Accord implementation proposals, part #4: Managed demand driven funding for equity students

When the Accord final report was published one recommendation that confused me was a policy to increase equity student enrolments that was “effectively ‘demand driven for equity’ but with planned allocation of places to universities”.

A demand driven system, under which universities can enrol unlimited numbers of students meeting set criteria, can sit alongside a system of allocated student places or funding. Current Indigenous bachelor degree demand driven funding, which would be retained in the Accord model, sits alongside a soft capped block grant for most other students. But for the same courses, or student categories, demand driven and allocated student place systems are mutually exclusive.

Any hope of clarity has been dashed by the Accord implementation paper on managed growth. It proposes “managed demand driven funding for equity students”.

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Accord implementation proposals, part #3: Distributing student places between qualifications & disciplines & the funding floor

Part 1 of this series on the government’s Accord implementation plans looked at the proposed Australian Tertiary Education Commission. Part 2 examined how student places would be allocated between universities. This post considers Accord implementation plans for distributing students places within universities between qualification levels and disciplines. In this post, at least, I find that some of the government’s proposals have merit.

Some background: The government has often allocated higher education resources differently depending on qualification level, course, field of education and sometimes students. This practice can target and/or limit spending on a policy goal. The trade-off is less flexibility in moving resources where they are needed. As a result, prospective students miss out or pay much more than the student contribution rate in the full-fee market.

In the 2010s sub-bachelor, bachelor and postgraduate CSPs were funded separately. Since 2021 they have been funded together, with exceptions for Indigenous bachelor degree students and medical courses.

The distribution of student places between qualification levels – postgraduate

While the Accord final report supported more Commonwealth supported places at the postgraduate level, it wanted to focus them on areas of “national priorities and skills needs”.

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Accord implementation proposals, part #2: The distribution of student places to universities and the folly of hard caps

An earlier post looked at the government’s plans for the Australian Tertiary Education Commission. This post examines the government’s proposals for setting the number of student places and distributing them between universities. This includes a hard institution-level cap on student places, so that universities would get zero funding for enrolments above their allocated level. This post explains why a hard cap is unnecessary and counter-productive.

Overall number of CSPs

The government will determine the total number of CSPs. For ‘fully funded’ places – places for which universities are paid both a Commonwealth and student contribution – this is similar to the current system of the government deciding on total CGS funding, other than the small demand driven system for Indigenous bachelor-degree students (which will be retained). However,

  • because universities will have flexibility in moving EFTSL between disciplines (discussed in a later post) the maximum dollar amount the government pays will be less predictable than now.
  • because of the first point and hard caps on student places at each university (discussed below) the maximum number of CSPs the system provides will be more predictable than now.

It is not clear whether ATEC will advise the government on the number of CSPs, as opposed to contextual factors such as demographics, demand, and skills needs.

And if ATEC does provide advice on system-level numbers, it is not clear whether this will be published or not. The consultation paper mentions the state of the sector report recommended by the Universities Accord final report, but this is framed as a ‘report on higher education outcomes’, not future higher education needs.

Former higher education commissions provided detailed public advice on likely student demand and the sector’s capacity to meet it. For an education minister there is a trade-off. Public and quality advice gives leverage in Cabinet when arguing for money and a semi-independent justification for the government’s overall policy direction. But if the minister does not get the money the sector, and opposition MPs, will use ATEC reports against the government.

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Lower-of CPI and Wage Price Index (WPI) HELP debt indexation – inherent weaknesses and design issues

This morning The Conversation published my argument, made last month on this blog, that HELP debt should be indexed at the lower of CPI or 4%. I argue that this is better than the other suggested ‘lower-of’ options, such as the government bond rate, the RBA cash rate, or a wage increase indicator. The Universities Accord final report chose the last option, specifically the Wage Price Index (WPI). WPI measures changes in hourly rates in the same job.

All the CPI alternatives have a relationship with CPI

A problem with all the lower-of proposals, except a fixed maximum, is that they have a relationship to CPI. If inflation starts going up the RBA increases its cash rate and government bond holders want higher interest rates to protect their real value. Workers and unions, often supported by policymakers, seek inflation compensating wage increases.

