (mailto:Ajita_R Talwalker@who.eoo.gov) Sent: Monday, November 25, 2013 3:51 PM To: Gest, Sara; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Soa, David; Cubarrubia, Archie Subject: Re: Change of Play- Holding FR Notices [iexs) Original Message From: Menon, Ajita T Sent: Monday, November 25, 2013 03:48 PM To: ‘Sara.past@ed gov’ >; ‘nelanie.muenzer@ed.cov' “>; efLappeled.gov' elf. ovcmailta:leff appelmed gou>>; amia.stucley@ed.gov' > Subject: Change of Play- Holding FR Notices [exs) 4GeyGeyPauline Abemathy Wednesday, December 04, 2013 1:06 PM Pauline Abernathy Ce: Joseph Mais; Connie Myers. Subject: TICAS releases Student Debt & the Class of 2012: Average Student Debt Climbs to $29,400 for Ciass of 2012 ‘Attachments: ‘Student _Debt_and_the_Class_of_2012_NR,PDF; classot2012.pdf vee institute to college FYI-Today TICAS’ Project on Student Debt access success released Student Debt & the Class of 2022, ‘our eighth annual report on the student lean debt of recent college graduates, Besed on new national NPSAS data that include public, nonprofit and for-profit colleges, the report finds: + College graduates who berrowed for bachelor’s degrees granted! in 2012 had an average student loan debt of, $28,400. © Seven in 10 college seniors (71%) who graduated last year had student loan debt. © One-fifth of their debt was in private loans even though the financial crisis caused a steep decline in private lending while these borrowers were in school. To estimate state-by-state averages and identify high- and low-debt schools, the report uses figures provided voluntarily by public and private nonprofit four-year colleges (virtually no for-profit colleges share these data}. We continue to find that average student debt ievels vary widely by state as well as by college, with high-debt states remaining concentrated in the Northeast and Midwest, and low-ebt states mainly in the West and South. The report includes policy recommendations to reduce the reed te borrow, collect and provide students with the information they need when they need it to make informed decisions, strengthen college accountability, reduce reliance: on private education loans, and improve and promote awareness of federal loan repayment options, ‘To view debt levels for all SO states plus the District of Columbia and more than 1,000 individual U Lniversities, visit our companion interactive map at http://projectonstudentcebt_ora/. colleges and FOR IMMEDIATE RELEASE: 12/4/13 CONTACTS: Shannon Gallegos Gretchen Wright Bill Swindell 540/318-7915 202/371-1999 510/318-7902, Average Student Debt Climbing: $29,400 for Class of 2012 New report includes state-by-state and campus-by-campus debt levels (Oakland, CA) ~ College graduates who borrowed for bachelor’s degrees granted in 2012 had an average student loan debt of $29,400, according to a new report from the Project on Student Debt at The Institute for College Access & Success (TICAS). Seven in 10 college seniors (71%) who graduated last year had student loan debt. Even though the financial crisis caused a steep decline in private education lending while these borrowers were in school, one-fifth of their debt wes in private loans, which are typically more costly and provide fewer consumer protections and repayment 1options than safer federal loans. From 2008 to 2012, average debt (federal and private loans combined) increased an average of six percent each year. ‘The report, Student Debt and the Class of 2022, includes lists of high- and low-debt states and colleges around the country and highlights significant differences among colleges and states, For example, new college graduates with loans ‘owed almost twice as much on average in Delaware as in New Mexico, and in five states average debt was more than $30,000. The odds of having student loans also differed from state to state, with 2022 graduates nearly twice as ely to have debt in South Dakota as in Nevada. At the college level, the share of graduates with loans and their average debt covered