Canada Student Loans Program Review: Seneca College Recommendations Seneca College s submission to the Canada Student Loan Program (CSLP) Review has been developed based upon a number of distinctive characteristics of our College and of the college sector as a whole in Canada. These factors are integral to the recommendations we make in our submission to the Government of Canada and Human Resources and Social Development Canada (HRSDC). Canadian College Students in the 21 st century First and foremost, colleges in Canada offer applied education and college students differ vastly from university students, both in their needs and their educational objectives. Based on Seneca s experience as a national college, offering certificates, diplomas, four year accredited applied B.A. degrees and post-graduate certificates, we can extrapolate the following general characteristics of Canadian college students (see Appendix for specific student profile information for Seneca College): The majority of college students are lifelong learners. Almost half of the college student population is older than 21 and younger than 30, indicating a strong likelihood that these are independent young adults who often cannot rely on parental support. The majority of students attending college are part time learners, many of whom are disadvantaged when accessing the CSLP. Within the large percentage of part time learners, many college students are not enrolled in a formal program of study, but are taking courses to meet industry regulatory standards, or to upgrade their skills. An increasing percentage of college students have prior university education, meaning they arrive already carrying an educational debt load. A large percentage of college students are first generation learners, from the under-represented sectors of the population in post-secondary education. Newcomers to Canada constitute a growing percentage of the college student population. College students tend to come from less advantaged backgrounds and are more vulnerable to financial difficulties. Unlike university undergraduate students, a large percentage of college learners have their own dependents, parents or children. College graduate debt levels are growing faster than university debt levels. While college graduates have higher rates of employability upon completion of study, the vast range of professions and occupations represents a wide disparity in earning power upon graduation, which has a direct impact on the ability to repay loans. Attrition rates at colleges can be related to an inability on the part of the individual learner to understand and navigate the complexities of CSLP. 1
Objectives of CSLP: Accessibility, Persistence and Completion Seneca agrees with the mission that the Federal Government has given the CSLP, namely: to promote accessibility to post-secondary education for students with a demonstrated financial need by lowering financial barriers through the provision of loans and grants, and to ensure Canadians have an opportunity to develop the knowledge and skills to participate in the economy and society. Seneca embraces this objective as a foundation for its own Strategic Plan (2004). Our vision is to lead in access to higher education, and our strategic goal is to increase access to education for eventual student success. The overall objective of all government student financial assistance (both federal and provincial) should remain that of increasing the numbers of Canadians who access higher education. The current skills shortage, the longer term productivity challenges faced by Canada, and the global opportunities for our citizens require that all sectors commit to concrete measures that will quickly lead to increased post-secondary participation rates. Seen in this light, the CSLP must improve its ability to respond to those who most need the financial assistance offered through the instruments under review loans and grants. The CSLP must be held accountable for increasing accessibility to higher education. Accessibility to PSE will be compromised in the years ahead if measures are not taken on a regular basis to increase the levels and kinds of funding available to students. While accessibility to higher education is the paramount concern of the CSLP -- and of all institutions of higher learning -- we should keep in mind that the success of the CSLP should also be measured in terms of the persistence and completion rates in higher learning, since the current system of student financial aid is complex and increasingly has negative impacts as students continue. Seneca s recommendations for improvements to the CSLP include measures to ensure persistence and completion of post-secondary education across Canada. In terms of modernizing the entire CSLP there should be four new priorities for HRSDC: 1. increase the participation levels in the CSLP from among various underrepresented groups demonstrable progress on accessibility as opposed to helping those already in the system 2. improve equity within the program to assist those who have the most need 3. recognize the changing needs of learners in Canada 4. Improve service delivery through better integration and consistency of regulatory changes with provincial authorities. 2
Other measures outside the CSLP can increase participation rates The present consultation relates to simplifying the CSLP for increased efficiency and effectiveness. This leaves out other means to increase participation in higher education which should be considered alongside any effort to improve the CSLP. Mentioned briefly, they are: The Federal Government should increase the amount of total loans and grants that the CSLP administers. We recognize that this is a political issue which we encourage the Minister to take up with his counterpart at Finance. The Federal Government should consider a review of the education tax credit process and system, to evaluate whether tax credits lead to an increase in entrants into the higher education system, or whether the money could be better spent on other instruments. The Federal Government should heed the unanimous calls from all stakeholders -- students, parents, educators, experts to renew the mandate of the Canada Millennium Scholarship Foundation. There may be ways to use the supports that the Foundation offers to address specific provincial higher education challenges. A major undertaking to simplify the administration of the CSLP would be to integrate the loan repayment and interest relief program with the income tax system, and to consolidate all federal information relating to individual students. Again this is outside the scope of this review, but Seneca is ready to provide detailed ideas on how this could be operationalized. While not an area of federal responsibility, Seneca does not find that tuition freezes truly assist students to enter or complete their higher education, and do not lead to an increased participation in post-secondary education Seneca Recommendations in Response to Stakeholder Questionnaire Turning back to the specific questions of the CSLP consultation, we have developed a number of recommendations based on specific problems which exist in the CSLP. Instruments The key instruments of the CSLP are: Grants Loans Interest subsidy or interest relief Grants: Seneca believes that non-repayable grants are the single most effective way to increase participation in post-secondary education across Canada. 3
