Scoring the College Scorecard: What’s Good and What Needs Improvement

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    Scoring the College Scorecard

    What’s Good and What Needs Improvement

    By Ben Miller February 2016

      WWW.AMERICANPROGRESS.O

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    Scoring the College ScorecardWhat’s Good and What Needs Improvement

    By Ben Miller February 2016

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      1 Introduction and summary

      3 The good

      7 Improve existing indicators

     19 New indicators needed from the Department of Educati

      27 Conclusion

      29 Endnotes

    Contents

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    Introduction and summary

    Te word “voluminous” does no even begin o describe he College Scorecard.

    Tis new ool o help sudens and heir amilies choose insiuions o higher edu-

    caion, released by he U.S. Deparmen o Educaion in Sepember 2015, conains

    1,700 variables abou more han 7,000 colleges across 18 years o daa rom 1996

    o 2013.1 I is almos cerainly he larges release ever o higher educaion daa.

     A is hear, he College Scorecard showcases he power o unlocking even a

    small porion o he daa capabiliies held by he ederal governmen. I conainsimporan indicaors ha have never previously been available or all insiuions

    o higher educaion. Tis includes he earnings o sudens who received ederal

    financial aid, muliple years o repaymen hisory or suden borrowers, and he

    ypical deb loads by year. Even beter, i disaggregaes mos o hese indicaors,

    making i possible o compare he resuls or sudens who graduaed wih he

    daa on hose who dropped ou, across income bands, and by gender.

    Spending several monhs analyzing he scorecard, however, reveals several weak-

    nesses and daa limiaions. Some o he acors underlying hese shorcomings are

    ouside he Deparmen o Educaion’s conrol. For insance, he agency can repor

    only daa on sudens who received ederal aid because o a congressional ban on

    including all sudens in he deparmen’s daabases.2 Oher issues, such as only

    reporing resuls or insiuions overall and no by program, will likely ge beter

     wih ime. Bu he Deparmen o Educaion could address some problems now.

    Tis includes using a rue measure o loan repaymen, aligning suden cohors

    across differen measures, and fixing daa suppression policies. Finally, here are sev-

    eral useul indicaors, paricularly relaed o loan perormance, ha he deparmen

    could generae off he daa ha i now holds in order o beter inorm he public.

     Wih his ieraion o he College Scorecard now approaching is six-monh

    anniversary, his repor akes a sep back o assess he ool’s daa. I looks a he

    scorecard hrough our secions. Firs, i highlighs he good measures ha were

    imporan inclusions. For example, he disaggregaion o resuls by ype o suden,

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    no jus insiuion, is imporan or ideniying places ha may be serving cerain

    ypes o individuals well. Similarly, reporing earnings and loan repaymen inorma-

    ion provides new measures or rehinking oucomes. And disclosing hese daa

    across several cohors and poins in ime allows or a beter undersanding o how

    resuls can change.

    Second, he repor looks a wha he Deparmen o Educaion could do beter

    in he nex round in erms o improving he indicaors ha i already repors and

    making changes ha improve he daa’s usabiliy and clariy. For insance, he

    deparmen could use a beter definiion o suden loan repaymen ha more

    accuraely capures people who are reiring heir deb, as well as beter align

    cohors or differen measures o assis in comparing oucomes.

    Tird, i suggess addiional measures he Deparmen o Educaion could add.

    For insance, i could disclose more inormaion abou loan oucomes, paricularly

    he use o income-driven repaymen plans. I also could break ou resuls or par-en borrowers and graduae sudens o help hese individuals beter undersand

    heir choices.

    Finally, his repor recommends ha Congress improve he College Scorecard by

    allowing he Deparmen o Educaion o collec daa on all sudens atending

    college, no jus hose receiving ederal financial aid. Tese addiional daa would

    make i possible o see how sudens who are served by he aid programs are com-

    pared wih hose who are no. I also would provide a complee picure o resuls

    or insiuions, somehing ha may no be happening now a places where only a

    small porion o sudens receive ederal assisance.

    Te hope is ha having an hones conversaion abou he College Scorecard’s

    daa will lay he groundwork or urning i ino an even more useul and compre-

    hensive ool in he uure. Doing his would help sudens and heir amilies make

    sound choices abou where o apply and how o pay or college based on clear,

    undersandable, and comparable inormaion. I also would make he daa more

    useul or policymakers o beter undersand comparisons, and more complee

    daa on earnings should be o paricular ineres o insiuions ha currenly can-

    no ge such inormaion in a comprehensive way.

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     The good

    Tis secion discusses he paricularly noeworhy or groundbreaking elemens o

    he College Scorecard, which are worh commending. Te elemens highlighed

     below are imporan or urhering our abiliy o undersand possecondary ou-

    comes and could help sudens and heir amilies in he college selecion process.

    Disaggregation

    By hinking abou inormaion in erms o suden characerisics and no jus

     by insiuion, he scorecard represens an imporan urning poin in he daa

    release sraegy rom he Office o Federal Suden Aid. radiionally, inorma-

    ion abou he ederal suden aid programs has been limied o a ew indicaors a

    he insiuional level. Tis includes measures such as he percenage o borrow-

    ers who deauled on heir loans wihin a ew years o enering repaymen. Te

    Deparmen o Educaion sared geting beter a his a ew years ago wih he

    creaion o he Federal Suden Aid Daa Cener.3 Tis websie discloses quarerly

    inormaion abou how much money each insiuion has received rom he differ-

    en ederal aid programs. I also provides breakdowns o he overall loan porolio

    in erms o he amoun o ederal loans in deaul, repaymen, and by differen

    delinquency sauses, among oher indicaors.

    In none o hese disclosures, however, did he deparmen break ou any o he

    daa by suden indicaors. For insance, he agency repors he amoun o loans

    received by a school bu no how much loan money wen o recipiens o he ed-

    eral Pell Gran or o dependen sudens, or oher characerisics.

    Te College Scorecard breaks his paradigm. Insead o jus providing a ew newoucomes merics, i provides several disaggregaion opions or mos measures.

    For insance, daa users can see repaymen raes and deb levels broken down by

     wheher a suden graduaed or no, heir dependency saus, heir income range,

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     when hey enered college, heir gender, i hey received a Pell Gran, and i hey

    are a firs-generaion suden. Compleion daa have all hese breakdowns, plus

    an indicaor ha saes wheher a suden received a ederal loan. While earnings

    indicaors are no as deailed, hey can sill show resuls by gender, income upon

    enry, and dependency saus.

    Tese disaggregaes make i possible o develop a more nuanced picure o suden

    loan perormance. For insance, he repaymen rae daa show ha he overall

    percenage o borrowers repaying heir loans hree years afer beginning repay-

    men declined rom 75 percen o hose who enered repaymen in 2006 or 2007

    o 62 percen o hose who enered in 2010 or 2011. 4 Bu breaking he daa down

    urher reveals differen sories. Among hose who compleed, repaymen raes

    declined rom 83 percen o 74 percen, a smaller drop han he overall number

    over he same ime rame. By conras, borrowers who did no complee saw a

    sunning drop in suden loan repaymen o 17 percenage poins, rom 70 percen

    o 53 percen during he same period. Similarly, high-income borrowers only sawa 6 percenage poin decline in repaymen raes versus a 17 percenage poin drop

    among he lowes-income borrowers. Tese resuls srongly sugges a need o do

    more o ackle college compleion and help low-income sudens avoid borrow-

    ingfindings ha would no be eviden rom jus he overall repaymen raes no

    disaggregaed by suden characerisics.

    Better measures of loan per formance and completion

    Te mos commonly used ederal higher educaion measures are he graduaion

    rae and suden loan deaul rae. Boh, however, have significan flaws in heir

    definiions. Graduaion raes only rack daa or sudens atending heir firs

    college and who go ull ime in he all semeser. Tis definiion is no inherenly

     wrong, bu i limis he measuremen o a college’s success in wo key ways. Firs,

    i does no give he insiuions credi or graduaing any o he increasingly large

    numbers o sudens who atend par ime, ranser, or sar in he spring or sum-

    mer semesers.5 Second, he measure generally keeps any suden who ransers

    ou o a college in he denominaor o he calculaion, reaing hem like a drop-

    ou.6

     In some cases, hese limiaions may undersae he rue college compleionpicure. Tis is paricularly rue or communiy colleges, which receive no credi

    or successully sending sudens o our-year insiuions under his ormula. In

    oher insances, hese ormulas may presen an overly posiive picure o gradua-

    ion, since sudens who go par ime are less likely o graduae.7 

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    Cohor deaul raes, meanwhile, are oo easily manipulaed.8 Because he measure

    only racks sudens who deaul wihin hree years o enering repaymen, insiu-

    ions can reduce heir deaul raes by having borrowers go ino deermen or

    orbearance on heir loans or a ew years. While doing so prevens sudens rom

    deauling wihin he measuremen window, i does no se hem up or long-erm

    repaymen success. Tis pracice resuls in a picure o deaul ha ails o capurelarge numbers o borrowers who are sruggling wih heir debs.