an even wider range Federal surveys only collect the data needed to calculate national average debt for new graduates once every four years, including 2012. TICAS used newly available federal data for the national figures in this report, which are not directly comparable to prior figures from other data sources and cannot be broken down by state or college. infact, colleges are not required to report their own graduates’ debt. To estimate state-by-state averages and identify high- and low-debt schools, TICAS used figures provided voluntarily by more than half of all public and private nonprofit four-year colleges. For-prafit colleges, which accounted for seven percent of 2012 bachelor's recipients, are not included in the state estimates or college lists because virtually none chose to share their data ‘The findings come as unemployment remains high compared to before the financial crisis. In 2012, 7.7 percent of young college graduates were unemployed, and a broader measure capturing under-employment showed 18.3 percent were either unemployed, working fewer hours then they wanted, or had given up looking for a job. Still, young adults without college degrees face far worse job prospects: 17.9 percent of young high school graduates with no college were unemployed in 2012. “Despite discouraging headlines, a college degree remains the best route to finding a job in this tight market. But students and families need to know that debt levels can vary widely from college to college,” said TICAS president Lauren Asher. “IF you need to borrow to get through school, federal student loans are the safest way to borrow. Whatever you earn, income-driven plans like Pay As You Earn can help keep federal loan payments manageable.” State highs and lows: State averages for borrowers’ debt at graduation in 2012 ranged from $18,000 to $33,650. High- debt states remain concentrated in the Northeast and Midwest, with Delaware the highest. New Hampshire, Pennsylvania, Minnesota, and Rhode Island also had average debt over $30,000. Low-debt states were mainly in the West and South, with New Mexico the lowest. Other low-debt states include California, Arizona, Nevada, and Wyoming. College highs and lows: At the campus level, average debt varied even more widely, ranging irom $4,450 to $49,450, and the share of students graduating with loans ranged from 6 percent to 100 percent. Colleges with higher tuition tended to have higher average debt, but there are many examples of high-cost colleges with relatively low average debt, and vice versa. ‘The report notes that colleges that receive scrutiny for their voluntarily reported debt levels may be more likely to stop providing such data. For example, 20 percent of the schools on the list of high-debt public colleges in our 2011 report, ‘and 30 percent of the schools on the list of low-debt colleges, chose not to report data in 2012. in comparison, overall ‘only 20 percent of all the colleges that reported debt data for 2011 didn’t report for 2012, Need for better data: Even for those cotleges that do report volunterily, the college-level debt figures in the report may understate actual borrowing because they don’t include transfer students or any private loans the college is unaware of, The report's state estimates are based on the available college-level data, so actual state averages may be higher as wellThe best national figures for public and nonprofit colleges combined show that 68 percent of their graduating seniors ‘owed an average of $27,850 in student loans, These are lower than the overall national figures because they do not include for-profit college graduates, who are more likely to borrow and graduate with more debt The report contains several policy recommendations to help ease student debt burdens, including collecting better college-level data on debt at graduation and private student loan borrowing, as well as more comprehensive data on graduation rates. “Right now, some colleges escape accountability by opting