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Policy Analysis Paper
The Catholic University of America
National Catholic School of Social Service
SSS 582: Social Welfare Policy and Services II
Dr. Donaldson
March 17, 2015
Problem Description
The D.C. Promise Establishment Act (D.C. Promise Act) aims to address the fact that a
significant proportion of D.C. residents are unable to afford higher education. In 2013, almost
30% of children in D.C. lived at or below the federal poverty level, as compared to 22% of
children nationally (Annie E. Casey Foundation, 2013). Additionally, a recent study conducted
by Pew on college attendance indicates that nearly half of respondents ages 18-to-24 who did not
go to college state they did not attend college because they could not afford it (Taylor et al.,
There are two central causes of the inability to pay for college. Firstly, family income in
all socioeconomic statuses has declined in the past ten years, except for families who have
incomes in the top 5% of the nation, making college even more difficult to afford for most
families than in prior years (College Board, 2014). This has been exacerbated by the second
central cause: the price of college has increased disproportionately compared to other goods and
services (College Board). In fact, the tuition and fees of public colleges have tripled and private
colleges have increased by two and a half times since 1984 (College Board).
Not being able to afford college, and therefore not attending, has deleterious economic
consequences. Firstly, the unemployment rate is higher for individuals with only a high school
education (Manganaris, 2013). In 2012, the unemployment rate in D.C. was seven times higher
for residents with only a high school degree than for those with at least a bachelor’s degree
(Manganaris). Additionally, lifetime earnings are lower for those without a post secondary
degree; the median income for families headed by someone with a post secondary degree is more
than twice that of families headed by someone without a post secondary degree (College Board,
An important trend that has exacerbated the problem is the rising importance of college
degrees. As the skill level for jobs increase in the United States, so has the need to have a college
degree (Executive Office of the President, 2014). In fact, nationally the proportion of jobs
requiring at least a college a degree has doubled over the last 40 years (Executive Office of the
President). The increasing value of having a college degree is not only pervasive on the national
level, but also in D.C. Estimates indicate that 76% of jobs in D.C. will require a college degree
by 2020 (Carnevale, Smith, & Strohl, 2013).
The most relevant example of how D.C. has addressed college affordability in the past is
the Tuition Assistance Grant Program (TAG). TAG, which was introduced in 1999, awards up to
$10,000 to pay the difference in cost for in-state and out-of state tuition to public universities
(Office of the State Superintendent of Education, n.d.). It also provides up to $2,500 to private
colleges in D.C., Historically Black Colleges and Universities, and two-year colleges (Office of
the State Superintendent of Education). The most notable differences between TAG and the D.C.
Promise Act is that TAG funds are primarily used for public universities, the grants are not
determined through means testing, and TAG does not require the student to remain a District
resident throughout college.
Major Provisions of the D.C. Promise Act of 2014
The D.C. Promise Act has two main provisions (D.C. Promise Establishment Act of
2014). Firstly, it provides grants for tuition and non-tuition expenses to attend institutions of
higher education for D.C. residents who have graduated from high school in the past three years.
Additionally, the act establishes a grant program for the pursuit of secondary education and
training for D.C. residents who exceed the age limit of the aforementioned grant program, which
is 24 years of age. Given that the Mayor has not yet established the eligibility criteria nor award
levels for the adult education grant, this analysis will solely focus on the aforementioned
A goal is “a statement of desired qualities in human and social conditions” (Chambers &
Bonk, 2013, p. 42). It aims to explain the purpose of a program or policy (Chambers & Bonk).
The goal of the D.C. Promise Act is to “assist individuals in obtaining post-secondary education
or training” (D.C. Promise Establishment Act of 2014, p. 2). This is accomplished by providing
students with grants for higher education to cover costs accrued during school, including both
tuition and non-tuition expenses. The D.C. Promise Act addresses the problem as outlined by the
bill; students in the District do not have enough money to pay for higher education. This policy
addresses that problem by giving students money to pursue their education. But the D.C. Promise
Act does not address the underlying causes of this problem: rising tuition costs and declining
family incomes. Each year, the price of tuition increases 8.3% for public universities and 4.5%
for private universities (U.S. Department of Education). While providing funding to students
certainly assists with the financial burden of paying for higher education, it is not helping to
reduce the trend of rising tuition prices, nor does it immediately help to reduce the overall trend
of declining income.
Forms of Benefits and Services
The grants for higher education provided through the D.C. Promise Act are considered
consumer subsidies. According to Chambers and Bonk (2013), consumer subsidies are payments
made to a third party “to provide an indirect benefit to a particular population group so as to
serve the national self-interest” (p. 66). In this case, the D.C. government will make direct
payments to the university or college of the student’s choosing.
The benefits provided through the D.C. Promise Act will be analyzed in regards to
consumer sovereignty, substitutability, and stigmatization in turn. Chambers and Bonk (2013)
define consumer sovereignty as the degree to which recipients are able to choose how a benefit
will be used. Consumer sovereignty is relatively high in this act due to the fact that students are
able to use the tuition portion of the grant at (nearly) any non-profit private or public college or
university in the country. It is important to note that consumer sovereignty is slightly threatened
because students can only use the non-tuition portion (not the tuition portion) of the grant at
institutions of higher education that already receive funding from the preexisting TAG program.
