Tertiary Education Report: Budget 2014 Suspending the student loan repayment threshold

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1 This document has been released under the Official Information Act 1982 (the Act). Some information has been withheld under section 9(2)(a) - to protect the privacy of natural persons, including deceased people. These sections are marked as [3]. Tertiary Education Report: Budget 2014 Suspending the student loan repayment threshold Date: 10 March 2014 Priority: Medium Security Level: Budget secret METIS No: Action Sought Addressee Action Sought Deadline Minister for Tertiary Education, Skills and Employment Minister of Revenue Enclosure: Yes In relation to progressing initiatives for Budget 2014: agree to suspend the CPI adjustment to the student loan repayment threshold either until 1 April 2016, 1 April 2017, or 1 April 2018 indicate whether student loan deductions should be made from income-tested benefits As above Round Robin: No 24 March Budget Ministers meeting 27 March final financial recs into CFIS net Contact for Telephone Discussion (if required) Name Position Telephone 1 st Contact John MacCormick Senior Policy Manager [3] [3] [3] [3] The following departments/agencies have seen this report: IRD MBIE MoE MFaT MoH MSD NZQA NZT&E TEC TPK Treasury Minister to Complete (please circle) 1 = very poor 2 = poor 3 = acceptable 4 = good 5 = very good Minister s Office to Complete: Approved Declined Comments: Noted Seen See Minister s Notes Needs change Overtaken by Events Withdrawn

2 10 March 2014 Tertiary Education Report: Budget Suspending the student loan repayment threshold Executive summary The Minister for Tertiary Education, Skills and Employment has directed officials to undertake further work on a Budget 2014 option to suspend Consumer Price Index (CPI) adjustments of the student loan repayment threshold until 1 April 2016 [METIS refers]. In 2011, Cabinet agreed to suspend CPI adjustments to the student loan repayment threshold (currently $19,084 p.a./$367 p.w.) until 1 April This report sets out options to continue holding the repayment threshold for one, two or three more years. Maintaining the repayment threshold would contribute to the financial sustainability of the Student Loan Scheme by reducing future lending costs. Table A sets out the operating savings available for reprioritisation under the three options: Table A: Financial impact of suspending the student loan repayment threshold Operating impact ($m) 2013/ / / / /18 & outyears Reduces cost of lending (cents per $) 1. Suspend the repayment (24.5) (6.2) (6.2) (5.8) (5.0) 0.28 threshold until 1 April Suspend the repayment (51.6) (13.0) (14.9) (14.3) (12.7) 0.66 threshold until 1 April Suspend the repayment threshold until 1 April 2018 (70.9) (18.0) (21.3) (22.6) (20.6) 1.02 The key trade-off in holding the repayment threshold is between the additional repayments generated and the potential hardship for borrowers on low incomes and for a small number of superannuitants, veteran pensioners and student allowances recipients. Both the fiscal gain and the impact on these groups is greater the longer the CPI adjustment to the student loan repayment threshold is suspended. The repayment threshold is forecast to increase to $19,448 p.a./$374 p.w. for the 2015/16 tax year. If the repayment threshold instead holds at its current rate, we estimate that 7,057 borrowers who would not have had a repayment obligation if the threshold were increased, will incur one. Those who currently have income over the repayment threshold would, on average, face a weekly repayment increase of $0.84 cents in 2015/16 increasing to $0.96 cents in 2017/18. The median repayment time on future lending would decrease by 5 weeks. Officials recommend suspending the repayment threshold until 1 April 2016 as this would have the least impact on low income borrowers and be consistent with the suspension of CPI adjustments to the student allowances parental income thresholds until this date. However, if further savings are required from student support in Budget 2014, extending the suspension for another year (until 1 April 2017) is our preferred option. Currently, the Ministry of Social Development (MSD) does not make student loan deductions from income-tested benefits (unless requested by the beneficiary) and Inland Revenue (IR) does not collect them. It may be viewed as inequitable that those on an income equivalent to a benefit are required to make loan repayments while beneficiaries are not. We are seeking your direction on whether student loan repayments should be automatically deducted from

