in debt and in the dark: it’s time for better information on student loan defaults

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    In Debt and In the Dark:Its Time or Better Inormationon Student Loan Deaults

    By Andrew Gillen

    Few domestic issues resonate more deeply with the public than the

    continually rising cost of college. With soaring tuitions (and oten disappointing

    completion rates) have come demands or cheaper alternatives and stricter

    institutional accountability. The responsibility or both has traditionally resided

    with colleges, but the ederal government can inuence postsecondary behavior

    in two key ways that relate to student loan deault rates: First, by providing better

    inormation on student loan deault rates. Second, by holding colleges more

    accountable or their part in student loan deaults.

    The three-year deault rate or student loans is 13.4 percent, and the cost odeault will be borne by studentsand taxpayers.1

    Tracking and reporting loan deault rates are a crucial means o monitoring how

    well higher education dollars are spent; it is a primary ederal responsibility.

    Better loan deault data would hold institutions to a stricter level o accountability,

    provide more useul inormation to students and parents, and help researchers

    determine which students struggle most to aord college, why they struggle, and

    how to address those problems. Yet, despite the debates about ways the ederal

    government might improve accountability and reduce student debtor example,

    by providing meaningul data on industries where graduates fnd jobs, by trackinggraduation rates or part-time students, or by increasing oversight o college

    accreditorspolicymakers have not devoted enough attention to overhauling one

    basic step: how the ederal government measures and reports data on student

    loan deaults.

    Incomplete Loan Deault Data

    Data on loan deaults is reported by institution. That means that whether you are

    looking at an elite Ivy or a local community college, you can see the percentage

    o borrowers who attended those schools and deaulted at some point in the

    frst three years o the repayment period.2 But thats all you can learn. There are

    no breakouts o that data. Consider Pell grants, given primarily to poor students.

    I you want to see how many o one schools Pell grant students deaulted

    compared to how many o the schools other students deaulted, you are out o

    luck. Likewise, you cant fnd out how deaults among Pell grant students at one

    school compare to deaults o Pell grant students at another school. You also cant

    look at deault rates or dierent types o degree programsbachelors versus

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    masters versus doctoral at a our-year university, or associate versus certifcate

    programs at a community college. Nor can you look at deault rates by students

    age, gender, or ethnic group.

    None o this inormation is available despite the act that deault rates are one

    o the primary means by which the ederal government determines eligibility orederal aid. (Schools also must be accredited and approved in their home states,

    but the ederal government does not directly inuence these decisions).

    Given the importance o deaults, and the recent jump in their numbers, it would

    make sense or the government to provide more detailed inormation on deaults,

    not just as an accountability lever but as a basic consumer right. Compared to

    other orms o debt, it is remarkably easy to qualiy or a ederal student loan

    (though remarkably difcult to discharge in bankruptcy): Good credit histories are

    not required or most loans, and the risk to students is shared by taxpayers since

    the ederal government is the direct lender or ederal loans. Parents and students

    would beneft rom better data showing which students, at which schools, are

    more likely to deault on higher education loans.

    Elsewhere in education, actions by the ederal government have ooded

    policymakers, parents, and other taxpayers with important and useul data. The

    ederal No Child Let Behind Act remains controversial, but because o it, at the

    K12 level, results o achievement tests are broken down by state and district.

    Results also are available by race and categories such as English profciency and

    special education status, so that schoolwide averages no longer mask dierent

    levels o perormance among sub-populations.

    Why cant the same rigor be applied to reporting requirements or deault rates

    at the college level? Already the ederal government has made some changes in

    how it calculates deault rates. Colleges will soon be judged on the percentage o

    What is a Student Loan Default?

    When student borrowers graduate, drop out, or all below hal-time enrollment,

    its time to start paying back their student loanswhat the government calls

    entering repayment. Most ederal loans have a six-month grace period

    beore entering repayment. Student borrowers also can be granted deerment

    (a temporary reprieve rom loan payments) or orbearance (an alternative

    payment schedule) to postpone or alter scheduled payments.