not to report their graduates’ debt, while those who do report are stuck on an unequal playing field,” said Matthew Reed, the report's primary author. “Students, researchers, and policymakers need and deserve better and more complete information." ‘This issue is especially crucial as President Obama has proposed developing ratings before the 2015 school year aimed at helping consumers compare colleges’ value and encouraging institutions to improve. "The success of the President's proposat to rate colleges based on access, affordability, value, and student outcomes will depend on the quality of the data used in the ratings, underscoring the urgency of gathering better information,” said TICAS research director Debbie Cochrane, NOTE: For more information on state and college debt for the Class of 2012, see our companion interactive map with details for all $0 states, the District of Columbia, and more than 1,000 public and private nonprofit four-year colleges. ane An independent, nonprofit organization, Ihe institute for College Access & Success (TICAS} works to make higher education mare eveioble and ‘offordebie for people of all backgrounds. TICAS' Project on Student Debt works to increase pubiic understanding of ring student debt and the ‘implications for aur fomiles, economy, an sacety. Follow vs am Tuite.tne institute for college access xsuccess FOR IMMEDIATE RELEASE: 12/4/13, CONTACTS: Shannon Gallegos Gretchen Wright Bill Swindell 510/318-7915 202/371-1999 520/318-7902 Average Student Debt Climbing: $29,400 for Class of 2012 ‘New report includes state-by-state and campus-by-campus debt levels {Cakland, CA) ~ College graduates who borrowed for bachelor’s degrees granted in 2012 had an average student loan debt of $28,400, according to a new report from the Project on Student Debt at The Institute for College Access & Success (TICAS}. Seven in 10 college seniors (7196) who graduated last {year had student loan debt. Even though the financial crisis caused a steep decline in private education lending while these borrowers were in school, one-fifth oftheir debt was in private loans, which are typically more costly and provide fewer consumer protections and repayment options than safer federal loans. From 2008 to 2012, average debt (federal and private foans combined) increased an average of six percent each year. The report, Student Debt and the Class of 2042, includes lists of high- and low-debt states and colleges, around the country and highlights significant differences among colleges and states. For example, new college graduates with loans owed almost twice as much on average in Delaware as in New Mexico, and in five states average debt was more than $30,000. The odds of having student loans also differed from state to state, with 2012 graduates nearly twice as likely to have debt in South Dakota as in Nevada, At the college level, the share of graduates with loans and their average debt covered an even wider range Federal surveys only collect the data needed to calculate national average debt for new graduates once every four years, including 2012. TICAS used newly available federat data for the national figures in this report, which are not directly comparable to prior figures from other data sources and cannot be broken down by state or college. In fact, colleges are not required to report thelr own graduates’ debt. To estimate state-by-state averages and identify high and low-debt schools, TICAS used figures provided voluntarily by more than half of all public and private nonprofit four-year colleges. For-profit colleges, which accounted for seven percent of 2012 bachelor’s recipients, are not Included in the state estimates or college lists because virtually none chose to share their data, The findings come as unemployment remains high compared to before the financial crisis. In 2022, 7.7 percent of young college graduates were unemployed, and a broader measure capturing under- ‘employment showed 18.3 percent were either unemployed, working