3 income-tested benefits. The numbers affected and the savings over the next four years would be small for each option and officials do not recommended a change at this time. The Tertiary Education Budget 2014 Cabinet paper is to be considered by the Social Policy Committee on 12 March and Cabinet on 17 March. This paper seeks Cabinet authority, subject to consultation with Budget 2014 ministers, to hold the student loan repayment threshold by one or more additional years. Budget Ministers are meeting on 24 and 31 March to agree on Budget packages for Recommended Actions We recommend that the Minister for Tertiary Education, Skills and Employment and the Minister of Revenue: Background a. note that in Budget 2011, Cabinet agreed to hold the student loan repayment threshold at $19,084 per annum until 1 April 2015 [CAB Min (110 14/10 refers] b. note that suspending CPI adjustments to the repayment threshold until 1 April 2016 or longer would release savings for reprioritisation but could result in hardship for some low income earners, superannuitants, veteran pensioners and student allowances recipients c. note the total operating savings over four years (2014/15 to 2017/18) are $23.20m for suspending the repayment threshold until 1 April 2016, $54.90m for suspending the repayment threshold until 1 April 2017, and $82.50m for suspending the repayment threshold until 1 April Options for suspending the student loan repayment threshold Either (recommended by officials) d. agree to include an initiative to suspend CPI adjustments to the student loan repayment threshold until 1 April 2016 in the Tertiary Education Budget Package for 2014 Or Or e. agree to include an initiative to suspend CPI adjustments to the student loan repayment threshold until 1 April 2017 in the Tertiary Education Budget Package for 2014 f. agree to include an initiative to suspend CPI adjustments to the student loan repayment threshold until 1 April 2018 in the Tertiary Education Budget Package for This excludes the one-off favourable impact on the valuation in 2013/14. 3

4 Beneficiaries g. note that Ministry of Social development does not make student loan deductions from income-tested benefits (unless requested to do so by the beneficiary) and Inland Revenue does not collect them and that this may raise a potential equity issue between beneficiaries and low income earners with equivalent income h. agree to include as part of the Budget 2014 package, a proposal for student loan deductions to be made from income-tested benefits (not recommended by officials) i. note that if you agree to recommendation (h) above we will update the financial implications accordingly Next steps j. note that Budget ministers will be meeting on 24 March and 31 March to agree on Budget 2014 packages k. note that a Cabinet decision to hold the student loan repayment threshold by one or more additional years (to be determined by you with Budget ministers) has been sought through the Tertiary Education Budget 2014 Cabinet paper to be considered by the Social Policy Committee on 12 March and Cabinet on 17 March l. note that following your decisions, officials will upload the financial recommendations into Treasury s CFIS system by 27 March m. forward a copy of this report to the Minister for Social Development for her information. Roger Smyth Acting Group Manager, Tertiary Education Policy Graduate Achievement, Vocations and Careers Hon Steven Joyce Minister for Tertiary Education, Skills and Employment / / Hon Todd McClay Minister of Revenue / / 4

5 Tertiary Education Report: Budget Suspending the student loan repayment threshold Purpose 1. You have directed officials to undertake further work for Budget 2014 on an initiative to suspend the CPI adjustment to the student loan repayment threshold until 1 April 2016 [METIS refers]. 2. This report provides our advice, including the implications of suspending CPI adjustments to the repayment threshold until 1 April 2017 and 1 April 2018 should further savings be needed for reprioritisation in Budget Background 3. The aim of recent student support changes is to improve the performance of the student support system in order to sustain it over the long term (particularly in the context of the Government s commitment to interest-free student loans). These changes have managed down the costs of the scheme from 47 cents in the dollar prior to Budget 2010 to its current level of around 41.8 cents. 4. In addition to targeting high risk lending, a number of the student loan changes aim to maximise repayments from borrowers. For domestic borrowers, these changes include: excluding losses from the definition of income (adding back) for repayment purposes from 1 April 2012 (Budget 2011) increasing the repayment rate from 10% to 12% from 1 April 2013 (Budget 2012) broadening the definition of income by including income from trusts and other sources from 1 April 2014 (Budget 2012). 5. Until the 2005/06 tax year, the student loan repayment threshold was set relative to the Domestic Purposes Benefit rate for a sole parent with two children. The threshold was then inflation-adjusted based on the movement in the Consumer Price Index (CPI) [CBC Min (05) 17/7 refers]. 6. In 2009, Cabinet agreed to suspend CPI adjustments to the repayment threshold for the 2010/11 tax year [SOC Min (10) 30/12 refers]. In 2010, the threshold was suspended again for the 2011/12 tax year and in 2011 was suspended for tax years up until 1 April 2015 [CAB Min (110 14/10 refers]. 7. From 1 April 2012, repayment deductions are made on a pay period basis (e.g. if a borrower is paid weekly, the annual repayment threshold is divided by 52 weeks). Fulltime students can apply for an exemption from pay period deductions if they expect to earn under the annual repayment threshold. 8. The student loan repayment threshold is currently $19,084 ($367 per week). Income above the repayment threshold is subject to a repayment rate of 12 cents in the dollar. The threshold is forecast to increase as follows: $19,448 p.a. in the 2015/16 tax year $19,968 p.a. in the 2016/17 tax year $20,550 p.a. in the 2017/18 tax year 5

