On Monday, the U.S. Education Department (ED) began formal negotiationson the draft language of a proposed new “gainful employment” rule. The rule, originally published in 2011, was designed to enforce a requirement of the Higher Education Act that states career education programs—non-degree programs at all colleges and most degree programs at for-profit colleges—must “prepare students for gainful employment” in order to participate in federal student aid programs. The rule was meant to discourage these programs from misusing federal aid dollars and leaving students with debts burdens they are unable to repay. However, in 2012 a federal judge rejected major provisions of the rule, requiring that ED rethink its strategy.
Here’s a summary of the changes:
- The proposed rule applies to programs with as few as 10 students, whereas the old rule counted only career-focused programs with 30 or more students. Because of this change, ED estimates that the new rule could cover 11,359 programs at for-profit and nonprofit colleges—nearly twice as many as the old rule covered—and that 974 of those programs (9 percent) could fail to meet the proposed standards.
- The draft regulation omits loan-repayment as a criterion for federal student aid eligibility. The old rule severed federal aid to programs where too few students were repaying their loans or where graduates’ debt-to-earnings and debt-to-discretionary-income ratios were too high. The new rule removes the loan repayment standards, which the courts deemed “arbitrary and capricious,” and relies only on the latter two measures.
- Debt-to-earnings calculations would be based only on students who receive federal aid, rather than students who complete the program. The old calculations were based on all students who completed the program, whereas the proposed calculations are based on any students who receive federal student loans and Pell Grants, regardless of whether they complete the program. As the rule is designed to ensure that federal aid is used effectively, this seems a more appropriate approach.
- Schools would have fewer chances to improve their performance before losing federal aid eligibility. Under the previous rule, programs that failed the measures in 3 out of any 4 years would be ineligible for federal student aid. However, the new rule only lets programs fail in 2 out of any 3 years before they lose eligibility.
For details, see a comparison of the two versions prepared by the Education Department. Please continue to follow our blog as well as the Federal Relations blog for updates on this topic.
Of the nearly 900 schools that received federal money for research and development (R&D) in FY 2011, the UW ranks first among public institutions and second overall in terms of federal research funding. According to a study by the National Science Foundation (NSF), approximately 20 percent of all federal R&D support went to just 10 universities. 24/7 Wall St. reviewed those universities, Table 1 summarizes their findings.
Johns Hopkins University, a private institution, topped the list with nearly $1.9 billion—more than doubling what any other university received that year. The majority of Johns Hopkins’ federal funding came from the Dept. of Defense and NASA. The university also brought in billions via fundraising efforts.
The UW came in second with almost $950 million in federal R&D funding—the most of any public school. The majority of the UW’s money came from the Dept. of Health and Human Services; however, the University was the top beneficiary of NSF funding, receiving more than $145 million in 2011.
Year after year, the same schools consistently receive the most money, said Ronda Britt, a survey statistician with the NSF. 24/7 Wall St. quotes her as saying, these universities “have big research programs that receive a lot of support year after year, and have a lot of infrastructure that helps them keep the money stable.” This holds true for the UW, which has ranked first among public schools since 1974. Having large endowments was another commonality of the top 10 schools, yet federal funding covered the bulk of R&D expenditures in all cases.
As these universities rely heavily on the federal government to support their research, many are concerned about the sweeping cuts of sequestration. The UW and other universities are preparing for a range of possible impacts. As described in our joint brief, the sequester could reduce the UW’s federal grant and contract support by an estimated $75M to $100M during FY13. The UW community is encouraged to remain cautious and conservative in spending federal awards and in planning for future federal funding.
On Wednesday, March 20, the Washington State Economic & Revenue Forecast Council (ERFC) released its quarterly update of State General Fund Revenues. Revenue from an anticipated increase in Washington housing permits and real estate excise tax receipts is expected to offset higher federal tax rates and spending cuts than were previously assumed. Overall, revenue projections for both the 2011-13 and 2013-15 biennia remain relatively stable, with a slight net gain of about $40 million across the two biennia. However, this net gain is negated by the roughly $300 million in additional Medicaid caseload costs. The state and its lawmakers now face a $1.3 billion deficit along with court-mandated funding for K-12 education, which could cost another $1 billion. Their upcoming budget proposals will have to reconcile these demands on the state purse.