For wages set nationally, the federal government wants the minimum wage increase linked to inflation this year. If the Fair Work Commission grants this increase, minimum wage and other CPI-driven wage rises will flow through to future WPI figures.

Real wage increases, over-and-above CPI, also push up WPI. Aged care workers have recently been awarded a large real wage increase. Statistics on enterprise agreements show wage increases returning to their normal pattern of exceeding both WPI and CPI.

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The politics of multi-rate marginal HELP repayments

In a couple of previous posts, I examined reasons for moving to a marginal rate system for repaying HELP debt, as proposed by the Universities Accord final report, and what the rates might be.

Under a marginal rate system HELP debtors would repay a % of all income above a threshold amount, instead of a % of all income once a threshold is reached, as now. An advantage of marginal rate repayment systems is that they can reduce effective marginal tax rates. High EMTRs discourage people from taking on more paid work. In some cases under the current system EMTRs exceed 100%, so disposable income goes down despite nominal income going up.

The Accord final report and the minister, Jason Clare, also suggest reducing annual repayments, at least for lower income HELP debtors. Except for HELP debtors just above an income threshold in the current system (especially the first one, where there are very high EMTRs) this is not an inherent feature of marginal rate systems compared to current arrangements. But it could be a political selling point for a marginal rate system designed to reduce repayments.

To cut annual repayments for lower income HELP debtors without causing a major reduction in HELP repayment revenue the government would need to introduce a multi-rate marginal system. This is implied in the Accord final report discussion. Multi-rate systems progressively increase the marginal rate as income goes up. There are many possible sets of rates, but my previous post looks at 7%-17%-22% and 10%-15%-20% models.

This post goes through some of the political implications of moving to a marginal rate system.

How will the percentage numbers be interpreted?

One initial challenge will be convincing people that a 7% or 10% first marginal rate will usually reduce their repayments compared to the current seemingly lower rates. How can charging 7% increase disposable income compared to 1%?!

Of course the answer is what the percentages are of, but for people half paying attention, who have never thought about marginal versus whole of income rates before, a higher percentage rate reducing their repayments is going to seem counter-intuitive.

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Possible marginal HELP repayment rates under Universities Accord reforms

The Universities Accord final report proposes changing how HELP repayments are calculated. It recommends abolishing our current system, which levies a % of all income once an income threshold is reached. It would be replaced with a system that charges a % of income above the threshold – a marginal rate system.

A major reason given for this change was to end the ‘unfair situation’ of some HELP debtors having very high effective marginal tax rates. These can exceed 100% in some cases, so that an increase in taxable income results in lower disposable income. In addition to the fairness issues, high EMTRs can lead to people working fewer hours and less income tax revenue.

Other Accord final report comments, however, suggest HELP repayment redesign with purposes beyond the EMTR issue. While not specifying thresholds or marginal rates, the report suggests a system in which the ‘majority of HELP debtors who make a repayment … would repay less in a given year’. They warn, however, that a ‘small number of higher income debtors (likely less than 10% of HELP debtors) [would] make higher repayments in a given year’.

Subsequent Jason Clare media interviews suggest that policy thinking on repayment systems has moved beyond a general preference for a marginal rate system. Referencing unpublished research by Bruce Chapman, Clare said on the day the final report was released that ‘someone on an income of $75,000 a year would pay every year about $1,000 less.’ He gave the same example again this week.

Speaking to the SMH, Chapman expanded on how the new system might work. He envisaged a multi-rate marginal HELP repayment system: ‘a person earning $86,000 would only be taxed the 5 per cent repayment rate on the income above the threshold at which the rate kicks in, being $84,430. All income below that threshold would be levied at the lower rates.’ A multi-rate marginal system is also consistent with the Accord final report reference to some HELP debtors repaying more each year than they do now.

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Why does the Universities Accord final report suggest repaying HELP debt on a marginal rate – a % of income above the threshold, rather than all income?

