American Association of Community Colleges
Higher Education Act (HEA) Reauthorization Priorities
Community colleges are a national asset. They educate more than four out of every 10
undergraduates in American higher education. They are largely open admissions institutions,
driven by the mission to serve all who can benefit, from recent high school graduates to adult
learners. Their affordability, convenient locations, and wide array of academic, vocational, and
other offerings attract a disproportionate share of those eager to learn, but facing financial and
other challenges. For example, community colleges enroll more than half of the students in all
of higher education in the lowest income quartile. The colleges serve their communities in a
myriad of ways by providing a less costly start to a baccalaureate degree and beyond,
workforce credentials to those seeking employment, English language skills to new Americans,
and basic skills for those who previously missed out, and programs for everyone pursuing selfenrichment. They are truly the modern version of the town square, the meeting place for civic
engagement.
The Higher Education Act (HEA) is the most important federal legislation for community
colleges and their students, providing statutory authority for the major federal student aid
programs and many key institutional assistance programs. These include the Pell Grant,
Federal Supplemental Educational Opportunity Grants, Federal Work Study, and Direct Loan
Programs, as well as TRIO and GEAR UP. A majority of community college students receive
some form of financial aid and around 40% receive federal student aid, mostly in the form of
grants under Title IV of the HEA. Titles II, III, and V authorize institutional aid and Title VI is
focused on international education. Additional programs authorized under Title VIII address the
needs of specific groups of postsecondary students and workforce programs.
Congress should seize the opportunity provided by the HEA
reauthorization to improve these critical programs to better serve
students, while ensuring institutional and taxpayer accountability.
The following recommendations for HEA reauthorization are the product of months of
discussion with community college chief executive officers, trustees, the American Association
of Community Colleges (AACC) Board of Directors, and the association’s Task Force on the
Higher Education Act Reauthorization.
The recommendations are organized into four major sections: (1) federal student aid programs;
(2) institutional assistance and support programs; (3) data collection and consumer information,
and (4) other issues.
I.
Federal Student Aid Programs
A. Pell Grant Program
The Pell Grant program is the bedrock student financial aid program, and about 38% of all
community college students receive awards. In 2013–14,i community college students*
received more than $11 billion in Pell Grant funds, comprising 36% of total expenditures. More
than 3.5 million community college students received the grants, 40% of the total. The average
Pell Grant for community college students was $3,227.
Between 2004–05 and 2014–15, the maximum Pell Grant covered 100% of the published price
of tuition and fees at public two-year institutions.ii However, taking into consideration the total
cost of attending college, which includes books and supplies, transportation, and room and
board, the coverage of the Pell Grant has diminished. This has contributed to an increasing
percentage of borrowing by Pell Grant students; a majority of community college Pell Grant
recipients take out federal loans.
Total Cost of A7endance Covered by Maximum Pell Grant Award: Two-­‐Year Public InsKtuKons 99% 62% 52% 1979-­‐80 2010-­‐11 2013-­‐14 Source: Education Trust, Beyond Pell: A Next-Generation Design for Federal Financial Aid, 2014, Figure 2.
http://edtrust.org/wp-content/uploads/2013/10/BeyondPell_FINAL.pdf and Education Week Webinar, Helping Low-Income
Students Get Into College, 2012, Slide 30.
Community colleges are defined as primarily associate degree-granting public institutions, which includes some
institutions classified in IPEDS as four-year, because they offer a limited number of baccalaureate degrees, in
addition to those classified as two-year.
*
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2 •
Extend the Pell Grant Program and Increase the Maximum Grant Annually by
Inflation
AACC supports adjusting the maximum Pell Grant amount annually by the increase in the
Consumer Price Index (CPI), a policy established in 2010. This would ensure that low-income
students would continue to be able to meet community college expenses without overly
relying on loans.iii Unfortunately, in recent years, community college average tuitions have far
eclipsed inflation, a direct result of cuts in state and local funding. There is absolutely no
relationship between increases in the maximum grant and community college tuitions as
evidenced by the fact that the maximum Pell Grant has exceeded community college tuitions
for decades.
•
Reinstate the Year-Round Pell Grant
In the 2008 Higher Education Opportunity Act, Congress created a “year-round” Pell Grant
(YRP) to accommodate the many students who desire to attend college continuously, rather
than suspending their studies in the summer. Research has consistently shown that staying and
making progress in school year-round fosters completion. This is especially true for the
neediest students.iv However, after just one year of implementation, Congress eliminated the
year-round Pell Grant because of a temporary program shortfall.
The elimination of YRP had a large, detrimental impact on community college students and
summer enrollments dropped significantly. Community colleges across the country had
already started to restructure academic programs to use the new, expanded assistance, but
with the elimination of YRP, much of that reform stopped in its tracks. Reinstatement of YRP
has bipartisan support. With the program now enjoying a large surplus, Congress should
immediately reinstate YRP. In addition, the year-round Pell Grant should be available to all
students who continue to meet standards of satisfactory academic progress. It should not be
limited to those who want to enroll full time in the summer or who have accrued a given
number of academic credits in the award year.
•
Increase the Limit on Pell Grant Eligibility to 14 Semesters
The year after the YRP was eliminated, Congress limited lifetime Pell Grant eligibility to a total
of 12 full-time equivalent semesters (reduced from 18). This change has negative implications
for many community college students. Many of the students who go on to seek a
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 3 baccalaureate degree unfortunately have to repeat credits after transferring, or find that their
credits do not apply to their majors, and face other obstacles on what should be a smooth
path to a four-year degree.v
Federal data show that more than two thirds of community college students require some
amount of developmental education.vi Even with broad-based reform in this area, the need
for developmental education often prolongs the path to a credential, exhausting as much as
two semesters of Pell eligibility. Other students must take English as a Second Language
(ESL) programs, and returning adult students can be affected as well. We urge a modest
increase of the semester limit to a minimum of 14 semesters.
•
Restore Title IV Eligibility for All “Ability-to-Benefit” (ATB) Students
Many individuals without a high school diploma or its recognized equivalent (generally a
General Education Development, or GED, credential) can benefit from attending a
community college and earning a postsecondary credential. Having to first obtain a GED and
then enroll in a postsecondary program lengthens their time to degree and reduces their
likelihood of success. Recognizing this, in the 1992 HEA reauthorization, Congress made
students lacking a high school diploma or its equivalent Title IV-eligible if they could show an
“ability to benefit” from higher education, usually by achieving a specified score on a
standardized assessment. In 2008, eligibility was extended to students who had successfully
completed six college credits. However, the Pell Grant shortfall drove Congress to eliminate
ATB eligibility for Title IV funds in the FY 2012 appropriations legislation. An important
advance was made when Congress partially restored Title IV eligibility for ATB students who
enrolled in statutorily defined career pathway programs.
Prior to the elimination of ATB eligibility, approximately 125,000 ATB students enrolled in
community colleges in the 2011–12 academic year.vii While career pathway programs are a
valuable means to help students complete a college credential, they are not universally
offered.
