A substantial amount of attention has been focused on student debt this fall, especially by President Obama and each of the frontrunners for the Democratic ticket. In their view, debt is due primarily to the rising cost of a degree, a byproduct of the failure of colleges and universities to exercise effective management and control costs.  The administration, and Secretary Duncan in particular, see in this a need for "greater accountability." 

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In taking a closer look at these assumptions, a different picture emerges. For instance, current student debt ($1.2 trillion) may have less to do with the cost of tuition than the state of the economy. Multiple studies, including one conducted by the New York Federal Reserve this past spring, support this argument.

These factors include:

    1) The inclusion of graduate student borrowing in aggregate debt totals. While graduate students account for only 10 percent – 12  percent of borrowers, they hold by some estimates around 40 percent of outstanding loans. Needing to attend school full-time, these future doctors, lawyers, dentists and future university professors borrow to cover their living costs, as well as their higher rate of tuition.

    2) Using student loans to pay off other debt. The number of students enrolled in college remains near an all-time high, and, due to the Great Recession, many of these borrowers have had to use their student loans to bridge the gap created by the decline of savings, investments and home equity. The New York Federal Reserve reports that from 2004-2014, there was an 89 percent increase in borrowing and a 77 percent increase in the amount borrowed. Interestingly, those over 40 have increased the rate of borrowing at twice the rate of younger students. This is consistent with the growth in graduate student debt.

    3) "Over-borrowing" has become a significant contributor to the record debt level.  In studies conducted by both the New America Foundation and the Brookings Institute, it has been found that students tend to borrow more than they need, not wanting to go through the borrowing process more than once.

    4)  Poor lending practices.  The Federal government has issued loans amounting to hundreds of thousands of dollars without regard to credit history, collateral, or expected ability to repay (unlike cheaper certificate programs that must meet strict "Gainful Employment" criteria). 

But what about tuition growth?

According to the U.S. Department of Education statistics, the average cost of tuition, plus room and board, at a four-year public institution was $10,385 in 1982 – or $25,646 in today’s dollars. That’s $1,774 MORE than the actual average cost of $23,872 in 2012, the most recent data made available by the department for comparison.

That average tuition costs fall below forecasted levels is particularly remarkable in light of the new costs that have been added to college budgets. Public institutions have increased tuition to off-set cuts in state support (all 50 states reduced their allocations following the start of the Great Recession), as well as increased regulatory compliance costs for all, as higher education has been hit with a tsunami of new rules and regulations from the federal government.

Of course, accreditors have also been caught in the crosshairs, especially among the candidates for president. Sen. Marco RubioMarco Antonio RubioOvernight Cybersecurity: Bipartisan bill aims to deter election interference | Russian hackers target Senate | House Intel panel subpoenas Bannon | DHS giving 'active defense' cyber tools to private sector Senators unveil bipartisan push to deter future election interference Puerto Rico's children need recovery funds MORE (R-Fla.) has gone so far as to characterize the accreditation community as akin to a “cartel,” stifling innovation and denying students access to alternative, lower cost educational providers. In this view, accreditors work to artificially prop up college costs on behalf of their members. Nothing could be further from the truth.

Rubio’s proposal offers a new way to expedite access to Title IV monies for alternative providers of quality instruction; however, this is neither as new nor unique as some would have us believe. A variety of “national” accreditors, with less restrictive standards, have been available to provide a similar function for decades. Nonetheless, if the emphasis of any new process is truly on “quality” and not just gaining easier access to federal dollars, everyone will win – including regional accreditors and America’s higher education – as they continue their focus on adding value to traditional credentials.

There is simply no data to support the belief that higher education is becoming more expensive because of mismanagement or failures of cost containment. The idea that both the six regional accreditors and the CEOs of more than 7000 Title IV eligible institutions have simultaneously and collectively failed in their stewardship is both incredulous and insulting.

Yes, accountability is important, especially as college and university presidents take on incredible challenges to the long term sustainability of their institutions. But we need even greater accountability on those who are increasing the cost of education through over regulation and lax lending policies.

Ebersole is president of Excelsior College, a private, nonprofit, distance learning institution based in Albany, NY.