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Saturday, March 29, 2025

CBO's Revised Student Loan Projections and FSA Operational Costs (Glen McGhee)

The Congressional Budget Office (CBO) has dramatically revised its projections for the federal student loan program, transforming what was once expected to be a profitable government investment into a significant fiscal liability. This report examines the details of these projection changes and analyzes the operational costs of the Federal Student Aid (FSA) program.

The CBO's updated budget projections released in 2024 reveal a stark shift in the expected financial performance of the federal student loan program. These projections represent a significant revision from earlier expectations and highlight growing concerns about the sustainability of current student lending policies.

According to the Committee for a Responsible Federal Budget (CRFB), the estimated federal cost of student loans issued between 2015 and 2024 has increased by $340 billion – transforming from a projected gain of $135 billion in the 2014 baseline to an expected loss of $205 billion in the 2024 baseline15. This represents a complete reversal in the financial outlook for the program over the past decade.

This dramatic shift is particularly evident when examining the changing projections for specific loan cohorts. In 2014, the CBO projected that taxpayers would generate an 11-cent profit for every dollar of student loans issued by the federal government in fiscal year 2024. However, the most recent projections indicate that taxpayers will instead incur a 20-cent loss per dollar of loans issued this fiscal year6.

Looking ahead, the situation appears even more concerning. Over the 2024-2034 budget window, the CBO expects federal student loans to cost taxpayers $393 billion1. This amount exceeds the $355 billion CBO expects to be spent on Pell Grants, the flagship college aid program for low-income students, over the same time period1.

The projected $393 billion cost includes several components:

$221 billion in losses on the $1.1 trillion in student loans the federal government will issue during this period
$140 billion in re-estimates of the losses taxpayers will bear on outstanding loans
$34 billion toward administering the student loan programs6

One particularly concerning aspect of the CBO projections is the growing cost of graduate student loans. These loans are expected to make up around half of new student loans originated in the current fiscal year11. The CBO projects that taxpayers will lose $102 billion on lending to graduate students over the coming decade11. According to the CRFB, graduate school loans are now nearly as subsidized as undergraduate loans and make up half of the cost of newly issued student loans15.

The dramatic increase in projected costs has several primary causes, as identified in the CBO reports and analyses by financial experts.

The primary catalyst for the growing losses is the expansion and increased utilization of income-driven repayment (IDR) plans6. While a borrower repaying loans under a traditional fixed-term repayment plan typically repays more than the initial amount borrowed, a typical borrower using an IDR plan will repay significantly less than the original loan amount6.

The CBO projects that taxpayers will lose between 30 and 48 cents for every dollar in federal student loans issued in fiscal year 2024 and repaid on an IDR plan1. Preston Cooper notes in his LinkedIn post that "the role of IDR plans in driving these costs can't be overstated. CBO generally expects taxpayers to profit on loans repaid through traditional fixed-term repayment plans. But loans repaid on IDR plans will incur losses ranging from 30 to 48 cents on the dollar"1.

The Biden administration's student loan forgiveness initiatives are cited as significant contributors to the growing cost of the program. The House Budget Committee press release states that "$140 billion or over a third of this cost directly stems from President Biden's student loan forgiveness schemes"7. These initiatives include changes to income-driven repayment plans to make them more generous1.

Beyond the projected losses on the loans themselves, the Federal Student Aid (FSA) program incurs significant operational costs to administer federal student aid programs.

According to FSA's 2024 annual report, the agency operated on an annual administrative budget of approximately $2.1 billion during FY 20244. As of September 30, 2024, FSA was staffed by 1,444 full-time employees who are primarily based in FSA's headquarters in Washington, DC, with additional staff in 10 regional offices throughout the country4.

The Department of Education's Salaries and Expenses Overview provides additional insight into how these administrative funds are allocated. The Student Aid Administration account consists of two primary components:

Salaries and Expenses
Servicing Activities

In the fiscal year 2020 budget request, for example, the Student Aid Administration account totaled $1,812,000,000, with $1,281,281,000 allocated for Salaries and Expenses and $530,719,000 for Servicing Activities5.

The latest CBO projections highlight a dramatic shift in the financial outlook for the federal student loan program. What was once projected to be a profitable government investment has transformed into a significant fiscal liability, with taxpayers expected to lose hundreds of billions of dollars over the next decade.

This transformation raises important questions about the sustainability of current policies and the potential need for reforms to address growing costs. The substantial operational budget of FSA ($2.1 billion annually) adds to the overall fiscal impact of federal student aid programs.

As policymakers consider the future of federal student aid, they will need to grapple with balancing access to higher education with fiscal responsibility and ensuring that federal resources are allocated efficiently and effectively.