    Te scorecard daa conains indicaors ha correc boh compleion and deaul

    raes. For he ormer, i uses he Naional Suden Loan Daa Sysem, or NSLDS,

    a comprehensive daabase ha conains inormaion on all sudens receiving

    ederal aid benefis in order o generae more robus compleion raes.9 Tese

    daa include couns o sudens who lef an insiuion and enrolled or graduaed

    elsewhere. I also racks he daa or eigh years, which is double he lengh o cur-

    ren graduaion rae calculaions or wo-year insiuions. And i is able o repor

    resuls separaely or Pell Gran recipiens going back o July 2012a daa poinha had been exremely difficul or policymakers o obain a he insiuional

    level.10 Tis way o reporing daa makes i possible o give insiuions credi or

    ranser sudens and also include hose who atend par ime.

    Te scorecard improves upon suden loan deaul raes by reporing a measure o

    suden loan repaymen. Tis figure looks a he percenage o borrowers who afer

    one, hree, five, and seven years are boh no in deaul and have reduced heir ou-

    sanding principal balance by a leas $1. Tis measure is ar less open o manipu-

    laion. For insance, sudens who go ino orbearance on paymens will ail he

    es because ineres will accumulae on heir loans and increase heir ousanding

     balance. Closing he loopholes ha undermine he deaul calculaions makes

    repaymen raes a much more meaningul measure o loan perormance.

    Redefining hese wo key measures represens an imporan sep in moving he

    possecondary daa discussion orward. Boh deaul and graduaion rae calcu-

    laions have been largely unchanged since hey were creaed in he 1990she

    deaul rae now racks borrowers or hree years insead o wo, bu he res o he

    calculaion is he same. Providing new daa makes i possible o quesion wheher

    hese indicaors should be changed or wha could come in heir sead.

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    Reporting earnings data

     While he use o earnings inormaion or he purposes o hinking abou a col-

    lege’s value is conroversial in some circles, i is also an unavoidable elemen o he

    equaion.11 Were sudens o pay no money ou o pocke or college and ake on

    no deb, hen perhaps earnings would cease o be relevan. Bu given he subsan-ial sums paid by sudens, especially wih loans ha mus be repaid afer leav-

    ing school, sudens mus know wheher programs are likely o have a sufficien

    reurn o jusiy heir expense. Moreover, sudens wan his inormaion. When

    surveyed, hey overwhelmingly indicae ha economic concerns drive a number

    o heir college decisions. Sudens worry abou wheher hey will be able o ge

    a beter job afer graduaing, build a beter lie or hemselves and heir children,

    and oher similar concerns.12 Generaing inormaion on he earnings o ormer

    sudens presens he only pah orward o answer hese quesions.

    Te scorecard presens he bes daa o dae on earnings o sudens across allinsiuions. Unlike websies such as PayScale, which rely on sel-repored daa,

    he College Scorecard figures are drawn direcly rom adminisraive daa held

     by he U.S. Deparmen o he reasury.13 Tis is a more comprehensive collec-

    ion han sel-repored daa. Similarly, i is beter han some earnings daa ha

    saes repor because hose measures ail o rack sudens who move o anoher

    sae, which is a problem ha he ederal governmen does no have. Finally, he

    scorecard’s earnings daa also include muliple measuresbreaking ou he daa

    annually or sudens in he 6 hrough 10 years ollowing heir enry ino higher

    educaion. Tis makes i possible o char change in earnings over ime and see

    how he pah o college sudens in he workorce may change.

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    Improve existing indicators

    Tis secion discusses elemens ha are currenly on he College Scorecard bu are

    in need o improvemens ha he Deparmen o Educaion could make now.

    Use a true repayment rate

    Te repaymen rae used in he scorecard is much beter han he exising mea-

    sure o suden loan deaul, or he reasons explained earlier. I is no, however,a paricularly meaningul indicaor o suden loan repaymen. Wha he mea-

    sure ess is he percenage o sudens who did no deaul and had paid down

    a leas $1 o principal wihin eiher one, hree, five, or seven years. Tis is in

    effec a negaive amorizaion esha is o say, is he debor paying off a leas

    he amoun o ineres ha accumulaes each year so ha hey are no worse off

    han a he sar o he loan?

    Te problem is ha no having a balance grow is no he same as making meaning-

    ul progress o reire a deb. A borrower who owed $10,000 upon enering repay-

    men, has a 5 percen ineres rae, and plans o pay off he deb over 10 years will

    have reired around 26 percen o wha hey owed afer hree ull years o paymens;

    on a 20-year plan, hey will have paid off almos 10 percen.14 Boh o hese sums

    are much larger han he $1 es required o coun as repaying on he scorecard.

    reaing he $1 reducion as successul repaymen hus poenially cass large

    numbers o sudens as deb successes who are ar rom ha siuaion. Someone

     who mees only he $1 es is sill nowhere close o reiring heir deb quickly. I jus

    means hey are no seeing heir deb siuaion worsen. Couning hem as a success-

    ul repaymen can make he suden loan siuaion seem beter han i is in realiy.

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    Forunaely, he Deparmen o Educaion could correc his issue in hree differ-

    en ways. Firs, i could redefine he successul repaymen es o say ha a suden

    couns as successully repaying i afer hree or our years in repaymen hey owe

    no more han wha he balance should be a ha poin in ime i hey were paying

    i off over 20 years. In oher words, he deparmen would use he loan’s ineres

    rae, original balance upon enering repaymen, and a 20-year repaymen period oesimae how much should remain ousanding afer hree or our years.15 I would

    hen compare ha amoun wih he acual loan balance afer he same period o

    ime. Borrowers wih amouns a or below his level would pass his es, while

    hose above i would no pass. In he case o he borrower noed above, his would

    mean ha heir balance a he end o hree years would have o be abou $9,029 or

    less. Tis is in effec a es o wheher a borrower has paid down a leas 9.7 percen

    o heir balance wihin hree years o enering repaymen. weny years is he bes

    ime rame because borrowers who are going o ake longer likely will receive loan

    orgiveness hrough an income-driven paymen, which is no an ideal oucome or

    he governmen.16 While making such a change is more mahemaically compli-caed, he Deparmen o Educaion’s sysems should be able o char a borrower’s

     balance a differen poins in ime o do he calculaion.

    I he above calculaion is oo complicaed, he deparmen could adop a variaion

    ha, insead o relying upon a loan’s acual ineres rae, uses he maximum allow-

    able rae. Currenly, Safford loans are capped a an 8.25 percen ineres rae.17 A

     borrower wih a loan a ha rae paying off a deb over 20 years would have abou

    93.3 percen o heir original loan balance remaining afer hree years o enering

    repaymen. So he deparmen could judge someone as successully repaying loans

    as long as hey owed no more han his amoun on he loans. Tis approach is much

    simpler o adminiser, hough i is a laxer bar han using he acual ineres rae. For

    insance, someone who has a 5 percen ineres rae should have paid down 90.6

    percen o heir balance. Te deparmen would have o deermine wheher ha

    difference is enough o warran using he acual loan erms.

    Te oher way o presen repaymen inormaion in a way ha is easier or su-

    dens and amilies o undersand is o use several years o pas paymen his-

    ory o generae an esimae o how long i will ake o pay down he deb. Tis

     would be easible only or direc loan borrowers or oher ederal loans held byhe Deparmen o Educaion, since he deparmen does no obain paymen

    inormaion rom loans ha privae companies hold. Forunaely, since Congress

    eliminaed he abiliy or privae companies o issue ederally guaraneed loans in

    2010, his will no be a problem going orward.18 

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    TABLE 1

    Options for improving the repayment rate

    Option Successful repayment definition

    Principal reduction

    needed in order to

    successfully repay loans*

    Current College

    Scorecard formula

    Borrowers who reduced the principal balance on

    their loans by at least $1 and have not defaulted0.01%

    20-year payment

    on actual loan terms

    Borrowers whose balance at the end of three years

    of repayment is equal to or less than what they would

    owe at that point if they were paying off loans with

    the same terms over 20 years

    9%

    20-year payment

    on maxium

    loan terms

    Borrowers whose balance at the end of three years

    of repayment is equal to or less than what they would

    owe at that point if they were paying off loans with the

    maximum interest rate of 8.25 percent over 20 years

    7%

    Estimated

    repayment time

    Based on the amount repaid over three years, how

    many years of repayment will the average borrower

    take to pay their loan in full?

    N/A

    * The projections in this table are based on a $10,000 loan with a 5 percent interest rate.

    Source: CAP projections of student loan balances using Amortization-calc.com, “Amortization Schedule Calculator,” available athttp://www.amortization-calc.com (last accessed January 2016).

    Here’s how a repaymen rae based on paymen hisory would work. Te

    Deparmen o Educaion would look a how much he borrower paid over hree,

    five, or seven years in repaymen. I would use hose amouns o creae an esi-

    mae o acual monhly paymens made by he borrower. I would hen calculae,

     based upon he borrower’s original balance, how long i would ake in oal o

    reire he deb i he borrower kep paying off he loan a ha rae. For example,

    say he borrower wih a $10,000 loan and a 5 percen ineres rae had made

    esimaed monhly paymens o $75 over he firs hree years; based upon ha

    amoun, i would ake a bi over 16 years o pay off he deb ully.19 Te depar-

    men could run his calculaion or all borrowers and hen presen he average or

    median number o years i esimaes borrowers will need o repay heir deb. Tis

    presenaion is likely more consumer riendly, since i expresses resuls in erms

    o years, which is easy o undersand.