    The U.S. Department o Education considers a loan to be in deault i the

    borrower is more than 270 days behind on payments. The deault rate is the

    percentage o a schools borrowers who enter repayment during a scal

    year and deault within three years. Note: Only subsidized and unsubsidized

    Staord loans are included in the deault rate calculation. The deault rate

    calculation ignores Parent PLUS, Grad PLUS, and Perkins loans.

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    borrowers who deault in the frst three years o the repayment period rather than

    the percentage who deault in the frst two years. (Three-year deault rates were

    published or the frst time in 2012). Under the new rules, schools with deault rates

    greater than 30 percent or three consecutive years will lose access to ederal

    student aid. (Lesser consequences kick in beore that.) Under the two-year rule,

    the eligibility threshold was 25 percent.3

    Two-Year vs. Three-Year Rates

    Congress instituted the three-year rule because o concerns that schools were

    gaming the two-year requirement by delaying the date at which students would go

    into deault (through orbearance, deerment, and other means). Since this would

    allow colleges to avoid accountability or their students deaults, taking action

    to prevent such schemes seemed a reasonable response. But Chart 1, which

    shows the two-year and the three-year deault rate or each college, indicates that

    with ew exceptions, i you know a schools two-year deault rate, you can pretty

    accurately predict its three-year deault rate. Colleges largely did not hide deault

    rates by shiting them outside the old two-year measurement window.

    There were a ew outliers such as Lassen Community College in Caliornia. Its

    two-year deault rate was 15.2 percent; its three-year deault rate jumped to 37.7

    percent. Several or-proft colleges also saw unusually large jumps. For example,

    at ITT Technical Institute, which has many campuses, deault rates or most o the

    system rose rom 18.2 percent to 34.1 percent.

    Deault Rates as an Accountability Tool

    Using deault rates as an accountability mechanism is appealing or two reasons:

    First, the rates provide an objective and quantifable measure o a colleges

    success in providing a cost-eective education. For many students, the main

    reason or enrolling in college is to improve their lietime fnancial well-being,

    and a high deault rate indicates that a college has ailed to help its students

    achieve this important goal.

    Second, deault rates are relatively hard or colleges to game. They are a

    better accountability tool than, or instance, graduation rates, which a college

    can improve by lowering its standards. To avoid punishment or high deault

    rates, a college could lower tuition (reducing the amount students need to

    borrow) or provide a better education, which should improve the job prospects

    o its graduates and their ability to repay their loans.

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    There are two drawbacks to using deault rates as an accountability tool:

    First, employment outcomes, even when calculated on a value-added basis,

    are not a complete measure o educational outcomes. As hundreds o

    academics have argued, there is a lot more to being college-educated than

    getting a good job. What this means in practice is that deault rates should not

    be the onlyaccountability tool used.

    Second, some students are more likely than others to deault or reasons

    that have nothing to do with the cost or the quality o their education. Auent

    parents oten can help their children with loan payments, or instance, while

    low-income parents oten cannot. Thereore, we would expect the deault

    rate to be higher at a college that educates more low-income students than

    at a college that educates more high-income students, even i the colleges

    are otherwise identical. An accountability system that ailed to account or

    HART 1

    Two-year andhree-year

    deault ratesmatch closely.

    Two-Year Default Rate

    Three-YearDefaultRate

    0 10 20 30 40

    0

    10

    20

    30

    40

    50

    60

    Source: Integrated Postsecondary Education Data System, Student Financial Aid, and authors calculations.

    1) Each dot represents a school a.) with sufcient data, b.) or which at least 100 students entered repayment inFY2009, and c.) with at least 250 ull-time-equivalent students in 2009 10.

    2) The red line indicates the best ft linear regression line.

    3) On average, a colleges three-year deault rate was 1.46 times its two-year deault rate. More than 92 percent othe variation in three-year deault rates is explained by variation in two-year deault rates.