6 9. In the 2011/12 tax year, 58% (356,811 borrowers) of New Zealand-based borrowers did not have a repayment obligation (this will continue to grow as the scheme matures). Borrowers currently earning under the repayment threshold reflect a range of individual circumstances including that they may be students, unemployed (i.e. a beneficiary or superannuitants), low income workers working part-time, or parents caring for children. Options 10. The options in this paper are to continue to suspend the CPI adjustment of the student loan repayment threshold until 1 April 2016 (option 1), 1 April 2017 (option 2), or 1 April 2018 (option 3). Inflation adjustments would occur thereafter. 11. Ministers may also wish to consider whether the Ministry of Social Development (MSD) should make student loan deductions from an income-tested benefit if the amount of that benefit exceeds the repayment threshold. Policy rationale 12. Suspending the repayment threshold for New-Zealand borrowers would increase total repayments made thereby reducing repayment times for borrowers and future lending costs for the Crown. Broadening the base of those required to make repayments may also help strengthen incentives around borrowing decisions. 13. A potential criticism of extending the suspension of the CPI adjustment to the repayment threshold is that the rationale for income contingent loans reflects the economic benefit gained by those with tertiary qualifications, and that low income earners are not gaining this benefit. However, the income threshold for repayment has never been set to only apply to those on high incomes and repayments required from those on lower incomes are small in proportion to their income. Financial implications 14. Most of the potential savings would be generated from the 432,800 borrowers currently over the repayment threshold (rather than from those currently under the repayment threshold but who would have a repayment obligation if the repayment threshold holds at its current rate). Repayments by this group would otherwise fall by 12% of the difference between the current and forecast repayment threshold, in effect by $43.68 per annum each. 15. The operating and debt impact of the options are set out below: Table B: Operating impact of suspending the student loan repayment threshold Operating impact ($m) 2013/ / / / /18 & outyears 1. Suspend repayment threshold until 1 April Suspend repayment threshold until 1 April Suspend repayment threshold until 1 April 2018 Reduces cost of lending ( per $) (24.5) (6.2) (6.2) (5.8) (5.0) 0.28 (2014/15 and out-years) (51.6) (13.0) (14.9) (14.3) (12.7) 0.58 (2014/15) 0.66 (2015/16 and out-years) (70.9) (18.0) (21.3) (22.6) (20.6) 0.81 (2014/15) 0.95 (2015/16) 1.02 (2016/17 and out-years) 6

7 Table C: Debt impact of suspending the repayment threshold Debt Impact ($m) 2013/ / / / /18 & out-years 1. Suspend repayment threshold until 1 April Suspend repayment threshold until 1 April Suspend repayment threshold until 1 April (3.6) (13.7) (15.8) (17.3) - (3.6) (19.8) (36.7) (39.2) - (3.6) (19.7) (43.6) (60.7) 16. Student support operating savings are available for reprioritisation. However, Treasury advise that the debt impact is not relevant with respect to the Future Investment Fund because a large proportion (although not all) of the capital paid out in student loans is repaid after 10 years. Overall impact 17. Table D provides an estimate of the weekly and annual increase in repayments required from borrowers who currently have income over the repayment threshold. Table D: Increase in repayments under the 3 options for those earning over $19,080 Option 1 Suspend repayment threshold until 1 April 2016 Option 2 Suspend repayment threshold until 1 April 2017 Option 3 Suspend repayment threshold until 1 April 2018 $ p.a. weekly p.a. Weekly p.a. weekly 2015/ / / (Source: Ministry of Education) 18. As Table D indicates, the impact on individual borrowers is small on a weekly basis. This can also be illustrated using the example of a borrower on the minimum wage ($14.25 per hour). In the 2015/16 tax year: under the status quo the borrower would work for hours a week before having a repayment obligation under the proposal the borrower would work for hours a week before having a repayment obligation (i.e. half an hour less). 7