    Align cohorts for repayment, cumulative debt, and earnings

     A major challenge wih he College Scorecard daa is ha he cohors or is main

    indicaors do no align. Tis hinders he abiliy o measure he ineraciviy o cer-

    ain oucomes, such as seeing how much he deb levels o sudens affec repay-

    men raes or how earnings correlae wih deb.

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    Te lack o alignmen beween repaymen raes and deb levels illusraes hese

    challenges. Te repaymen daa are based upon he ederal fiscal year in which a

     borrower eners repaymen. By conras, he cumulaive deb measures are based

    upon he ederal fiscal year in which he suden separaes rom college. Te problem

    is ha borrowers do no ener repaymen unil six monhs afer hey leave school. 20 

    Depending on when borrowers graduae or drop ou, he ederal fiscal year in whichhey separae and he one in which hey ener repaymen may be differen. For

    insance, a borrower who graduaed in May 2010 enered repaymen in FY 2011. So

    heir repaymen saus is racked in 2011, bu he deb is couned in 2010.

    Earnings daa, meanwhile, are aligned wih he compleion rae daa bu no he

    deb figures. Boh he earnings and compleion figures define cohors based upon

    he ederal aid award year in which a suden enered college, which runs rom July

    1 o one year o June 30 o he ollowing year.21 Tis makes i possible o see how

    college compleion raes migh affec earnings resuls. Te deb figures, however,

    are based upon he year ha sudens separaed rom college, so hey are com-pleely differen rom he earnings resuls.

    TABLE 2

    How the College Scorecard defines cohorts for its different indicators

    Indicator Cohort definition

    Repayment

    rates

    The federal fiscal year in which a borrower enters repayment after their six-month

    grace period

    Cumulative

    debtThe federal fiscal year in which a borrower exits school before their six-month grace period

    Earnings The federal aid award year in which a student who receives federal aid enters college

    Completion The federal aid award year in which a student who receives federal aid enters college

    Note: Federal fiscal years run from October 1 of one year to September 30 of the following year. Federal aid award years run from July 1of one year to June 30 of the following year.

    Source: College Scorecard Data, Data Documentation for College Scorecard  (U.S. Department of Education, 2015), available athttps://collegescorecard.ed.gov/assets/FullDataDocumentation.pdf.

    Te Deparmen o Educaion can fix all o hese issues. For sarers, he agency

    should a leas repor consisen cohors or he deb indicaors. o do his, i

    should change he deb calculaion o reflec he amoun owed when a sudenenered repaymen and he year in which ha occurred so ha his lines up wih

    he repaymen rae cohor. Te deparmen also should fix he earnings calcula-

    ion o beter align wih hese measures, as described below.

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    Generate earnings results based upon when students leave

    Te cohor used or earnings daa is arguably he mos misundersood indicaor

    in he scorecard. Ta’s because unlike he repaymen or deb figures, his cohor

    is no based upon he ederal fiscal year in which someone enered repaymen bu

    raher he aid award year when he or she sared college. In addiion, he earn-ings daa do no disaggregae figures based upon wheher someone did or did no

    graduae. In oher words, he mos up-o-dae earnings figure in he daa racks he

    income levels in 2011 or 2012 o undergraduae sudens who received ederal aid

    and sared college in 2005 or 2006.

    Tere are some advanages o measuring earnings based upon enry. For one, i

    aligns he earnings daa wih he compleion figures presened on he scorecard.

    Tis makes i possible o undersand he possible correlaion beween comple-

    ion raes and uure earnings. Measuring earnings based upon enry also allows

    sudens o undersand heir poenial oucomes regardless o wheher hey gradu-ae. Te advanage o his is ha an insiuion where only a small percenage o

    enrans graduae and ge good jobs will no presen an overly posiive picure by

    only ocusing on he oucomes or people who graduae.

     A he same ime, measuring earnings based only on year o enry has several

    problems. Mos imporanly, i complicaes comparisons across differen ypes o

    colleges. For insance, looking a earnings resuls six years afer enry a a our-year

    college may be capuring people who have been in he workorce or less han a

     year. By conras, he resuls a a wo-year college could represen someone who

    has been working or our years. Defining he cohor based upon year o enry also

    means ha graduaes and nongraduaes boh ge couned in he daa. Te prob-

    lem is ha he earnings reurn could be wo very differen scenariosone level

    o reurn or hose who graduaed and a presumably lower one or hose who did

    no. Adding he wo ogeher does capure how noncompleion can drive down

    resuls bu also likely undersaes he benefis o graduaing.

    Te Deparmen o Educaion should address hese issues by making some

    fixes o he exising earnings daa and considering addiional cohors o repor.

    Firs, i should include a compleion disaggregaion or he earnings daa basedupon when a suden enered college. Tis makes i possible o see how earnings

    differ or hose who compleed and hose who did no. Second, i should repor

    an addiional earnings cohor o define sudens by he year hey lef college,

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    disaggregaed by wheher hey graduaed or wihdrew. Te deparmen should

    align his new cohor wih he repaymen and deb cohors.22 Doing so makes

    i possible o beter undersand he linkages beween compleion saus, deb

    amouns, repaymen, and earningscrucial connecions ha are necessary or

    undersanding he financial reurns o a college educaion.

    Te qualiy o older daa is a poenial impedimen o fixing his problem. I is only

    in he pas ew years ha he Deparmen o Educaion has placed a srong emphasis

    on making insiuions accuraely repor wheher sudens compleed or wihdrew.

    Te problem wih poenially inaccurae reporing is ha many insiuions appear

    o have been incorrecly reporing all or mos o heir sudens as having wihdrawn,

    regardless o wheher hey did in ac graduae. Because earnings are measured or as

    long as 10 years, his means i will be several years beore he deparmen can gener-

    ae longer-erm earnings daa based upon when sudens finished.

    Repaymen rae daa disaggregaed by compleion saus show insances oalmos cerain incorrec insiuional reporing o wheher a suden graduaed.

    For insance, he Universiy o Alabama repored ha o he borrowers who

    enered repaymen in 2006 and 2007 and were racked or seven years, more

    han 2,400 sudens had no graduaed, while he number o sudens who did

    finish was suppressed or privacy reasons. Tis figure is unquesionably wrong.

     According o daa repored o he Inegraed Possecondary Educaion Daa

    Sysem, or IPEDS, he insiuion had a 2007 graduaion rae among firs-ime,

    ull-ime sudens o 63 percen, wih more han 938 compleers.23 While no

    all o hese individuals had suden loans, he insiuion did have a borrowing

    rae o 38 percen, suggesing ha a leas several hundred individuals should

     be in he compleion cohor or repaymen raes.24 Moreover, he Universiy o

     Alabama’s mos recen repaymen daaor sudens enering repaymen in 2010

    or 2011 and racked or hree yearsshows ha 3,080 borrowers graduaed and

    ha he number o dropous was no large enough o avoid privacy suppression.

    Tese are almos cerainly he correc figures.

    I i urns ou ha insiuions only recenly fixed heir daa reporing enough o

    rus he compleion figures, hen i will be some ime beore long-erm earnings

     based upon when sudens lef school will be easible. For insance, he 2010 and2011 cohors will no have boh hi six years ou o college unil 2017, and i will

    ake unil 2021 o hi 10 years ou. Add in anoher year or so or daa analysis, and

    long-erm earnings based upon compleion saus may be a long way off.

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    Generate outcomes by program, not just institution

    Policymakers ofen ocus on analyzing insiuions, bu increasing bodies o

    research demonsrae ha earnings may vary as much across he differen pro-

    grams in a college as hey do beween schools.25 Similarly, many lower-income

    sudens, who may ace geographic consrains ha limi hem o only one or wopossecondary opions, sill have he abiliy o choose wha o sudy. 26 Tese indi-

     viduals also would benefi rom seeing oucomes daa by program.

    Breaking ou resuls by program is an issue ha he Deparmen o Educaion

    is working oward fixing over ime. Tis is because colleges are now required

    o repor o he Naional Suden Loan Daa Sysem wha program a suden

    enrolls in and graduaes rom. Tis new requiremen by he deparmen, how-

    ever, did no sar unil 2013, and i is no reroacive.27 As a resul, he depar-

    menand, in many cases, he insiuioncanno go back and break down

    resuls by program or pas cohors. Te deparmen can, however, sar o dohis in he uure. For insance, i will have program daa or borrowers saring

     wih he 2014 ederal fiscal year; assuming i ollows he patern o combining

    wo cohors o daa, i should be able o generae one-year repaymen raes by

    program or he cohors o sudens who enered repaymen in 2014 or 2015 a

    he end o Sepember 2017.28 Unorunaely, he newness o he program-level

    reporing requiremen does mean ha daa on longer-erm oucomes will ake a

     bi longer o generae. Bu i will be here evenually.