Consumer sovereignty is less clear in regards to the non-tuition expenses portion of the grant due
to the fact that the Mayor has yet to establish these guidelines in rulemaking. Should students be
able to use the grant money for any expenses they incur while attending an institution for higher
education, consumer sovereignty would remain high.
According to Chambers and Bonk (2013), substitutability is the extent to which a
recipient is able to use a benefit for a purpose that was not intended by the policymaker.
Substitutability for tuition expenses is very low due to the fact that the D.C. government gives
the money directly to the college or university that the student will attend. Therefore, the student
does not have an opportunity to use the funds for anything except tuition. However, because the
guidelines of non-tuition expenses have not yet been defined, the risk of substitutability may
increase depending on how funds are administered. For example, if funds are given as cash to the
student, he or she could use the cash for an unsanctioned purpose.
Chambers and Bonk (2013) define stigmatization as being “marked as having lesser
value, to bear the burden of public disapproval” (p. 91). The risk of stigmatization in this act is
very low due to the fact that the money goes directly to the college or university, and therefore is
not a payment that the student has to transfer in a public space. While the act does not delineate
the application process for the grant, one can assume that the application for the grants will be
the same format as TAG, which is conducted electronically and therefore relatively privately; the
applicant does not have to apply in a facility that would indicate they are applying for grant
Eligibility Rules
The target population of this policy is students enrolled in secondary schools in the
District. However, there are many eligibility rules they must follow in order to be eligible to
receive funds from the program. The student must be younger than 24 years of age, must have
graduated from a secondary school within the District for grades 9 through 12, have obtained a
diploma or equivalent, or be homeschooled within the District. In addition, students must have
been accepted by an institution of higher education on at least a part-time basis, not already
obtained a bachelor’s degree, and have been domiciled in the District for at least 12 months. The
student must also have exhausted all other forms of financial assistance. Lastly, the student must
come from a family with an annual taxable household income of 200% or less of the Area
Median Income (AMI).
The eligibility rules will be analyzed in terms of target efficiency, stigmatization,
adequacy, and equity in turn. Target efficiency measures whether or not the benefits and services
of a policy are being directed to the population the policy intends to serve (Chambers & Bonk,
2013). In the case of the D.C. Promise Act, the target efficiency is high. The population is
determined using means testing, which consists of totaling income or assets and seeing if that
total is less than the outlined criteria (Chambers & Bonk). For example, in the D.C. Promise Act,
the student’s family must make less than 200% of the AMI and ensures that the funds are only
provided to those in the targeted population.
According to Chambers and Bonk (2013), eligibility criteria should aim to have low
levels of stigmatization, so people will feel secure using the services or benefits offered. In the
case of the D.C. Promise Act, the threat of stigmatization is very low. The eligibility criteria
allow a large number of students from a wide range of socioeconomic statuses to qualify for this
program. If many people (including those that are relatively wealthy) are involved in the
program, then the chance of feeling singled out is diminished.
Lastly, eligibility rules can be analyzed in terms of adequacy and equity. While the D.C.
Promise Act attempts to bridge the gap between lower and higher income students in terms of the
ability to go on to higher learning, it does not seem entirely adequate. One of the main points of
the D.C. Promise Act is that the funding a student receives can be used at a private university,
while TAG funding cannot. The average cost of tuition each year at a private, four-year
university is $30,094 (College Board, 2014). The most a student can receive, if they are at the
lowest bracket of household income (up to 80% of the AMI) is $7,500 per school year, unless
they have been in foster care, which allows for receiving $10,000 per year. That leaves
approximately $22,500 unaccounted for in tuition payments. Even though students must apply
for all other forms of financial aid first, the amount of funding from this program may still not
cover all expenses. When interviewing a current D.C. resident (a 24-year-old mother) about the
D.C. Promise Act, she said the funds offered by the act would be helpful for her, but she
imagines it would not be sufficient for lower-income families.
Chambers and Bonk (2013) state equity is fulfilled when “similarly situated citizens [are]
treated similarly by a social policy or a social program as a matter of fairness or justice” (p. 57).
The D.C. Promise Act is equitable given that eligibility is determined through means testing; the
amount of money a student receives is directly tied to his or her household income. However,
equity is threatened because the amount a student receives does not meaningfully change relative
to household income. For example, if a student comes from a household making 79% of the AMI
(therefore falling into the highest need category of up to 80% of the AMI) he or she will receive
$7,500 per year. A student coming from a household making exactly 81% of the AMI (therefore
falling into the category that is at least 80% of the AMI, but less than 125% of the AMI) will
receive only $5,000 per year. The policy would be more equitable if the grant money was more
proportional to household income.