Grants for students from lower income family are making a difference, but need to be increased both in terms of total dollars and relative to the percentage of total student financial assistance through loans or tax credits. Grants are not keeping pace with the rising cost of higher education. If the Government of Canada wishes to address the new needs of the diverse post-secondary student body, more targeted grants should be designed for specific segments of the student population still unserved by current grant programs, such as, all part time learners, more Aboriginal Canadians, newcomers. Improvements can be made to some existing grant programs, including the Canada Access Grants by expanding the program for up to four years of study. Loans: Seneca s overall concern with respect to the current student loan system is its one size fits all approach. As we stated at the outset, the current system does not address the specific demographics or financial situation faced by college students. Given the diversity of needs amongst the national student population, which varies by province, by local needs, by the very nature of the learner (part time, older, low income, independent of parental support), more flexibility needs to be built into the student loan system to address these realities. Given the large variance in total education costs depending upon program of study, location of institution, and cost of living disparities, again the student loan system is inflexible in its universal application. Find new and responsive ways to address the growing unmet financial needs: the gap between student need and the availability of government student assistance. Student borrowers should be allowed to work for needs unmet by CSLP or parental contributions and not have these earnings reduce the loan amount. Loan amounts should not be reduced by earnings of independent students who cannot access parental contributions through parents inability to pay. Exclude institutional grants and scholarships (needs or merit based) from the need assessment calculation of the CSLP. Extend the time frame that students are eligible to receive government financial assistance and to continue studies interest free to allow for the completion of each of a college-level program, undergraduate degree, professional or graduate degree, including PhD programs, plus one year. Allow post-secondary students to borrow only what they need, and not be obliged to borrow the full amount calculated. Allow part time and lifelong learners to draw loan amounts pro-rated on the percentage of course of study. Canada student loans should be interest free for part time students who are continuously enrolled in a recognized program of study. Recognize that the cost of on-campus residence is higher than the housing cost allowance built in to the need calculator. 4
Adjust the weekly maximum limit of the CSLP according to an annual indexing formula. Raise the in-study resource exemption in recognition of the need of full time students to pay the shortfall between all education-related costs and loan threshold or maximum, allowing 15 hours of in study work at minimum wage. Interest Rate: Make the interest rate on student loans equal to government cost of borrowing or fix at prime rate only. Mandate an annual review and adjustment to interest rates on student loans to ensure both levels of government are using same rate of interest consistency of interest rate application. Interest Relief: Since the Canadian interest relief program already has features similar to income contingent loan repayment programs in other countries, consider modernizing the interest relief program through measures such as the following: Improve communication and information about existing interest relief system which is not well understood by student borrowers. Create an on-line automated interest relief application process. Consider linking loan collection and interest relief measures to the income tax system. Make the six month post-graduation period interest free. Make repayment plans individualized with appropriate tiered interest relief tied to real earnings, limiting monthly payments to a percentage of the borrower s discretionary income. Use tiered repayment and interest relief to prompt skills realignment in Canada for example, if skills shortages exist in early childhood educators, use interest relief and loan forgiveness as incentive. Part time students: In Canada, part time student loans are income based and not need-based. The system is kept separate from the financial assistance for full time students. Loans to part time students are not subsidized, i.e. they accrue interest during the period of study. The loans for part time learners are for tuition costs only and not the total educational cost. Grants for part time learners are not as generous as they are for full time students and are limited to a CSLP offering for high need part time students. Given the growing number of part time students and lifelong learners attending college across Canada, this is a major inequity and will have a direct impact on the country s ability to address the skills gap and re-training needs of its workers. Furthermore, a vast majority of college learners take one course or two, and because they are not formally enrolled in a program of study or do not meet minimum thresholds as defined by the CSLP, they receive no assistance for this iterative learning. 5