We anticipate that the Senate Majority Caucus Coalition will release its operating budget proposal sometime next week, while the House will likely release its budget by early next month. Until that time, any specific impact on the UW cannot be assessed. Please see the full OPB brief for more information.
Sequestration will take effect tonight at midnight. While the cuts will be smaller than originally mandated ($85 billion instead of $109 billion), the impact in federal FY13 will be higher since the cuts must now be applied to only seven months instead of nine. Immediate and long-term impacts on the UW and Washington State are difficult to predict. However, during the remaining months of federal FY13, we estimate that the sequester could reduce the UW’s federal grant and contract support by an estimated $75 million to $100 million and cut Build America Bonds (BABs) subsidy payments by $500K to $700K. Additionally, the UW is projected to lose about $33,000 in work study funds for 2013-14. The potential impact on Washington State includes $11.6 million less for primary and secondary education, $11.3 million less for education of children with disabilities, and 1,000 fewer children receiving Head Start services.
Please see the full brief prepared by the Offices of Federal Relations, Planning & Budgeting, and Research and be sure to visit at the UW’s Federal Relations blog for regular updates.
“Aligning the Means and the Ends: How to Improve Federal Student Aid and Increase College Access and Success” is the Institute for College Access & Success’s (TICAS) white paper for the Reimagining Aid Design and Delivery project, sponsored by the Bill & Melinda Gates Foundation (see our recent post for more information). Some of the report’s suggestions have been echoed in other white papers and publications, such as simplifying the federal financial aid application process, making the Pell program a mandatory federal budget item, and fostering more understandable and comparable reporting of college costs. The paper’s others recommendations include:
- Holding colleges accountable not only to the percentage of student borrowers who default on loans (represented by the currently-used cohort default rates), but also to the percentage of students who take out loans in the first place. TICAS proposes denying federal aid to colleges that score below a certain threshold on a combined index of the two measures. The group also recommends increasing federal aid to colleges scoring above a certain threshold. The amount of additional aid would be determined by how much Pell funding their students receive.
- Shoring up the Pell Grant. TICAS proposes doubling the maximum Pell grant award, to about $11,000 a year, and extending the eligibility timeframe from 6 years to 7.5.
- Creating a single federal student loan with no fees and a fixed interest rate. The rate would be low while students are in school and would rise, by a fixed amount with a cap, when they leave.
- Streamlining repayment plans, replacing multiple options for income-based plans with only one. Delinquent borrowers would automatically be placed in the income-based plan; but, a non-income-based option would be available to other borrowers. TICAS wants to leave borrowers with a choice, but argues they need real counseling—not just disclosure—to help them decide.
- Eliminating higher education tax benefits and sending the savings to Pell Grants and monetary incentives for states and colleges. If tax benefits are preserved, the group recommends restructuring them into an upgraded American Opportunity Tax Credit aimed at helping low- and moderate-income students.
TICAS’ paper outlines a few ways the government could fund these proposals in addition to potentially eliminating higher ed tax benefits. As The Chronicle nicely summarized, those options include, “limiting the benefit of itemized tax deductions, taxing private equity and hedge-fund income like other income, and removing or reforming tax-exempt bonds for private nonprofit colleges.”
Christy Gullion, Director of Federal Relations, recently provided an update on the sequester–the large, automatic federal spending cuts originally scheduled to take effect January 1st of this year, but delayed until March 1st thanks to a last-minute, bipartisan deal.
For background information, please see our most recent post on the topic as well as the brief put out jointly by the UW offices of Federal Relations, Planning & Budgeting, and Research.
Last week, Moody’s Investors Service issued a negative short-term outlook for the entire sector of higher education based on its conclusion that every traditional revenue source for even the most elite colleges and universities is under pressure. That pressure, according to the report, is the result of nation-wide economic, technological and public opinion shifts, which are largely beyond institutions’ control.