Administration and Service Delivery Structure
The D.C. Promise Act provides very minimal information regarding its administration. It
merely states that the Mayor shall, “administer D.C. Promise and may enter into a grant,
contract, or cooperative agreement with another public or private entity for the management of
the program if the Mayor determines that doing so would provide for a more efficient
administration” (D.C. Promise Establishment Act of 2014, p. 2). It goes on to stipulate that
should the Mayor enter such an agreement, the organization must have had at least five years of
experience with college scholarship administration. Presumably this organization would also
handle evaluating and coordinating the policy.
Given this limited information, the writers will discuss relevant considerations of the
policy’s optimal administration beginning with accessibility. To optimize accessibility applicants
should be able to apply for the grant both online and in-person; and as the interviewee posited, it
is critical that applications and instructions be available in multiple languages. Furthermore,
there should be over-the-phone assistance for those who are technologically inept, but do not
want the stigma of applying for the benefit in person. The interviewee also contributed that at the
most basic level, it is critical to accessibility that all students in the District know the funds exist
(given that she had not heard of the program). She proposed that representatives from the
administering entity visit every high school in the District to explain the program to both
students and guidance counselors.
Chamber and Bonk (2013) state the importance of organizational accountability in policy
administration. Having each application reviewed and signed by a designated reviewer can
ensure accountability. Should an applicant refute the decision to not be awarded the grant, the
reviewer can present the case for why the application was denied in a formal hearing. However,
it is noteworthy that the eligibility rules are very straightforward for this benefit (given that there
is no professional nor administrative discretion); therefore, challenging a decision should be a
relatively rare occurrence.
Sensitivity to racial, gender, and ethnic diversity is critical in the administration of all
benefits. As Chambers and Bonk (2013) posit, the organization that administers the D.C.
Promise Act would optimally have a staff that reflects the demographic diversity of the D.C.
residents who receive the benefit. Should this not be possible, Chambers and Bonk advocate for
consciousness raising among staff to ensure applicants from all backgrounds feel comfortable
receiving services. It is important to note that how the benefit is ultimately administered will
dictate the amount of interaction between staff and applicants. If the whole application process is
conducted over the Internet, it is feasible that an applicant may never interact with an
administrator. In this case, the relevance of cultural sensitivity in in-person interaction is less
The fact that the administration and service delivery structure have not yet been
determined provides an opportunity to meaningfully engage D.C. residents in the decisionmaking process. Optimally, the Mayor would develop a council with a significant number of
seats given to potential grant recipients so that those who will receive the grant can provide input
about the most convenient ways to apply for and access the grants. Meaningfully contributing to
these formative decisions can serve as an empowering experience for potential grant recipients.
Financing Mechanism
The D.C. Promise Act is a federally funded grant program (DeWitt, 2014). The higher
education grants will cost an estimated $7.8 million in FY2015 and approximately $42.6 million
over the next four-years (DeWitt). Once the program is fully implemented, it is expected to cost
approximately $25 million each year (DeWitt). The level of funding greatly impacts the
adequacy but not the equity of the program. In terms of horizontal adequacy, the program seems
poised to provide funding to all eligible students. The projections and budgets laid out in the
fiscal impact statement appear conservative given that estimates assume on-time graduation
rates, which likely overestimate the number of applicants. However, the vertical adequacy of the
program could be dramatically changed if funding for the program were cut. Less money would
be available to provide to students, thus causing the program to be less adequate in providing for
their higher education. Conversely, cutting funding should not affect the equity of the program,
because of its use of means testing.
In terms of the D.C. Promise Act, one can expect continuous, but not stable funding;
meaning the money for the program may be reduced during an economic shift. When the
government needs money, such as in a recession, education programs often have their funding
reduced (Oliff, Mai, & Leachman, 2012). For example, despite the fact that TAG has had
continuous funding since its introduction, the program endured a dramatic cut in funding due to
federal reductions in spending (Barras, 2013). Thus, if the economy experiences another
recession, it seems likely that the D.C. Promise funds will suffer.
In an attempt to strengthen the policy and make it more consistent with social work
values, the policy should focus more on equity. As it currently stands, a student can come from a
household making 200% of the AMI and still qualify for the D.C. Promise funds. To better serve
the population, the policy should focus only on those students coming from households making
the lowest qualifying household income of 80% or less of the AMI (DeWitt, 2014). This would
allow the most needy students to receive more money, and would be especially important if
future recession cuts funds and limits the number of students who can receive grant money.
The interviewee contributed a useful recommendation that would allow the act to not
only remove financial barriers to college, but also potentially increase the number of graduates
who qualify for college. She proposed adding an additional fund that would incentivize high
grades. For example, a student with a certain grade point average would qualify for a full ride at
the institution of his or her choosing. The interviewee understood that financially, this may not
be feasible, but still sees the merit of such a provision.
In conclusion, this analysis of the D.C. Promise Act has implications for both social work
practice and research. In terms of practice, this policy highlights the high level of financial aid
needed by students in the District. This knowledge can help to inform social work practice. For
example, when working with a student from a low-income family in the District, being aware of
this policy can hel …
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