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    this dierence would punish colleges or serving students who are at greater

    fnancial risk.

    Fortunately, it is possible to devise input-adjusted or predicted deault rates to

    create a better accountability system, one that makes allowances or dierences in

    students backgrounds. Under this system, external actors that inuence deaultrates would be taken into account, adjusting a colleges actual deault rate or

    actors such as amily income. While we cannot know all the inuencing actors,

    analysis with available data illustrates the wisdom o accounting or probable

    deault-risk actors.

    The frst step is to select the risk actors. Income is one. Unortunately, there is

    almost no publicly available data on the income o students at each college. But

    we do know what percentage o students receive Pell grants, and since these

    grants are awarded largely to students rom low-income amilies, the percentage

    o Pell grant recipients can serve as a good proxy or the proportion o low-income

    Finding the Predicted Default Rate

    To nd the predicted deault rate, Education Sector ran a regression analysis

    using the deault rate as the dependent variable, and the percentages o

    undergraduates receiving Pell grants and part-time undergraduates as the

    independent variables.

    Four-Year Colleges Regression Results

    Estimate Std. Error t value Pr(>|t|)

    Constant -2.134891 0.256028 -8.339 < 0.001***

    % Pell 0.284719 0.005995 47.49 < 0.001***

    % Part time 0.037259 0.006677 5.58 < 0.001***

    N = 1,600, Adj. R2 = .61

    Two-Year Colleges Regression Results

    Estimate Std. Error t value Pr(>|t|)

    Constant 13.181325 1.106419 11.913 < 0.001***

    % Pell 0.125689 0.014634 8.589 < 0.001***

    % Part time 0.009817 0.012049 0.815 0.415

    N = 1,052, Adj. R2 = .11

    The coecient estimates were combined with each colleges actual values

    or the percentage o Pell grant recipients and percentage o students who

    were part time to yield the predicted deault rate. For example, a our-year

    college with 30 percent o students receiving Pell grants and 10 percent o

    students attending part time would have a predicted deault rate o: -2.13489

    + 30 * 0.284719 + 10 * 0.037259 = 6.8%. This predicted rate can be compared

    to the colleges ocial rate to determine i the college is doing better or

    worse than expected.

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    HART 2

    Four-yearcolleges with

    similar studentshave widelyvarying deaultates.

    students at a college. Similarly, the percentage o part-time students can serve

    as a proxy or nontraditional students, a category that also may present a higher

    deault risk.

    These two variables (percentage Pell and percentage part time) were used to

    calculate each colleges expected or predicted deault rate. Charts 2 and 3 plotthe predicted deault rate against each colleges actual deault rate.

    I a colleges actual deault rate is lower than its predicted deault rate, its dot

    is below the red line in Charts 2 and 3, and that college is doing better than

    expectedgiven the students it educates. I a colleges actual deault rate is higher

    than its predicted deault rate, its dot is above the red line in Charts 2 and 3, and

    that college is doing worse than expected. It is likely that ewer o these students

    would deault i they attended other schools. Rather than holding colleges

    Source: Integrated Postsecondary Education Data System, Student Financial Aid, and authors calculations.

    1) Each dot represents a our-year college a.) with su fcient data, b.) or which at least 100 students entered

    repayment in FY2009, and c.) with at least 250 ull-time-equivalent students in 2009 10.

    2) The red line shows all points or which the predicted deault rate is equal to the actual deault rate.

    3) Predicted values are each colleges expected deault rate, based on a regression using as independent variables

    the percentage o students who are Pell grant recipients and the percentage o students who are par t time.

    Predicted vs. Actual Student Loan Default Rates: 4-Year Colleges

    Predicted Default Rates Based on % of Pell and Part-Time Students

    ActualDefaultRate

    0 10 155 20 25 30

    0

    10

    20

    30

    40

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    accountable or whether they meet hard caps (such as an unadjusted deault rate

    below 30 percent), we should hold colleges accountable or whether they are

    signifcantly above or below the red predicted-deault line.4 While this example only

    accounts or two inputs (because other desired data was not available), it does

    show the wisdom o designing accountability thresholds that are input-adjusted.