State and local governments provide about 49% of all community college revenues.viii They,
and community college leaders, believe that these students, along with others, merit the
investment. If these entities with the biggest investment are willing to invest in ATB students,
federal policy should follow suit. Congress should build on this and restore eligibility for all ATB
students. The cost is marginal in relation to the Pell Grant program’s size.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 4 •
Give Institutions Limited Flexibility to Extend Pell Grant Eligibility for ShortTerm and Innovative Programs
At many community colleges, new programs are being developed that do not meet the
minimum length for Title IV programmatic eligibility, which is 16 semester, 24 quarter, or 600
clock hours offered over 15 weeks. These short-term programs are often focused on preparing
students for specific occupations. More than two thirds of all the less-than-one-year
certificates awarded by community colleges in 2013–14 were in the areas of healthcare,
mechanic and repair technologies, homeland security, law enforcement and fire protection,
computer and IT, precision production, transportation and material moving, and engineering
technologies, with those in healthcare comprising 29%.ix These programs are often tailored to
meet the needs of working adults who are not able to return to college for extended periods.
Research has shown that short-term certificate programs that are closely aligned with industry
needs and that are “stackable” (i.e., count towards longer certificate and degree programs)
can have positive financial returns for students.x The Department of Education (ED) has
conducted a demonstration of Pell Grant eligibility for short-term programs under its
Experimental Sites authority.
Congress should add to the Pell Grant program a mechanism in which each institution
receives a separate funding pool of program funds in the amount of 2% of prior year Pell
Grant disbursements. Institutions would be authorized to use these funds to award Pell
Grants to students in short-term or innovative programs not currently eligible for Title IV that
meet specific conditions. This approach would allow institutions to focus these additional
resources on their most effective, high-priority training programs while imposing a strict
limit on the overall amount of additional Pell Grant spending.
B. Campus-Based Aid: Federal Work-Study (FWS) and Federal
Supplemental Educational Opportunity Grants (FSEOG)
The Campus-Based student aid programs are important to community college students. In
addition to the financial assistance they provide, FWS supplies valuable work experiences
related to students’ academic and career programs. However, community college students
receive only 23% of all FSEOG and 18% of FWS funds, despite their relatively low family
incomes and the size of the sector.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 5 Percent Enrollments of Public Two-­‐Year Students and Receipt of Campus-­‐based Aid 40% 34% 35% 30% 29% 25% 23% 20% 18% 15% 10% 5% 0% All FTE Students FTE Undergraduates FSEOG Federal Work Study Source: College Board, Trends in Student Aid 2015, Figure 9
•
Create More Equitable Distribution Formulas that Emphasize Current
Student Need Rather than Historical Allocations
The impact of the Campus-Based programs unfortunately is limited both by substantial
underfunding and institutional distribution formulas that deny community college students an
equitable share of funds. Funds are largely distributed on the basis of allocations made to
institutions more than 30 years ago that have little bearing on today’s student populations. The
reauthorization should change this by allocating funds based on an institution’s relative
enrollment of financially needy students. The FWS program also may benefit by being more
closely aligned with internship, apprenticeship, and service learning opportunities.
C. Federal Loan Programs
Nineteen percent of community college students take out federal student loans, a much lower
borrowing rate than that seen at all types of four-year institutions.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 6 Percentage of Students Who Borrow at Select Postsecondary InsKtuKons 70% 64.3% 60% 50% 40% 30% 61.0% 52.6% 58.1% 49.6% 40.7% 27.5% 20% 10% 24.4% 15.3% 0% 2000-­‐01 2005-­‐06 2007-­‐08 Public two-­‐year 2008-­‐09 2009-­‐10 Public four-­‐year 2010-­‐11 2011-­‐12 2012-­‐13 2013-­‐14 Private non-­‐profit four-­‐year Source: Digest of Education Statistics, 2015. Table 331.20. Full-time, first-time degree/certificate-seeking undergraduate students
enrolled in degree-granting postsecondary institutions, by participation and average amount awarded in financial aid programs,
and control and level of institution: 2000–01 through 2013–14.
Community college students accounted for 16% of Subsidized Stafford Loans and 7% of
Unsubsidized Stafford Loans in 2013–14, in comparison to their 36% share of Pell Grants.xi
Community colleges historically and presently do all that they can to minimize student
borrowing, foremost by having the lowest tuition levels in higher education. xii
Federal loan policy is largely oriented to students who attend institutions where borrowing is
more frequent and in greater amounts than at community colleges. The federal loan programs
need to better address the specific nature and needs of community college students. For
example, Pell Grant recipients are more likely to borrow than non-Pell undergraduates at
community colleges, which makes it all the more important to ensure that borrowers make fully
informed decisions. Community colleges are particularly focused on limiting borrowing
wherever possible, especially for at-risk students. Moreover, community colleges want the loan
accountability measures, such as repayment and cohort default rates (CDRs), to more
accurately reflect the overall institutional characteristics in terms of borrowing rates and student
demographics.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 7 Public InsKtuKon Associate Degree Graduates with Debt 56% 60% 55% 48% 50% 40% 40% 42% 31% 28% 30% 27% 19% 20% 10% 0% Total Undergraduates Pell Grant Recipients 2003-­‐04 2007-­‐08 Non-­‐Pell Recipients 2011-­‐12 Source: Demos, The Debt Divide: The Racial and Class Bias Behind ‘New Normal’ of Student Borrowing, 2015, Figure 6.
Determining how much money is needed to finance college is complicated for many
community college students. For numerous students, relying on federal loans to meet their
educational costs, including living expenses, makes eminently good sense. This can enable
students to work less and take more classes. However, borrowing can be risky, reflected in the
19.1% community college cohort default rate (CDR).xiii Default is highly correlated with noncompletion, creating the counter-intuitive fact that students who borrow less are more likely to
default more as they have not been enrolled long enough to accrue large debts.
Recurring high CDRs can negatively impact Title IV eligibility, leading some community
colleges to voluntarily leave the federal loan programs. Currently, almost 9% of all community
college students are enrolled in colleges that do not participate in the federal loan programs.xiv
•
Allow Institutions to Lower Loan Maximums in Defined Circumstances
Community colleges support providing institutions with new authority to reduce student loan
eligibility in defined circumstances. Not all students are equally strong candidates for
borrowing, in ways not reflected in needs analysis. Limiting borrowing in certain conditions
where borrowing is, on balance, not warranted, is a potentially powerful tool that can
complement efforts by servicers and the federal government to reduce delinquency and
default.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 8 In using any new discretion, college officials will assume significant responsibility for ensuring
equitable treatment of students. Institutions should be granted authority to reduce loan
amounts, or deny loans altogether, only in prescribed circumstances that are documented in
writing and provided to all students. Circumstances in which institutions might implement a
policy to reduce loan amounts include students enrolled less-than-full-time (reflecting the
proposal below); students enrolled in programs in which completers have relatively low
earnings, a policy reflected in the gainful employment regulations; students who are
academically underprepared for a community college education, which in turn is associated
with non-completion and subsequent default; and students with previous debt burdens above
a specific amount. Other approaches might include setting institution-wide aggregate loan
limits or establishing a limit on the amount of non-tuition expenses covered by federal loans.
Students who are not certified for the amount they qualify for under needs analysis should be
permitted to appeal the institution’s policy. Such appeals would be granted on a case-by-case
basis, as under current professional judgment.
•
Reject Student Loan Risk Sharing for Community Colleges
The concept of student loan risk sharing, or “skin in the game,” has gained traction in the
reauthorization debate. The essence of risk sharing is to assess institutions a share of the costs
associated with non-repayment of student loans. Supporters of the concept maintain that it will
incentivize colleges to ensure that students complete programs with manageable levels of
student debt and enhance institutional management of the loan programs.