    Stop suppressing data for cohorts with many students

    Suppressing daa is an imporan privacy proecion ool. No reporing resuls or

    cohors wih ew sudens in hem proecs agains he possibiliy ha someone

    may be able o ideniy oucomes or a specific individual. Tis is an issue ha he

    Deparmen o Educaion aces wih all is daa indicaors. I is why, or example, i

    adds ogeher he daa or muliple years o borrowers’ suden loan deaul raes i

    ewer han 30 borrowers ener repaymen in a given year.29 

     Ye in many cases, he College Scorecard daa appear o go much urher han neces-sary when suppressing daa. For example, exas A&M Universiy had 6,185 com-

    pleers ener repaymen in FY 2006 or FY 2007.30 Ye is hree-year repaymen rae

    or graduaes is privacy suppressed. So are he resuls or Michigan Sae Universiy,

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     wih 5,861 compleers. All old, o he hree-year repaymen raes or borrowers

     who enered repaymen in 2006 or 2007, nearly 1,400 insiuions wih more han

    30 sudens in heir compleer cohor had heir resuls privacy suppressed.31 Tis

    includes more han 300 insiuions wih more han 500 compleers. I is no oally

    clear wha migh be causing his suppression o large cohors, bu whaever proocol

    produces i needs o be rehough o beter balance he need or privacy wih makingpublic he resuls or very large cohors.

    Reduce completion categories to avoid suppression issues

    Similar suppression issues exis elsewhere in he daa. For insance, he score-

    card conains deailed ranser and compleion daa or ederally aided sudens

    wo, hree, our, six, and eigh years afer enering college. For each o hose

     years, he scorecard indicaes wheher sudens were sill enrolled, wihdrew,

    compleed, or i heir saus is unknown. In each o hese caegories, he score-card also disaggregaes daa based upon wheher he suden achieved ha

    saus a ha school, afer ranserring o a our-year insiuion, or afer rans-

    erring o a wo-year college. Along wih he rae o sudens who died, his

    presens 13 differen sauses a given individual could end up in during a year.

    Teoreically, he combined percenage o sudens in hese sauses should add

    up o 100 percen. Bu ha is almos never he case. Te problem, again, is privacy

    suppression. Te Deparmen o Educaion does no repor he rae or any saus

    ha only has a ew sudens in i. Tis pracice makes i impossible o add properly

    across all he sauses o generae a perec picure o compleion.

    Privacy suppression is paricularly problemaic or evaluaing compleion raes.

    Consider he case o James H. Faulkner Sae Communiy College in Alabama.

    able 3 shows how he scorecard repors he oucomes afer eigh years or is

    ederally aided sudens who enered Faulkner Sae in 1997 or 2005.

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    TABLE 3

    How privacy suppression affects completion data

    at Faulkner State Community College

    Share of federally aided students at Faulkner State,

    by outcome eight years after entering college

    College entry year 1997 2005

    Completed: original institution Suppressed 9

    Completed: transferred to a 4-year institution 20 13

    Completed: transferred to a 2-year institution 3 4

    Withdrew: original institution Suppressed 24

    Withdrew: transferred to a 4-year institution 20 20

    Withdrew: transferred to a 2-year institution 2 5

    Still enrolled: original institution 3 Suppressed

    Still enrolled: transferred to a 4-year institution 6 3

    Still enrolled: transferred to a 2-year inst itut ion Suppressed Suppressed

    Unknown: original institution 29 15

    Unknown: transferred to a 4-year institution 5 1

    Unknown: transferred to a 2-year institution 9 3

    Died Suppressed Suppressed

    Source: CAP analysis of U.S. Department of Education, “College Scorecard Data: 2004 and 2012,” available athttps://collegescorecard.ed.gov/data/ (last accessed January 2016).

    By suppressing hese daa in he 1997 cohor, i is impossible o deermine wha

    percenage o sudens acually graduaed rom he insiuionnor can he

    public see wha percenage wihdrew. I also is no clear how o calculae he col-

    lege’s compleion rae, since surely some percenage o sudens did graduae rom

    Faulkner Sae. While IPEDS daa do no go back o he 1997 cohor, hey do

    show ha he sudens who enered he insiuion in 1998 beginning as ull-ime

    sudens had a compleion rae o 16 percen.32 Forunaely, as he 2005 daa show,

    he incidence o suppression appears o be declining. In his case, he compleion

    and wihdrawal resuls a he original insiuion are visible, while he percenage

    unknown ell by nearly wo-hirds.

     While hopeully he beter resuls or more recen cohors sugges his daaproblem will become less requen wih ime, here are some ways o fix his issue

    or earlier years. Te deparmen could sop reporing ranser merics broken

    down by wo-year or our-year insiuions as a way o reduce he number o

    caegories and hopeully lessen privacy suppression. In his case, he agency would

     break down resuls in he ollowing caegories: compleed a original insiuion;

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    ranserred and compleed; wihdrew rom original insiuion; ranserred and

     wihdrew; and so on. Te advanage o his approach is ha i preserves daa on

    ranser. A shorcoming, however, is ha i does lose he disincion beween

    someone who sars a one communiy college and finishes a anoher, bu his is

    arguably less imporan han knowing wheher someone rom a wo-year school

    goes on o a our-year college and graduaes.

     Alernaively, he deparmen could repor resuls across ewer caegories, such

    as sudens who compleed, wihdrew, were sill enrolled, or have an unknown

    saus. Tis change would mean ha someone who ransers and complees ges

    combined wih someone who complees a he original insiuion, wih a similar

    approach aken or hose who wihdrew or have an unknown saus. I is less likely

    ha hese combined groups will be privacy suppressedespecially eigh years

    afer enrollingso hey will presen a more accurae picure o wha happened o

    sudens. While he advanage o his approach is ha i ocuses on he ulimae

    oucome, i does mean ha less daa on ranser specifically would ge repored.

    TABLE 4

    Alternate completion reporting options

    Current scorecard outcomes

    Moderate

    consolidation

    Greater

    consolidation

    Completed: original institution

    Completed: transferred to a 4-year institution

    Completed: transferred to a 2-year institution

    Completed: original institution

    Completed: transferredCompleted

    Withdrew: original institution

    Withdrew: transferred to a 4-year institution

    Withdrew: transferred to a 2-year institution

    Withdrew: original institution

    Withdrew: transferredWithdrew

    Still enrolled: original institution

    Still enrolled: transferred to a 4-year institution

    Still enrolled: transferred to a 2-year institution

    Still enrolled: original institution

    Still enrolled: transferredStill enrolled

    Unknown: original institution

    Unknown: transferred to a 4-year institution

    Unknown: transferred to a 2-year institution

    Unknown: original institution

    Unknown: transferredUnknown

    Died Dropped Dropped

    Source: CAP suggestions for possible new completion metrics are based on analysis of U.S. Department of Education, “College ScorecardData,” available at https://collegescorecard.ed.gov/data/ (last accessed January 2016).

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    Finally, he Deparmen o Educaion should consider dropping he percen-

    age o sudens who died rom he compleion daa, paricularly i i would help

     wih privacy suppression issues. I i deleed his saus, i also would need o

    exclude any sudens in his caegory rom he coun o oal enering sudens.

    Excluding hese daa will no affec he overall compleion picure; deceased

    sudens are almos always privacy suppressed, and i is common pracice odrop anyone who passed away rom graduaion rae cohors.33 And i his means

    one ewer caegory ha migh resul in he need o suppress oher, more impor-

    an oucomessuch as compleion or ranserhen removing he deceased

    caegory would be worhwhile.

    Improve the data download process

    Te commimen o making all he daa in he College Scorecard easily down-

    loadable and accessible is criically imporan. o he Deparmen o Educaion’scredi, i made significan effors o help users access daa boh hrough download-

    able spreadsheeswhich included he opion o secure he mos recen key indi-

    caorsand he creaion o an applicaion programming inerace, or API, which

    makes i easy o impor scorecard daa ino hird-pary applicaions and auomai-

    cally updae figures i and when hey change. Te documenaion ha came wih

    hese files was also invaluable or helping navigae such a wealh o daa.34 

     A he same ime, he basic srucure o he daa could be more user riendly.

    Indicaors are sored in individual spreadshees grouped by he year he daa were

    colleced. Te challenge wih his pracice is ha he daa or a given year may con-

    ain inormaion on several differen cohors. For example, he 2011 file conains

    earnings inormaion on hree differen earnings cohors, as well as repaymen rae

    daa on hree oher cohors.35 Tus, puting ogeher he daa or a given cohor

    means siching ogeher muliple large files.

    Te deparmen could ake wo seps o make his process simpler. Ideally, i should

    creae an inerace ha allows users o download selec indicaors or subses o

    insiuions. For example, a user could access repaymen daa jus on public our-

     year colleges. One way o do his would be o add he scorecard ino he ineraceha he deparmen already operaes or IPEDS.36 Te advanage o his approach

    is ha researchers already know how o use his ool and i would cenralize daa. In

    addiion, he scorecard already includes some indicaors rom IPEDS, so his would

     jus mean adding in daa such as repaymen raes, earnings, compleion, and deb,

    among ohers. I ha does no work, he deparmen could build a new inerace

     jus or he scorecard, hough ha would ake more ime and resources.

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     Alernaively, he deparmen could hink abou releasing daa in differen group-

    ings. For insance, insead o releasing daa by collecion year, i could separaely

    produce spreadshees grouped by cohor. Tis would allow users o ge daa on

     jus he 2006 and 2007 repaymen cohors all in one place wihou having o draw

    on muliple differen files.

