Archive | September, 2017

Proposal Seven: Providing Information to Consumers on University Value

27 Sep

Proposal Seven: Rank Universities on Basis of Costs Quality, Graduation Rate and Income of Alumni


In 2013, President Obama announced plans to create a federal rating system that would allow parents and students to easily compare colleges. He also planned to encourage Congress to pass legislation to link student aid to the rating system. President Obama’s proposal was bitterly opposed by college presidents.

On September 12, 2015, the Obama Administration abandoned its proposal to rank colleges let alone tie the ranking of the colleges to student aid and simultaneously introduced a web site providing raw statistics on university performance including
information on annual costs, graduation rates, and salaries after graduation.

Readings on the Obama Era Efforts:

New York Times Article on Announcement by President Obama on plan to rank colleges on results and costs and link financial aid to the college rankings

New York Times Article on Reaction to College Rating Proposal by University Presidents:

Ner York Times article on Obama Abandoning Plan to Rank College

A Discussion of the College Score Card web site:

The web site

introduced by the Obama Administration to provide information on the cost and value of colleges has some interesting raw data and a lot of limitations. The information on this web site for each school includes – average annual cost, graduation rate, salary 10 years after attending school, percent of students receiving guaranteed loans, typical loan amount for student borrowers who finished the program, percent of graduates who earn more than a high school graduate, SAT and ACT scores, demographics of students, and type of programs.


• The debt totals excluded private student loans and PLUS loans. The site also does not have separate information on percent of student using private loans and PLUS loans for each school.   These loans often are cause financial hardship for borrowers. The use of these loans is likely to widely vary across schools. The omission of information on private loans and PLUS loans will have a substantial impact on financial risk measures across schools.

• The ScoreCard software only reports median debt levels by student borrowers at a school.   It is likely the dispersion of debt levels is higher for some schools than for other schools.   It would be interesting to know the percent of borrowers with debt levels exceeding certain amounts ($50,000 or $75,000) at each school or debt levels at the 90th percentile for each school. These alternative statistics are a better measure of the likelihood a student attending a school borrows too much.

• The repayment statistic in the database — the share of students who paid back at least one dollar on their student loan three years after leaving school — is not particularly useful.  Initial repayment rates could be low at a school where many alumni go to graduate school.   The default rate, delinquency rate, and the proportion of students not in graduate school who are on target to finish payment on their student loans in 10 years are all more useful measures of repayment difficulty.

• The benchmarks in the database based on national averages are not particularly useful. Common sense suggests that the College Score Card cannot be used to compare the value of a state university to the value of an elite private institution.   The difference in post-graduate earnings is likely largely determined by the difference in the talent as measured by SAT score of the student body.  The difference in debt is likely determined by the price tag and the amount of available aid.  A ranking that found Harvard University graduates earned more than students from Ohio State but owed more at graduation would not provide new news. However, universities in the same category (highly selective, moderately selective, not selective) could and should be compared with universities in the same category.

Concluding Thoughts:  President Obama’s proposal to rank colleges based on their costs and the value they give their students was slammed by university presidents who proved they have a lot in common with executives running tobacco firms or leaders in the financial services industry opposing regulation after collapsing the financial system. Statistical analysis can and should be used to compare similarly situated universities and statistical information should also be used to guide the allocation of resources.


Proposal Six: Improving On-time Graduation Rates

26 Sep

Policies to Improve On-Time Graduation Rates

Many people incur a large amount of college debt because they spend more than four years in college. Only 50 of the more than 580 public four-year colleges have four-year graduation rates over 50 percent according to a USA Today article.
Breaking the 4-year myth: Why students are taking longer to graduate

At four year-public schools the average cumulative debt is around $27,000 for people who take six years to graduate, around $21,000 for people who take four years to graduate, and around $20,000 for people who graduate in three years. These figures do not include PLUS loans for parents. The article below has a more detailed discussion on how the amount of time it takes students to graduate impacts debt accumulated in college.
The importance of finishing college on time:

The issue of on-time graduation is intrinsically related to the issue of the quality of K-12 education, which is beyond the scope of the current memo. This post describes three narrower policies — (1) programs which improve AP exam pass rates, (2) guarantees of college credit for people who take and pass AP exams, and (3) funding for computer science and language camps and colleges prior to college.