Citations:

Friday, March 28, 2025

Higher Education Inquirer continues to follow IPO/sale of University of Phoenix

On March 6, 2025, Apollo and Vistria publicly announced a possible IPO or sale of the University of Phoenix. These companies have been trying to sell the University of Phoenix since 2021, but there have been no takers. The owners claim the school is worth $1.5B to $1.7B, but we (and experts we know) are skeptical, given the financials we have seen so far. The University of Phoenix was previously on sale for about $500M-$700M but the University of Arkansas System, the State of Idaho, and apparently other colleges declined the offers.

The University of Phoenix offers subprime education to folks, historically targeting servicemembers, veterans, and people of color. While some students may profit from these robocollege credentials, one wonders what these workers actually learn. The current student-teacher ratio at the University of Phoenix, according to the US Department of Education, is 132 to 1.

The University of Phoenix has faced a number of scandals, sometimes getting away with no penalty, and other times paying large fines.

In 2023 we made a Freedom of Action (FOIA) request to the US Department of Education (ED) to get Phoenix's most recent audited financials. In March 2025, more than 20 months later, we were provided with a 35-page report, audited by Deloitte, with numbers from 2021 and 2022.

HEI has filed a number of FOIAs with ED and discovered that almost 1 million former University of Phoenix students owe approximately $21.6 Billion in student loan debt. In addition, about 19,000 borrowers have had their student loans forgiven as a result of the Sweet v Cardona Borrower Defense to Repayment case. According to ED FOIA 23-02373-F, more than 73,000 have filed fraud claims against the school.

This month the Higher Education Inquirer followed up with a Freedom of Information request with the ED to obtain more up-to-date financial numbers for the University of Phoenix. We hope they will be responsive and timely enough to get the word out to the public.

Borrower Defense Case Goes to US Supreme Court. How will it decide?

On January 10, 2025, the U.S. Supreme Court granted the Department of Education’s petition for a writ of certiorari to review the U.S. Court of Appeals for the Fifth Circuit’s decision in Career Colleges and Schools of Texas v. Department of Education. The Fifth Circuit had preliminarily enjoined the 2022 Borrower Defense to Repayment (BDR) final rule on a nationwide basis. This rule, published on November 1, 2022 (87 Fed. Reg. 65,904), is a key component of the Biden administration’s broader student loan forgiveness efforts.

The Supreme Court’s review will focus on one pivotal question: whether the court of appeals erred in holding that the Higher Education Act does not permit the assessment of borrower defenses to repayment before default, in administrative proceedings, or on a group basis. Notably, the Court will not address the second question posed by the Department: whether the appeals court erred in ordering the district court to grant preliminary relief on a universal basis.

Background and Legal Battle

The lawsuit originated on February 28, 2023, when the Career Colleges and Schools of Texas (CCST) filed in the United States District Court for the Northern District of Texas. CCST sought to enjoin and vacate the 2022 BDR rule, arguing that it creates unlawful processes, serves no legitimate purpose under the Higher Education Act, and constitutes executive overreach by the Biden administration, violating the Department’s statutory authority and the Constitution’s separation of powers.

After the U.S. District Court for the Western District of Texas denied the preliminary injunction, CCST pursued an interlocutory appeal to the Fifth Circuit. On April 4, 2024, the Fifth Circuit overturned the lower court’s decision and, despite the Department’s objections, postponed the effective date of the 2022 BDR rule pending final judgment. The Department’s petition for rehearing was denied, prompting its appeal to the Supreme Court.

What’s at Stake

The Supreme Court’s decision will likely have significant consequences for both borrowers and institutions. If the Court rules against the Department of Education, it could severely limit the scope of borrower defense claims, especially on a group basis, making it harder for defrauded students to receive relief. For-profit colleges and other institutions might feel emboldened to challenge similar regulations and forgiveness measures.

A ruling in favor of the Department, while seemingly less likely given the Court’s conservative majority, would affirm the Biden administration’s approach to processing borrower defenses and may secure loan forgiveness for thousands of borrowers who attended predatory institutions.

The Political Dimension

The timing of this case is crucial. Just days before the Supreme Court granted certiorari, the Biden administration announced the cancellation of loans for 150,000 borrowers—most of which were through the borrower defense process. Shortly afterward, additional forgiveness for income-based repayment plan borrowers and individual borrower defense approvals was announced. However, the future of these forgiveness efforts remains uncertain, as the second Trump administration has signaled intentions to rollback or revise Biden’s loan forgiveness policies.

A Conservative Court’s Approach to Executive Power

Given the Supreme Court’s current composition and its recent track record in cases like West Virginia v. EPA, it seems likely that the justices will scrutinize the executive authority wielded in crafting the BDR rule. The conservative majority may favor a narrow interpretation of the Higher Education Act, signaling that large-scale forgiveness should come from Congress rather than executive agencies.

