Comments Regarding Proposed College Ratings Framework

February 17, 2015

U.S. Department of Education
Attention: National Center for Education Statistics
1990 K Street NW, 8th Floor
Washington, DC 20006

Re: For Public Feedback: A College Ratings Framework

Dear Sir or Madam:

Thank you for the opportunity to provide feedback on the College Ratings Framework as published on December 19, 2014. As a non-profit research and advocacy organization working toward expanding economic opportunity for young adults, we applaud the Department of Education’s (hereafter “the Department”) work to make institutions of higher learning more accountable to students and families, better able to improve, and more transparent for taxpayers.

We understand and appreciate the difficulty of achieving an ambitious project such as the one that the Department lays out in its framework. Systems within higher education are extremely complex, often to the detriment of students and families. How the Department will assign value to its activities and outcomes speaks to our values and priorities as a nation. We hope that our comments are beneficial to your work and will result in a usable system that benefits students and families, with an emphasis on students from underrepresented communities.

Click here to download our full Comments.

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Comments Regarding the Administration’s Intent to Expand Pay As You Earn (PAYE)

November 4, 2014

Ms. Wendy Macias
U.S. Department of Education
1990 K Street NW, Room 8017
Washington, DC 20006

Re: Docket ID ED-2014-OPE-0124 – Intent to Establish Negotiated Rulemaking Committee

Dear Ms. Macias:

We write in response to the September 3, 2014 Federal Register notice soliciting input on the U.S. Department of Education’s upcoming negotiated rulemaking. Young Invincibles is a national nonprofit dedicated to creating economic opportunity for young adults and amplifying the voices of 18 to 34 year olds on issues like health care, higher education, and jobs. Thank you for giving us the opportunity to submit comments on the administration’s intent to expand Pay As You Earn (PAYE).

To download our full Comment, please click here.

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Investing In Young America: What’s In the President’s 2016 Budget?

Click the fact sheet to read, “Investing in Young America: What’s In the President’s Budget?


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A Millennial Agenda for Illinois

Click here to download the full report: A Millennial Agenda for Illinois.

The NextGen Illinois project is an initiative of Young Invincibles and the Roosevelt Institute | Campus Network, in collaboration with dozens of other Illinois organizations, designed to activate young people to shape a unique policy agenda for the state of Illinois. Young adult voices are frequently overlooked in state-level political conversations, and the NextGen project aims to strengthen the youth voice by elevating shared political priorities.

From June to September of 2014, we met with young people from across Illinois and hosted discussions and town halls on campuses, in classrooms, and in bars to gather policy ideas. Over 700 young people, ages 14 to 34, participated in discussions about Illinois’ biggest policy challenges such as education, jobs, and health care. Participants also tackled important reform questions around political corruption, money in politics, and fair elections.

On September 27, hundreds of NextGen Illinois participants came together at a state convention to vote on some of the best ideas that young people contributed throughout the process and created a cohesive 10-item agenda for Illinois.

Here you will find the resulting agenda, containing the top 10 ideas supported by young people from all over the state. We have included a brief analysis of each policy and information on how you can help move these policies forward.

Next Gen IL

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Comment on the Proposed Removal of Question 12 of American Community Survey

Department of Commerce
Attn: Jennifer Jessup
Departmental Paperwork Clearance Officer
14th and Constitution Avenue N., Room 6616
Washington, DC 20230

Proposed Information Collection; Comment Request; The American Community Survey
Content Review Results

Dear Ms. Jessup:

Thank you for the opportunity to comment on the content review results of the American Community Survey (ACS) and the proposed removal of questions. We appreciate the Department of Commerce’s efforts to reduce burden on survey respondents by weighing the benefits and costs of questions included in the survey. The ACS is an important instrument for measuring the economic and social conditions in this country, and soliciting public input on changes is appropriate and necessary.

However, we have concerns over the Department’s assessment of Question No. 12 asking respondents to “print below the specific major(s) of any BACHELOR’S DEGREES this person has received.” We cannot agree that Question No. 12 qualifies as a “low benefit” question. We strongly urge the Department to commit to retaining this question in all future editions of the ACS.

Click here to download our full Comment.

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The Case for Payroll Withholding: Preventing Student Loan Defaults With Automatic Income-Based Repayment

Read and download the report here:


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Got Covered in 2014? Stay covered in 2015! (California)

Renewing Your Plan_CA_10.27.14

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Got Covered in 2014? Stay covered in 2015! (National)

Renewing Your Plan_FFM_10.20.14

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Comment: Disclosure of Consumer Complaint Narrative Data

September 22, 2014
Monica Jackson
Office of the Executive Secretary
Consumer Financial Protection Bureau
1700 G Street NW
Washington, DC 20552
(submitted via

Re: CFPB-2014-0016, Request for Comment on Disclosure of Consumer Complaint
Narrative Data

Dear Ms. Jackson:

Young Invincibles is a national non-profit, non-partisan organization that amplifies the
voices of young adults ages 18 to 34 to expand economic opportunity for our generation. We commend the Consumer Financial Protection Bureau (Bureau or CFPB) for bringing attention to challenges facing consumers. In particular, the Bureau occupies a critical role in addressing poor student loan servicing. We have found that harmful servicing practices by both government and private servicers affects millions of borrowers across the country. CFPB has done a great job providing a space for consumers to log complaints, processing those complaints, and disseminating them through semi-annual reports. As a result, we have encouraged many individuals to file complaints with the Bureau. Borrowers feel a sense of relief when they know that they have a place to turn.

We thank you for the opportunity to comment on the decision to allow borrowers to make their complaints regarding private student loan servicers public. We believe this choice will spotlight poor loan servicing practices to the public ultimately leading to improved servicing quality. The Bureau should expand disclosure to include unstructured consumer complaint narrative data (‘‘narratives’’) for the following reasons:
1) Publically monitoring these complaints improve student loan servicing.
2) Public narratives are integral to the work of consumer advocates.
3) Borrowers themselves have a lot to gain from reading public narratives.

Click here to download YI’s full Comment on the Disclosure of Consumer Complaint Narrative Data.

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A Federal Work Study Reform Agenda to Better Serve Low-Income Students

Decades ago, a young person could graduate from high school, join a company, and receive all the training on the job that she or he needed for a successful career. Today, the world is different. A young man with only a high school diploma now earns 75 cents on the inflation-adjusted dollar his father made in 1980. Even worse, a brutal recession and sluggish recovery has young people confronting double-digit unemployment rates. Fierce competition for entry-level positions requires our generation to not only acquire post-secondary education, but also gain on-the-job experience and skills. Approximately 79 percent of employers expect real-world experience from college graduates when they evaluate potential hires. Unfortunately, our higher education system is not built to meet this need, particularly for low-income students.

An updated Federal Work Study (FWS) program could help a great deal. Congress created FWS in 1964 as a part of the Economic Opportunity Act to allow low-income students to defer college costs by working while enrolled. In 2011-2012, the Department of Education allocated $972 million to over 3,000 schools, serving slightly more than 700,000 students. However, FWS could be more effective at serving those in need of financial support. Only 16 percent of institutions awarded Federal Work Study to every eligible student. During 2011-2012, only 16.4 percent of dependent students whose families make less than $20,000 received FWS aid, while 8.2 percent of dependent students with family incomes over $100,000 received FWS aid.

This report recommends reforming Federal Work Study to better serve low-income students working their way through school, and providing them with experience and skills for today’s economy.

Click here to download A Federal Work Study Reform Agenda to Better Serve Low-Income Students.

Federal Work Study Reform Agenda Sept 18_Page_01

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