Community colleges strongly oppose federal loan risk sharing. As public institutions,
community colleges already have massive skin in the game. This starts with the state and local
government funding of the colleges and their students, accounting for 49% of annual
revenues.xv In an increasing number of states,xvi at least some of this funding is based on
student outcomes.
As largely open admissions institutions, community colleges do not select which students are
admitted and they do not, at present, determine who receives loans. Nor are they primarily
responsible for their collection. And, under some risk-sharing scenarios, a college could be
subject to payments even if student borrowers are repaying their loans under an income-based
repayment plan, but not retiring principal.
Policymakers should recognize that risk sharing for community colleges will inevitably result in
either increased tuitions or reduced educational services, and very likely both. Institutions have
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 9 no other options. Community colleges operate on the margins; small declines in revenues,
whether due to budget cuts or decreased enrollments, often lead to immediate reductions in
personnel and other core services. Finally, risk sharing could have the unintended consequence
of increasing the number of community colleges that choose not to participate in federal loan
programs.
Instead of the heavy-handed approach of risk sharing, Congress should enact a broad range of
common-sense student loan reforms to achieve prudent borrowing and better debt
management on the part of students and institutional ability to ensure student success with
adequate means and resources.
•
Consolidate and Refine Income-Related Repayment of Student Loans
The available borrower repayment options have demonstrably increased the complexity of the
federal loan programs. There are currently seven different loan repayment options, including
four income-related repayment plans. The complexity of various overlapping options and, in
some cases, negligible eligibility differences often makes it difficult for borrowers to
understand their options and enroll in the program that best suits them.
For borrowers with small debt loads, the standard 10-year repayment plan often helps
minimize the total interest paid and length of repayment. However, graduates with lower
incomes or higher debt burdens may find standard repayment unmanageable.
ED should be applauded for improving the loan application and repayment process,xvii but
Congress should consolidate the four income-related plans—Income Based Repayment (IBR),
Pay as You Earn (PAYE), Income Contingent Repayment (ICR), and Revised Pay as You Earn
Repayment (REPAYE)—into one new and improved income-based plan. The new incomedriven repayment plan should be available to all borrowers, regardless of their debt or income
level, whether the loans are Direct or FFEL, or the date of loan disbursement. Rather than
requiring borrowers to have a certain debt-to-income ratio to enroll, borrowers with higher
incomes should be able to make larger income-based payments as determined by the
consolidated plan’s sliding scale. Congress should also make it easy for borrowers to enroll in
income-driven payment and to keep their income information up to date, including allowing
borrowers to use all available IRS data for pre-population. Additionally, Congress should
explore specific debt thresholds that could trigger automatic enrollment in an income-related
plan.
Currently, federal regulations require students make a minimum payment of $50 per month
under a standard repayment plan.xviii This amount can be prohibitively expensive for lowAmerican Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
0 income borrowers, and if borrowers fall behind in monthly payments, the past-due amount can
quickly add up to hundreds of dollars.xix Providing students access to a cheaper repayment
option with a lower barrier to entry than income-driven repayment plans can help keep lowdebt borrowers out of default. We recommend that Congress reduce the minimum standard
monthly payment amount to as little as $10 per month. We also recommend that the plan be
reconfigured so that the maximum repayment term is five years, rather than the current 10, for
low-debt borrowers.
•
Authorize Institutions to Provide Annual Loan Counseling
Currently, institutions are required to provide entrance and exit loan counseling. They cannot
require more frequent counseling, although they may offer it.
Congress should allow, but not mandate, institutions to require annual loan counseling; many
community colleges are likely to adopt this practice. Where employed, this will ensure that all
borrowers remain keenly aware of their loan obligations. However, authorizing institutions to
require annual loan counseling for a designated group of borrowers should not be
accompanied by a requirement that institutions document the counseling, as it would be
extremely difficult for under-resourced institutions to sustain.
Recent user-experience research has shown that counseling via ED’s online tool, which about
70% of institutions report using, falls short of its intended purpose.xx Borrowers said that they
found the language in the online counseling to be complex and often irrelevant, due to the
information being impersonal rather than individualized. It is also thought to be too long. The
timing of the entrance counseling, typically after the borrower has already made choices, is
also problematic. In the reauthorization, all counseling should be made more concise. Finally,
the department should revise its online counseling tool to include personalized borrower
informationxxi and efforts should be made to improve the Master Promissory note in a similar
manner.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
1 •
Improve Loan Servicing
ED, together with the Department of the Treasury and the Consumer Financial Protection
Bureau, issued a Joint Statement of Principles on Student Loan Servicing, as part of several
actions, including a Student Aid Bill of Rights, to improve loan servicing and help individuals
manage their student debt.xxii We urge Congress to consider incorporating language that
reflects these principles. As one specific example, if a student is at risk to default, ED and loan
servicers should be required to contact borrowers to provide the option of enrolling into an
income-related repayment plan, rather than waiting for the student to request this information.
Another is to ensure that ED implements an easy to navigate loan repayment systemxxiii that
includes a single, Department of Education-branded Web portal that all borrowers can use to
find the latest information about their loans, make payments, and apply for benefits.
•
Tie Loan Amounts to Enrollment Intensity
Current undergraduate loan limits do not take into account either program length or
enrollment intensity. Loan limits are designed to accommodate the higher tuition levels
associated with full-time enrollment in a four-year degree program. Therefore, Stafford loan
limits, both subsidized and unsubsidized, should be tied to a student’s enrollment status or
intensity, as with the Pell Grant program. Similarly, aggregate loan limits should be aligned
with program length, so that students at two-year institutions are eligible to borrow up to half
of the aggregate undergraduate loan limit.
A student attending one-half or three-quarters time should be eligible for proportionally less
loan volume each year than a student attending full time. Prorated limits based on enrollment
status should also include some allowance for cost of living (e.g., pro-rata base eligibility plus
20 percent) for students who are enrolled less than full time.
•
Ensure that Loan Defaults Do Not Unfairly Limit Community College Student
Aid Eligibility
The 1998 HEA reauthorization created a new institutional penalty that can eliminate Pell Grant
eligibility for colleges with high CDRs. Despite legitimate Congressional concerns about
defaults and the need for institutions to actively promote loan repayment, this sanction works
against the interests of community college students and should be eliminated. Rather,
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
2 Congress should emphasize a broader agenda to promote responsible student borrowing and
create a more efficient delivery and repayment system.
The potential loss of Pell Grants at colleges at which former students do not repay their loans is
unfair to those currently enrolled. In addition, many factors contribute to defaults that have
nothing to do with institutional performance, including changes in economic conditions and
disparate loan servicer performance.
This sanction is especially problematic for community colleges, since they are the only higher
education sector that has a higher percentage of Pell Grant recipients than federal loan
borrowers, by a factor of two to one. Also, there is evidence that the threat of losing Pell Grant
eligibility has resulted in some institutions choosing not to participate in the loan programs,
which in turn could result in students having to resort to higher cost loans.
