In January, the Department of Education published a request for information seeking public comments regarding how best to identify “low-financial-value” postsecondary programs.  In response, NAICU and 34 member associations of independent colleges, submitted comments to the Department regarding the Biden Administration’s plan to hold colleges and universities accountable for providing “financial value” to students.
 
NAICU’s comments acknowledge its shared concerns with the Department about student debt and affordability, while also raising questions about the Department’s proposed approach.  Specifically, NAICU’s comments address the following issues: 

• The limitations of quantitative financial metrics and the non-financial value of a higher education;
• The potential chilling effect a quantitative financial metric could have on first-generation college students;
• The potential effect a likely incomplete metric would have on programs that provide graduates who dedicate their lives to public service; and
• Factors beyond an institution’s control that affect student debt and earnings.

 The Department’s approach appears to be designed to ensure that the Administration’s proposed reduction in federal student loan costs to borrowers do not lead to increased borrowing. Under the Administration’s proposal, the Department is planning to: 

• Create a methodology that will identify low-financial-value programs;
• Publish a warning list regarding those programs to students who wish to borrow federal loans for those programs and require them to sign a form if they still wish to borrow for the program; and
• Request improvement plans from institutions with programs on the list.