Comment on FR Doc # 2013-11515

The executive summary states that the purpose of the stautory chages is to encourage to students to complete their academic programs in a timely manner. This regulation is unnecessarily burdensome for aid administrators to explain and students to understand when we already have a means of calculating a student who has exceeded 150% of program length (Maximum Time Frame). Would it not be more efficient for administrators and intuitive for students to end their subsidized eligibility once the student had reached the maximum time frame threshold for his/her academic program? Another option, as suggested by other commentors, is to limit the subsidized borrowing based on a set dollar amount related to program length. For example: 1 year certificate: $3,500 2 year associates:$12,000 (150% of $3500+$4500) 4 year bachelors:$23,000 (current aggregate limit) I am very concerned about how students will understand these calculation of 150% usage, particularly first generation and non-native English speaking students. Most new borrowers come in with the intention of completing in a timely manner, and the loan subsidy is unlikely to incentivize those who do not do so. If the intention is simply to reduce spending on the loan subsidy, there are more efficient ways to do that, such as reducing aggregate limits by program that are also easier to explain to students.