•
Establish a Student Default Risk Index (SDRI)
Current CDRs assess institutional eligibility for Title IV financial aid based on the share of a
school’s borrowers who default within the first three years of repayment. Colleges with CDRs
above certain thresholds may face sanctions. However, the current CDR calculation, which
excludes non-borrowers, neither serves as a good measure of institutional quality nor a useful
source of consumer information. Therefore, Congress should generate a CDR metric that takes
into account the incidence of borrowing at institutions, establishing a Student Default Risk
Index (SDRI). Under the SDRI, each school’s three-year CDR would be multiplied by the
percentage of students at that school who take out federal loans. By incorporating the share of
students who borrow, the SDRI would more accurately convey the pattern of default risk for all
of a school’s students, a more meaningful measure of default risk.
•
Increase the Participation Rate Index (PRI)
Potential sanctions for institutions with high CDRs can be negated through a participation rate
index (PRI) appeal. The PRI is designed to reflect the fact that, when relatively few eligible
students take out federal loans, a college’s default rate is an extremely unreliable proxy for
institutional performance. We applaud ED for permitting the filing of a PRI appeal on the basis
of data for any single year (rather than after three years), and urge Congress to codify this
action in statute. We believe that another change to the PRI should be made, which is to set
the threshold to .0875, to reflect the reality of much greater loan availability and borrower
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
3 need since the PRI was last addressed by Congress. In practice, this means that if a college’s
borrowing incidence is less than about 29% of its eligible students, it could benefit from a PRI
challenge.
D. Enact a Federal America’s College Promise Program
The America’s College Promise proposal advanced by the Obama Administration has
transformed the debate about community college and higher education, emphasizing the need
for universal postsecondary education. Over time, the basic tenets of the proposal will likely be
seen as a common-sense proposition: for most Americans, a high school education no longer
provides a family-sustaining income. Community colleges strongly support legislation (H.R
2962, S.1716) that would provide federal funds to states to develop their own programs that
would result in no tuition being charged for courses that meet defined standards. The formula
of reduced financial burdens for many, plus a resounding signal that college is for all, might
encourage more students to attend community college. The early evidence from the
Tennessee Promise program indicates that it has drawn additional students to community
college.
The tremendous enthusiasm with which the Promise concept has been met across the country
testifies to its inherent appeal and need. Any new federal program should be “first dollar,” as
in the introduced legislation, which allows any student grants to be used for the non-tuition
expenses that usually exceed institutional charges. It appears that all state and local programs
established thus far have provided “last-dollar” benefits.
Congress has many options in setting the parameters of a potential Promise program. A
federal program would add immeasurably to the numerous state and local programs that have
been created.
E. Other Student Financial Aid Issues
• Help Institutions Increase FAFSA Completion
Nearly 40% of all community college students do not fill out the Free Application for Federal
Student Aid (FAFSA).xxiv This is a higher percentage than any other sector. While this
percentage has decreased slightly in recent years, the fact that so many students fail to
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
4 complete a FASFA is a tremendous shortcoming of the student aid system. While the student
application form is a barrier, it is not the only one, as there is strong evidence that many
students misperceive both the total costs of college as well as what student aid is available.
Therefore, better counseling and early awareness is necessary, and in this regard the
institutions bear a great deal of responsibility, limited resources notwithstanding.
While institutions are required to provide a lengthy list of often confusing disclosures to
prospective and current students, Congress should consider requiring institutions to put in
place some sort of a “check-off” mechanism when students enroll that would document the
students’ acknowledgement of being notified of the availability of federal student aid. This
could contribute to the expansion of a minimal awareness of the availability of Title IV aid.
AACC and its member colleges, meanwhile, are focused on a variety of efforts to enhance
FASFA completion by community college students.
Percent of Students CompleKng FAFSA 80% 70% 60% 50% 70% 62% 59% 58% 45% 43% 40% 30% 20% 10% 0% 2003-­‐04 2007-­‐08 All Postsecondary InsKtuKons 2011-­‐12 Community Colleges Source: U.S. Department of Education, National Postsecondary Student Aid Study, Undergraduates, 2003–04, 2007–08, and 2011–
12.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
5 Reasons for Not CompleKng FAFSA Thought ineligible No need Did not want to take on the debt No informaKon about how to apply Forms were too much work 0% 5% 10% 15% Community Colleges 20% 25% 30% 35% 40% 45% 50% All InsKtuKons Source: U.S. Department of Education, 2011–2012 National Postsecondary Student Aid Study.
•
Fully Implement Prior-Prior Year Tax Return Information
The ability of student applicants to directly import income and financial data from their IRS
Form 1040 to the FAFSA (known as the “IRS Data Retrieval Tool”) has greatly simplified the
application process for many students. For the 2014–2015 FAFSA application cycle, the
majority of applications with already filed tax returns (53%) and 40% of all applications, used
the data retrieval tool.xxv It is expected that an even higher portion of FAFSA applicants will
avail themselves of the IRS data retrieval tool when prior-prior year tax return information will
be accepted.xxvi Numerous studies have confirmed that the use of prior-prior year (or two-years’
prior) income data in place of the prior-year (one-year prior) data currently used in determining
eligibility for student financial aid often results in making the process of FAFSA completion
much easier for students.xxvii Congress should codify the prior-prior year provision in statute.
•
Establish Pell Early Notification Systems for Low-Income Students
Having more information about available aid at an earlier point in the college selection process
has been shown to dramatically improve students’ chances of attending and staying in
collegexxviii and receiving the benefits for which they are eligible. In order to raise awareness
about the availability of financial aid, ED should begin early notification of potential Pell Grant
eligibility for 8th graders receiving National School Lunch Program benefits, and should
rigorously evaluate it. Although these students would not confirm their eligibility until they file
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
6 the FAFSA and receive financial aid award letters, this additional information earlier in the
process would encourage college attendance for low-income students.
II.
Institutional Assistance and Support Programs
•
Extend TRIO, GEAR UP and CCAMPIS Programs
In addition to student aid, there are other federal programs aimed at helping students achieve
their academic and career goals. We call attention to three of them.
TRIO provides important support services that enable economically disadvantaged, firstgeneration students to succeed in college. More than a third (36%) of community college
enrollees are first-generation students. Of the nearly 2,700 postsecondary institutions to have
received one or more of the FY 2015 TRIO grants (Student Support Services, Talent Search,
Educational Opportunity Center, Upward Bound, Upward Bound for Veterans, Upward Bound
for Math/Science, and Training Program for TRIO staff), more than 1,000, or about 39%, went
to community colleges. These awards totaled about $286 million and helped almost 270,000
community college students.xxix
GEAR UP, a competitive grant program that increases the number of low-income students
prepared to enter and succeed in postsecondary education, provides services at high-poverty
middle and high schools. GEAR UP provides essential early college awareness and support
activities, including tutoring, mentoring, academic preparation, financial education, and college
scholarships, to improve access to higher education for low-income, minority, and
disadvantaged first-generation students and their families.
The CCAMPIS program supports the participation of low-income parents in postsecondary
education through campus-based childcare services. Grants ranging from $10,000 to more
than $300,000 are awarded through a competitive process to institutions of higher education
that enroll large numbers of Pell Grant recipients. In addition to campus-based childcare for
infants and toddlers, the program also funds before- and after-school care for older children
and parenting classes. This is particularly important as data show a decline in the percent of
community colleges that have on-campus child care from 52% in 2002 to 45% in 2014.xxx
During the past decade, the total amount of CCAMPIS funds has remained steady at around
$15 million, of which community colleges have received $6 million. The number of total awards
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
7 has declined, however, from more than 300 in FY 2004 to 85 in FY 2015. There was a similar
trend for community colleges, more than 170 awards in FY 2014 compared to less than 50 in
FY 2015.xxxi
•
Continue the Primary Institutional Aid Programs that Augment Title IV
Programs and Ensure Deserving Institutions Can Become Eligible to
Compete for Funds
The institutional aid programs authorized in the HEA provide valuable support to community
colleges. The programs augment the federal student aid investment by providing financial
resources to colleges that serve large percentages of needy and/or traditionally
underrepresented students to help those students succeed, consistent with national goals. The
programs function effectively and should be continued. One of their basic strengths is the fact
that funding priorities are determined on the campus level, consistent with national priorities.