    Consider two public, our-year universitiesCentral State University in Ohio and

    Southern University at New Orleans. Seventy-seven percent o students at Central

    State receive Pell grants and 7 percent attend part time. Seventy-six percent o

    students at Southern University at New Orleans receive Pell grants and 21 percent

    attend part time.

    HART 3

    Two-yearcolleges with

    similar studentshave widervariationn deault rateshan our-year

    schools.

    Source: Integrated Postsecondary Education Data System, Student Financial Aid, and authors calculations.

    1) Each dot represents a two year college a.) with sufcient data, b.) or which at least 100 students entered

    repayment in FY2009, and c.) with at least 250 ull-time equivalent students in 2009 10.

    2) The red line shows all points or which the predicted deault rate is equal to the actual deault rate.

    3) Predicted values are each colleges expected deault rate, based on a regression using as independent variablesthe percentage o students who are Pell grant recipients and the percentage o students who are par t time.

    4) There are several colleges (e.g. ITT Technical Institute) that report systemwide deault rates, but campus-specifc student characteristics. This results in slightly dierent predicted values (based on variations in studentcharacteristics by campus), and the same actual values (based on the systemwide deault rate), which appear on

    the graph as a group o horizontally arrayed dots.

    2016 18 22 24 26 28

    0

    10

    20

    30

    40

    50

    Predicted Default Rates Based on % of Pell and Part-Time Students

    ActualDefaultRate

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    Statistical analysis indicates that the typical deault rate or colleges that have

    similar student characteristics is around 20 percent. But Central State Universitys

    deault rate is 32.8 percent; Southern University at New Orleans is 17 percent.

    Students rom Central State are deaulting at a much higher than expected rate,

    while students rom Southern are deaulting at a lower than expected rate.

    This example shows how just two inputs can improve accountability metrics. I

    the ederal government releases data on other appropriate input variables, these

    calculations would provide a uller picture, one that better shows which schools

    are more successul at preparing students or lie ater college.

    Pairing Deault and Graduation Rates

    The 1990 Student Right-To-Know Act required colleges to report their graduation

    rates or frst-time, ull-time degree- or certifcate-seeking students. Deault rates

    are also a key piece o consumer inormation or college students. Chart 4 shows

    that graduation rates plus deault rates provide a clearer understanding o each

    schools outcomes.

    For example, Gettysburg College (Pennsylvania), St. Ola College (Minnesota), and

    Martin Methodist College (Tennessee) are all private, nonproft, our-year-and-above

    colleges with similar Carnegie Classifcations. All have an impressive graduation

    rate o 85 percent. However, Gettysburgs deault rate is 0.4 percent, and St. Olas

    is 1.6 percent. Yet Martin Methodists is 26.6 percent. (Keep in mind however,

    that ewer o Martin Methodists students borrow.) Students are well-advised to

    consider more than simply the graduation rate when choosing a college.

    Toward a Better Understanding o Deaults

    The ederal government has long played a vital role in education research. But too

    oten, the voluminous data the U.S. Department o Education collects ocuses on

    inputs (such as stafng levels, expenditures, and incoming student test scores)

    and stops well short o providing the kind o data that could provide answers to

    important public policy questions. This shortcoming applies especially to higher

    education, where many colleges remain stubbornly resistant to providing detailed

    inormation around outcomes, and the government has not required them to do

    otherwise.

    The U.S. Department o Education is now the sole originator o ederal student

    loans. Given the soaring costs o college, the still-ragile job market, and rising

    rates o college loan deaults, the ederal government should oer better data or

    analysis and research to reveal which types o students, in what felds and degree

    programs, are most likely to deault. The importance o this inormation is clear.

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    Yet, despite lending more than $100 billion annually, the government requires

    minimal standards or students to qualiy and leaves taxpayers on the hook or

    billions o dollars in deaults.

