Thank you for your letter requesting that the regulations for the College Work-Study (CWS) program be amended to allow payment on a salary rather than hourly basis for graduate and professional students.

The statute describes the CWS program as a program of parttime employment. We feel that it is both usual and customary to pay part-time employees an hourly rate for actual time on the job.

Concerning your suggestion that graduate students be paid on a salary basis, while undergraduate students apparently would not, there is no statutory rationale for unequal treatment of this nature. The statute makes undergraduate, graduate, and professional students all equally eligible for CWS funds. It also provides that employment under the program must be made reasonably available to all needy students in the institution and that preference for employment must be given to the neediest students.

However, the next time we revise our regulations, your suggestion will be given every consideration.

Cordially

Ernest L. Boyet
U.S. Commissioner
of Education

STATEMENT OF JOHN CROWLEY, DIRECTOR, FEDERAL RELATIONS FOR SCIENCE RESEARCH OF THE ASSOCIATION OF AMERICAN UNIVERSITIES

Mr. CROWLEY. Thank you, Mr. Chairman. My name is John Crowley. I am director of Federal relations for science research of the Association of American Universities.

It really is in my former incarnation as a graduate student that I will be speaking to you this morning about the use of the Federal College Work-Study Program for Graduate Students.

In 1977, I completed a research project on the use of the Federal College Work-Study Program for Graduate and Professional Students by the 48 American universities which are members of the Association of American Universities. A published summary has been provided to the committee.

I will restrict these remarks to a brief review of recent trends in the support of graduate students and of my conclusions from that research project.

In the years since the passage of the Higher Education Act of 1965, the Federal role in graduate education and in the support of graduate students has been eclipsed by the need to address pressing needs for undergraduates.

I think it has been forgotten that graduate students account for 10 percent of total enrollment in colleges and universities. The extensive Federal fellowship and traineeship support that was available during the early 1960's has largely disappeared. While some Federal funds remain available for doctoral students, most of these are limited to advanced graduate students in the sciences who work as research assistants to faculty on funded research projects.

Other options are limited. Graduate students are ineligible for grant funds under both the BEOG and the SEOG programs, although I do believe a strong case can be made for a limited change that would allow SEOG recipients who are admitted to graduate and professional schools to be eligible for SEOG assistance through at least the first year of graduate study.

The graduate and professional opportunities program authorized under title IX is a small program targeted on racially and ethnically underrepresented populations. In 1978-79 only $8 million was available to make just 350 awards of $3,900 each. If the $15 million requested in 1980 is appropriated, this still will equal only a small fraction of the sum available for BEOG's. Institutional funds and funds from private agencies do provide some support, but private sources of support have also diminished.

In the face of this, Federal graduate student financial aid policies now force many graduate students to rely most heavily on loans. As a result, the number of students borrowing to finance their education has substantially increased between 1971 and 1975. The proportion of total dollar volume of guaranteed student loans awarded to graduate students in that period jumped from 11 percent to 18 percent.

According to the 1971-76 data of the National Research Council's doctorate record file, the number of students using loans as their most important financing sources has steadily increased.

As a result, the cumulative debt burdens of graduate students are growing significantly. Graduate students now seem to be expected to incur debts in amounts that strain their means. The present maximum that a student may borrow under the GSL and NDSL programs combined is $25,000, but it has been calculated that a beginning professional, with a salary of about $15,000-an assistant professor, for example-cannot reasonably be expected to service a loan in excess of $8,000.

Many graduate students complete their undergraduate educations with substantial debts of several thousand dollars. They then can afford to borrow only a small additional amount to help finance their graduate degree before exceeding a reasonable or manageable debt limit.

Prospective arts and science graduate students typically face difficult financial situations compounded by several factors: high expenses for undergraduate education, low or nonexistent student earnings and assets, families unable or unwilling to contribute to the graduate education of their children, no access to grant funds (BEŎG or SEOG), limited Federal fellowship opportunities, constricted academic career opportunities, and low salary prospects for the successful new faculty member.

All of this is compounded by the substantial foregone income that results from up to 6 or more years of graduate or professional training.

Consequently, the financial prospects facing a talented prospective graduate student in arts and sciences frequently are forbidding. The system seems now to favor those who either have the necessary financial resources or who can borrow in substantial amounts.

Many students fear, or simply cannot incur a major debt. Administrators working with these students know that this seems to be true particularly for students from low-income backgrounds.

The case for the Federal role in graduate education today rests not on the arguments of the sixties for the production of steadily increasing numbers of highly trained individuals, but on the need to provide for continued access and free choice for the Nation's most intellectually qualified.

Graduate education is not viewed as an entitlement; no one should, I believe, argue that everyone has a right to go to graduate school, or that there should be a graduate equivalent of the BEOG program.