The diverse nature of the programs’ expenditures makes it difficult to capture their collective
value in quantitative terms, but there is no questioning their positive impact on students.
Community colleges receive a majority of all of the Strengthening Institutions Program (SIP)
awards (Title III-A), Hispanic-Serving Institutions (HSIs) awards (Title V), and Predominantly Black
Institution (PBI) formula and discretionary awards. The colleges account for more than half of all
HSIs across the nation.
Community College Percent of Title III and V Grant Program Recipients and Funding Amount: FY 2015 100% 80% 79% 79% 66% 65% 55% 60% 55% 40% 20% 0% SIP HSIs Awards Funded PBI Funding Amount http://www2.ed.gov/programs/iduestitle3a/awards.html; http://www2.ed.gov/programs/idueshsi/index.html;
http://www2.ed.gov/programs/pbihea/index.html; http://www2.ed.gov/programs/pbi/index.html
Source: U.S. Department of Education Grant Programs: Higher Education
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
8 The Title III-A program should be streamlined to make it easier for institutions to qualify for
eligibility; this only enables them to engage in the fierce competition for funds. For technical
reasons, smaller institutions—more than 500 community colleges have enrollments less than
3,000 students—have found it particularly difficult to qualify under the education and general
expenses (E and G) criterion or its waiver options, and this should be carefully reviewed to
ensure that more institutions are able to compete for funds.
III.
Data Collection and Consumer Information
As college attendance has grown in importance to the nation, greater attention is being paid
to the information that the federal government generates about students and institutions, and
on how that information is presented and used by prospective students and their families. The
following recommendations are designed to make overdue improvements to this system.
•
Establish a Federal Unit Record Data System
The creation of a federal comprehensive student unit record data system (URDS) is needed to
provide essential information for students, families, and policymakers. The extant education
data system is actually not a system as much as a set of multiple, often disjointed, data. It is
also difficult to square with the tremendous federal investment in student aid and the
information on individuals already collected through the Title IV programs.
The federal URDS should provide comprehensive data on students’ progress throughout
postsecondary education, and it would have the additional benefit of enabling the government
to perform earnings record matches as proposed below. A URDS would not only produce far
more meaningful and comprehensive data than is now being generated, but, once fully
implemented, would actually reduce administrative burden for institutions.
Proponents of the URDS ban cite concerns over student privacy, but this argument is hard to
sustain given the nature and extent of data gathered by a wide variety of public and private
entities. This is not to understate the need for creation of a system that is as secure as current
technology permits. In addition, the information that should be included in the system should
be limited to a student’s academic progression at a given institution or institutions, along with
related student aid data currently collected via the Integrated Postsecondary Education Data
System (IPEDS) and the National Student Loan Data System (NSLDS). These limits should
mollify concerns about the potential disclosure of data.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 1
9 •
Establish a Six-Year, 300% of “Normal Time” Graduation Rate for
Community Colleges that Includes Transfers
Community colleges and their students have been poorly served by the federal government’s
data collection and graduation rate policies. The most glaringly deficient item is the official
graduation rate annually released by the National Center on Education Statistics. This
graduation rate of 150% of the “normal time” for completion excludes transfers-out and
woefully understates actual community college success. This single federal data point leads to
broad unfounded negative perceptions about community college performance, largely
because of the fact that older, working students with family and other responsibilities take
longer to graduate, often from an institution other than the one they originally entered.
The graph below shows that, according to the National Student Clearinghouse, 55% of all fulltime community college students graduate from some institution of higher education within six
years. This contrasts the 21% official graduation rate, for full-time students, published by the
Department of Education.
CompleKon Rates of First-­‐Kme, Full-­‐Kme Students Who Start at Public Two-­‐year InsKtuKons 60% 54.6% 50% 41.8% 40% 26.7% 30% 20% 21.2% 11.3% 10% 0% 100% 150% 200% 300% 300% + Transfers Sources: U.S. Department of Education, Graduation Rates for Selected Cohorts, 2006-11; Student Financial Aid, Academic Year
2013-14; and Admission in Postsecondary Institutions, Fall 2014, 2015, Tables 1 and 2. http://nces.ed.gov/pubs2015/2015181.pdf;
National Student Clearinghouse Research Center, Signature Report 10: Completing College: A National View of Student
Attainment Rates, Fall 2009, Figure 12, 2015. https://nscresearchcenter.org/wp-content/uploads/SignatureReport10.pdf
The official community college graduation rate should be 300% of the “normal time” to
graduation—six years in the case of community college students—including transfers-out,
which have always been a central focus of the community college mission. The current 150%
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
0 graduation rate benchmark should also be retained, as it is more appropriate for four-year
institutions and will provide useful trend data. Six years is the metric that community colleges
use for their own Voluntary Framework of Accountability—a detailed accountability and quality
improvement scheme developed by community college leaders.xxxii
Later this year, ED will release data on four new student cohorts, adding part-time students and
non-first-time students. The student cohorts will be tracked for six and eight years, and this is a
welcome change; transfers-out will be incorporated, at the end of the eight years. This
collection has many positive features and will paint a clearer overall picture of higher education
institutions. However, in the reauthorization, Congress needs to align these new data with the
three graduation rates (100%, 150% and 200% of “normal time” to completion) for the cohort
of first-time, full-time students currently reported by institutions under the HEA.
•
Provide Program-Specific Earnings Data to Institutions and the Public
For the vast majority of college students, the primary reason for attending is to increase their
economic prospects.xxxiii Despite recent advances in generating data on the economic benefit
of college for students enrolled in particular institutions or programs, better and more refined
data are needed. Community colleges strongly support the generation and disclosure of the
average earnings of program completers. The earnings information now displayed on the
College Scorecard—a step that is generally to be commended—has significant limitations in
that it is provided at the institutional level only, and covers all students rather than just program
completers. The earnings information that the federal government is capturing under the
gainful employment regulations is used strictly for purposes of calculating debt-to-earnings
metrics and has other inherent limitations.
Comprehensive earnings data for program completers would capture the earnings associated
with specific community college certificates and degree programs and would be of immense
value to students, institutions, and other stakeholders. As was done with the College
Scorecard, appropriate timeframes need to be set for the different types of students and
programs because the arc of post-graduate earnings varies substantially depending on the
nature of the studies. This additional information will also serve as a key institutional
accountability measure. As outlined above, this wage information is best provided through the
establishment of a unit record data system.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
1 IV.
Other Issues
There are a variety of other high-priority items concerning Title IV policy that Congress should
review in the HEA reauthorization.