The outlook report, released annually, articulates the fundamental credit conditions that Moody’s expects higher education will face during the next 12 to 18 months. For the last two years, Moody’s gave elite colleges and research universities a stable forecast; but this year, the following factors contributed to a negative outlook for the entire industry:
Struggling Revenue Sources:
- State appropriations are unlikely to increase meaningfully due to weak economic recovery.
- Federal spending on research and student aid could be truncated in response to the nation’s fiscal concerns.
- Tuition revenue continues to be suppressed by low family incomes and public/political pressure to keep prices down.
- Endowment returns are vulnerable to any economic volatility that could stem from federal tax and budget decisions.
- Donations are not expected to increase and could face pressure as Congress evaluates associated tax deductions.
- Financial diversity is no longer helpful as all revenue streams are strained.
- Student debt and loan default rates have increased and thus challenged the perceived value of a degree.
- High school graduates are declining in number.
- Public and political scrutiny of efficiency and degree value could add to institutions’ list of regulatory requirements.
- New technologies such as online learning and MOOCs could provide new revenue opportunities, but could also undermine traditional higher ed models.
Moody’s analysts warn that revenue streams will never rebound to post-2008 levels and leaders in higher education will need to adapt by thinking strategically and adjusting their operations.
But not all is gloom and doom. Although Moody’s gave higher education a negative outlook, most of the country’s top colleges and universities still hold the strong credit rankings. The UW, for one, continues to maintain a Aaa credit rating—the highest offered by Moody’s. Additionally, the report stressed that the intrinsic value of and demand for higher education remains stable.
Yesterday, the Senate and House of Representatives approved legislation to avert the fiscal cliff. The deal postpones the automatic, across-the-board spending cuts—known as “the sequester”—by two months and increases tax rates only for individuals earning over $400,000 and couples earning over $450,000. The bill also preserves funding for Pell Grants and extends for five years the American Opportunity Tax Credit (AOTC), which allows students and their parents to claim up to $2,500 a year for tuition and college expenses.
For details, please see the blog post provided by Christy Gullion, Director of Federal Relations, and the articles provided by Inside Higher Ed and The Chronicle
Christy Gullion, Director of Federal Relations, recently provided an update on the fiscal cliff–the combination of large decreases in federal spending and simultaneous increases in income taxes set to take effect January 1st. For background information, please see the brief put out jointly by the UW offices of Federal Relations, Planning & Budgeting, and Research.
On Friday, the National Institutes of Health (NIH) approved a rough implementation plan for a set of initiatives that could affect biomedical studies and the faculty, postdoctoral, and student researchers who conduct them. Three working groups proposed the plan back in June and mean for it to guide, diversify, and improve biomedical research through new grant programs and guidelines.
The biomedical workforce working group recommended that the NIH:
- Help students prepare for careers by providing institutions with additional grants for training and professional development;
- Encourage graduate students to complete their degrees on-time by capping the number of years they can receive NIH funds;
- Urge institutions to financially commit to their researchers by slowly reducing the percentage of NIH funds that go toward faculty salaries; and
- Support the decision-making of prospective graduate students and postdoctoral researchers by asking that NIH-funded institutions provide data on student career outcomes.
The working group on diversity was founded after an NIH report revealed that black researchers were underrepresented in grant applicant pools and that, when they did apply, they were significantly less likely to receive NIH grants relative to their white counterparts. The group called for the NIH to:
- Help bridge diversity gaps by implementing a system of career mentorship “networks” for underrepresented minority students;
- Support under-funded colleges that have a history of training underrepresented minorities in the sciences by considering them for a “well-funded, multi-year” competitive grant program;
- Establish a committee to address implicit or explicit biases in the NIH peer review system; and
- Experiment with completely anonymizing grant applications by removing the names of researchers and their institution.
Lastly, the working group on data and informatics asked that the NIH develop a better framework for information exchange and fund more fellowships and training in statistics and other quantitative areas.
These initiatives may sound familiar as many have been pursued, yet subsequently aborted in the past due to a lack of funding. This time may be no different if Congress fails to resolve the fiscal cliff and mandatory spending cuts that could slash the NIH’s budget by 8.2 percent in the coming year.
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