Improving AP Exam Pass Rates:

The post below analyzed grades from the 20 most popular AP exams taken in 2016. The data covered results from over 4 million tests.

• The average grade was below a C on 14 out of 20 of the most popular AP exams.

• Around 1.9 million out of the 4.4 million test results were a D or F.

Policies which might improve AP Exam Performance

• Provide funds for students to take on-line or private taught AP exams in schools with low AP exam pass rates.

• Increase in-school AP course time for students taking AP exams. For example, people taking AP exams could have both the regular AP exam course and a second course emphasizing extra readings, labs and/or practice tests. (It may be possible to fund the second course with non-profit funds.)

• Change the content of some AP exams to cover a semester of college content rather than a full year of college content. (This was recently done with the AP Physics tests.)

• Create software that will evaluate AP exam workloads and provide advice on AP schedule, which could increase pass rates. (One goal of the software is to predict which people are likely to fail multiple AP exams and provide appropriate guidance.)

Guarantee the Award of College Credit for Students Passing AP Exams at Any School with Students Using Guaranteed Student Loans

Some major colleges have stopped or restricted awarding college credit to students in some or all AP courses.

This policy change will result in some students taking out thousands more dollars in student debt and losing substantial wage income.

Many states have passed laws requiring public universities and colleges give some credit to students passing AP exams. There are no such restrictions on private universities.

Students at virtually all private universities and colleges take out federally guaranteed student loans. Private schools denying AP credit to students passing AP exams often causes students to incur more federally-backed debt. The government should regulate credit awards when it impacts the financial exposure of students and taxpayers, guaranteeing debt.

Note: The faculty in the university of Pennsylvania chemistry and biology department found that some students who skipped the introductory courses fared worse than students who took the introductory course on upper level courses. The faculty did not publish a paper documenting the extent and the significance level of the future performance differential. Such a paper would also determine whether students with an extremely high grade on the AP exam performed worse in upper level courses if they skipped the introductory level.

The issue of lower performance on upper-level chemistry and biology courses for people who place out should not prevent the school from giving people who passed AP exams with a grade of 4 or a grade of 5 s credits. The faculty should be able to fix performance issues in upper level course by adding some review material or by creating a one credit problem solving class.

The issue as I see it is that the faculty at Penn would rather their students take on thousands (perhaps tens of thousands) of dollars in additional debt and forego a year of wage income rather than do a little bit of work and figure out how to more efficiently transmit their valuable knowledge. The article on college debt including a quote from a Penn faculty member stating that college students would prefer a fifth year of college rather than graduate early. This preference is not surprising. College is fun and students don’t consider the full costs of repaying their loans or the cost of loan forgiveness to taxpayers. The Penn faculty should be more focused on the long term economic needs of their students rather than their short-term fun.

Expand resources for teaching of computer science and language prior to college:

In general, most school districts are focused on teaching the basic subjects – math, history, English and the sciences.

There is a shortage of students ready to enter STEM fields and in students trained in certain languages. In 2015, fewer than 60,000 people graduated with a bachelor degree in computer science. Relatively few high schools offer computer courses. Computer science is not generally a required subject. There is a shortage of qualified language teachers in many schools

There are two ways to improve education of computer science and language.

• Allow private firms to teach these schools in public and charter schools to take advantage of economies of scale. (This approach would improve outcomes at schools with modest budgets, which are struggling to fund basic subjects.)

• Fund scholarships at summer camps specializing in language and computer science. (This approach helps students at lower and middle income students who cannot currently afford expensive camp-based educational programs outside of school.)

The Trump Administration with the support of major tech companies are moving to support STEM education efforts outside the class room.

Concluding Remarks: One reason some student borrowers incur too much debt is that they fail to graduate on time. Policies that improve on-time graduation rates will reduce college debt.

Some colleges do a better job in educating students, helping students find a job and having students graduate on time than other colleges. Students and their parents need information on college quality and educational outcome prior to selecting a college. The last essay describes rules requiring colleges provide additional information to students and parents.

Proposal Seven: Improving Information for Consumers of Education

Proposal Five: Potential Changes to Bankruptcy Laws

25 Sep

Impact of Bankruptcy Law on Student Debt

Background: The discharge of government guaranteed or issued student debt has always been extremely difficult and rare. Most courts require that the borrower show a “certainty of hopelessness” for his or her financial situation over the repayment term of the loan. An August 31, 2012, New York Times article describing the petition of a legally blind, unemployed man illustrated the hurdles a student loan borrower must clear in order to have student debt discharged in bankruptcy.