•
Dramatically Reduce the Title IV Compliance Burden
More than any other sector of higher education, community colleges are negatively impacted
by the vast regulatory burden imposed through Title IV and other programs, because of their
relatively limited administrative resources. In addition, community college students tend to be
more vulnerable to elaborate administrative requirements, particularly in the FAFSA
completion process. Community college campus officials are hoping that reauthorization can
effect a substantial reduction in unnecessary administrative burden, complexity, and rigidity.
AACC participated in, and strongly supports, the recommendations of the ACE Task Force
Report on the Federal Regulation of Higher Education.xxxiv Of particular concern to community
colleges are the elaborate Return of Title IV regulations, which need to be overhauled;
verification of student aid information; gainful employment, as mentioned above; and Title IX
compliance, which presents unique challenges for largely commuter institutions.
Overarching these concerns is the relationship between the Department of Education and Title
IV participating colleges. ED has an essential role in preserving the integrity of the student
financial aid programs, but their administration should reflect the compliance challenges that
administrators face. The posture of ED vis-à-vis institutions should be one of partnership, rather
than command-and-control.
In addition, the number of policy directives and guidance letters to institutions must be
reduced. On the gainful employment regulations, for example, to date 79 Dear Colleague
Letters and Electronic Announcements have been issued.xxxv The sheer frequency of
communications to institutions about changes in Title IV administration rules places an
intolerable compliance burden on colleges. The frequency with which changes are imposed
should be limited.
Furthermore, the department should work with institutions to create a process and mechanism
for reporting that best serves the college and its community. The Clery Act is particularly
problematic. While community colleges support the fundamental purpose of the Clery Act, it
has proven to be an extraordinarily complex and burdensome regulation, with more than 70
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
2 new interpretations of compliance issued by ED in 2011. The required coordination and
simplification of regulatory and sub-regulatory changes will foster greater institutional
compliance, reduce costs, and potentially provide more relevant and accurate information for
students.
•
Clarify Policy on Gainful Employment
The Department of Education’s implementation of gainful employment (GE) has become a
flashpoint for community colleges. Despite the fact that the regulations are associated with the
for-profit sector, community colleges provide the majority of all gainful employment programs,
well over 20,000. The GE regulations were designed to weed out low-quality programs from
Title IV eligibility, defined by students assuming inordinate debt burdens in relation to labor
market earnings. In this basic policy aspect, the framework has much merit. However, the
regulation’s applicability to community colleges is dramatically limited by the fact that fewer
than 20% of all students take out federal loans. The rule’s relevance to these institutions is
further undermined by its being applied only to Title IV recipients (for legal reasons), who
constitute fewer than half of all community college students. But at the same time, the
regulation carries huge compliance costs.
The ongoing implementation on community college campuses of the second set of GE
regulations has been fraught with costly and frustrating implementation snags. This frustration
is compounded by the fact that much of the student data reported by colleges will neither
impact institutional eligibility—community college students borrow so infrequently that they do
not assume the average debt burdens that threaten program eligibility—nor generate
disclosures, because GE programs tend to be so small that data cannot be disclosed, in order
to protect student privacy. Furthermore, even when provided, the extensive list of often
confusing disclosures will be lost on most students, when a few simple data points might have
been far more helpful.
The gainful employment regulation has been implemented in a fashion never conceived by
legislators. (We also call attention to the fact that many programs that are in fact designed to
provide students for what would commonly be understood as “gainful employment” are not
covered under the existing statutory definition.) Given this, in the reauthorization process
Congress needs to affirmatively determine its policy on gainful employment via statute. A
policy of this significance merits explicit Congressional direction.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
3 •
Establish Stronger State Maintenance of Effort Provisions
State and local governments have traditionally played a constitutive role in financing higher
education, reflecting a desire to promote economic mobility as well as a recognition that
higher education is a public good. In the HEA reauthorization, Congress should insist that
states and localities continue to provide their fair share. Unfortunately, state funding per
community college student dropped dramatically during the last recession, and despite some
upticks since then has not rebounded significantly. In the 2007–08 academic year, state and
local funding accounted for 54% of the per full-time equivalent student revenue of public twoyear institutions. The percentage contribution of state and local funds hit the lowest point in
2011–12 at 45% and rebounded somewhat to 49% in the 2013–14 academic year.xxxvi
State funding cuts have resulted directly in community college tuition increases.xxxvii This
divestment places enormous strains on the entire community college system.
State and Local Funding as Percent of Per Full-­‐Time Equivalent Student at Public Two-­‐Year InsKtuKons 56% 54% 54% 52% 50% 49% 48% 46% 45% 44% 42% 40% 2007-­‐08 2008-­‐09 2009-­‐10 2010-­‐11 2011-­‐12 2012-­‐13 2013-­‐14 Source: U.S. Department of Education, Digest of Education Statistics 2015, Table 331.20. Full-time, first-time
degree/certificate-seeking undergraduate students enrolled in degree-granting postsecondary institutions, by participation
and average amount awarded in financial aid programs, and control and level of institution: 2000–01 through 2013–14.
https://nces.ed.gov/programs/digest/current_tables.asp
AACC supports a maintenance-of-effort (MOE) provision that would require states to
continue to fund public higher education at historic levels. Despite some fiscal sleights-ofhand, the MOE provisions included in the American Recovery and Reinvestment Act (ARRA)
provided vital financial sustenance to institutions. Ideally, MOE provisions would be based
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
4 on per-student funding levels, rather than aggregate amounts that do not reflect
fluctuations in enrollment.
•
Preserve Accreditation for Students, Institutions, and the Public
The accreditation process continues to play two essential roles: ensuring institutional
improvement and quality assurance and serving as a gatekeeper to Title IV programs.
Preserving both these functions continues to place agencies under extreme pressure, in a
complex and changing higher education environment.
As Congress reviews the accreditation statute, policymakers should recognize that
accreditation remains a potent and prominent force in institutions’ activities, and infuses
virtually all aspects of campus life. Many of the basic assumptions of institutional
governance, management of academic programs and faculty, and the appropriate
educational and related services that are to be provided to students all derive from the
accreditation process.
Congress has a clear need to ensure that its investment in student aid is undergirded by a
rigorous accreditation system. The diversity of American higher education challenges
accreditors to meet this fundamental responsibility while responding to each institution's
unique characteristics and priorities.
First and foremost, accreditation is about academic quality. Accreditors must continue to work
with each college in relation to its articulated mission. This is a long-held tenet of accreditation
and the relevant federal statute. Institutions that have difficulty meeting their articulated goals
should be given a fair opportunity to do so, and, if they cannot, justify why that is the case. The
loss of accreditation for a community college is, and should remain, an action of absolute last
resort. A primary reason for this is that the support by state and local governments for these
institutions represents an inherent valuation of, and commitment to, the college.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
5 •
Use Language in Provisions to Combat Sexual Harassment and Violence that
Reflects the Unique Characteristics of Community Colleges
Any provisions added to the HEA to augment Title IX and the Clery Act as they apply to sexual
harassment and violence must be nuanced enough to reflect the fact that this issue affects
different types of institutions in varying ways. Community colleges are overwhelmingly
commuter institutions. Only 1.2% of the more than 13 million students live in campus housing.
Generally, community colleges are not structured to be and do not serve as a primary locus of
students’ social lives. This influences both the nature and prevalence of sexual assault at the
institutions. Recent data reported by ED indicate that more forcible sex offenses were reported
at institutions with residence halls than at institutions without them (4.6 vs. 0.5 per 10,000
students). Previous data show that about 7% of all forcible sexual offenses occurred on
community college campuses. In contrast, community colleges enroll 45% of undergraduates.
