TICAS Comments on Topics for Negotiated Rulemaking
Comments in response to the September 3, 2014 Federal Register notice soliciting input on topics to be included in the U.S. Department of Education’s upcoming negotiated rulemaking. Key recommendations include: increasing access, targeting, simplicity, and fairness in the Pay as You Earn federal student loan repayment plan; preventing cohort default rate and 90/10 rule manipulation; increasing the efficacy of Participation Rate Index appeals by colleges with low borrowing rates; and ensuring that loans are discharged for defrauded students.