fewer hours than they wanted, or hhad given up looking for a job. Still, young adults without college degrees face far worse job prospects: 17.9 percent of young high school graduates with no college were unemployed in 2012. “Despite discouraging headlines, a college degree remains the hest raute to finding a job in this tight market. But students and families need to know that debt levels can vary widely from college to college,” said TICAS president Lauren Asher. “If you need to borrow to get through school, federal student loans are the safest way to borrow. Whatever you earn, income-driven plans tike Pay As You Earn can help keep federal loan payments manageable.” State highs and lows: State averages for borrowers’ debt at graduation in 2012 ranged from $18,000 to $33,650. High-debt states remain concentrated in the Northeast and Midwest, with Delaware thehighest. New Hampshire, Pennsylvania, Minnesota, and Rhode Island also had average debt over $30,000, Low-debr states were mainly in the West and South, with New Mexico the iowest. Other low: debt states include California, Arizona, Nevada, and Wyoming. College highs and lows: At the campus level, average debt varied even more widely, ranging from $4,480 to $49,450, and the share of students graduating with loans ranged from 6 percent to 100 percent, Colleges with higher tuition tended to have higher average debt, but there are many examples ‘of high-cost colleges with relatively low average debt, and vice versa. The report notes that colleges that receive scrutiny for their voluntarily reported debt levels may be more likely to stop providing such data. For example, 20 percent of the schoais on the list of high-debt public colleges in our 201 report, and 30 percent of the schcols on the list of low-debt colleges, chose not to report data in 2012. In comparison, overall only 10 percent of all the colleges that reported debt data for 2011 didn’t report for 2012. Need for better data: Even for those colleges that do report voluntarily, the college-level debt figures in the report may understate actual borrowing because they don't include transfer students or any private loans the college is unaware of. The report's state estimates are based on the available college-level data, so actual state averages may be higher as well. ‘The best national figures for public and noaprofit colleges combined show that 6B percent of their graduating seniors owed an average of $27,850 in student loans, These are lower than the overall national figures because they do not include for-profit college graduates, who are more likely to borrow ‘and graduate with more debt. The report contains several policy recommendations to help ease student debt burdens, including collecting better college-level data on debt at graduation and private student loan borrowing, as well as more comprehensive data on graduation rates. "Right now, some colleges escape accountability by opting not to report their graduates’ debt, while those who do report are stuck on an unequal playing field,” said Matthew Reed, the report's primary author. “Students, researchers, and policymakers need and deserve better and more complete information." This issue is especially crucial as President Obama has proposed developing ratings before the 2025, school year aimed at helping consumers compare colleges’ value and encouraging institutions to Improve. “The success of the President's proposal to rate colleges based on access, affordability, value, ‘and student outcomes will depend on the quality of the data used in the ratings, underscoring the urgency of gathering better information," said TICAS research director Debbie Cochrane, NOTE: For more information on state and collage debt for the Class of 2012, see our companion interactive mag with details forall $0 states, the District of Columbia, and more than 2,000 public and private nonprofit four-year colleges. awe ‘Anindependent, nonprofit organization, The insiute for Colle Access & Success (TICAS) works