The enactment of the 2005 bankruptcy reform law severely reduced rights of all debtors in bankruptcy. The most documented aspect of the new law was to make it much more difficult for debtors to obtain a chapter 7 bankruptcy and immediately get unsecured loans discharged. Other procedures imposed additional hardships on people with student debt.

Prior to the enactment of the 2005 bankruptcy law private student loans were dischargeable in bankruptcy. The 2005 bankruptcy law changed this rule and made it very difficult to discharge private student loans in bankruptcy.

Note the discharge of private student loans in bankruptcy does not adversely impact taxpayers. In fact, the discharge of private student loans in bankruptcy should free funds for debtors and accelerate the repayment of guaranteed student loans in bankruptcy.

Financial outcomes of borrowers in bankruptcy are also affected by the rules governing whether a debtor can obtain a Chapter 7 bankruptcy or a Chapter 13 bankruptcy.

Student debts are not forgiven in chapter 7. Student debt does not generally have priority over consumer debt in most Chapter 13 repayment plans. Student loan borrowers in Chapter 13 can petition the bankruptcy court to allocate a greater amount of their payment plan to the repayment of student loans and a lower amount to the repayment of other unsecured credit card debt. However, most courts tend to favor a payment plan that does not discriminate against any class of unsecured creditors. As a result, many student loan debtors emerge from the bankruptcy process five years older with a substantial amount of unpaid student loans. Many individuals experience decreases in income and have fewer job prospects after age 50. A delay in repayment of student loans caused by a forced entry into a Chapter 7 bankruptcy plan will increase financial exposure to taxpayers, increase student loan default rates, and decrease collection rates.

Potential changes to the bankruptcy code that would benefit over-extended student borrowers:

There are four potential changes to bankruptcy law, which could assist over-extended student borrowers.

First, the law could be modified to make it easier for debtors to obtain immediate debt relief under chapter 7 rather than file a payment plan under chapter 13. The immediate discharge of consumer would free up funds that could be used for the repayment of student debt. However, the borrower after leaving bankruptcy could incur new debt and forego student loan payments.

Second, the rules governing payment plans in chapter 13 could be modified to give student deb priority over consumer loans. A revision of Chapter 13 bankruptcy rules that gives priority to student debt payments over other unsecured debt payments in bankruptcy would provide student loan debtors with a fresh financial start and would ultimately reduce taxpayer losses. Unsecured creditors would still enjoy greater collection rights than existed prior to the 2005 bankruptcy law. This change would also benefit taxpayers guaranteeing student debt repayment,

Third, bankruptcy law should be changed so that private student loans are dischargeable in bankruptcy. Many private student loans have high interest rates and have more in common with consumer debt than traditional student loans. The restriction on the discharging of private student debt in bankruptcy does not provide clear direct benefits to taxpayers.

Fourth, whether a private student loan is dischargeable or not in bankruptcy could become contingent on the characteristics of the loan. Many private student loans have characteristics closer to high-risk high-fee consumer debt than they do with government guaranteed student debt. Private student loans with high fees and high rates should be classified as consumer debt not student loans for their treatment in bankruptcy. Moreover, unless private student loans can be consolidated in the IBR program they should not be dischargeable in bankruptcy.

Concluding Thoughts: The 2005 bankruptcy law imposed substantial hardships on many households. It was enacted shortly before the collapse of the housing market and financial systems. The law, by reducing forgiveness of student debt caused many borrowers to default on their mortgage.

Today the lack of relief on consumer loans in bankruptcy, the treatment of private student loans in bankruptcy, and the rules governing chapter 13 repayment plans have made it more difficult for borrowers to repay student debt.

The changes to the bankruptcy code would benefit both student debtors and taxpayers, guaranteeing student debt.

Next Up: Debt relief is a last resort. We all prefer to lower the amount of debt incurred. Students who graduate on time incur less debt. The next post discusses policies to improve on-time graduation rates.