Nor should we, under current circumstances, argue that total enrollments should be increased and that more students should be going to graduate schools. Proposals have been made to this committee to extend eligibility for student assistance programs to students enrolled in undergraduate programs on a less than half-time basis. That may be a desirable change in public policy.

I would argue, however, that it is at least as much in the Nation's interest that individuals who are pursuing a graduate degree be our most intellectually able and not our most financially able. This country's system of financial assistance should provide for the needy among those who have the ability to pursue advanced studies and training and who will become the Nation's leaders in the arts, sciences, and the professions.

One small, but effective way to address a part of the problem is to make some needed adjustments in the administration of the work-study program that would encourage its use for graduate and professional students.

RECOMMENDATIONS-A REAFFIRMATION OF INTENT

From the time the work-study program was created in 1964 as part of the Economic Opportunity Act, the law has made undergraduate, graduate, and professional students eligible for the funds. Thousands of graduate students have received work-study funds. Many work in jobs directly related to their studies. Over the years, the number of graduate students receiving work-study assistance while small, has steadily increased.

According to a 1977 report by the American Council on Education, in 1976-77, 5 percent or 35,000 of all work-study recipients (698,000) were graduate students. In public universities, 10.8 percent of work-study students were graduate students and in private universities 16.7 percent of students receiving work-study were enrolled in graduate and professional programs.

The growth in the use of the program at the postbaccalaureate level is encouraging, but much remains to be done to inform students, their graduate and professional schools and others of the availability and potential of this program and to encourage Federal program administrators to foster the use of the program for graduate and professional students.

Therefore, I would urge the committee to include in its report a strong reaffirmation of the role of the work-study program for graduate and professional students and to encourage graduate and professional schools and student aid officers to develop the untapped potential of the program. This committee should encourage Federal program managers to take the steps necessary to enhance the use of the program for these students.

A strong reaffirmation by this committee of your intention in this area I believe would make a difference. It is fair to say that despite a law which clearly states that graduate and professional students shall be eligible for work-study and a long, clear congressional record of support for the program, confusion remains among graduate and professional students, their schools and student financial aid administrators. A restatement of congressional intent for this dimension of the program would be timely and helpful.

PAYMENT ON A SALARY BASIS

Second, I would urge the committee to direct that the regulations-section 175.24(a)-be amended to permit universities the option of compensating graduate and professional students on a salary basis. Current regulations require that students aided with work-study funds be paid hourly wages.

Time cards or comparable recordkeeping and reporting mechanisms must be used by students and work reports must be certified by their supervisors. This causes institutions to restrict work-study employment to less than professional jobs and to construct convoluted nonstandard payment procedures for compensating graduate students with work-study funds.

Not all, but many undergraduate students hold work-study jobs in libraries, food service departments, and similar activities where hourly wage reporting is reasonable and appropriate. For them, current regulations and time-keeping systems are entirely satisfactory. But many graduate and professional students are employed as junior professionals. They often serve as colleagues to faculty and serve as teaching and research assistants.

For many of them and for their faculty supervisors, hourly time reporting is an impediment to the use of the program. It just doesn't fit the circumstances of their employment, or their relationship with their supervisors. The hourly requirements are burdensome and impractical and are generally held by graduate and professional schools to be inappropriate for junior professionals serving in administrative, teaching or research-related positions. The use of the work-study program at the graduate and professional levels would be used if universities were given the option in the regulations to compensate graduate and professional students, as appropriate, on a salary basis. Of course, reasonable certification of effort and performance should be required.

It would be appropriate to require periodic, perhaps term, certification from faculty supervisors stating that assisted students have satisfactorily fulfilled professional responsibilities for which they were receiving work-study compensation.

Last year several higher education associations made this recommendation to Commissioner Boyer. The Commissioner declined to make the change because, he replied, "there is no statutory rationale" to differentiate between undergraduate and graduate students. For your information, a copy of our letter to him and the Commissioner's response has been given to your staff. I hope the committee will provide the statutory basis for this technical change in the regulation. No other change would do as much to ease the use of the program for graduate and professional students' need.

NEED

Third, because many graduate students find themselves unable to call on already strained family resources in financing their advanced education, it may be appropriate to provide the flexibility in the law to allow graduate students to receive work-study assistance, when funds are available, without regard to need.

While the law should retain priority for undergraduate and graduate students with the greatest financial need, it would enhance the use of the program at the graduate and professional levels if work-study funds were available to graduate students without regard to need where appropriations are sufficient.

A specific proposal on this point has been presented to the committee by the Association of American Universities, the Association of Graduate Schools and by the Council of Graduate Schools. I urge the committee to give it careful consideration.

Mr. Chairman, I want to thank you for the opportunity to present these views to the committee. I know that this committee has been a particularly strong advocate of the work-study program since it was created.