to moke higher education more vollabie and offordabte for people of ol hockarounas. CAS’ Exact on Student Dokt works ta increass public understaning of rising student bt ond the implicaticns for out formes, economy, end secicty. Follows us an Totter.STUDENT DEBT AND THE CLASS OF 2012 DECEMBER 2013 SPD DEB feta T pam fear hOW | Beer 2 fl | Presents STUDENT DEBTeo rras teeter neh Se uur re econ lara ea CM geeiaa vel Saag ae SCLC Ue Lele kG recat, Coen ee eeeSTUDENT DEBT AND THE CLASS OF 2012 ‘TABLE OF CONTENTS over STUPENT BERT BY STATE Table b sigh-betst Sta Table 2" Loe Duns Slates P jeans, 99 Stale ang? Giadusles ws Dabs act Aveteye Dest Woot Dataavs selnkedanthe Stale Averages! STUNENT DEBT AT COW LEGIS High Dat Colleges Table 4: High Dead vale Nonprutil Collages eid Unnwersites “ale High-Doo: Publee Colleyas ae Univers eaten Ave They Now? Low: Dent College Table GL om Dent Colleges anei Un verses A Nate on li-P4eril Callens PRIVATE (NON-FEDERAL) LOAN’ RICOMMFNIDAT ONS FOR ADARFSS.AG Kl NO STUENT DEST APPEND sETHODOLOGY 1» w 4 16 aOVERVIEW State averages for debt at graduation ranged widely fn 2072 jeom $18,000 ta $33,650, end graduating seniors’ jikelivood of faving debt ranged from 41 percent to 78 percent. Stoxler] Dal on the “less of 201 soe waghth gnnualvepoet cm the cunt fled © accvnt pres a fieynt” Ce sto geacales ils wove Cun sv, oth cans drab verily onscryy Staty Seven 10 fio rated ws 2012 fae sruuene ve oh SSS}210 far these ih lens, The ast onal share ef seniors recut {years lo 8c onl COO to fT petians 2A stale Fa ey Gn gertagesd o> pera pr yea fen Ihwins We inurl er seat wiv de hen peste garam sng Tm fbb is craps of walt oes aie ae culestions nel repayarent olin thay she Slate awureuas hi dt ot radunro vanged widely in 20°2. trom B18 898 19 33,65 ab roving seo elt of heyy le average duh was mae Ihe 540.008 1 gh-cebl states eeraie angen Michuesk with eseesiobt stare ts the Wing! aid Sets Senay fon taletyedal h nes At sercor 8 Tecenrent In tay inthe Hort mest Ascrage debt var es even were el the seve le then ol the stele sue Imam 20 ta Fo9o%h Fowerops ft bul hers are marty exoreg es Fghssest on! inching lies ef hgh and ood “1 sige tersa. FF motie abo ad MUL ol Ihe cal ee ey He pss la. Hess Ua: the stale aan cole: est gus fpublh, one! pine nist Reur-yoar cl Ans bee for t00 1 line nocesary els Beery fos wears elu 7012, a ebaal say cols He ae foe leu abs rata debt Hipaies nol prowl sae ors ial anelyoleges anne: exqa es teapot Ue sessed eh let Ihab why wee se lata pray ccd wns by anny la £6 est male stzte swerages an inl 22) grestutted {rant suls, ancl soopreat Leal ee hanad kavvceds sb Navanatly 6% perce i 2 les seth: and atsate nance t foe gear elages tu scent debs, sth an ave O per iuirever These ae as the the avira nat onal Figures becotine Hey i eluent lige sri ari tee Re Gee a aaa e on vonintar ty repost dot unseen fo Ul cs wares woke the eb they sleet alu: Woneter striones The iar ans 24 revi of dort dedi dela for al stvoos Lette 2a Uberescerl my understate actus bona nb jrzsumgeane ot Thee epers sl privat ons tie sbog Wese-tive lata sve aelial sale eames ay epi stulen ans £39 pose paelcule: shell hed rough weeb arteularip # ther howe pivate Free During te tres any woes A ceciny th job aval, oe unos ym al ea: fe youn, ce 2 yea fe roan 22 soy pe ge ets ul eh hist i seeDoegas tap foro Poanesl vse. tn adam, (acu maps; unt rates se no cereuadercnphuee A heeader nnasune tel nites both uncenpny halos tere eeorhing few hous reloenplagrriel sts th 18.3 peteenl of soung ors ng bul seer ny For sacra had ywvessuy aokeny tor srr ve these ets ave irl, sent ese waderse facing anid eos toes. On average, oumyers co ie eretes continue higher selaresthon dhe cine l eoduates ean IS peccea peesports lor chose wilh col ge rover grew ar ss uner-egmere Iygsgmes wurst Iheunanpeyrrent oa tron thot dubs ‘he rte for youre 2 ge ned a ys aroun, neg desaen repayment Heyes iB 7h Touisans SET fol a a 26 1 on ia S352 if ars A D a i varied 325961 [ae % 3 20 TP Mosse wae 26.60 epee 10 2 08 752 Miengen #28320 of 69% = 7 30 5% Tease Se? 0 n a 7 i isis $2322 26am 31 v7 5 7 wes @ eps % a aa‘TABLE 3 (CONTINUED) erie Rui GUL ck LLL aati haya alla ea Lua Aaa ada Institutions Class of 2012 corgrantng) Graduates State ae Rank — | ewithDebt / Rank Total Usable ° aero Montana) a7na75 8 ae 2 9 g Se Tehvast $2607 7 #4 6 i s : Nevede $20.588, a8 a 2. 