Prior to 1996, Ontario had a successful way of making part time students eligible for financial aid. After calculating a student s need, it was multiplied by the course load factor. If a student was taking 40% of a full course load, s/he could receive 40% of the need. Improvements in the eligibility of part time students and life long learners for financial assistance will increase and improve persistence and completion rates. Therefore, the CSLP should consider the following actions for part time learners: Pro-rate the loan amount available to part time students enrolled in a program of study on the percentage of course load taken and remove interest accrual while pursuing study. Allow unsubsidized loan for tuition cost of single courses of study or for students taking many courses outside of a formally defined program of study. Administration Currently the Federal and Ontario administration and integration of student financial assistance is vastly improved. The Ontario Student Assistance Program (OSAP) Access window on the web is a useful tool for all stakeholders and individuals. Yet more can be done by: Consistent use of integrated web-based information and calculators, providing one stop information on all financial support programs across Canada. HRSDC and its provincial counterparts should launch a major communications and outreach campaign to increase secondary school student and parent awareness of how the student financial assistance system works. Career and guidance counsellors in both secondary and post-secondary school systems should be part of the outreach campaign, helping students to make the right career choices to avoid carrying unnecessary debt burdens. The Federal government can invest some funding in this outreach. This outreach campaign should be used to explain the complexities, seek simplifications where possible, and to increase the awareness of kinds of support available to students throughout the course of study, even upon completion of study. Inform students what their allowable in-study earnings will be at the time of signing the loan. Align parental contribution limits federally and provincially these are not the same currently. If parental contribution limits are increased by one jurisdiction, then the other must do so simultaneously. Improve federal-provincial communication on regulatory changes to the CSLP. Consult and cooperate with each province to ensure that the CSLP is meeting provincial higher education objectives. For example, in New Brunswick a key objective is to retain students in the New Brunswick system of education, but 6
in Ontario a key objective is to ensure equitable treatment of the increasing numbers of students accessing education. Seneca agrees with recommendations made by the Auditor General of Canada in May 2007 and calls for more transparent and timely performance measurement information about the CSLP and its primary objective of increasing accessibility to higher education. Consolidated annual data should be available on the kinds of learners making the most use of the CSLP instruments. Delivery Seneca endorses recommendations, notably from the National Advisory Group on Student Financial Aid and Canadian Association of Student Financial Aid Administrators, to move to an electronic delivery of student assistance, removing the paper burden on all administrators and students. Direct deposits will remove considerable lag in payments. An electronic, consolidated student financial aid calculator, (such as the Web Access for OSAP in Ontario) will give students improved ability to manage their loan, forecast their loan threshold and payments. An automated on-line interest relief application process through a dedicated website will make it easier for student borrowers to know about the interest relief system. Seneca has compiled data and research on these recommendations and would welcome any opportunity to expand on any of these ideas with a view to improving the ability of college students to access the financial assistance that most suits their individual situations and needs. For further information, please contact: Nobina Robinson, Senior Government Relations Advisor nobina.robinson@senecac.on.ca 7
Appendix: Seneca College: Student profiles and financial assistance Seneca is a national institution of advanced higher learning offering the full set of credentials including certificates, diplomas to applied B.A. degrees, and post-graduate certificates. One of Seneca s paramount 2004 strategic goals is to increase access to post-secondary education Access to Success. Seneca will become the Canadian model for the creation of access opportunities to higher education and training. This will be accomplished by extending counseling, financial and other supports that promote access, retention and student success As one of the largest colleges in Canada, and in the Greater Toronto Area, Seneca has a broad and diverse student population with a vast range of needs (2006 data follow below). At any point in time, Seneca s full time student complement is 18,000; parttime learners total 25,000 per term. Over a year, we would typically serve close to 100,000 part time learners. 47% of Seneca s full time learners are in the 21 to 30 age group, which indicates that they are more mature students and often independent of parental support. Approximately half of these learners are female. 15% of our full-time students and 40% of our part time students are university graduates, indicating that they are accessing Seneca s course offerings in order to find employment. It is very likely that many of these learners, particularly the full time students, have arrived at Seneca with some form of post-secondary education debt. Almost 10% of our full time student body is older than 30 indicating a significant use by those who wish to upgrade their credentials or re-train for other careers. 63% of the part time student population is 25 to 40 years of age. The majority of students studying part time at Seneca are seeking to upgrade a specific skill, obtain the educational requirements to meet an industry standard, or do not apply to graduate from a program until all course requirements are met. Over 60% of Seneca full time students are newcomers to Canada. 39% of first year full time students have self-identified as first-generation learners, with no previous family experience of post-secondary education in Canada. 4% of our full time student population has self-identified as Aboriginal. Only 12% of the full time enrolment is 18 years of age or younger (more likely to rely on parental contributions for education costs). 39% of our student population accesses the Ontario Student Assistance Program (OSAP) for financial assistance representing about $42 million per year in government support through CSLP and Ontario programs. Only 13 students qualified for the Part time Canada Student Loans Program in 2006. 8