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    New indicators needed from

    the Department of Education

    Tis secion looks a wha oher daa or uncionaliy he deparmen could add

     bu does no currenly have.

    Provide more data on income-driven repayment usage

    Income-driven repaymen plans are he mos imporan addiion o he suden

    aid programs in he pas several years. Tese opions provide borrowers wih asaey ne o ensure ha heir paymens will no exceed cerain percenages o

    heir income. A he same ime, excessive usage o hese plans could be a sign o

    disressspecifically, ha borrowers are no earning enough money o avoid

    needing help on heir paymens.

    Unorunaely, he Deparmen o Educaion currenly provides minimal inorma-

    ion abou he usage o income-driven repaymen plans. I discloses some daa

    or he enire porolio abou how many borrowers and loan dollars are on one o

    hese paymen plans bu nohing a he insiuional or programmaic level.37 Tis

    is a significan inormaion gap or consumers and researchers. Knowing hese

    kind o daa is paricularly imporan due o concerns raised abou he poenial

    or misuse o income-driven plans.38 Wihou knowing more abou who is using

    hese plans and wha colleges hey are atending, i can be hard o couner he

    narraives criiquing income-driven repaymen, which could lead o congressional

    changes ha make he plans less generous o people who need hem.

    Te deparmen could address his inormaion gap by saring o provide daa

     by cohor and insiuion on repaymen plan usage, including he Public Service

    Loan Forgiveness Program. Tis would allow researchers and consumers o see which insiuions rely heavily on hese plans. I also would give poenial borrow-

    ers a sense o wha ype o repaymen experience hey can expec.

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    Report more loan performance data

    In recen years, he Deparmen o Educaion has goten much beter abou

    reporing daa on he overall suden loan porolio. Tis includes inormaion on

    he volume o loans in repaymen, deermen, deaul, and oher caegories, as well

    as breakdowns o he ype o paymen plan or direc loan borrowers. While hesedaa are exremely useul, he deparmen has no disclosed hem a he insiu-

    ional level. Knowing more abou loan perormance by insiuion could help he

    deparmen and he public spo poenially roubling deb behavior ha is no

    capured by he exising cohor deaul rae accounabiliy meric.

    Suggested improvements to indicatorsand disaggregates for College Scorecard data

      Type of change Suggestions

      Overall suggestions Disaggregate by program

      Report results for graduate students

      Break down results for branch campuses

    Address data suppression

      Repayment rates Use a true measure of repayment

      Estimate total time to repay

      Earnings Disaggregate by completion status

      Disaggregate by year in which students leave school

      Cumulative debt Align with repayment rate cohort

      Completion Combine categories to lessen suppression

      New loan measures Repayment plan usage

      Share of borrowers who are 90 days late

      Share of borrowers on forbearance

      Parent PLUS loan outcomes

    New enrollment measures Popular colleges, by high school

      Popular high schools, by college

      What Congress can do End the ban on a student-level data system

    Source: CAP suggestions for improving the College Scorecard are based on analysis of U.S. Department of Education, “CollegeScorecard Data,” available at https://collegescorecard.ed.gov/data/ (last accessed January 2016).

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    Tere are several addiional indicaors on loan perormance ha he deparmen

    should release as well. In many cases, hese may only be available or direc loan

     borrowers or oher ederal loans now held by he deparmen, which could limi

    how ar back hey could go. In paricular, he agency should release daa abou he

    usage o paymen opions known as deermens and orbearances, which allow

     borrowers o sop making paymens wihou going ino deaul. I also shouldprovide daa on he percenage o sudens who are 90 or more days lae on a loan

    paymen. Knowing he percenage o borrowers using one o hese ools o sop

    paymens beore hey deaul would help ideniy colleges ha are being overly

    aggressive in managing heir deaul raes. Imporanly, i he deparmen does

    release deermen and orbearance daa, i should break down resuls by he ype

    o paymen cessaion sough. Tis maters because no all orms o deermen

    and orbearance are problemaic. For insance, borrowers who go back o college

    receive an in-school deermen.39 Te delinquency daa, meanwhile, are helpul or

    ideniying insiuions ha are likely o have repaymen problems in he uure.

    Report outcomes for parent loans

     While sudens make up he majoriy o borrowers, a large number o parens also

    ake on ederal debs o help heir children pay or college. Tey do so hrough

    somehing known as a Direc PLUS Loan or parens. Te ederal governmen,

    however, provides no daa o help paren borrowers undersand he risks hey may

    ace. I does no provide any inormaion on ypical deb levels o paren PLUS

     borrowers,40 nor does i repor perormance daa on hese debs, such as deaul or

    repaymen raes. Adding hese daa o he College Scorecard would ensure ha i

    can be jus as useul a ool or parens as i is or sudens.

    Report data on graduate students

    Graduae sudens make up a subsanial share o suden loan borrowers. In

    he 2014-15 award year, nearly 1.5 million graduae sudens received ederal

    suden loans, abou 15 percen o all borrowers.41 While graduae sudens may

    have beter repaymen oucomes han undergraduaes in general, hey also havehe abiliy o ake on much higher deb levels.42 A subsanial number o hem

    also appear o be users o income-driven repaymen plans.43 As a resul, prospec-

    ive sudens would be well served o know i a poenial large loan invesmen

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    hey migh make is worh i. Given he wide range o differen ypes o graduae

    educaion, his is an area where program-level oucomes would be paricularly

    imporan. I also would represen an expansion o he scorecard beyond is cur-

    ren ocus on jus undergraduae educaion.

    Report data at the campus level

    Te Deparmen o Educaion collecs daa on insiuions o higher educaion

    rom wo major sources: he Inegraed Possecondary Educaion Daa Sysem or

    daa on pricing, compleion, spending, and enrollmen, and he Naional Suden

    Loan Daa Sysem or daa on he ederal suden aid programs. While each is

     very useul, he wo, unorunaely, do no align perecly. Daa rom IPEDS end

    o be repored a he campus level. So an insiuion such as he Universiy o

    Phoenix shows up 38 differen imesonce or each sae in which i operaes.44 

    By conras, NSLDS daa ofen end o aggregae he resuls or muliple campusesunder a single indicaor. In he case o he Universiy o Phoenix, his means ha i

    shows up as a single insiuion in he NSLDS daa.

    Tis seup creaes a complicaed daa crosswalk ha means consumers hinking

    abou atending one o he campuses ha rolls up all is daa canno see resuls or

    he specific locaion hey are considering. Making maters worse, he daa roll-up

    is no consisen. While he Universiy o Phoenix repors as a single school or

    financial aid purposes, compeior chains such as Kaplan Universiy show up as

    nearly 30 differen campuses.45 Alhough his issue is mos relevan a privae or-

    profi colleges, i also occurs in he public secor. For insance, Pennsylvania Sae

    Universiy combines he resuls o is main campus wih all o is branch cam-

    puses. Tis means someone choosing beween he main Penn Sae campus and

    Michigan Sae Universiy canno see apples-o-apples comparisons.

    Te deparmen has he abiliy o fix his problem. o address his issue, i should

    adop common insiuional idenifiers or boh IPEDS and NSLDS. Moreover,

    hose indicaors should be a he campus level. Colleges ha offer an online learn-

    ing componen should have he abiliy o repor heir online campus as a separae

    locaion. Breaking ou resuls in his manner would ensure ha consumers gedaa disaggregaed o he proper level ha helps hem make inormed choices. I

    also would reduce conusion abou wheher resuls presened may be covering he

    experiences o sudens atending schools housands o miles away.

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    Tis change will ake some work. Righ now he idenifier used or NSLDS comes

    rom a documen known as a Program Paricipaion Agreemen.46 Tis orm can

    cover muliple campusesas is he case wih he Universiy o Phoenix. So i

    could require insiuions o sar signing several documens when previously hey

    had o sign only one. I also would mean clearly defining wha consiues anoher

    campus, raher han jus a place where a course or wo may be augh.

    Te curren numbering sysem or idenifiers provides one opion or resolving

    his issue. Te NSLDS idenifier is currenly repored as six or eigh digis. In

    mos cases, he las wo digis o he eigh-number idenifier represen a branch

    campus. For insance, he eigh-digi idenifier or Ohio Sae Universiy’s main

    campus is 00309000, while is Lima campus is 00309001 and he Newark campus

    is 00309004.47 Each o hese campuses already has a unique idenifier or IPEDS,

    so reporing daa as he eigh-digi idenifier or NSLDS should in mos cases have

    an easy crosswalk o he IPEDS daa. Alernaively, colleges could be required

    o ideniy which o he campuses under he eigh-digi idenifiers are branchcampuses versus smaller learning sies. Tis is somehing hey likely already have

    o do anyway or heir accrediaion agencies.48 Forunaely, he Deparmen o

    Educaion already appears o be moving somewha in his direcion by ensuring

    ha more insiuions repor heir enrollmen and financial aid daa ino NSLDS

    a he more granular campus level.49

    Allow for data correction

     A subsanial amoun o he scorecard daa comes rom insiuional repor-

    ing. Even or indicaors such as repaymen raes or earnings, which come rom

    NSLDS, he Deparmen o Educaion sill relies on colleges or grouping sudens

    ino caegories such as “graduaed” or “wihdrew.” Errors are ineviable wih so

    many colleges, indicaors, and years o daa. In oher cases, daa qualiy may suffer

     because some indicaors were no always necessary or operaional purposes. For

    insance, insiuions did no have o repor he compleion saus o Pell Gran

    recipiens unil 2012.50 As a resul, he qualiy o older compleion daa on Pell

    Gran recipiens is poor.