2 3 News ammashive Sas, Te z 3 s Row Jersey, 529.287, 8 6 W 3 20 New Mgnieo tH 38 a io 7 Niger, $25,597 Us, Ba oxi Cavaine $23893 1 = Nevth Dakela : : 5 a Fa one $20097 e 20% e we 2 = Calnnorna $23.636 34 53% 30. 29 5 708 Gregor S789) 2 oo a ZI 7 Pennsylvania #51875 3 70% 4 ee a Br ve far Sau 5 fs & i 7 728 South Carolina Sa.MG 3 55% 36 34 vy ca Sout Ducota S250 2 2 o 5 4 Tennessee 1775 a3 58 2 a6 2 B35) eas $4040) a bee a a0 a Tee Utah SD4S20 4 50% 45 2 a 52% vermont 575,298 iE a, 16 i 1 ¥ Vingnia 325007 29 0% 23 38 Es Wass $23,293 26 se 2 16 Bie West Virwinia 326.227 25 5496. 38 10 1% Wscossin Bu Mi io a = 28 ete Wyoming S224 5 a6 48 1 7 Too pore 5 meWHAT DATA ARE INCLUDED IN THE STATE AVERAGES? Several organizations conciuct annual surveys of colleges that include cuestions about student loan debt, including US. News & World Report, Peterson's (publisher ofits own college guides), and the College Board. To make the process easier far colleges, these organizations use questions from a shared survey instrument, called the Common Dats Set (CDS). Despite the name “Common Data Set,” there is no actual repository or “set” of data. Each surveyor conducts, follows up, and reviews the results of its ov survey independently. For this analysis, we icensed ‘and used the data from Peterson's". For more detail on the data and cur methodology, please see Aapenti A The state averages are calculated using data voluntarily reported by campus officials at L075 colleges, which are not audited or reviewed by any ‘outside entity. For their data to be considered usable for calculating state averages, colleges hed to report both the percentage of graduating students with loans and their average debt, and report that they awarded bachelor's degrees during the 2011-12 year. As shown in Table 3, we cid not calculate state averages for North Dakota because the usable cases with student dabt data coveted fess than 30 percent of bachelor’s degree recipients in the Class of 2012, or for Hawaii because the under'ying data for that state showed a change of 30 percent or more in average debt from tie previous year. Such large year-to-year swings likely effect different institutions reporting each year, reporting errors, or changes in methodelogy by institutions reporting the data, rather than actual changes in debt ievals. We woight the state averages according tothe size of the graduating class (number of bachefor's degree recipients during the 2011-12 year) and the proportion of graduating seniors with deo, ‘The state averages and rankings in this report are not directly comparable to averagesiin previous years’ reports, cue to changes in which colleges in each state seport data each year, corrections to the underlying data submitted by colleges, and changes in methodology.STUDENT DEBT AT COLLEGES, Stucdea dent ruts ean waey “oesiceas acceny eal a lores in ality aid laws Liv nwespety. 3 ¥ee orate He seashell sgraaluate gs class, to2 waaay oF Pectoral Fy ea sis poli wd praciizes ce extend lash ch parents tasevd Forge PLUS was are a pale allege, he estent of aurao “tate envalhvzen, Lag boty shakes word ss evenly be a Jt shay ateus ating al ged last quate dnf-eqirn the deny Passe a An Sbinntnce PRASEAA) S35 under ses . igre nal Caraeses 1 AGE Raga Poonarimerat autho ity te gies ie are mine aan + Shopeins Sheet. oy Ue Dap Linen ane Genrer ee Frotection Brea, seyigsles = gdb Seem 9 {nent alt ollers, thy juaes tes mace i eany fat tuabease va oa coloye to uniersland ard compare tie neve Ha L300 volleys algo! jolenrl imal age louse Se Sagpni Shges "Fe uate Ue lear ane! coannrabie moriiat na 19% lage ev sore ig arsartisan log station tg tune all cobs, mera sik aa) use a sil stancarg ge ae 3. 