Proposal Six: Improving On-Time Graduation Rates

Proposal Four: Interest Rate Reductions on Student Loans After Several Years of Payments

25 Sep

Proposal Four: Interest Rate Reductions on Student Loans After Several Years of Payments

The previous post concluded that IBR loan programs will likely prove ineffective at providing debt relief. First, many people who are initially good candidates for the IBR program end up paying more on their loans when their financial status and marital status change. Second, burdensome annual qualification process means very few people will eventually receive loan forgiveness.

Proposal four is a potential improvement over IBR.

Proposal Four: Reduce or eliminate interest on student loans after 12 years of scheduled payments. The loan agreement would also allow for more years of partial negative amortization of interest when the borrower’s income was low. However, the loan agreement would not allow for forgiveness of principal.

Comments on this Proposal:

The elimination of interest rates after 12 years reduces lifetime interest costs for all people where the loan maturity is greater than 12 years. However, people with a loan maturity of less than 12 years (10 years is standard) will pay less in interest than people with longer maturities.

Delinquent borrowers would be reported to credit bureaus, penalties could be applied to overdue accounts, and overdue accounts would be handled by collection agencies, even after the interest rate was reduced or eliminated.

The lower interest rate on this loan after 12 years could be coupled with a shortening of the loan’s amortization schedule. The more affordable payment could result in the government being repaid quicker than otherwise. In one example, the elimination of interest after 20 years reduces the annual interest rate from 4 percent to 3.53 percent while reducing loan maturity from 20 years to 18.8 years.

Cash flows to the lender under the interest rate reduction proposal are more predictable than cash flows under the IBR program. As a result, it may be easier to securitize student loans with an interest rate reduction provision than IBR loans.

Concluding Remark: I believe that lenders and many borrowers will be better off under a proposal which eliminates interest rates after12 years than under IBR. This proposal targets people with demonstrated need without creating an incentive for people to over borrow. However, this proposal will not provide enough debt relief for borrowers in extreme difficult. These borrowers could benefit from modifications to the bankruptcy code, which currently favors creditors over both debtors and lenders.

Proposal Five: Potential Changes in Bankruptcy Law

Proposals Three: Reforming Income Based Replacement Loans

24 Sep

Reforming Income Based Replacement Loans

Three types of policies income driven student loan programs, public service loan programs, and bankruptcy laws and procedures impact the ability of over-extended borrowers to obtain debt relief. This section looks at income driven loan programs and public service loan programs. We describe the program and discuss potential modifications.

Background on Income Driven Loan Programs:

Income driven loan programs tie monthly loan payments to annual income and offer loan forgiveness after several years. The Federal government offers at least four different income-driven loan plans — the revised pay as you earn repayment plan (REPAYE Plan), the Pay as you earn Repayment Plan (PAYE), the Income Based Repayment Plan (IBR plan) and the Income Contingent Repayment Plan (ICR Plan).

The terms and conditions of each of these plans differ and sometimes vary across date of enrollment. The largest income contingent plan is the IBR program. The IBR plan was favored by President Obama. President Trump has proposed consolidating all income driven loan programs into a modified IBR program. His alterations involve higher monthly payments and shortening the period before students receive loan forgiveness.

Description of IBR program:  The primary objective of the IBR program is to help student borrowers avoid defaulting on their loans when their household income is low.  This is accomplished by linking student debt to household income.

The second most important objective of the IBR program is potential loan forgiveness. Any outstanding balance on the IBR loan could be forgiven 20 or 25 years after enrollment, depending on the enrollment date. However, to obtain loan forgiveness the person must remain in the program for the entire period.

Under the IBR program, the required student loan payment is $0 when household income is less than 150% of the federal poverty line.  When household income is more than 150% of the federal poverty line, the IBR payment is the minimum of 10% of disposable income or the standard payment on a 10 year-student loan. (Disposable income is defined as household income minus 150% of the federal poverty line.)  Individuals with family income exceeding 10% of disposable income will make the standard payment for a 10-year loan.

Other important features of the IBR program include:

Government payments of monthly interest for up to three consecutive years if the IBR payment does not cover monthly interest under the 10-year repayment plan,

No capitalization of interest when income is less than 15% of disposable income,

Facilitation of eligibility for public loan forgiveness for student borrowers employed by public service organizations.

There are many limitations to the IBR program:

Under the program, it takes 25 years to get debt forgiven.

The Department of Treasury has ruled that any debt relief would be taxed at ordinary tax rates.