    Realisically, i is no easible or he deparmen o go back o every insiuion

    and ask hem o fix heir daa going back wo decades. Doing so would be very

    ime consuming or he governmen and schools and is probably no worh he

    resource commimen. Individual insiuions, however, may wish o fix resuls

    ha hey see as major problems, or hey may decide ha heir daa need o be

    grouped differenly, such as o show resuls by program wihin he insiuion.

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    o help insiuions ha wan o correc heir daa, he deparmen should offer a

     volunary daa improvemen process. I would provide insrucions or how col-

    leges could updae heir inormaion i hey wished o and promise o rerun any

    resuls once up-o-dae daa are enered. I also could urher assis insiuions

     by providing hem wih he rosers o sudens used o creae cohors or differen

    merics. Tis process should no be paricularly burdensome or he deparmen,since he colleges will be doing mos o he work. And i would no creae a lo

    o burden or colleges since only hose insiuions mos concerned abou heir

    resuls would choose o ake par.

    Avoid relying on student-reported level in college

    Because he Deparmen o Educaion only has individual-level daa on people who

    received ederal suden aid, i someimes has o guess wha year a suden enered

    college. Tis occurs when sudens do no receive ederal aid in heir firs year buend up receiving i laer in heir college career. Relying on a suden’s year in college

    o make judgmens abou wha cohor hey should coun in makes sense. However,

    he scorecard figures his ou using daa sel-repored by he suden when hey fill

    ou a Free Applicaion or Federal Suden Aid, or FAFSA.51 Te problem, however,

    is ha sudens may no correcly know heir year in college and repor incorrec

    daa. For insance, his migh be because a suden has been enrolled or a year bu

    has no compleed enough credis o advance and incorrecly hinks ime spen is

    enough o move up a level. Tis can lead o sudens geting atached o he wrong

    cohors or he purposes o measuring compleion, poenially affecing esimaes

    o ime o degree or he atainmen rae.

    Te deparmen’s analysis released wih he scorecard showcased he exen

    o which sudens are no accuraely lising heir year in college. o assess he

    accuracy o his variable, he deparmen compared is esimaes o he firs year in

    college or sudens in Virginia wih similar inormaion held by he Sae Council

    o Higher Educaion or Virginia, or SCHEV, which mainains one o he bes

    higher educaion daa sysems in he counry. O he Virginia sudens ha he

    deparmen hough sared in 2008, only 70 percen acually firs enered college

    in ha year, according o he SCHEV daa.52

     In general, he deparmen’s daa were no off by a lo18 percen o Virginia sudens enered college in eiher he

    wo years prior o or afer 2008bu ha is sill a significan number o sudens

    placed ino he wrong cohor.53 

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    Insead o coninuing o rely on suden-repored daa o assign college level, he

    deparmen should insead ge his inormaion rom insiuions. Obaining hese

    daa going orward should no be hard; colleges already repor hem o he depar-

    men in a differen daabase called he Common Originaion and Disbursemen

    Sysem.54 Unorunaely, he daa will be o lesser qualiy or older years because

    he deparmen only sared requiring more inormaion on Pell Gran recipiensin 2012, and i is no reroacive.55 Alhough hese daa may sill have imperecions

    due o complexiies o when inormaion is repored, insiuions have a much

    greaer reason or geting his inormaion righ since a suden’s level in college

    affecs how much hey can borrow and annual audiors will come in o check ha

    sudens received he proper amoun o aid dollars.56 By conras, sudens who

    incorrecly repor heir college level on he FAFSA ace minimal consequences.

    Report data that is useful for high school counselors

    One o he Deparmen o Educaion’s saed goals wih he scorecard is o pro-

     vide daa ha can help sudens make sound college choices. For many sudens,

    paricularly younger ones coming sraigh rom high school, he possecondary

    search and selecion process can be srongly influenced by heir college coun-

    selors. Depending on he sae in which hey work and live, hese counselors

    may no have much inormaion on where heir sudens go or how hey are in

    possecondary educaion.

    Ulimaely, i would be ideal i he deparmen could ell high school coun-

    selors how heir ormer sudens ared in college, eiher a he individual level

    or a leas by insiuion. Bu i hose daa are no available now, he depar-

    men could sar by reporing where sudens commonly enroll by high school

    and rom where insiuions ypically draw heir sudens. Tis would mean

    reporing or each high school he five or so mos commonly atended colleges.

    Similarly, he deparmen also could repor by college he five or so high schools

    ha sen he larges numbers o sudens o a paricular insiuion. Tese iniial

    daa could sar he conversaion abou where high schools are sending sudens

    and where insiuions are finding hem.

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    What Congress can do to

    improve the College Scorecard

     While here is much ha he Deparmen o Educaion can do o improve he

    scorecard, here is one major srucural challenge ha only Congress can fix:

    he Deparmen o Educaion’s inabiliy o collec daa on sudens who did no

    receive ederal financial aid.

    For mos indicaors, only having daa on ederal aid recipiens works. I is no

    necessary o know abou sudens who did no ge ederal suppor in order o

    generae deb esimaes or repaymen raes. Bu no knowing abou all college su-dens can depress compleion raes and earnings daa significanly. In paricular,

    many colleges may only have a minoriy o sudens who receive ederal financial

    aid, ensuring ha he scorecard resuls o hese insiuions are no represena-

    ive. Moreover, i he scorecard is viewed as nonrepresenaive i may undermine

    consumers’ accepance o i and make i harder o achieve is goals.

    Te deparmen needs congressional approval o include sudens who did

    no receive ederal financial aid in he scorecard daa. Tis is because o a 2008

    congressional provision ha bans he Deparmen o Educaion rom collec-

    ing daa or operaing a new daabase o suden-level inormaion.57 Also known

    as he “suden uni record ban,” his law prevens he deparmen rom geting

    he daa i needs on individuals who did no receive ederal aid. Overurning

    his prohibiion would make i possible o presen more complee and accurae

    picures o perormance a all colleges.

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    Conclusion

    Te College Scorecard is a crucial developmen in higher educaion daa policy. Tis

    is because i opens he door o housands o daa indicaors ha were previously

    unavailable o he public and he governmen. Is mach wih Deparmen o he

    reasury daa o generae earnings figures and a ransparen manner o posing and

    sharing he daa are examples o how governmen agencies can work well ogeher

    and uncion. Te scorecard is o be lauded or all o hese accomplishmens.

     Ye he Deparmen o Educaion mus ensure ha he curren ieraion o heCollege Scorecard is jus he beginning and no he end o ha daa improvemen

    process. As laid ou in his repor, here are several fixes o is exising indicaors and

    new measures ha he Deparmen o Educaion should address going orward.

    Doing so will ensure ha prospecive sudens, parens, and researchers have he

     bes daa possible. Te resul will be no only smarer amily decision-making bu

    also an enhanced abiliy o analyze and assess he resuls o America’s possecondary

    sysem o ensure ha all sudens have access o a high-qualiy college educaion.

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    About the author

    Ben Miller is he Senior Direcor or Possecondary Educaion a he Cener or

     American Progress.

    Acknowledgments

    Te auhor would like o hank he reviewers who ook ime o read and offer

    houghul eedback on his repor.

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    Endnotes

      1 The public tool only reports data for about 4,000colleges—those that offer at least one associate orbachelor’s degree. This figure reflects downloadabledata, not the public tool. This includes both main andbranch campuses. Not all variables are available forevery year, and branch campuses tend to have dataidentical to those of their main campuses on indicatorssuch as repayment rates and earnings. See U.S. Depart-ment of Education, “College Scorecard Data,” availableat https://collegescorecard.ed.gov/data/ (last accessedJanuary 2016).

      2 Clare McCann and Amy Laitinen, “College Blackout”(Washington: New America, 2014), available at https://www.newamerica.org/downloads/CollegeBlackoutFI-NAL.pdf .

    3 U.S. Department of Education, “Federal Student AidData Center,” available at https://studentaid.ed.gov/sa/data-center (last accessed February 2016).

    4 Center for American Progress analysis of College Score-card data from U.S. Department of Education, “CollegeScorecard Data.”

      5 Bryan Cook, “Incomplete Completers: Analysis ofa Comprehensive Graduation R ate” (Washington:American Council on Education, 2012), available athttps://www.acenet.edu/news-room/Documents/Grad-Rate-110812.pdf .

    6 The exceptions to this are students who leave school toserve in the armed forces, those who die or have a totaland permanent disability, and other similar instances.See National Center for Education Statistics, “2005Graduation Rates for 4-Year Institutions,” available athttps://surveys.nces.ed.gov/ipeds/VisForms.aspx?survey=2&form=83&index=0&ri=0&show=all&instid=485 (last accessed February 2016).