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Strengthen college accountability Lane ant making punt ele segue eas fe Seitunls ha ad Ms gralacte: bang Siudiets are gad svotle a0, Held aru towaid a cule! stonsly eau staclons th eleols Fins can SPOR stunts 8 recummend mare these tying 2 collages iy toe Tye yc bo tos nk lrg snd sre nse tases nove slusenss yal + Student Default Risk Index (SDR sedan louis Stushont Nelall Sisk noes SPRL rabeer “han tree Pulrt Daal hates“ PR, = ER whos wy Ine Fare aychocls siutest loan aearoacrs nh fail Pe CDR musta ly the seacals honvemg rate. iy wneeepirolig te shaves! shade cho keno Ioan inte ve acasure. 298 SER chee aceuraaly cane sche 's isk + Risk Sharing. Wave acy allen chao! elit, O° aK! ny vensacne eve a magennyros seo revpniy om etal Sami a relalve’y hgh but lal Levers Ube oa iy etl + Rewards, hi foe ulores bi coh eetcingeme stucleuls ase) aola then aeip'y to aid anil lll [ni ward colleges silt wary low SIoRHs, easels incon iy cong sues le sais aN Finerider + Gainful Employment. | fess tinal eonsiglenlly uvesecoarge aad uKletde unable hit crpmend ol Une frrinstraice atomialy wiovanlgabe rie tues Lease the ‘slatlony ocuiernon tha ste ev iswokoley wid natdst. colleges nay actually nave 2 Aismesive a harmns aa All surtug, Tobey that rewrale y Colcol sai eee” Sarr yea et hats exiles silt wae coe fs ith snr sea sel fat Waar eH ieee deh les sec emp igus al al Aenean Sow ferrous test a ala Hoag DS. and not enaldal oe ter bering ioeula a fe ctcht culeg ox repro. rf gh than porary, eels ot abe: byes elles er Ho pel ang Desctie tne hnilalions ve suntletn tudes dat eves ry sarge dayree ecient oxy yor nd tog Wate om peect CDE tate ae sill yso"ul “oe llustraking Hae arabes corral 21 voles WHAT DATA ARE INCLUDED IN THE STATE AVERAGES? Foe slate avoragss are cnt ulated “om dala eeaastei 2p the 1 8 callages dosern ese catnpese evil deb Hsin ate ese eh Hin, ae ear ba ha yang cs ad 209 ated bt thet lmlowtcd tabs bir val lai cllagus had ba renin hl Lhe nd port sal ey vet ales slate aes ages wong the rssaale eas sill dd" Teh eas cevseeel Pay a Doct state showed ach Srv sn yell sin methostcgy by Pst stale: averages, acest“ sludents wir 635 “in average de tory lie 201 Oe boo Peas allele Mayes athe me sale ausrages ac conc £ pyaciat vachelorsshagee “ecunenls du-ing be 2012 vn) an ne reagent sith dv Te state average ara vatings in bis po ary“ Paces yess “cutis ssc courmges im vent inges, evtnnic fo mre unelyg cata ioral tat Colleges Sizhl (1 Pr hes etewlont dees ahate Soy sled sileyes, bac « sealing yrat-longed wana sores ue augiagates vin the ae dar daa otis dat lagen tent CDS, The Ladeniging creat af cosheges rent sealing oh seg sup; om a sey, ray Cage RO: veo" Fa yeaa DORD Qasse® ODP Sab sie renee teal using mag WHAT DATA ARE INCLUDED IN THE LISTS OF COLLEGES? Tre f cotkeons aug allies data aul slurent He: At enbeges es wae, Soe sme a lhe LOG collages that acewerae al gverall dba questions Ha ars Hey line aaeue £7 exces! arte Cassa 2012 and Ty aera at let the lasso: 2012 Heuclde celleyes sil small gre pole otages et ca es ve Leb fort ve fe Me boressengs “ya ie ee ots In ade woe 1 small 60 6 Fe aca naghelor's dite recipients a sul id uraks qa aes mre aon] Sir very sera rar asia classes nase bovis oe bxe's ase mea we Hoe ens area pore 28Pemberton, Tina Wednesday, December 04, 2013 11:06 AM Bhagat, Wendy: Cameron, Cindy; Mulford, Priscilla; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vuong, Sandra! Coogan, Elizabeth; May, Todd, Stennis, Fred; Challenger, Maisha; Essex, Adam; Copeland, James; Roberts, Kevin; Johnson, Amber; Biasen, Richard: Coates, Katherine; Winzer, Evenna; Lemmie, Christopher, Sellar, Golin Ce: Runcie, James; Wensil, Brenda; Greene, Chris; Marini, Tara; Douglas, Jennifer Subject: FW: Wednesday tooikit + ex-sites + ralings RF! announcement Hi Everyone, {t looks like the press release and other announcements are now live, so we