Conclusion

The Supreme Court’s ruling on the 2022 BDR rule will set a precedent that could define the future of student debt relief and the Department of Education’s authority. For borrowers hoping for widespread relief, the outcome could mean the difference between long-awaited forgiveness and a protracted legal battle. For institutions, particularly for-profits, a ruling against the Department could bolster their resistance to accountability measures.

Thursday, March 27, 2025

Potential Title IV Disruption Catastrophic (Glen McGhee)

Impact of Department of Education Dismantlement on Higher Education Act Programs

On March 20, 2025, President Trump signed an executive order to begin dismantling the Department of Education, a move that threatens to create significant upheaval across higher education's federal support system. While the order cannot immediately eliminate the department without congressional approval, it has already resulted in substantial workforce reductions and signals major changes ahead for the administration of federal education programs 1.

Title IV: The Most Vulnerable and Consequential Program

Among all eight titles of the Higher Education Act (HEA), Title IV federal student aid programs would create the most severe upheaval for the higher education sector if destabilized through the Department of Education's dismantling. Title IV represents the foundation of federal financial support for higher education, administering approximately $111.6 billion in financial assistance to 9.8 million students in FY202211. This massive program encompasses Pell Grants, federal student loans, and work-study opportunities that directly enable student access and persistence.

Financial Impact Scale

The sheer financial magnitude of Title IV makes its disruption particularly consequential. In 2021 alone, 10.5 million students received $125 billion in federal student aid through the Department of Education15. Title IV's Office of Federal Student Aid received the largest departmental budget allocation - over $68 billion, with $20 billion promised for distribution during 20254. This represents the largest financial relationship between the federal government and higher education institutions.

Enrollment Consequences Already Evident

Even small disruptions to Title IV administration have already demonstrated severe enrollment impacts. Recent problems with the Free Application for Federal Student Aid (FAFSA) system implementation led to measurable enrollment declines:

43% of private institutions reported smaller freshman classes
27% noted fewer financial aid recipients
18% reported decreased racial or ethnic diversity in incoming students2

These enrollment impacts disproportionately affect disadvantaged student populations. The FAFSA completion rates dropped nearly 10%, showing how administrative dysfunction can directly reduce educational access2.

Complex Regulatory Framework

Title IV administration involves an extraordinarily complex regulatory structure that would be challenging to transfer or maintain during a departmental transition. The program includes more than 300 pages of regulations, with significant compliance requirements for institutions6. Recent rule changes have created new financial responsibility, administrative capability and certification requirements applicable to institutions participating in Title IV programs7.

Presidential Assurances vs. Implementation Reality

While President Trump has indicated that essential functions like Pell Grants, Title I funding, and programs for students with disabilities would be "fully maintained and redistributed to various other agencies and departments," the implementation details remain unclear1 8. The executive order instructs Education Secretary Linda McMahon to "undertake all necessary actions to facilitate the dissolution" while ensuring continuous provision of services8.

However, the Department's workforce has already been reduced from over 4,000 to approximately 2,000 employees through layoffs and voluntary resignations1 4. This reduction in administrative capacity raises serious questions about the continuity of Title IV program implementation.

Other HEA Titles: Significant but Less Catastrophic Impact

While all HEA titles would face disruption through departmental dismantling, Title IV's combination of massive funding scale, direct impact on enrollments, and regulatory complexity makes its destabilization particularly consequential.

Other HEA titles, while important, would not create the same level of immediate financial and enrollment chaos:

Title I: Provides general provisions and administrative requirements, but lacks direct funding mechanisms
Title II: Supports teacher preparation programs, but with significantly smaller funding scales
Title III: Provides institutional aid for minority-serving institutions, representing important but more targeted support
Titles V-VIII: Offer specialized program support for specific institutional types or educational priorities

Conclusion

The dismantling of the Department of Education threatens all federal higher education programs, but Title IV student aid programs represent the most consequential area for potential upheaval. The scale of financial support, direct impact on enrollment and access, complexity of administration, and early evidence from FAFSA disruptions all indicate that Title IV destabilization would produce the most severe consequences for higher education institutions and students.

While the administration has promised to maintain essential functions, the mechanisms for doing so remain unclear, and the significant reduction in departmental workforce suggests potential administrative challenges ahead. The higher education community must closely monitor this transition to ensure that critical student financial support systems remain functional during this unprecedented departmental restructuring.

Citations:

Wednesday, March 26, 2025

A Planned Failure? The Dangerous Path to Privatizing Student Loans

In a move that has raised eyebrows across Washington and beyond, President Donald Trump recently announced a plan to transfer the U.S. Department of Education’s vast student loan portfolio—totaling a staggering $1.8 trillion—to the Small Business Administration (SBA). Ostensibly, the goal is to "reorganize" and streamline the management of federal student loans. But behind the curtain, some experts and insiders are questioning whether this bold move is merely the beginning of a much darker plan: privatization at the expense of millions of American borrowers.