Under the IBR program borrowers must apply to their service annually for payment adjustments. The Consumer Finance Protection Board has reported that services often put obstacles in the path of borrowers applying to the IBR program.

These road blocks to annual enrollments will prevent many borrowers from ever getting any IBR debt relief.

The IBR program is of limited use to many households. The debt relief is based on household income, including income for both the student borrower and the income for the spouse. A decision to enter the IBR program made when a person is single may lead to higher payments after marriage. Married household must file separate returns to take full advantage of the IBR program. (Separate returns tend to result in higher tax payments than joint returns.)

Neither private student loans nor PlUS loans for parents can be included in an IBR loan.

One of the problems with IBR cited by lenders is that IBR will allow some borrowers to increase the amount they borrow without increasing their ultimate or expected payment obligation. The payment rules will cause some borrowers to increase the amount they borrow.

Potential Modifications to the IBR Program:

• Make it easier for student borrowers to enroll in the program. This would require clear rules and procedures requiring loan servicers to enroll applicants into the IBR program. Moreover, regulators would need to enforce these rules.

Currently the Trump Administration is moving in the opposite direction by rescinding rules covering the proper servicing of loans.

See this article for a discussion of Trump Administration IBR policies:

• Allow student borrowers to include all PLUS loans and all private student loans in the IBR loan program. This provision is especially important because the use of PLUS loans and private loans have both risen in recent decades. The use of PLUS loans and co-signed private loans have both contributed to the increase in number of older Americans with student debt obligations. The percent of borrowers in the lower income quartile with a PLUS loan has gone from 2.96% in 1996 to 6.22% in 2022.

• Allow married couples participating in the IBR loan program to file joint tax returns.

• Donald Trump as a candidate for president called for two modifications of the IBR program – (1) an increase in annual repayments and (2) forgiveness after 15 years rather than 20 years. No actions towards implementing these proposals have been taken.

Next I address public service loan programs, which are facilitated by the IBR program.

Background on Public Service Loan Programs: Public service loan programs started in 2007 are designed to provide loan forgiveness to people who work at public service jobs and make 120 consecutive payments on their loan. The loan program is designed to help people with public service jobs in the IBR program obtain debt forgiveness after 10 years.


The Trump Administration has proposed ending the public service loan program. I am a bit mystified as to why the Trump Administration would target this relatively small program.

The program began in October 20007; hence, no one would have received loan forgiveness until 2017. As a result, as of this date 9/25/2017 there is no data on the number of people who have had their loans forgiven under the public service loan program or have had their assistance blocked by the Trump Administration.

I don’t believe many people are going to have their loans forgiven under this program. First, many people will switch from a public service job to some other position in the ten-year period. Second, late payments could make a person ineligible for loan forgiveness. Third, periods of loan forbearance could make a person ineligible for loan forgiveness. Fourth, (and possibly most importantly) people who do not enter and remain in the IBR program may lose eligibility for the loan forgiveness.

A Potential Modification:

I understand that society gains when people take public service jobs but I don’t like the fact that this program ties a person into a public service job for 10 years. In some cases, a person may be happier and more productive elsewhere. It might be useful to give people in public service jobs a lower interest rate for a short period of time rather than loan forgiveness after 120 consecutive on-time payments in a public service position.

I am very skeptical that public service loan program will help many people. Show Me the Numbers!

Concluding Remarks: I am also skeptical that the IBR program will prove effective in providing debt relief to a lot of people. The IBR program was the signature student debt relief program of the Obama Administration. My view is relatively few people will eventually obtain loan forgiveness under the IBR program. First, loan servicers are making it extremely diffficult for many people to enroll in the program. Second, many debts, including many forms of student loans are not covered by IBR. Third, many households which initially appear to benefit from the IBR program will end up paying more on their student debt in the long term when their financial status or marital status changes.

Economists are concerned about some of the incentives created by the IBR program The IBR program will also cause some borrowers to increase the amount they borrow because there is a possibility they could borrow more without repaying more. A more appropriate debt relief formula would plan for a positive relationship between amount borrowed and amount repaid under all circumstances.

My alternative debt relief program will improve status of both lenders and borrowers compared to IBR.

Proposal Four: Delayed Interest Rate Reductions on Student Loans

Proposal Two: Improvements to Work Study and College Internships

23 Sep

Proposal Two: Improvements to Work Study and College internships

Funds for work study positions on campus should be increased. Additional funds should be allocated to subsidize internships at start-up firms. Student interns at federal agencies and departments should be paid at least a minimum wage.

