This week CGS submitted public comment regarding the Department of Education’s proposed changes to the Revised Pay As You Earn (REPAYE) plan. We state our concern about the discretionary income payment provision which requires graduate borrowers to pay ten percent of their discretionary income per month, while decreasing the discretionary income requirement for undergraduate borrowers to five percent. CGS is also concerned about the provision which requires graduate borrowers to repay their loans for 25-years before the cancellation of their remaining debt, as well as the unintended consequences these proposed changes may have on women and underrepresented minorities.
CGS also submitted public comment regarding the Department of Education’s Request for Information (RFI) Regarding Public Transparency for Low-Financial Value Postsecondary Programs. In the RFI, the Department of Education asks the public to provide suggestions, metrics and methodology that may be used to identify low-financial-value programs. In the CGS comment letter, we question if there is a set of metrics that captures the relevant information the Department of Education is seeking to use to identify low-financial value programs.