8 19. Median repayment times of future lending are estimated to decrease as follows: Table E: Reduction in the projected median repayment time of future lending Options 1. Suspend repayment threshold until 1 April Suspend repayment threshold until 1 April Suspend repayment threshold until 1 April 2018 Weeks (reduction) (Source: Ministry of Education) 20. The numbers of borrowers who are affected by these options are set out in Table F. Table F: Numbers affected by the repayment threshold options Options 1. Suspend repayment threshold until 1 April Suspend repayment threshold until 1 April Suspend repayment threshold until 1 April 2018 Total borrowers affected 2 432,800 7, ,800 12, ,800 17,740 Borrowers that only have a repayment obligation as a result of suspending the repayment threshold (Source: Inland Revenue) 21. The total number of borrowers who would be affected by suspending the threshold is 432,800 under each of the proposed options. This is because of two reasons: affected borrowers for each option are forecast using the same base of borrowers (data from 2012) and each policy suspends the threshold at the same level. Most of the borrowers in this affected group will already be over the threshold for at least one pay period and making repayments on their loan. 22. If the CPI adjustment of the repayment threshold is suspended, a subset of affected borrowers will be pushed over the threshold as their nominal incomes grow. For example, for option one 7,057 of these borrowers would not have a repayment obligation in 2015/16 if the threshold is adjusted by inflation on 31 March This number increases as the length of the threshold suspension increases. The effect of the policy is greater the more inflation adjustments are missed. 23. All of these options will have a flow on effect in all subsequent years beyond their suspension date. These effects result from the loss in adjustments for all the tax years included in the suspension, causing the thresholds to always be lower than they would be if the policy to suspend the threshold was not adopted. 2 These estimates were forecast assuming; all monthly income is from one single 4 weekly pay period, there is no change to wages, the population of borrowers stays the same and all employers are fully compliant. 8

9 24. Figure 1 in Appendix A compares various income rates against the repayment threshold and the proposed options. Impact on low income borrower groups Priority groups 25. Low income borrowers are more likely to be in the Government s priority groups as a large proportion of those currently under the threshold are Māori, Pasifika, under 25 and borrow for lower level study. 26. We examined the population of New Zealand-based borrowers who are not current students. This is estimated to be 44% of people with a student loan. As a proxy for those on the cusp of having a repayment obligation we have examined the sub-group who have an income between $15,000 and $25,000. The information reveals the following: 68% were women (compared to 58% of the population) 59% were on benefit (compared to 30% of the population) 41% were European (compared to 46% of the population) 9% were Pasifika (compared to 9% of the population) 30% were Māori (compared to 22% of the population) 40% were under 25 years of age (compared to 49% of the population) 39% were out of study for 1 or 2 years (compared to 36% of the population). Student allowances, NZ Superannuation (NZS)/Veterans Pension (VP), and benefits 27. MSD automatically makes student loan deductions from NZS/VP and student allowances if the payment rate exceeds the student loan repayment threshold. It does not do so for income-tested benefits. 28. The payment rates that currently exceed the repayment threshold and for which deductions are automatically made are: the student allowances rate for students with a dependant spouse (with or without children) which is $ gross per week. In 2013, StudyLink made student loan repayments deductions totalling $2.34m from 10,171 student allowances recipients. the NZS/VP rate for those who are single, living alone ($ gross per week) and for those who are single and sharing ($ gross per week). MSD advises that 4,047 people receiving single rates of NZS/VP had a student loan at some point over the last 14 years 3 and may still have an outstanding balance. 29. Under the Student Loan Scheme Act 2011 where a repayment deduction is required to be made from a benefit, the repayment deduction is required to be an amount the Commissioner of IR determines in consultation with the Chief Executive of MSD. Currently this amount is zero. This is because benefit rates are specified in the Social Security Act 1964 at after-tax rates, and grossed up at a single, standard tax rate across all beneficiaries. 3 MSD s data set goes back to the year 2000 when StudyLink took over administering student loans. 9

