GAO-15-663, FEDERAL STUDENT LOANS: Education Could Do More .

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United States Government Accountability OfficeReport to Congressional RequestersAugust 2015FEDERAL STUDENTLOANSEducation Could DoMore to Help EnsureBorrowers Are Awareof Repayment andForgiveness OptionsGAO-15-663

August 2015FEDERAL STUDENT LOANSEducation Could Do More to Help Ensure BorrowersAre Aware of Repayment and Forgiveness OptionsHighlights of GAO-15-663, a report tocongressional requestersWhy GAO Did This StudyWhat GAO FoundAs of September 2014, outstandingfederal student loan debt exceeded 1 trillion, and about 14 percent ofborrowers had defaulted on their loanswithin 3 years of entering repayment,according to Education data. GAO wasasked to review options intended tohelp borrowers repay their loans.Many eligible borrowers do not participate in the Department of Education’s(Education) Income-Based Repayment and Pay As You Earn repayment plansfor Direct Loans, and Education has not provided information about the plans toall borrowers in repayment. These plans provide eligible borrowers with lowerpayments based on income and set timelines for forgiveness of any remainingloan balances. While the Department of the Treasury estimated that 51 percentof Direct Loan borrowers were eligible for Income-Based Repayment as ofSeptember 2012, the most recent available estimate, Education data show 13percent were participating as of September 2014. An additional 2 percent were inPay As You Earn. Moreover, Education has reported ongoing concerns regardingborrowers’ awareness of these plans. Although Education has a strategic goal toprovide superior information and service to borrowers, the agency has notconsistently notified borrowers who have entered repayment about the plans. Asa result, borrowers who could benefit from the plans may miss the chance tolower their payments and reduce the risk of defaulting on their loans.For Direct Loan borrowers GAOexamined: (1) how participation inIncome-Based Repayment and Pay AsYou Earn compares to eligibility, and towhat extent Education has taken stepsto increase awareness of these plans,and (2) what is known about PublicService Loan Forgiveness certificationand eligibility, and to what extentEducation has taken steps to increaseawareness of this program. GAOreviewed relevant federal laws,regulations, and guidance; September2014 data from Education and its loanservicer for Public Service LoanForgiveness; Treasury’s eligibilityestimates; and 2012 employment data(most recent available) from theBureau of Labor Statistics. GAO alsointerviewed officials from three loanservicers that service about half ofEducation’s loan recipients.What GAO RecommendsGAO recommends Educationconsistently notify borrowers inrepayment about income-drivenrepayment, and examine borrowerawareness of Public Service LoanForgiveness. Education generallyagreed with GAO’s recommendations,but it believed the report overstated theextent to which borrowers lackawareness of income-drivenrepayment. GAO modified the report toclarify this issue.View GAO-15-663. For more information,contact Melissa Emrey-Arras at (617) 7880534 or emreyarrasm@gao.gov.Repayment Plan Participation of Direct Loan Borrowers in Active Repayment, September 2014Few borrowers who may be employed in public service have had theiremployment and loans certified for the Public Service Loan Forgivenessprogram, and Education has not assessed its efforts to increase borrowerawareness. Beginning in 2017, the program is to forgive remaining Direct Loanbalances of eligible borrowers employed in public service for at least 10 years.As of September 2014, Education’s loan servicer for the program had certifiedemployment and loans for fewer than 150,000 borrowers; however, borrowersmay wait until 2017 to request certification. While the number of borrowerseligible for the program is unknown, if borrowers are employed in public serviceat a rate comparable to the U.S. workforce, about 4 million may be employed inpublic service. It is unclear whether borrowers who may be eligible for theprogram are aware of it. Although Education has a strategic goal to providesuperior information and service to borrowers and provides information aboutPublic Service Loan Forgiveness through its website and other means, it has notnotified all borrowers in repayment about the program. In addition, Education hasnot examined borrower awareness of the program to determine how well itsefforts are working. Borrowers who have not been notified about Public ServiceLoan Forgiveness may not benefit from the program when it becomes availablein 2017, potentially forgoing thousands of dollars in loan forgiveness.United States Government Accountability Office