    This needs to change.

    Until we have better data on loan deaults, the ederal government will continue

    to lend billions to students every year with little to show students, taxpayers, or

    policymakers about what happens when those students have to pay back that

    money. Recent rule changes will let us know i these borrowers deault within the

    frst three years o repayment, but beyond that, each borrowers status will remain

    a mystery. Further, when deault rates improve as we emerge rom recession, they

    HART 4

    Deault Rates+ Graduation

    Rates = BetterDecisions.

    Source: Integrated Postsecondary Education Data System, Student Financial Aid, and authors calculations.

    1) Each dot represents a school a) with sufcient data, b) or which at least 100 students entered repayment inFY2009, and c) with at least 250 ull-time equivalent students in 2009 10.

    2) The red line indicates the best ft linear regression line.

    3) Graduation rates are the Student-Right-to-Know rates or 2009 10.

    4) There are several colleges (e.g. ITT Technical Institute) that report systemwide deault rates, but campus-specifcgraduation rates, which appear on the graph as a group o horizontally arrayed dots.

    Graduation Rate

    Three-YearDefaultRate

    0 20 40 60 80 100

    0

    10

    20

    30

    40

    50

    60

    70

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    may well mask shortcomings in certain degree programs that, even in a strong

    economy, represent poor career investments or students.

    At the same time, colleges that do a superior job o educating Pell students and

    have lower than expected deault rates will still have higher deault rates than other

    schools that enroll relatively ew Pell students. Better data would highlight thesecolleges accomplishments.

    We have seen how changes in ederal policy have led to markedly better outcomes

    data at the K12 level. The ederal government spends even more money on

    higher education, and postsecondary students assume more risk. With stakes this

    high, students and taxpayers need to know ar more about what they are getting

    themselves into. Improving deault-rate data would be a good place to start.

    Red Flags: When Default Rates TopGraduation Rates

    Exasperated fnancial aid expert Tim Ranzetta proposed that

    some colleges post this disclosure:

    WARNING: This education can be hazardous to your fnancial

    health. At this institution, you have a higher probability o deaulting

    on your student loan than you do o completing this program.5

    These colleges should set o a red ag in the minds o prospective student

    borrowersand their parents. Many students at these colleges will no doubt

    take out loans, graduate, and get good jobs. But the high deault rates and

    lower graduation rates suggest that many students will not.

    Comparing graduation rates and deault rates or the same students would

    produce a list o these red ag colleges. But the U.S. Department o Education

    does not have that list, and the data it releases doesnt allow others to easily

    put one together. Instead, graduation rates are tracked only or frst-time,

    ull-time degree- or certifcate-seeking students (ignoring part-time, returning,and transer students); deault rates are tracked or students based on the

    time period when they enter repayment.6 In addition, campuses with several

    branches (such as the University o Phoenix) oten have one systemwide deault

    rate and branch-by-branch graduation rates.

    Nevertheless, using the ofcial graduation and deault rates as the best

    estimate o the overall graduation and deault rates or college borrowers, we

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    can identiy the schools that are the most likely candidates to set o red ags.

    These are colleges where students who borrow are more likely to deault on

    those loans than they are to graduate. For example, New River Community

    and Technical College in West Virginia has a graduation rate o 5 percent and a

    deault rate o 25.7 percent.7 It is not alone.

    O the 514 red ag colleges identifed, 314 (61 percent) are public, two-year

    colleges. While these schools tend to have low tuitions, they oten serve

    at-risk students. Among our-year colleges, the list included 100 or-profts, 48

    nonprofts, and 29 public colleges.