In addition to being non-residential institutions, community college locations are often more
geographically diffuse than other institutions. It is not unusual for a college to have many
locations ranging from a main campus to a shopping mall storefront. Finally, the average
community college student is 28 years old and attends part time.
Given the above, provisions in this area that reflect residential institutions comprised of a more
traditionally aged student body will not apply well to community colleges. For instance, any
requirement for institutions to have memoranda of understanding with local police forces must
be well defined to avoid a situation where community colleges are overly burdened with
having to establish MOUs with numerous law enforcement agencies. Though community
colleges will generally seek to do everything they can for students involved in incidents no
matter the circumstances, any provisions for confidential advising and other services should
carefully delineate the connection that must exist between the incident and the institution
before any federal requirements are triggered. Finally, a separate fee structure for compliance
violations in this area is not warranted or necessary, but in any case fees must not be
disproportionately punitive nor should they be applicable to small errors that occur even when
an institution is acting in good faith to comply.
In a number of areas, in particular Title IX as it applies to sexual harassment and violence on
campus, ED has promulgated new policy through sub-regulatory guidance. Though, by its
official statements, ED guidance is not technically mandatory, the actual experience of
institutions that have been investigated indicates that this guidance, in effect, has the force
of regulation. Anything that amounts to regulation should be promulgated as such, with an
opportunity for public comment.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
6 •
Create a State-Based Grant Program for Dual Enrollment and Similar
Programs in Targeted Circumstances
Without fanfare, community college dual enrollment programs have transformed the high
school and community college landscape. These programs provide high school students with
exposure to college coursework and allow them to accrue postsecondary credits. Dual
enrollment also creates a more efficient and integrated educational system. According to a
2013 ED report on dual enrollment programs and courses,xxxviii 96% of all community colleges
offer dual enrollment programs, with 83% of the courses being taught on community college
campuses. Another related innovation, early college high schools (ECHS), show striking results:
94% of ECHS students earn free college credits and 30% of them complete an associate
degree or other postsecondary degree while in high school.
A number of legislative proposals have been offered to foster greater participation in dual
enrollment programs, which have patchy availability. Any new federal funding should efficiently
target support on students and institutions that need support, without supplanting funds that
would have been otherwise provided. Currently, less affluent students have much less access to
dual enrollment programs as evidenced by the percent of students who themselves or whose
parents pay for all or some of the costs of the program. A majority of community college dual
enrollment programs reported that students paid for books, 46% reported that students paid
the fees, and 38% reported that they paid either the full or some of the tuition costs.xxxix Given
this, and given the broad array of dual enrollment program structures and funding frameworks,
the most effective form of support is a competitive grant program directed at states, which
would have to demonstrate that funds were being provided to establish or expand programs
for the most deserving populations.
At this time, the Pell Grant program should not be broadly extended to dual enrollment
students, because of the financial pressures it faces and the potential complexity of awarding
federal aid to high school students. ED’s current experimental sites program on dual
enrollment may provide useful information in this area.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
7 i
U. S. Department of Education, Federal Data Center, Student Aid Data (https://studentaid.ed.gov/sa/about/datacenter/student/title-iv). Information is provided for applicants, recipients and disbursements of Title IV aid, including loans, grants
and campus-based aid at the institutional level.
ii
American Council on Education. (2015). The Status of Federal Student Aid Programs: The Pell Grant, Student Borrowing, and
Student Support Programs (Figure 3e). Washington, DC. Retrieved from https://www.acenet.edu/news-room/Documents/TheStatus-of-Federal-Student-Aid-Programs.pdf
iii
College Board. (2013). Rethinking Pell Grants. New York, NY. Retrieved from
http://media.collegeboard.com/digitalServices/pdf/advocacy/policycenter/advocacy-rethinking-pell-grants-report.pdf
iv
MDRC. (2015, June). Year-Round Financial Aid: Evidence from Three Studies. Retrieved from
http://www.mdrc.org/sites/default/files/Issue%20Focus-YearRoundPell.pdf; Bannister, K. & Kramer, D. (2014). The Impact of the
Year-Round Pell Grant on Summer Credit Hour Completion: A Quasi-Experimental Case Study at Hillsborough Community
College. (Unpublished). Retrieved from
https://aefpweb.org/sites/default/files/webform/aefp40/Bannister_Kramer_YRP_HCC_v6.pdf
v
Attewell, P. & Monaghan, D. (2014, March). “The Community College Route to the Bachelor’s Degree.” Educational Evaluation
and Policy Analysis. Retrieved from
http://epa.sagepub.com/content/early/2014/02/28/0162373714521865.full.pdf+html?ijkey=m8EKj850s9SvE&keytype=ref&siteid=
spepa; Jenkins, D., & Fink, J. (2015). What we know about transfer. New York, NY: Columbia University, Teachers College,
Community College Research Center. Retrieved from http://ccrc.tc.columbia.edu/media/k2/attachments/what-we-know-abouttransfer.pdf
vi
Community College Research Center. (2014, January). What We Know About Developmental Education Outcomes. New York,
NY: Columbia University, Teachers College, Community College Research Center. Retrieved from
http://ccrc.tc.columbia.edu/media/k2/attachments/what-we-know-about-developmental-education-outcomes.pdf
vii
National Postsecondary Student Aid Study, Undergraduates, 2011-12, U.S. Department of Education. Washington, DC: National
Center for Education Statistics. Retrieved from http://nces.ed.gov/datalab/
viii
Ginder, S.A., Kelly-Reid, J.E., and Mann, F.B. (2015). Enrollment and Employees in Postsecondary Institutions, Fall 2014; and
Financial Statistics and Academic Libraries, Fiscal Year 2014: First Look (Provisional Data) (NCES 2016-005). U.S. Department of
Education. Washington, DC: National Center for Education Statistics. Retrieved from http://nces.ed.gov/pubsearch
ix
Integrated Postsecondary Education Data System (IPEDS), Completion Survey, 2013-14. U.S. Department of Education.
Washington, DC: National Center for Education Statistics. Retrieved from http://nces.ed.gov/ipeds/Home/UseTheData
Carnevale, A., Jayasundera, T. & Hanson, A. (2012, September). Career and Technical Education: Five Ways That Pay Along the
Way to the B.A. Washington, DC: Georgetown University Center on Education and the Workforce. Retrieved from
https://cew.georgetown.edu/wp-content/uploads/2014/11/CTE.FiveWays.FullReport.pdf
Carnevale, A., Rose, S. & Hanson, A. (2012, June). Certificates: Gateway to Gainful Employment and College Degrees.
