The Council of Australian Postgraduate Associations has a paper out today opposing the government’s legislation that would cap HELP debt at $104,000 for most students, or $150,000 for students taking the high-end health courses. A media summary is here.

There is already a similar cap for students borrowing under the full-fee student HELP program, FEE-HELP.  The legislation would count HECS-HELP borrowing towards the total – this is the loan scheme used by the vast majority of domestic undergraduates paying student contributions for Commonwealth supported places.

Contrary to the impression given by the media article, adding in HECS-HELP would be prospective, only applying to debt accrued after 1 January 2020.

CAPA is right that a cap will tip more students into an at least partial up-front fee market. But given HELP’s overall design, this is not a knock-down argument against it.

As I have long argued, HELP has substantial costs in doubtful debt. And although the big debtors tend to be in fields with relatively good earnings prospects, the more someone owes the greater the risks for taxpayers – both because of the total amount owed, and because of the danger that the debtor will not spend long enough earning an income above the repayment threshold to repay in full.

Especially when it is hard to control costs by reducing repayment thresholds or abolishing the deceased estate HELP write-off, that creates pressure to reduce high-risk debt by limiting what students can borrow. The government can’t lose what it doesn’t lend. We are already seeing this in other parts of the system.

Loan caps can also usefully serve as soft fee caps in the fee-deregulated parts of the system. CAPA notes that even the current FEE-HELP cap isn’t enough for some JD courses. But if some universities are charging exorbitant fees for law courses that isn’t something public policy should encourage, especially when the fees end up being subsidised through HELP debt write-offs. There are plenty of much cheaper law courses out there.

There is room for debate about exactly what the cap should be. But $104,000 would allow most students to do an undergraduate degree and professional development postgraduate courses. In an amendment proposed by the government, debtors could replenish their cap by paying off some of their existing debt.

If we completely re-worked HELP, we could take a more actuarial approach to lending at higher levels – allowing it for low-risk borrowers, declining for high-risk borrowers. But that would be a radical conceptual change to HELP, with discipline, age, and gender all likely to significantly influence actuarial risk.

Staying within HELP’s current conceptual basis, we need general rules that support reasonable amounts of study but protect taxpayers from courses with excessive fees and from perpetual students. A cap on outstanding HELP loans is one such rule.