      7 Doug Shapiro and others, “Completing College: ANational View of Student Attainment Rates – Fall 2009Cohort” (Herndon, VA: National Student Clearinghouse,2015), p. 25, available at https://nscresearchcenter.org/wp-content/uploads/SignatureReport10.pdf .

    8 Letter from The Institute for College Access and Successto Interested Parties, “Steps the Education Depart-ment Should Immediately Take to Curb Default RateManipulation,” August 21, 2012, available at http://ticas.org/sites/default/files/pub_files/TICAS_memo_on_CDR_evasion_082112.pdf.

      9 Executive Office of the President, Using Federal Data toMeasure and Improve the Performance of U.S. Institutionsof Higher Education (2015), p. 23, available at https://collegescorecard.ed.gov/assets/UsingFederalDataTo-MeasureAndImprovePerformance.pdf.

      10 Since Pell Grant reporting has only been availablesince July 2012, the department relied on the NationalStudent Clearinghouse, a private organization, tosupplement some of the Pell Grant data on thescorecard. For an example of how hard it is to get Pell

    Grant graduation rates, see Kevin Carey and AndrewKelly, “The Truth Behind Higher Education DisclosureLaws” (Washington: Education Sector and AmericanEnterprise Institute, 2011), available at http://www.thecollegesolution.com/wp-content/uploads/2011/11/HigherEdDisclosure_RELEASE.pdf. 

    11 See, for example, Christopher Nelson, “Salary Isn’tthe Only Measure,” Inside Higher Ed , September 14,2015, available at https://www.insidehighered.com/views/2015/09/14/essay-criticizes-obama-administra-tions-new-scorecard-colleges.

    12 Rachel Fishman, “Deciding to Go to College” (Washing-ton: New America, 2015), p. 6, available at https://www.luminafoundation.org/files/resources/deciding-to-go-to-college.pdf .

      13 Executive Office of the President, Using Federal Data toMeasure and Improve the Performance of U.S. Institutionsof Higher Education,” p. 24.

      14 Figures estimated using a 10- and 20-year repaymentterm on a $10,000 balance and a 5 percent interest rateusing Amortization-calc.com, “Amortization ScheduleCalculator,” available at http://www.amortization-calc.com (last accessed January 2016).

    15 This calculation would be more complicated if loanshad a variable interest rate, but this has not been thecase for federal loans for some time.

    16 Federal Student Aid, “Income-Driven Plans,” available athttps://studentaid.ed.gov/sa/repay-loans/understand/plans/income-driven (last accessed February 2016).

      17 Jenna Johnson, “Obama Signs Student Loan InterestRate Legislation Into Law,” The Washington Post , August9, 2013, available at https://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.html.

    18 David Herszenhorn and Tamar Lewin, “Student LoanOverhaul Approved by Congress,” The New York Times,March 25, 2010, available at http://www.nytimes.com/2010/03/26/us/politics/26loans.html.

    19 Figures estimated using a $10,000 original balance, a5 percent interest rate and monthly payments of $75using Free-Online-Calculator-Use.com, “Missing Loan

     Term Calculator for Calculating the Unknown Variable,”available at http://www.free-online-calculator-use.com/missing-term-loan-calculator.html(last accessedFebruary 2016).

    20 Federal Student Aid, “Understanding Repayment,”available at https://studentaid.ed.gov/sa/repay-loans/

    understand (last accessed February 2016).

    21 U.S. Department of Education, Data Documentation (2015), p. 16, available at https://collegescorecard.ed.gov/assets/FullDataDocumentation.pdf .

    22 To make this issue work for students who only receivedPell Grants, the year they left school would be definedas whatever year falls six months after their date ofseparation. Doing so aligns Pell-only students with bor-rowers who do not enter repayment until exhaustingtheir grace period.

    23 National Center for Education Statistics, “The Universityof Alabama: Graduation Rates, status as of August 31,2007,” available at https://nces.ed.gov/ipeds/datacen-ter/ (last accessed January 2016).

      24 Ibid.

    25 Anthony Carnevale, Jeff Strohl, and Michelle Melton,“What’s It Worth?” (Washington: Georgetown UniversityCenter on Education and the Workforce, 2014), avail-able at https://cew.georgetown.edu/wp-content/uploads/2014/11/whatsitworth-complete.pdf .

      26 Nicholas Hillman and Taylor Weichman, “EducationDeserts: The Continued Significance of ‘Place’ in the

     Twenty-First Century” (Washington: American Councilon Education, 2016), available at http://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdf .

    https://collegescorecard.ed.gov/data/https://www.newamerica.org/downloads/CollegeBlackoutFINAL.pdfhttps://www.newamerica.org/downloads/CollegeBlackoutFINAL.pdfhttps://www.newamerica.org/downloads/CollegeBlackoutFINAL.pdfhttps://studentaid.ed.gov/sa/data-centerhttps://studentaid.ed.gov/sa/data-centerhttps://www.acenet.edu/news-room/Documents/GradRate-110812.pdfhttps://www.acenet.edu/news-room/Documents/GradRate-110812.pdfhttps://surveys.nces.ed.gov/ipeds/VisForms.aspx?survey=2&form=83&index=0&ri=0&show=all&instid=485https://surveys.nces.ed.gov/ipeds/VisForms.aspx?survey=2&form=83&index=0&ri=0&show=all&instid=485https://nscresearchcenter.org/wp-content/uploads/SignatureReport10.pdfhttps://nscresearchcenter.org/wp-content/uploads/SignatureReport10.pdfhttp://ticas.org/sites/default/files/pub_files/TICAS_memo_on_CDR_evasion_082112.pdfhttp://ticas.org/sites/default/files/pub_files/TICAS_memo_on_CDR_evasion_082112.pdfhttp://ticas.org/sites/default/files/pub_files/TICAS_memo_on_CDR_evasion_082112.pdfhttps://collegescorecard.ed.gov/assets/UsingFederalDataToMeasureAndImprovePerformance.pdfhttps://collegescorecard.ed.gov/assets/UsingFederalDataToMeasureAndImprovePerformance.pdfhttps://collegescorecard.ed.gov/assets/UsingFederalDataToMeasureAndImprovePerformance.pdfhttp://www.thecollegesolution.com/wp-content/uploads/2011/11/HigherEdDisclosure_RELEASE.pdfhttp://www.thecollegesolution.com/wp-content/uploads/2011/11/HigherEdDisclosure_RELEASE.pdfhttp://www.thecollegesolution.com/wp-content/uploads/2011/11/HigherEdDisclosure_RELEASE.pdfhttps://www.insidehighered.com/views/2015/09/14/essay-criticizes-obama-administrations-new-scorecard-collegeshttps://www.insidehighered.com/views/2015/09/14/essay-criticizes-obama-administrations-new-scorecard-collegeshttps://www.insidehighered.com/views/2015/09/14/essay-criticizes-obama-administrations-new-scorecard-collegeshttps://www.luminafoundation.org/files/resources/deciding-to-go-to-college.pdfhttps://www.luminafoundation.org/files/resources/deciding-to-go-to-college.pdfhttps://www.luminafoundation.org/files/resources/deciding-to-go-to-college.pdfhttp://www.amortization-calc.com/http://www.amortization-calc.com/https://studentaid.ed.gov/sa/repay-loans/understand/plans/income-drivenhttps://studentaid.ed.gov/sa/repay-loans/understand/plans/income-drivenhttps://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.htmlhttps://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.htmlhttps://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.htmlhttps://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.htmlhttp://www.nytimes.com/2010/03/26/us/politics/26loans.htmlhttp://www.nytimes.com/2010/03/26/us/politics/26loans.htmlhttp://www.free-online-calculator-use.com/missing-term-loan-calculator.htmlhttp://www.free-online-calculator-use.com/missing-term-loan-calculator.htmlhttps://studentaid.ed.gov/sa/repay-loans/understandhttps://studentaid.ed.gov/sa/repay-loans/understandhttps://collegescorecard.ed.gov/assets/FullDataDocumentation.pdfhttps://collegescorecard.ed.gov/assets/FullDataDocumentation.pdfhttps://nces.ed.gov/ipeds/datacenter/https://nces.ed.gov/ipeds/datacenter/https://cew.georgetown.edu/wp-content/uploads/2014/11/whatsitworth-complete.pdfhttps://cew.georgetown.edu/wp-content/uploads/2014/11/whatsitworth-complete.pdfhttp://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdfhttp://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdfhttp://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdfhttp://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdfhttp://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdfhttp://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdfhttp://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdfhttp://www.acenet.edu/news-room/Documents/Education-Deserts-The-Continued-Significance-of-Place-in-the-Twenty-First-Century.pdfhttps://cew.georgetown.edu/wp-content/uploads/2014/11/whatsitworth-complete.pdfhttps://cew.georgetown.edu/wp-content/uploads/2014/11/whatsitworth-complete.pdfhttps://nces.ed.gov/ipeds/datacenter/https://nces.ed.gov/ipeds/datacenter/https://collegescorecard.ed.gov/assets/FullDataDocumentation.pdfhttps://collegescorecard.ed.gov/assets/FullDataDocumentation.pdfhttps://studentaid.ed.gov/sa/repay-loans/understandhttps://studentaid.ed.gov/sa/repay-loans/understandhttp://www.free-online-calculator-use.com/missing-term-loan-calculator.htmlhttp://www.free-online-calculator-use.com/missing-term-loan-calculator.htmlhttp://www.nytimes.com/2010/03/26/us/politics/26loans.htmlhttp://www.nytimes.com/2010/03/26/us/politics/26loans.htmlhttps://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.htmlhttps://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.htmlhttps://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.htmlhttps://www.washingtonpost.com/politics/obama-signs-student-loan-interest-rate-legislation-into-law/2013/08/09/98fb0426-00f2-11e3-9711-3708310f6f4d_story.htmlhttps://studentaid.ed.gov/sa/repay-loans/understand/plans/income-drivenhttps://studentaid.ed.gov/sa/repay-loans/understand/plans/income-drivenhttp://www.amortization-calc.com/http://www.amortization-calc.com/https://www.luminafoundation.org/files/resources/deciding-to-go-to-college.pdfhttps://www.luminafoundation.org/files/resources/deciding-to-go-to-college.pdfhttps://www.luminafoundation.org/files/resources/deciding-to-go-to-college.pdfhttps://www.insidehighered.com/views/2015/09/14/essay-criticizes-obama-administrations-new-scorecard-collegeshttps://www.insidehighered.com/views/2015/09/14/essay-criticizes-obama-administrations-new-scorecard-collegeshttps://www.insidehighered.com/views/2015/09/14/essay-criticizes-obama-administrations-new-scorecard-collegeshttp://www.thecollegesolution.com/wp-content/uploads/2011/11/HigherEdDisclosure_RELEASE.pdfhttp://www.thecollegesolution.com/wp-content/uploads/2011/11/HigherEdDisclosure_RELEASE.pdfhttp://www.thecollegesolution.com/wp-content/uploads/2011/11/HigherEdDisclosure_RELEASE.pdfhttps://collegescorecard.ed.gov/assets/UsingFederalDataToMeasureAndImprovePerformance.pdfhttps://collegescorecard.ed.gov/assets/UsingFederalDataToMeasureAndImprovePerformance.pdfhttps://collegescorecard.ed.gov/assets/UsingFederalDataToMeasureAndImprovePerformance.pdfhttp://ticas.org/sites/default/files/pub_files/TICAS_memo_on_CDR_evasion_082112.pdfhttp://ticas.org/sites/default/files/pub_files/TICAS_memo_on_CDR_evasion_082112.pdfhttp://ticas.org/sites/default/files/pub_files/TICAS_memo_on_CDR_evasion_082112.pdfhttps://nscresearchcenter.org/wp-content/uploads/SignatureReport10.pdfhttps://nscresearchcenter.org/wp-content/uploads/SignatureReport10.pdfhttps://surveys.nces.ed.gov/ipeds/VisForms.aspx?survey=2&form=83&index=0&ri=0&show=all&instid=485https://surveys.nces.ed.gov/ipeds/VisForms.aspx?survey=2&form=83&index=0&ri=0&show=all&instid=485https://www.acenet.edu/news-room/Documents/GradRate-110812.pdfhttps://www.acenet.edu/news-room/Documents/GradRate-110812.pdfhttps://studentaid.ed.gov/sa/data-centerhttps://studentaid.ed.gov/sa/data-centerhttps://www.newamerica.org/downloads/CollegeBlackoutFINAL.pdfhttps://www.newamerica.org/downloads/CollegeBlackoutFINAL.pdfhttps://www.newamerica.org/downloads/CollegeBlackoutFINAL.pdfhttps://collegescorecard.ed.gov/data/