Background on work study programs: Around 700,000 students per year receive federal work study positions, mostly in jobs on campus. Work study positions are disproportionately used at private four-year colleges. The use of work study has fallen by 25 percent in real inflation adjusted terms between 2000 and 2015.

Discussion on internship issues: Increasingly, internships are a necessary step towards a first job. Students from lower income households may not be able to afford to take an unpaid position. The percent of students taking unpaid internships to obtain job experience has risen substantially in recent decades. Many students taking unpaid internships rather than normal jobs end up incurring more college debt.

Private firms hire unpaid internships often find themselves in violation of state and federal minimum wage laws. Start-up firms often do not have the cash to pay interns salaries. The use of federal funds for work study positions at start-ups would enable these firms to hire interns.

One concern with unpaid and paid internships involves the possible displacement of full time hires. This concern is mitigated by limiting the duration of the internship to six months and by limiting eligibility to students enrolled in a university.

I don’t have much to say about this proposal except that government should lead by example. Budgets are always tight at federal agencies but believe me budgets are generally much tighter at start-up firms, which often find it difficult to take on unpaid interns due to minimum wage laws.

Next set of issues:
The next set of proposals involve providing debt relief to students who find themselves over-extended. Many conservatives have taken a really harsh view of debt relief and bankruptcy. I believe their approach is shortsighted because debt relief efforts can closely target people with the greatest need. Debt relief efforts can in some circumstances benefit taxpayers. Also, debt relief for the most vulnerable make austerity programs and budget cuts more humane.

I have three posts on debt relief, one on possible changes to the income based replacement plan, one on issues related to public service debt forgiveness programs, and the third on rules governing bankruptcy.

Proposal Three: Reforming Income Based Replacement Loan Program

Proposal One: Increased Financial Assistance for First-Year Students

23 Sep

Proposal One: Increased Financial Assistance for First-Year Students

The objective of this program is to eliminate or at least substantially reduce the amount of debt incurred by first-year students. Schools that wish to participate in this program would be required to match 25 percent of the federal contribution. The program would be open to all accredited private and public schools. Schools would be required to publish information on the percent of first-year students incurring debt along with information on the income of their student body.

There are three reasons why most increases in financial assistance should be targeted towards first-year students.

First, a program targeting financial aid for students entering their freshman year is the most effective way to encourage additional study and training for people who might otherwise be deterred because of financial risk.

Second, either the student borrower or the government must pay interest on student loans as soon as the loan is granted. As a result, debt incurred in the freshman year is more expensive to either the borrower or the government than debt incurred later in the student’s career.

Third, many students drop out of college early in their academic career and these students who leave college early in their career often have problems repaying their loans because they have lower starting salaries than those who stay in school. As a result, a reduction in student debt incurred during the freshman year should have a larger impact on student loan default and delinquency rates than a reduction in student debt incurred by upper class students or graduate students.

The proposal presented here is less ambitious than the ones offered by Bernie Sanders and Hillary Clinton.

It is also less administratively burdensome more fiscally responsible and fairer towards private universities.

Hillary Clinton’s proposal would provide grants for tuition assistance only in states that fund public universities at a high level. Her proposal also includes penalties for universities that fail to meet certain goals including reducing costs, earnings of graduates, and reduced tuition. These conditions are problematic because state differ in their resources and priorities. Moreover, this approach would favor state university systems that emphasized research over teaching.

This proposal requires schools to contribute 25 percent of the cost of grants to first-year students. Schools could reasonably choose to forego the grants if they did not want to contribute their share. Schools and states should be able to maintain this contribution level during economic down turns.

The proposal should require universities to publish information about the percent of students with debt after their first year of school. The federal government should provide information about how this statistic differs for different types of schools and is affected by other variables like the percent of students from lower income families.

The tuition assistance grants should be available for private as well as public institutions. Any accredited institution that is willing to contribute 25 percent of the cost of the grants should be eligible for the program. The Clinton or Sanders approaches would both have reduced enrollment at private schools. This approach might encourage more people to transfer from private to public schools after completion of their first year of college.

The second proposal involves the allocation of work-study funds for positions at private companies.

Proposal Two: Improvements to Work Study and College Internships