ContentsLetter1BackgroundMany Eligible Borrowers Do Not Participate in IBR and PAYE, andEducation Is Missing Opportunities to Increase Awareness ofThese PlansFew Borrowers Who May Be Employed in Public Service HaveHad Their Employment and Loans Certified for PSLF, andEducation Has Not Assessed Its Efforts to Increase Awarenessabout PSLFConclusionsRecommendations for Executive ActionAgency Comments and Our Evaluation25363637Appendix IObjectives, Scope, and Methodology39Appendix IISelected Characteristics for Direct Loan Borrowers in ActiveRepayment, by Repayment Plan, September 201445Status of Public Service Loan Forgiveness Employment CertificationForms, September 201446Appendix IVComments from the Department of Education47Appendix VGAO Contact and Staff Acknowledgments50Appendix III413TablesTable 1: Selected Eligibility Requirements, Loan Limits, andInterest Rates for Direct LoansTable 2: Summary of Income-Driven Repayment Plans forEducation’s Direct Loan BorrowersPage i47GAO-15-663 Federal Student Loans

FiguresFigure 1: Education’s Voluntary Process for CertifyingEmployment and Loans for Public Service LoanForgivenessFigure 2: Repayment Plan Participation of Direct Loan Borrowersin Active Repayment, September 2014Figure 3: Total Loan Costs, Repayment Periods, and MonthlyPayments, by Repayment Plan, for Two Borrowers withDifferent IncomesFigure 4: Annual Adjusted Gross Income of Income-BasedRepayment and Pay As You Earn Participants in ActiveRepayment, September 2014Figure 5: Amount Borrowed by Direct Loan Borrowers in ActiveRepayment, by Repayment Plan, September 2014Figure 6: Loan Status of Direct Loan Borrowers Who EnteredRepayment from Fiscal Year 2010 through 2014, byRepayment Plan, September 2014Figure 7: Cumulative Number of Borrowers Who Had Employmentand Loans Certified for PSLF, January 2012 toSeptember 2014, by QuarterFigure 8: Borrowers Who Had Employment and Loans Certifiedfor PSLF by Repayment Plan, September 2014Figure 9: Annual Adjusted Gross Income of Borrowers Who HadEmployment and Loans Certified for PSLF, September2014Figure 10: Amount Borrowed by Borrowers Who Had Employmentand Loans Certified for PSLF, September 2014Figure 11: Total Loan Costs, Payment Periods, and MonthlyPayments under PSLF, by Repayment Plan, for TwoBorrowers with Different IncomesPage ii1214171920212629303133GAO-15-663 Federal Student Loans

AbbreviationsDirect liam D. Ford Federal Direct LoanU.S. Department of EducationFederal Family Education LoanHigher Education Act of 1965, as amendedIncome-Based RepaymentIncome-Contingent RepaymentNational Student Loan Data SystemPay As You EarnPublic Service Loan ForgivenessU.S. Department of the TreasuryThis is a work of the U.S. government and is not subject to copyright protection in theUnited States. The published product may be reproduced and distributed in its entiretywithout further permission from GAO. However, because this work may containcopyrighted images or other material, permission from the copyright holder may benecessary if you wish to reproduce this material separately.Page iiiGAO-15-663 Federal Student Loans

Letter441 G St. N.W.Washington, DC 20548August 25, 2015The Honorable Patty MurrayRanking MemberCommittee on Health, Education, Labor, and PensionsUnited States SenateThe Honorable Bernard SandersRanking MemberCommittee on the BudgetUnited States SenateTo help students and their families pay for higher education, theDepartment of Education (Education) provides billions of dollars in federalstudent loans each year through programs authorized under Title IV ofthe Higher Education Act of 1965, as amended (HEA).1 However, as ofSeptember 2014, about one in seven student loan borrowers (14 percent)had defaulted on their loans within 3 years of beginning repayment, andapproximately 103 billion of more than 1 trillion in student loan debtwas in default according to data from Education. In recent years,Education has implemented several programs to help borrowers underthe William D. Ford Federal Direct Loan (Direct Loan) program repayfederal student loans. The Income-Based Repayment (IBR) and Pay AsYou Earn (PAYE) repayment plans set borrowers’ monthly paymentsbased on income and establish timelines after which remaining loanbalances are forgiven. In addition, beginning in 2017, the Public ServiceLoan Forgiveness (PSLF) program is to forgive remaining student loanbalances of certain borrowers employed in public service, and borrowersmay request that Education certify their employment and loans inadvance for eligibility purposes. Although such options may helpborrowers manage their payments and receive loan forgiveness,Education and others have noted that many eligible borrowers have notparticipated. You asked us to review the IBR, PAYE, and PSLF programs.1Pub. L. No. 89-329, 79 Stat. 1232-1254 (codified at 20 U.S.C. §§ 1070-1099d and 42U.S.C. §§ 2751-2756b).Page 1GAO-15-663 Federal Student Loans