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      27 U.S. Department of Education, “150% Direct SubsidizedLoan Limit—Frequently Asked Questions: FTB-Q1,”available at http://ifap.ed.gov/150PercentDirectSubsidizedLoanLimitInfo/FAQ.html#FTB-Q1 (last accessedFebruary 2016); U.S. Department of Education, “WilliamD. Ford Direct Loan Program; Interim Final Rule,”  FederalRegister  78 (95) (2013), available at https://ifap.ed.gov/fregisters/FR051613DLProgramInterimFinalRule.html.Although the requirement that limits eligibility forsubsidized loans to 150 percent of a program’s lengthonly applies to new borrowers as of July 1, 2013, thedepartment requires the data reported for anyone bor-

    rowing after that date.

    28 To do this, the department would be measuring thosewho entered repayment in 2014 by their results in 2015and the results for the 2015 cohort in 2016.

    29 U.S. Department of Education, Cohort Default RateGuide (2015), p. 16, available at http://ifap.ed.gov/De-faultManagement/guide/attachments/CDRMasterFile.pdf.

      30 Analysis of the 2009 file from U.S. Department ofEducation, “College Scorecard Data.”

    31 Ibid.

    32 National Center for Education Statistics, “James H.Faulkner State Community College: Graduation Rates,status as of August 31, 2001,” available at https://nces.

    ed.gov/ipeds/datacenter/(last accessed January 2016).

      33 National Center for Education Statistics, “200% Gradu-ation Rates for 2-Year Institutions,” available at https://surveys.nces.ed.gov/ipeds/VisForms.aspx?survey=2&form=83&index=0&ri=0&show=all&instid=485 (lastaccessed February 2016).

    34 U.S. Department of Education, “Data Documentation,”(September 2015), available at https://collegescore-card.ed.gov/data/documentation/  (last accessedFebruary 2016).

      35 Analysis of 2011 file from U.S. Department of Educa-tion, “College Scorecard Data.”

    36 National Center for Education Statistics, “IPEDS DataCenter,” available at https://nces.ed.gov/ipeds/datacen-ter/ (last accessed February 2016).

    37 Federal Student Aid, “Federal Student Loan Portfolio,”available at https://studentaid.ed.gov/sa/about/data-center/student/portfolio (last accessed February 2016).

    38 Jason Delisle and Alex Holt, “Safety Net or Windfall?”(Washington: New America, 2012), available at https://static.newamerica.org/attachments/2332-safety-net-or-windfall/NAF_Income_Based_Repayment.18c8a688f03c4c628b6063755ff5dbaa.pdf .

     39 Federal Student Aid, “Deferment and Forbearance,”available at https://studentaid.ed.gov/sa/repay-loans/deferment-forbearance(last accessed February 2016).

      40 Janet Lorin, “This Parent Trap Involves $71 Billion ofFederal Education Debt,” Bloomberg, December 18,2015, available at http://www.bloomberg.com/news/articles/2015-12-18/this-parent-trap-involves-71-bil-

    lion-of-federal-education-debt.

    41 Federal Student Aid Office, Award Year 2014-15 RecipientSummary  (U.S. Department of Education, 2015), availableat https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/AidRecipientsSummary.xls .

    42 Federal Student Aid, “Subsidized and Unsubsidized Loans,”available at https://studentaid.ed.gov/sa/types/loans/subsidized-unsubsidized (last accessed February 2016).

    43 Matthew Sessa, “Servicer Summit: Loan PortfolioBriefing Document,” Presentation at Federal StudentAid Servicer Summit, December 1, 2014, slide 36,

    available at http://fsaconferences.ed.gov/conferences/library/2014/servicing/2014ServicingSummitPortfolioOverview.pdf .

    44 College Navigator, “Search results: University of Phoe-nix,” available at https://nces.ed.gov/collegenavigator/?q=university+of+phoenix&s=all&ct=3&pg=1 (lastaccessed February 2016). Phoenix’s example is furthercomplicated by the fact that it recently aggregated itsIPEDS data to have one campus for each state in whichit operates, rather than one entry for each campus.

    45 Analysis of U.S. Department of Education, “CollegeScorecard Data.”

    46 Legal Information Institute, “34 CFR §668.14 – Programparticipation agreement.”, available at https://www.law.cornell.edu/cfr/text/34/668.14 (last accessed February2016).

    47 College Navigator, “Search results: Ohio State University,”available at http://nces.ed.gov/collegenavigator/?q=ohio+state+university&s=all (last accessed February 2016).

    48 See, for example, Middle States Commission on HigherEducation, “Branch campuses, additional locations,and other instructional sites,” available at http://www.msche.org/?Nav1=NEWS&Nav2=OTHER(last accessedFebruary 2016).

    49 Executive Office of the President, Using Federal Data toMeasure and Improve the Performance of U.S. Institutionsof Higher Education, p. 29.

    50 Institute for Higher Education Policy, “National StudentLoan Data System (NSLDS)” (2015), p. 2, available athttp://www.ihep.org/sites/default/files/uploads/posts-ecdata/docs/resources/nslds_final.pdf .

      51 Executive Office of the President, Using Federal Data toMeasure and Improve the Performance of U.S. Institutionsof Higher Education, p. 23.

    52 Ibid., p. 70.

    53 Ibid.

    54 Ibid., p. 22.

    55 U.S. Department of Education, “William D. Ford DirectLoan Program; Interim Final Rule.”

     56 Office of Inspector General, Audit Guide: Audits of Fed-eral Student Financial Assistance Programs at Participat-ing Institutions and Institution Servicers (U.S. Departmentof Education, 2000), pp. I–13, available at http://www2.ed.gov/about/offices/list/oig/nonfed/sfgd2000.pdf. 

    57 McCann and Laitinen, “College Blackout.”

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