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This appendix discusses in detail our methodology for addressing two research questions for the Direct Loan program

by 홍반장 2015. 10. 24.

This appendix discusses in detail our methodology for addressing two

research questions for the Direct Loan program: (1) How does borrower

participation in Income-Based Repayment (IBR) and Pay As You Earn

(PAYE) compare to available estimates of eligibility, and to what extent

has the Department of Education (Education) taken steps to increase

borrower awareness of these plans? and (2) What is known about Public

Service Loan Forgiveness (PSLF) certification and eligibility, and to what

extent has Education taken steps to increase awareness of this program?

To address these questions, we used data from Education, the

Department of the Treasury (Treasury), the loan servicer that administers

PSLF for Education, and the Department of Labor’s Bureau of Labor

Statistics. We reviewed relevant federal laws, regulations, and

documentation from Education. We also conducted interviews with

officials from Education and three of its loan servicers, Treasury, and the

Bureau of Labor Statistics; representatives of higher education

associations; borrower advocacy groups; researchers; and a

nongeneralizable sample of Direct Loan borrowers.

Page 39 GAO-15-663 Federal Student Loans

1 We conducted this

performance audit from November 2013 to August 2015 in accordance

with generally accepted government auditing standards. Those standards

require that we plan and perform the audit to obtain sufficient, appropriate

evidence to provide a reasonable basis for our findings and conclusions

based on our audit objectives. We believe that the evidence obtained

provides a reasonable basis for our findings and conclusions based on

our audit objectives.

To examine participation and key characteristics of borrowers in IBR,

PAYE, and other repayment plans,2 we reviewed summary data from

Education’s National Student Loan Data System (NSLDS) on 19.3 million

Direct Loan borrowers

Page 40 GAO-15-663 Federal Student Loans

3

(excluding parent PLUS)4 who entered repayment

and had an outstanding loan balance as of September 2014. We chose

these parameters in order to get as close as possible to the eligibility

criteria for IBR and PAYE. To determine participation in IBR and PAYE,

we focused on data for 11.2 million borrowers in active repayment (not in

deferment, forbearance, or default). For borrowers with multiple loans, the

repayment plan was based on the most recent loan that either entered

repayment or was loaded into NSLDS. While borrowers with multiple

loans are able to participate in different repayment plans, we found that to

be the case for only 1 percent of borrowers in our analysis.

In addition, we reviewed available estimates of IBR eligibility from a

Treasury analysis of tax return data and Education’s student loan data for

a random sample of borrowers. These estimates, which are based on

September 2012 NSLDS data for borrowers who entered repayment in

2010 or earlier and Internal Revenue Service tax return data from 2010

and 2011, depending on the most recent available for each borrower, are

the most recent and only available estimates of IBR eligibility we

identified. We were not able to estimate eligibility using data from

Education because only borrowers who apply for income-driven

repayment plans are required to provide information on their income and

family size.

We also analyzed data from the Pennsylvania Higher Education

Assistance Agency, the loan servicer that administers PSLF for

Education, on 146,866 borrowers who voluntarily requested and had their

employment and loans certified for PSLF, as of September 22, 2014.

Page 41 GAO-15-663 Federal Student Loans

5

Specifically, we analyzed the number of certifications over time,

repayment plan participation, and available borrower characteristics (i.e.,

sector of employment, amount of student loan debt, and adjusted gross

income).6

To approximate the percentage of Direct Loan borrowers who may be

eligible for PSLF, we used 2012 Bureau of Labor Statistics data—the

most recent available.7 We calculated the percentage of workers

nationwide who were employed by federal, state, and local government

agencies and 501(c)(3) nonprofit organizations, and applied it to our

summary NSLDS data on 16.3 million Direct Loan borrowers (excluding

parent PLUS) who were in repayment, deferment, or forbearance as of

September 2014. We also applied this percentage to the sub-population

of these Direct Loan borrowers who were participating in IBR, PAYE, or

ICR, the repayment plans more likely to enable borrowers to benefit from

PSLF.