Washington, DC: Georgetown University Center on Education and the Workforce. Retrieved from https://cew.georgetown.edu/wpcontent/uploads/2014/11/Certificates.FullReport.061812.pdf
Schneider, M. (2015, Summer). “The Value of Sub-baccalaureate Credentials.” Issues in Science and Technology. Retrieved from
http://www.air.org/sites/default/files/downloads/report/Schneider%20-%20The%20Value%20of%20Subbaccalaureate%20Credentials%20(Summer%202015%20IST)_0.pdf
x
ix
College Board. (2015). Trends in Student Aid 2015 (Figure 9). New York, NY. Retrieved from
http://trends.collegeboard.org/sites/default/files/trends-student-aid-web-final-508-2.pdf
xii
College Board. (2015). Trends in College Pricing 2015 (Table 1A). New York, NY. Retrieved from
http://trends.collegeboard.org/sites/default/files/2015-trends-college-pricing-final-508.pdf
xiii
U.S. Department of Education. (2015, August). Comparison of FY 2012 Official National Cohort Default Rates to Prior Two
Official Cohort Default Rates. Retrieved from http://www2.ed.gov/offices/OSFAP/defaultmanagement/schooltyperates.pdf
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
8 xiv
The Institute of Student Access and Success (TICAS). (2014, July). At What Cost? How Community Colleges that do not Offer
Federal Loans Put Students at Risk. Oakland, California. Retrieved from
http://ticas.org/sites/default/files/pub_files/At_What_Cost.pdf
xv
Supra note viii.
xvi
National Conference of State Legislatures. (2015, July). Higher Education: Performance-based Funding. Retrieved from
http://www.ncsl.org/research/education/performance-funding.aspx
xvii
U.S. Department of Education. (2016, April). Repayment Information Tool Added to StudentLoans.gov Web Site. Retrieved from
http://ifap.ed.gov/eannouncements/042916RepaymentInfoToolAddedtoStudentLoansdotgovWebSite.html; The White House.
(2016, April). FACT SHEET: Taking Action to Help More Americans Manage Student Debt (Press release). Retrieved from
https://www.whitehouse.gov/the-press-office/2016/04/28/fact-sheet-taking-action-help-more-americans-manage-student-debt
xviii
Legal Information Institute. (2016). 34 CFR 685.208 – Repayment Plans. Retrieved from
https://www.law.cornell.edu/cfr/text/34/685.208.
xix
Dynarski, S. & Kriesman, D. (2013). Loans for Educational Opportunity: Making Borrowing Work for Today’s Students.
Washington, DC: The Hamilton Project, Brookings Institution. Retrieved from
http://www.hamiltonproject.org/assets/legacy/files/downloads_and_links/THP_DynarskiDiscPaper_Final.pdf.
xx
Fernandez, C. (2016, January). Effective Counseling, Empowered Borrowers: An Evidence-based Policy Agenda for Informed
Student Loan Borrowing and Repayment. Round Rock, Texas: TG Research and Analytical Services. Retrieved from
http://www.tgslc.org/pdf/Effective-Counseling-Empowered-Borrowers.pdf
xxi
Fernandez, C. (2015, February). From Passive to Proactive: Understanding and Improving the Borrower Experience with Online
Student Loan Counseling. Round Rock, Texas: TG Research and Analytical Services. Retrieved from
https://www.tgslc.org/pdf/From-Passive-to-Proactive.pdf
xxii
U.S. Department of Education. (2015, September). Department of Education, Department of Treasury and the Consumer
Financial Protection Bureau Issue Joint Principles on Student Loan Servicing (Press release). Retrieved from
http://www.ed.gov/news/press-releases/department-education-department-treasury-and-consumer-financial-protection-bureauissue-joint-principles-student-loan-servicing
xxiii
Mitchell, T. (2016, April). “A New Vision for Serving Student Loan Borrowers.” Home Room: The Official Blog of the U.S.
Department of Education. Retrieved from http://blog.ed.gov/2016/04/a-new-vision-for-serving-student-loan-borrowers/
National Postsecondary Student Aid Study, Undergraduates, 2011-12, U.S. Department of Education. Washington, DC: National
Center for Education Statistics. Retrieved from http://nces.ed.gov/datalab/
xxiv
xxv
U.S. Department of Education. (2016). Federal Student Aid Data Center. Retrieved from
https://studentaid.ed.gov/sa/about/data-center/student/application-volume/fafsa-school-state
xxvi
U.S. Department of Education. (2016). Federal Student Aid, Information for Financial Aid Professionals (IFAP). Retrieved from
http://ifap.ed.gov/EarlyFAFSA/indexV1.html
xxvii
National Association of Student Financial Aid Administrators. (2015). Prior-Prior Year. Retrieved from
https://www.nasfaa.org/ppyresources
xxviii
Goldrick-Rab, S., and Kelchen, R. (2012, December). Accelerating College Knowledge: Examining the Feasibility of Targeted
Early Commitment Pell Grant Program. Madison, Wisconsin: University of Wisconsin-Madison. Retrieved from
https://www.insidehighered.com/sites/default/server_files/files/Kelchen%20GoldrickRab%20Early%20Commitment%20Paper%20with%20summary.pdf
U.S. Department of Education. (2016). Federal TRIO Programs - Home Page. Retrieved from
http://www2.ed.gov/about/offices/list/ope/trio/index.html
xxix
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 2
9 xxx
Institute of Women’s Policy Research. (2016, May). Quick Facts: Mothers in College Have Declining Access to On-Campus Child
Care. Washington, DC. Retrieved from http://iwpr.org/publications/pubs/mothers-in-college-have-declining-access-to-on-campuschild-care
xxxi
U.S. Department of Education. (2016). Child Care Access Means Parents in School Program. Retrieved from
http://www2.ed.gov/programs/campisp/index.html
American Association of Community Colleges. (2016). Voluntary Framework of Accountability. Retrieved from
http://vfa.aacc.nche.edu/Pages/default.aspx
xxxii
xxxiii
Eagan, K., Stolzenberg, E. B., Bates, A. K., Aragon, M. C., Suchard, M. R., & Rios-Aguilar, C. (2015). The American Freshman:
National Norms Fall 2015. Los Angeles: Higher Education Research Institute, UCLA. Retrieved from
http://www.heri.ucla.edu/monographs/TheAmericanFreshman2015.pdf; Fishman, R. (2015, May). College Decisions Survey:
Deciding to Go to College. Washington, DC: New America. Retrieved from http://www.edcentral.org/collegedecisions/
xxxiv
American Council on Education. (2015, February). Recalibrating Regulations of Colleges and Universities: Report of the Task
Force on Federal Regulation of Higher Education. Washington, DC. Retrieved from
http://www.help.senate.gov/imo/media/Regulations_Task_Force_Report_2015_FINAL.pdf
xxxv
U.S. Department of Education, IFAP, Gainful Employment. Retrieved from
http://ifap.ed.gov/GainfulEmploymentInfo/GEDCLandEAV2.html
National Center on Education Statistics. (2015). Digest of Education Statistics 2015, Table 333.10. Revenues of Public DegreeGranting Institutions by Source of Revenue and Level of Institution 2007-08 through 2013-14. In constant 2014-15 dollars.
Retrieved from http://nces.ed.gov/programs/digest/d15/tables/dt15_333.10.asp?current=yes
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xxxvii
College Board. (2015). Trends in College Pricing 2015 (Table 1A). New York, NY. Retrieved from
http://trends.collegeboard.org/sites/default/files/2015-trends-college-pricing-final-508.pdf
xxxviii
Marken, S., Gray, L., and Lewis, L. (2013). Dual Enrollment Programs and Courses for High School Students at Postsecondary
Institutions: 2010–11 (NCES 2013-002). U.S. Department of Education. Washington, DC: National Center for Education Statistics.
Retrieved from http://nces.ed.gov/pubs2013/2013002.pdf
xxxix
Ibid, Table 11.
American Association of Community Colleges Higher Education Act (HEA) Reauthorization Priorities 3
0