    Red Flag Colleges

    OfcialDeault Rate >

    OfcialGraduation

    Ratea

    OfcialDeault Rate >

    OfcialGraduation Rate

    & at least30% o Students

    Borrowb

    OfcialDeault Rate >

    OfcialGraduation Rate

    & at least100 Students

    Deaultedc

    AdjustedDeault Rate >

    OfcialGraduation

    Rated

    Sector

    Private or-proft2-year

    19 19 16 12

    Private or-proft4-year or above

    100 97 96 64

    Private nonproft4-year or above

    48 36 33 18

    Public2-year 314 88 188 18

    Public4-year orabove

    29 22 24 6

    Other 4 3 2 2

    Total 514 265 359 120

    Source: Integrated Postsecondary Education Data System, Student Financial Aid, and authors calculations.

    Notes: This table includes every college with a) sufcient data, b) or which at least 100 students enteredrepayment in FY2009, and c) with at least 250 ull-time equivalent students in 2009 10. There are several

    colleges that report systemwide deault rates, but campus-specifc student characteristics. Each campus witha lower graduation rate than the systemwide deault rate was counted as a separate college. We also excludedroughly 100 colleges whose Ofce o Postsecondary Education identifcation number (OPEID) could not be

    matched to an OPEID number in the deault rate database.

    a) The ofcial graduation rate is or 2009 10. The ofcial deault rate is the three-year rate or all students whoentered repayment between Oct. 1, 2008 and Sept. 30, 2009.

    b) The ofcial graduation rate is or 2009 10. The ofcial deault rate is the three-year rate or all students who

    entered repayment between Oct. 1, 2008 and Sept. 30, 2009. The percentage o students who borrow is defnedas the percent o undergraduate students who took out a ederal loan in 2009 10.

    c) The ofcial graduation rate is or 2009 10. The ofcial deault rate is the three-year rate or all students who

    entered repayment between Oct. 1, 2008 and Sept. 30, 2009. The number o students who deaulted is rom theStudent Financial Aid database.

    d) The adjusted deault rate is the colleges three-year deault rate or all students who entered repayment

    between Oct. 1, 2008 and Sept. 30, 2009 multiplied by the percentage o undergraduate students who took outederal loans in 2009 10.

    ABLE 1

    Hundreds o

    colleges shouldset o red fagsor borrowers.

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    Among these colleges, there is considerable variation in the percentage o

    students borrowing, so the second column in Table 1 shows only those

    colleges where at least 30 percent o undergraduate students took out ederal

    loans. The number o colleges drops to 265, o which 97 are or-proft, our-year

    colleges; 36 are nonproft, our-year colleges; 88 are public, two-year colleges;and 22 are public, our-year colleges.

    The third column in Table 1 shows only those colleges where the absolute

    number o students who deaulted is at least 100. The result is a new list o

    359 colleges. Most o the change in the list occurs among 188 public,

    two-year colleges.

    The last column o Table 1 provides a fnal alternative list. Multiplying the

    deault rate by the percentage o undergraduate students who took out

    ederal loans yields an adjusted deault rate. This new rate estimates the

    prevalence o deault among the whole student body rather than just among

    borrowers. For example, Los Angeles City College, Blue Ridge Community

    and Technical College (West Virginia), and Lane Community College (Oregon)

    are all public, two-year community colleges with an ofcial deault rate o 19.5

    percent, indicating that borrowers at all three schools have a similar likelihood

    o deaulting. But there is considerable variation in the percentage o students

    who borrow. Only 4 percent o Los Angeles City Colleges students took out a

    ederal loan in 2009 10, but 33 percent o Blue Ridge students and 65 percent

    o Lane students did. Using this inormation to calculate an adjusted deault rate

    that applies to all studentsas opposed to just borrowersestimates that lessthan 1 percent o all students at Los Angeles City College deaulted on their

    student loans, 6.4 percent o Blue Ridge students deaulted, and 12.7 percent

    o Lane Community Colleges students deaulted.

    O the 120 red ag colleges using the adjusted rate, more than hal (64) are

    our-year, or profts. There are 18 public community colleges and 6 public,

    our-year universities.

    Table 1 makes two main points. First, some student loan borrowers are

    attending colleges where it appears that they are more likely to deault than

    they are to receive a degree. Second, red ags will pop up across all types o

    schoolspublic, private nonproft, and private or-proft.