To examine how IBR, PAYE, and PSLF may affect total loan costs for

borrowers with various characteristics, we used summary data from

Education’s NSLDS, specifications from November 2014 for a calculator 

on Education’s website that allows borrowers to estimate loan payments,

and program requirements based on federal laws and regulations. We

developed repayment scenarios by assigning selected levels of adjusted

gross income and loan debt to a set of hypothetical borrowers to simulate

their total payments under IBR, PAYE, and 10-year Standard plans, and

under PSLF.

Page 42 GAO-15-663 Federal Student Loans

8

In each of our scenarios, we assumed:

· each borrower is single with no dependents;

· borrowers’ initial annual adjusted gross incomes will increase 5

percent annually, consistent with the assumption Education uses for

its loan calculator;

· the poverty threshold will increase at an average annual rate of 2.3

percent, which is based on the Congressional Budget Office’s inflation

rate projections from 2014 through 2024, and is consistent with the

assumption Education uses for its loan calculator;

· all loans have an interest rate of 6.8 percent, the rate for certain

borrowers with federal student loans disbursed from July 1, 2006

through June 30, 2013;

· all Direct Loans are subsidized. While borrowers may have a

combination of subsidized and unsubsidized loans, making this

assumption allowed us to show the effect of Education paying the first

3 years of interest if an IBR or PAYE borrower’s payments do not fully

cover the interest owed on a subsidized loan.9 This assumption

means we might understate total loan costs for IBR and PAYE

borrowers with unsubsidized loans whose payments do not fully cover

interest. Education’s loan calculator assumes that all Direct Loans are

unsubsidized and therefore does not account for this potential interest

benefit for IBR and PAYE borrowers with subsidized loans. Education

officials told us this assumption would have a slight effect on total loan

costs, and that the department plans to revise the calculator by

Changing the assumptions explained above would change the monthly

and total loan costs for borrowers in our scenarios. To the extent

possible, we validated our results against Education’s loan calculator and

worked with Education officials to resolve discrepancies. These scenarios

are intended for illustrative purposes only; they do not incorporate

experiences that could affect individual borrowers’ eligibility for incomedriven

repayment or their payment amounts. For example, individual

borrowers could experience periodic unemployment or job promotions,

and get married or form families. These and other experiences could

change income levels or household size, which help determine the

applicable poverty threshold for monthly income-based payments.

We determined that data from each of these sources were sufficiently

reliable for the purposes of this report by reviewing existing information

about the data and the systems that produced them, and by interviewing

knowledgeable agency officials.

To understand program terms and eligibility requirements, we reviewed

relevant federal laws, regulations, and documentation from Education. To

determine the extent to which Education has taken steps to raise

awareness of IBR, PAYE, and PSLF, we reviewed program information

Education makes available to borrowers on its website, including fact

sheets; a loan repayment calculator; and entrance, exit, and financial

awareness counseling tools. We also reviewed information about

Education’s targeted efforts to raise awareness of IBR and PAYE,

including documentation of borrower email campaigns and partnerships,

press releases, and memoranda from the President. We compared

information on Education’s efforts to criteria outlined in contract

requirements applicable to Education’s 11 Direct Loan servicers related to

communication with borrowers and the goals and objectives in the Office

of Federal Student Aid’s Fiscal Year 2012-2016 Strategic Plan.

To examine IBR and PAYE participation and eligibility, PSLF certification

and eligibility, and determine the extent to which Education has taken

steps to raise awareness of the programs, we interviewed officials from

Education, Treasury, and the Bureau of Labor Statistics. In addition, we

interviewed representatives of higher education associations, borrower

advocacy groups, and researchers about student loan repayment and

forgiveness, including factors that may affect borrowers’ decisions about

repayment. We also interviewed representatives of, and reviewed

documentation for, 3 of Education’s 11 loan servicers, which serviced 

about half of all recipients of loans owned by Education.

Page 44 GAO-15-663 Federal Student Loans

10 In addition,

during April and May 2015, we interviewed a nongeneralizable sample of

14 randomly selected borrowers about their awareness of income-driven

repayment plans. Using a random sample of Direct Loans from a 4-

percent random sample of loans from the NSLDS, we identified 4,000

borrowers who, as of January 2014, were in active repayment, deferment,

or forbearance. Education sent emails to these borrowers inviting them to

email us to participate in interviews.