This report examines the following questions for the Direct Loan program:(1) How does borrower participation in Income-Based Repayment andPay As You Earn compare to available estimates of eligibility, and to whatextent has Education taken steps to increase borrower awareness ofthese plans? (2) What is known about Public Service Loan Forgivenesscertification and eligibility, and to what extent has Education taken stepsto increase awareness of this program?We used a variety of approaches and data sources in conducting thiswork. To examine participation and key characteristics of borrowers inIBR, PAYE, and other repayment plans2 and to examine PSLF we: reviewed summary data from Education’s National Student Loan DataSystem (NSLDS) on 19.3 million Direct Loan3 borrowers who hadentered repayment and had an outstanding loan balance as ofSeptember 2014;reviewed available estimates of IBR eligibility from a Department ofthe Treasury (Treasury) analysis of Education and tax return data fora random sample of borrowers;4analyzed data from the loan servicer that administers PSLF forEducation, on borrowers who voluntarily requested and obtainedcertification of their public service employment and loans as ofSeptember 2014;5used 2012 data, the most recent available, from the Department ofLabor’s Bureau of Labor Statistics on public service employment to2While the focus of this review was on IBR and PAYE, we mention other income-drivenrepayment plans, such as Income-Contingent Repayment (ICR), as they relate to ourreview.3While loans under the Federal Family Education Loan (FFEL) program are eligible to berepaid under IBR, we excluded them from our review based on data limitations. Educationdoes not have repayment plan information for FFEL loans held by commercial lenders,and repayment plan information for FFEL loans that Education holds is limited. Privatestudent loans are not eligible for IBR, PAYE, or PSLF and were outside the scope of ourreview.4Treasury estimates of IBR eligibility are based on NSLDS data from September 2012 forborrowers who entered repayment in 2010 or earlier and 2010 and 2011 Internal RevenueService tax return data, depending on the most recent available for each borrower. Theseare the most recent IBR eligibility estimates we identified.5Data on PSLF reflect only the borrowers who voluntarily had their public serviceemployment and loans certified by Education. Actual participation numbers will not beavailable until borrowers apply for and begin receiving loan forgiveness benefits in 2017.Page 2GAO-15-663 Federal Student Loans

approximate the percentage of Direct Loan borrowers who may beeligible for PSLF; andreviewed and applied assumptions from a repayment calculator onEducation’s website to examine the potential effects of IBR, PAYE,and PSLF for borrowers with various characteristics.We determined that data from each of these sources were sufficientlyreliable for the purposes of this report by reviewing existing informationabout the data and the systems that produced them, and by interviewingknowledgeable agency officials.To understand program terms and eligibility requirements, we reviewedrelevant federal laws and regulations, and documentation from Education,such as program fact sheets. To determine the extent to which Educationhas taken steps to raise awareness of the programs, we interviewedEducation officials and reviewed documentation of its efforts, includinginformation Education makes available to borrowers. We comparedinformation on Education’s efforts to criteria outlined in contractrequirements applicable to Education’s 11 Direct Loan servicers related tocommunication with borrowers and the goals and objectives in the Officeof Federal Student Aid’s Fiscal Year 2012-2016 Strategic Plan. Weinterviewed representatives of higher education associations, borroweradvocacy groups, and researchers about student loan repayment andforgiveness, including factors that may affect borrowers’ decisions aboutrepayment. We also interviewed representatives of, and revieweddocumentation for, 3 of Education’s 11 loan servicers, which servicedabout half of all recipients of loans owned by Education.6 In addition,during April and May 2015, we interviewed a nongeneralizable sample of14 randomly selected borrowers about their awareness of income-drivenrepayment plans. We did not review costs to the government or proposalsto revise existing repayment and forgiveness plans, as these topics werebeyond the scope of our review. See appendix I for more detail on ourscope and methodology.We conducted this performance audit from November 2013 to August2015 in accordance with generally accepted government auditingstandards. Those standards require that we plan and perform the audit toobtain sufficient, appropriate evidence to provide a reasonable basis for6This includes borrowers with Direct Loans and FFEL loans whose loans were in activerepayment, deferment, or forbearance as of September 2014.Page 3GAO-15-663 Federal Student Loans