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    ABOUT THE AUTHOR

    Andrew Gillen is the research director at Education Sector. He can be reached [email protected] .

    ACKNOWLEDGMENTS

    Id like to thank all those who oered invaluable eedback. Susan Headden and Carol Knopes spent

    many hours helping improve this report. Any remaining errors or omissions are my own.

    ABOUT EDUCATION SECTOR

    Education Sector is an independent think tank that challenges conventional thinking in education policy.

    We are a nonproft, nonpartisan organization committed to achieving measurable impact in education, both

    by improving existing reorm initiatives and by developing new, innovative solutions to our nations most

    pressing education problems.

    Notes

    1. U.S. Department o Education, Three-year Ofcial Cohort Deault

    Rates or Schools, available at http://www2.ed.gov/ofces/OSFAP/

    deaultmanagement/cdr.html

    2. Prior to 2012, the two-year deault rate was reported.

    3. Details on the sanctions tied to deault rates can be ound at

    http://iap.ed.gov/DeaultManagement/guide/attachments/

    CDRGuideCh2Pt4CDREects.pd

    4. The line used or accountabi lity purposes should take into account the

    confdence intervals or the predicted deault rates.

    5. Tim Ranzetta, Warning: This Education Could Be Hazardous To Your

    Financial Health, Student Lending Analytics Blog, October 18, 2009. http://

    studentlendinganalytics.typepad.com/student_lending_analytics/2009/10/warning-this-education-can-be-hazardous-to-your-fnancial-health.html

    6. The graduation rate used in this study is the Student Right-To-Know rate or

    2009 10. The three-year deault rates used in this study are or those students

    who entered repayment in fscal year 2009 (between Oct. 1, 2008 and Sept.

    30, 2009).

    7. This graduation rate is rom the U.S. Department o Educations Integrated

    Postsecondary Education Data System (IPEDS). The deault rate is rom the

    U.S. Department o Educations Student Financial Aid database.

    http://www.educationsector.org/mailto:agillen%40educationsector.org?subject=http://www2.ed.gov/offices/OSFAP/defaultmanagement/cdr.htmlhttp://www2.ed.gov/offices/OSFAP/defaultmanagement/cdr.htmlhttp://ifap.ed.gov/DefaultManagement/guide/attachments/CDRGuideCh2Pt4CDREffects.pdfhttp://ifap.ed.gov/DefaultManagement/guide/attachments/CDRGuideCh2Pt4CDREffects.pdfhttp://studentlendinganalytics.typepad.com/student_lending_analytics/2009/10/warning-this-education-can-be-hazardous-to-your-financial-health.htmlhttp://studentlendinganalytics.typepad.com/student_lending_analytics/2009/10/warning-this-education-can-be-hazardous-to-your-financial-health.htmlhttp://studentlendinganalytics.typepad.com/student_lending_analytics/2009/10/warning-this-education-can-be-hazardous-to-your-financial-health.htmlhttp://studentlendinganalytics.typepad.com/student_lending_analytics/2009/10/warning-this-education-can-be-hazardous-to-your-financial-health.htmlhttp://studentlendinganalytics.typepad.com/student_lending_analytics/2009/10/warning-this-education-can-be-hazardous-to-your-financial-health.htmlhttp://studentlendinganalytics.typepad.com/student_lending_analytics/2009/10/warning-this-education-can-be-hazardous-to-your-financial-health.htmlhttp://ifap.ed.gov/DefaultManagement/guide/attachments/CDRGuideCh2Pt4CDREffects.pdfhttp://ifap.ed.gov/DefaultManagement/guide/attachments/CDRGuideCh2Pt4CDREffects.pdfhttp://www2.ed.gov/offices/OSFAP/defaultmanagement/cdr.htmlhttp://www2.ed.gov/offices/OSFAP/defaultmanagement/cdr.htmlmailto:agillen%40educationsector.org?subject=http://www.educationsector.org/