Ms. Wendy Macias
U.S. Department of Education
1990 K Street, NW, Room 8017
Washington, DC 20006
Dear Ms. Macias:
These comments provide a response to the U.S. Department of Education’s intent to establish a negotiated rulemaking committee to prepare proposed regulations to govern the Federal Direct Loan program. The comments are submitted by the Institute for Higher Education Policy (IHEP), on behalf of the Postsecondary Data (PostsecData) Working Group. IHEP is a nonpartisan, nonprofit organization committed to promoting access to and success in higher education for all students, especially students who traditionally have been underserved by our education system. Based in Washington, D.C., IHEP develops innovative policy‐ and practice‐oriented research to guide policymakers and education leaders in developing high‐impact policies that will address our nation’s most pressing education challenges. IHEP convenes the PostsecData Working Group, which engages thought leaders from over 20 organizations on issues related to postsecondary education data quality and use. The comments presented are produced and supported by the Center for Law and Social Policy (CLASP), Georgetown University Center on Education and the Workforce, the Institute for Higher Education Policy (IHEP), National Center for Higher Education Management Systems (NCHEMS), National College Access Network (NCAN), New America, State Higher Education Executive Officers (SHEEO), The Institute for College Access and Success (TICAS), Thomas Weko (American Institutes for Research), and Young Invincibles.
When used effectively, responsibly, and contextually, data can empower policymakers, researchers, and practitioners seeking to improve higher education performance. We need robust, valid, and secure data in order to answer the critical questions that will drive this change, and to uncover compelling success stories, areas for improvement, and previously unrecognized inequities. However, current data are insufficient for these tasks, particularly regarding student debt and loan repayment. For example, data are not regularly available publicly to answer questions such as:
- How much student loan debt are graduates and non‐graduates incurring?
- How successful are borrowers in repaying their debts?
- How many borrowers are accessing income‐driven repayment plans, and how effective are PAYE expansion policies?
- How long are borrowers carrying student loan debt?
- How much are borrowers repaying compared with their original debt balance?
- How much debt forgiveness do borrowers receive?
- How common is student loan default in the short‐ and long‐term?
- How are borrowers using the system, and what role do different plans and servicers serve?
Given our collective desire for more robust data collection and greater data transparency, the members of the PostsecData Working Group strongly recommend that a portion of the negotiated rulemaking
agenda for the Pay As You Earn (PAYE) expansion be reserved for a discussion of the data reporting that should accompany such a program expansion...Read more.