One quirk of the HELP repayment system is that, on reaching each repayment threshold, the debtor pays a % of their entire income. England and New Zealand followed Australia in creating income contingent student loans. But their repayment systems are based on a % of their income above the threshold – they have marginal rate systems. The Australian income tax system also uses marginal rates.

The Universities Accord final report HELP repayment recommendations include ‘moving to arrangements based on marginal income’.

As explained below, this Accord change would reduce ‘effective marginal tax rates’ – the loss of disposable income on each dollar above the threshold. Under the current system, EMTRs can exceed 100% – so that earning an extra dollar reduces rather than increases a HELP debtor’s annual disposable income. The Accord final report calls this an ‘unfair situation’.

The Accord final report does not specify a marginal rate – an issue I discuss in another post. England and New Zealand have marginal loan repayment rates of 9% and 12% respectively above their repayment thresholds.

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Changing the HELP indexation date – 30 November?

A common HELP indexation complaint over the last couple of years is that compulsory repayments during the financial year are not deducted prior to indexation. I explained the current system in this post last year.

In that post, I noted that one reason for not taking compulsory HELP repayments out prior to the current 1 June indexation date is that their exact amount is not yet known by the ATO. The repayment amount is calculated after the financial year ends, on 30 June, and during tax return processing. There are many reasons why HELP repayments sent via the PAYG system could be less or more than the final repayment amount.

The ATO has raised another administrative obstacle, which is that HELP repayments are not separately identified in the PAYG information it receives from employers. As the ATO collects salary information, and already knows who is a HELP debtor, it perhaps would not be that hard to infer why the amount withheld from an employee is higher than income tax rates require. But clarity on what is intended as a HELP repayment would require system re-designs for the ATO and employers. HELP PAYG information would still often vary from the final correct amount, so the system would need a reconciliation after 30 June, with corresponding adjustment of indexation up or down. This would add complexity and administrative costs. These practical issues rule out real-time reduction of HELP balances.

The Accord final report instead recommends another option, changing the date of HELP indexation. They do not, however, suggest a date.

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HELP debt indexation at the lower of CPI or a fixed maximum rate – giving HELP borrowers more certainty than the Universities Accord final report lower of CPI or WPI recommendation

Over the last two years high CPI-driven HELP debt indexation – 3.9% in 2022, 7.1% in 2023, probably in the vicinity of 5% this year – has been a major issue. It has brought to public attention HELP debt issues that had been waiting for their trigger.

The last time HELP debt indexation exceeded 5% was in 2001, as the the new GST flowed through into prices and an indexation rate of 5.3%. At that time 1.1 million people had HECS (as it then was) debts of about $7.2 billion. A Factiva search shows that this unusually high indexation was newsworthy at the time. But with much lower HELP balances per person than now the average debt increase was only $350. The indexation issue then went quiet for two decades, except when the government wanted to charge more than CPI.

The reason for HELP indexation’s long low media profile was that between 2002 and 2021 it averaged 2.4%. It was below 2% between 2016 and 2021. This extended period of low inflation left HELP indexation as a latent issue, as increases in HELP debtor numbers and average debts gave it far more potential to cause significant personal cost and political trouble than it had in 2001.

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How would student places be allocated by the proposed Australian Tertiary Education Commission?

Based on the Universities Accord interim report I was concerned that its proposed tertiary education commission would be highly interventionist, controlling university enrolments to meet the government’s equity, attainment and skills targets. I called it Job-ready Graduates 2.0.

The Australian Tertiary Education Commission proposed in the Universities Accord final report is – I think, a lot of detail remains to be seen – considerably better than the version of my policy nightmares last year.

The overall funding system would have more central steering than now, but on my reading ATEC probably will not routinely micromanage – that university A must offer B places in C course and fill them with students meeting criteria D, E or F. That was the approach of recent ad hoc student place allocations, such as the 20,000 new places for skills shortages and equity groups. The Accord final report admits that these places won’t be used. Even without recent soft demand, every condition added to a student place reduced the chance that a student could be found to fill it.

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