our findings and conclusions based on our audit objectives. We believethat the evidence obtained provides a reasonable basis for our findingsand conclusions based on our audit objectives.BackgroundFederal Student LoansUnder the Direct Loan program, Education issues several types ofstudent loans. They are Subsidized and Unsubsidized Stafford Loans,PLUS Loans, and Consolidation Loans.7 The federal government setslimits on the maximum interest rate,8 loan origination fee and othercharges, and annual and aggregate amounts that can be borrowed (seetable 1).Table 1: Selected Eligibility Requirements, Loan Limits, and Interest Rates for Direct LoansAggregate loan limitsaType of Direct LoanEligibilityDirect Stafford LoansSubsidized:Subsidized:Undergraduate students enrolled at 23,000 for undergraduateleast half-time who canstudentscdemonstrate financial need. The 65,500 for graduate andegovernment subsidizes these loansprofessional studentsby paying the interest that accruesTotal (subsidized andwhile borrowers are in school,during a 6-month grace period after unsubsidized): 31,000 for dependentleaving school, and during certaindundergraduatesperiods of deferment. 57,500 for independentUnsubsidized:undergraduates andUndergraduate and graduate anddependent students whoseprofessional students enrolled atparents cannot obtain PLUSleast half-time. Financial need isloansnot required. Borrowers are 138,500 for graduate andresponsible for paying all interestprofessional studentsfrom disbursement to final payoff ofthe loan.Interest ratesb4.29% for undergraduates(subsidized and unsubsidized)5.84% for graduate andprofessional students(unsubsidized)7The Student Loan Reform Act of 1993, Pub. L. No. 103-66, tit. IV, subtit. A, 107 Stat.312, 341, established the Direct Loan program, as Part D of Title IV of the HEA.8Federal student loan interest rates for new loans are set annually using a statutoryformula based on the 10-year Treasury note rate plus a mark-up that depends on theborrower and loan type, with specified maximum rates. Loans have a fixed interest rate forthe life of the loan.Page 4GAO-15-663 Federal Student Loans

Aggregate loan limitsaInterest ratesbType of Direct LoanEligibilityDirect PLUS LoansGraduate and professional students Cost of attendance for the entireand parents of dependentperiod of enrollmentundergraduate students. Borrowersmust pay all interest on theseloans.Students must be enrolled at leasthalf-time, and applicant must haveno adverse credit history. Financialneed is not required.6.84%Direct ConsolidationLoansStudent and parent borrowersNot applicablewanting to combine multiple federalloans into one loan. Consolidationloans may have both subsidizedand unsubsidized components.Weighted average of interestrates of loans beingconsolidated, rounded up tonearest 1/8 of 1 percentSource: U.S. Department of Education and GAO analysis of laws and regulations. GAO-15-663aSubsidized and unsubsidized borrowers are also subject to annual loan limits based on grade level,dependency status, and type of loan (subsidized or unsubsidized). For PLUS loans, annual borrowingis limited to the cost of attendance.bFederal student loan interest rates are set annually for new loans using a statutory formula based onthe 10-year Treasury note rate plus a mark-up that depends on the borrower and loan type, withspecified maximum rates. Loans have a fixed interest rate for the life of the loan. The rates in thiscolumn apply to loans made on or after July 1, 2015 and before July 1, 2016.cFinancial need for federal student aid purposes is generally the difference between a student’s costof attendance and an estimate of the student’s (and his or her family’s, in the case of a dependentstudent) ability to pay these costs—this is called the expected family contribution.dBorrowers are not expected to make loan payments when they are enrolled in school at least halftime or during the grace period, usually 6 months for Direct Loans, that occurs after a borrower leavesschool or drops below half-time enrollment. The Consolidated Appropriations Act, 2012 eliminated thegrace period interest subsidy for Direct Subsidized Stafford Loans disbursed on or after July 1, 2012,and before July 1, 2014. Pub. L. No. 112-74, div. F, tit. III, § 309(d), 125 Stat. 786, 1101. Thegovernment does not charge borrowers for interest costs on Direct Subsidized Stafford Loans duringperiods of authorized deferment, during which borrowers can temporarily suspend repayment if, forexample, they pursue additional higher education, provide military service, or experience economichardships. New borrowers on or after July 1, 2013, may not receive Direct Subsidized Stafford Loansfor a period that exceeds 150 percent of the published length of the academic program in which theyare currently enrolled.eThe aggregate loan limit for Direct Subsidized Stafford Loans to graduate and professional studentsapplies to loans borrowed for programs of instruction beginning before July 1, 2012. Graduate andprofessional students are generally not eligible for Direct Subsidized Stafford Loans for periods ofinstruction beginning on or after July 1, 2012.Education contracts with 11 loan servicers to manage Direct Loanaccounts. Loan servicing includes activities such as com

To help students and their families pay for higher education, the Department of Education (Education) provides billions of dollars in federal student loans each year through programs authorized under Title IV of the Higher Education Act of 1965, as amended (HEA).

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