The Alleged 'Rescue' of the Loan Portfolio

The White House has framed the transfer as a necessary step to relieve the Department of Education (ED) of a heavy burden, positioning the Small Business Administration as the new "caretaker" of the nation’s student debt. According to President Trump, the SBA—under the leadership of Kelly Loeffler—will now handle the $1.8 trillion student loan portfolio, while the Department of Education focuses on other key educational initiatives.

For some, the move seems like a fresh approach to a problem that has long plagued U.S. higher education: the overwhelming student debt crisis. However, a deeper look into the mechanics of the transfer suggests that this could be the first step toward a far more troubling goal: the dismantling of the federal student loan system and the privatization of debt, a shift that could harm millions of consumers in the process.

The SBA’s Inexperience with Student Loans

For starters, the SBA has no real experience with managing educational debt. Historically, the agency has focused on small business loans, a niche financial product entirely different from student loans. The SBA is not equipped to handle the complex structure of federal student loans, which include income-driven repayment plans, loan forgiveness programs, and myriad protections for borrowers struggling to repay their debt.

While the SBA does have experience guaranteeing loans, it has never managed a portfolio of this size or complexity. With the agency also facing a 43% workforce reduction, including 2,700 staff members, it seems highly unlikely that the SBA will be able to competently manage the student loan system—especially when 40% of these loans are already in default or behind on payments.

This raises an obvious question: is the SBA being set up to fail?

The Planned Failure

According to several former senior officials within the Department of Education and others close to the discussions, the transfer of the student loan portfolio to the SBA could very well be a deliberate failure. These sources suggest that the true purpose of the transfer is not to improve the system, but to destabilize it—creating a crisis that would ultimately justify selling off the loan portfolio to private companies. In other words, the apparent "failure" of the SBA to manage the loans could be the prelude to a much broader and more damaging shift.

“This is the classic playbook of the privatization agenda: create a crisis, then say the only solution is to sell off the asset to the private sector,” one former senior Education Department employee explained. “If the SBA fails to manage the portfolio, it will create a narrative that only the private sector can do it effectively, and that will pave the way for Wall Street to swoop in.”

This strategy mirrors similar efforts in other sectors, where privatization has often been sold as a solution to government inefficiency. In the case of student loans, the "failure" of the SBA to properly manage the portfolio could lead to a private sector takeover, where for-profit companies would be free to set the terms of repayment, charge higher interest rates, and strip away borrower protections—all at the expense of consumers.

The Consumer Cost

While the government may pocket the short-term profits from selling off the portfolio, it is borrowers who will feel the brunt of the consequences. Private companies, driven by the desire for profits, would have little incentive to offer the same borrower-friendly protections currently available under the federal student loan system.

The end of income-driven repayment options, the loss of loan forgiveness programs, and an end to the temporary moratorium on student loan payments could push millions of borrowers into even deeper financial distress. Higher interest rates, less favorable repayment terms, and a complete lack of support for struggling borrowers are all potential outcomes if the loans are sold to the private sector.

Moreover, the move could disproportionately affect low-income borrowers and those already in default, who would likely face harsher terms under a privatized system. For many, this could mean years—or even decades—of paying off debt that continues to balloon, with no hope of relief.

A Dangerous Precedent

If this plan succeeds, it will set a dangerous precedent. The government's involvement in student loans has, for decades, been a safety net for borrowers. The idea of privatizing this essential system could open the floodgates for more essential public services to be sold off to private corporations, with little regard for the public good.

“Once you give the private sector control over something as critical as education debt, it’s hard to see where it stops,” said another insider. “This is not just about student loans. It’s about how we view the role of government in providing public services.”

The Long-Term Fallout

In the long run, the privatization of student loans could exacerbate the country’s growing wealth inequality, widen the racial wealth gap, and place an insurmountable burden on future generations of borrowers. For many, student loans are not just a financial issue—they are a life issue, affecting everything from career prospects to the ability to buy a home or start a family. The sale of the loan portfolio could result in an economic landscape where the cost of education becomes a permanent burden on a generation, with few avenues for relief.

A Predatory Scheme?

The proposed transfer of the student loan portfolio to the SBA may appear to be an effort to reform the system, but closer inspection reveals a much darker agenda: one that seeks to create a crisis that will pave the way for the privatization of federal student loans. While the government may stand to gain in the short term, the long-term consequences for borrowers could be devastating.

In the end, the real price of this maneuver will be paid by consumers, who could face higher costs, fewer protections, and more financial instability. If this plan moves forward as expected, it will be a devastating blow to the millions of Americans who rely on the federal student loan system—a Pyrrhic victory that benefits private interests, but leaves consumers to bear the consequences.

In the quest for privatization, the true cost of this gamble may well be borne by those who can least afford it: the borrowers.

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