can go ahead and begin reaching out to our partners. Thanks and please let me know if you have any questions, Tina From: Pemberton, Tina Sent: Wednesday, December 04, 2013 7:56 AM To: Bhagat, Wendy; Cameron, Cindy (Cindy.Camieron@ied.gov); Mulford, Priscilla; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vuong, Sandra; Coogan, Elizabeth: May, Todd; Stennis, Fred; Challenger, Maisha; Essex, Adam; Copeland, James; Roberts, Kevin; Johnson, Amber; Blasen, Richard; Coates, Katherine; Winzer, Etienna; Lemmie, Christopher; Seliar, Colin Ce: Runcie, James; Wensil, Brenda; Greene, Chris; Marini, Tara; Douglas, Jennifer Subject: FW: Wednesday toolkit + ex-sites + ratings RFI announcement Hi FSA Folks, [exer Please let me know if you have any questions, Thanks! Tina From: Gast, Sara Sent: Tuesday, December 03, 2013 7:38 PM To: Wensil, Brenda; Soo, David; Runcie, Jemes; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Cubarrubia, Archie; Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Kanter, Martha} Vadehra, Emma; Ritsch, Massie; Nolt, Dorie; Spector, Stephen; Stratman-Krusemark, Karen; Whitman, David; Darnieder, Greg; Waldo, Eric; Marini, Tara; Henderson, Josh; Ragland, William; Fingland, Jodie; Pemberton, Tina; Brenchley, Cameron; Protopsaltis, Spiros; Gomez, Gabriella; Muenzer, Melanie; Valerius, Matthevr; Stanek, Taylor; Amore, Andrew; Wall, Mary Catherine; Honeysett, Adam; Glickman, Jane; Horwich, Lloyd; Dann-Messier, Brenda; Byrd-Johnsen, Linda; Immerman, Suzanne; Negron, Nancy; Rogister, ColinCameron, Cindy; Mulford, Priscilla; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vuong, Sandra; Coogan, Elizabeth; May, Todd; Stennis, Fred; Challenger, Maisha; Essex, Adam; Copeland, James; Roberts, Kevin; Johnson, Amber; Blasen, Richard; Coates, Katherine; Winzer, Etienna; Lemmie, Christopher; Douglas, Jennifer Subject: RE: Wednesday toolkit + ex-sites + ratings RFI announcement Hi everyone! [iexsy From: Gast, Sara Sent: Tuesday, December 03, 2013 10:32 AM To: Wensil, Brenda; Soo, David; Runcle, James; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Cubatrubia, Archie; Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Kanter, Martha; Vadehra, Emma; Ritsch, Massie; Nok, Dorie; Spector, Stephen; Stratman-krusemark, Karen; Whitman, David; Darnieder, Greg; Waldo, Eric, Marini, Tara; Henderson, Josh; Ragland, William; Fingland, Jodie; Pemberton, Tina; Brenchley, Cameron: Protopsaltis, Spiros; Gomez, Gabriella; Muenzer, Melanie; Valerius, Matthew; Stanek, Taylor; Amore, Andrew; Wall, Mary Catherine; 2Honeyselt, Adam; Glickman, Jane; Horwich, Lloyd; Dann-Messier, Brenda; Byrd-Johnson, Linda; Immerman, Suzanne: Negron, Nancy; Rogister, Colin Ce: Cameron, Cingy; Mulford, Priscilla; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vueng, Sandra; Coogan, Elizabeth; May, Todd; Stennis, Fred; Challenger, Maisha; Essex, Adam; Copeland, James; Roberts, Kevin; Johnson, Amber; Blasen, Richard; Coates, Katherine; Winzer, Etienna; Lemmie, Christopher; Douglas, Jennifer ‘Subject: RE: Wednesday toolkit + ex-sites + ratings RFI announcement Ai alll Quick update. [(exs) vey From: Gast, Sara Sent: Monday, December 02, 2013 12:13 PM ‘To: Wensil, Brenda; Soo, David; Runcie, James; Bhagat, Wendy; Muenzer, Melanie; Appel, Jeff; Studley, Jamie; Cubarrubia, Archie; Greene, Chris; Gomez, Robert; Dann-Messier, Brenda; Kanter, Martha; Vadehra, Emma; Ritsch, Massie; Nolt, Dorie; Spector, Stephen; Stratman-Krusemark, Karen; Whitman, David; Darnieder, Greg; Waldo, Eric: Marini, Tara; Henderson, Josh; Ragland, Wiliam; Fingland, Jodie; Pemberton, Tina; Brenchley, Cameron; Protopsaltis, Spires; Gomez, Gabriella; Muenzer, Melanie; Valerius, Matthew; Stanek, Taylor; Amore, Andrew; mary.wall@ed,qov; Honeysett, Adam (Adam. Honeysett@ed.qov); Glickman, Jane; Horwich, Lloyd; Dann-Messier, Brenda; Byrd-Johnson, Linda; immerman, Suzanne; Negron, Nancy; Rogister, Calin Ce: Cameron, Cindy; Mulford, Priscilla; Thares, Susan; Callahan, Nicole; Anderson, Jared; Vuong, Sandra; Coogan, 3