10 30. Where the benefit income 4 is over the repayment threshold MSD can make the required deduction if the beneficiary requests it. MSD does not take voluntary repayments from beneficiaries. Beneficiaries who wish to make a voluntary repayment on their student loan must arrange this directly with IR. 31. Currently there is only one benefit rate over the repayment threshold, the Supported Living Payment, Sole Parent. MSD data shows that 2,843 of those receiving this benefit rate have had a student loan at some point over the last 14 years and may still have an outstanding balance. 32. The student allowances, NZS/VP and benefit borrower numbers in this section provide an indication of the maximum numbers of those who could be affected if CPI adjustments to the repayment threshold are suspended (and applied in the case of benefits). Determining the actual numbers would require data matching with IR. 33. Our forecast data indicates that the proposals in this paper are unlikely to affect any additional student allowances, NZS/VP or benefit rates over the next four years, nor would they significantly change the number of people affected. 34. Table G in Appendix A, compares the increases to repayment obligations for individuals in these groups if the student loan repayment threshold is suspended. The impact is greater for the NZS/VP group as their rates are indexed to the average wage (see Figure 1 and Table G in Appendix A). Comment 35. The key trade-off in suspending the CPI adjustment of the student loan repayment threshold is between the potential savings coming from a large number of borrowers with an existing obligation and the impact of the suspension on low-income earners and a small number of NZ superannuitants, veteran pensioners and student allowances recipients. Both repayment revenue and potential for hardship would be more marked the longer the repayment threshold is suspended. 36. Superannuitants and veteran pensioners are likely to be more affected than student allowances recipients because their payment rates are indexed to the average wage (see Figure 1). However, the Government gets very little return from people who have not fully repaid their student loan by the time they retire. Therefore suspending the repayment threshold for an extra year or more will help the government reduce some of this high cost lending. 37. The impact on low income earners may be reduced in particular cases, because the Student Loan Scheme Act 2011 contains hardship provisions to provide relief to borrowers whose repayment obligations are causing them serious hardship. If a repayment obligation will cause a borrower serious hardship, they may apply to IRe to have their repayment deductions lowered for the upcoming or preceding tax year. The Commissioner may also refund repayments made in the previous tax year. 38. Officials recommend suspending the CPI adjustment of the student loan repayment threshold by one more year as this would have the least impact on low income earners, superannuitants, veteran pensioners and student allowances recipients. It would also align the policy with the suspension of the student allowances parental income threshold until 1 April For beneficiaries, benefit income that counts towards income for the student loan income repayment threshold is the amount of the main benefit only (e.g. Supported Living Payment, Jobseeker Support). Supplementary assistance such as Accommodation Supplement and Disability Allowance is not treated as income. 10

11 39. Ministers may wish to consider whether student loan deductions should be made automatically from income-tested benefits and collected by IR. This is because it may be viewed as inequitable that beneficiaries do not have repayments deducted from their benefit when low income earners are required to make repayments. 40. Given the small number of beneficiaries this proposal would affect (now and over the next four years) and the small amount of savings generated, we recommend maintaining the status quo for now. IR s hardship provisions partly mitigate differences in treatment between beneficiaries and low income earners. 41. If Ministers decide to progress with an automatic deduction of student loan repayments from benefits we will finalise the financial implications. Administration Implications 42. There will be minimal impact to IR s administration processes if the current repayment threshold is suspended for one, two or three more years. Any information updates would be dealt with under business as usual, as part of the annual cyclic updating of forms and guidance. 43. MSD is currently investigating the implications of implementing the proposal of automatically deducting student loan repayments from income-tested beneficiaries. Initial indications are that changing MSD s payment system to deduct student loan repayments from those who are affected by this proposal will cost between $25,000 and $75,000. There are likely to be further implementation and administrative costs (e.g. communicating the changes and changes to forms etc.) and MSD is in the process of working through what these costs will be. MSD expects this work will be completed by the week ending 14 March Legislative implications 44. If the repayment threshold is to be inflation adjusted from 1 April 2016 regulations will need to be made by the end of December If the threshold is suspended, no legislative amendments will be required, but Cabinet will need to agree to suspend the decision made to adjust the threshold by the movement in the September CPI. Next steps 46. The Tertiary Education Budget 2014 Cabinet paper is to be considered by the Social Policy Committee on 12 March and Cabinet on 17 March. This paper seeks Cabinet authority, subject to consultation with Budget 2014 ministers, to hold the student loan repayment threshold by one or more additional years. 47. In terms of the Budget process, Budget ministers will be meeting on 24 March and 31 March to agree on Budget 2014 packages. Treasury advise that the financial recommendations of key initiatives need to be uploaded recommendations into Treasury s CFIS system by 27 March. 48. Once we have your feedback on which option to progress we will finalise the financial impacts and prepare the financial recommendations. 11

12 APPENDIX A: Figure1: Comparison of repayment threshold against other income rates (actual and forecast) Note: The minimum wage rate is set by the Government each year. The forecast rates in this graph are a best estimate based on the average of past increases. Table G: Increases in repayment obligations for student allowances, superannuitants/ veteran pensioners and beneficiaries (subject to a policy change) if no CPI adjustments are made to the repayment threshold Payment rate Student allowances (student with a dependent partner) Superannuitants/Veterans (single, living alone) Supported Living Payment, Sole Parent benefit Current weekly repayment obligation 2015/ / /18 $3.20 $4.56 $5.79 $6.90 $5.19 $7.37 $8.65 $10.18 None $3.99 $5.20 $

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