To protect the identities of schools, data presented in this section (e.g., percent free-or-reduced-price lunch) were rounded; all school and personnel names are pseudonyms. School numbers and pseudonyms are used interchangeably.
Part of Michigan’s AP program expansion in the last 10 years included subsidizing exams for low-income students at or at least $5. The term “at least” introduced ambiguity in state-level documents that, though seemingly negligible, ultimately shaped schools’ implementation of this policy in practice. Despite MDE memos suggesting low-income students pay $5, schools had a wide range of exam fee structures. Some schools did not experience challenges setting the subsidized price at or below $5. Three schools reported charging $5—with Curtis High School citing “state legislation” for doing so. Another group of nine schools did not charge FRL students for AP exam-taking in a bimodal fashion. The first set of schools were generally high-resourced, with a combination of few FRL students (10% or fewer) and additional resources (e.g., discretionary funds) from which to draw upon. The second set of schools were typically considered low-resourced high schools with a large FRL population (60% or higher); these schools had additional Title I funding to absorb the exam costs.
In contrast, almost half of our sample (N = 13) reported they charged FRL students more per exam—as high as $25 to $50 (see Table 3). Schools in this category fell in what we termed the less-obvious murky middle: they served a considerable population of FRL students, but most did not qualify for additional government subsidies. These schools may not have had resources necessary to offset all the costs associated with administering exams for their sizable FRL populations. In the following sections, we enumerate the major challenges that limited the ability for resource-strapped schools to implement the $5 fee policy with fidelity and discuss how school personnel beliefs shaped price-setting.
Challenges to Implementation
While we did not initially set out to examine the implementation of Section 94 in Michigan, the between-school variation in exam pricing and its implications for class-based inequality in exam taking warranted an investigation of school price-setting processes and rationales. We found three major areas in which uncertainty and ambiguity in the nature of the policy compromised the aim to reduce financial barriers for low-income students.
Challenge #1: Uncertainty of Legislative Subsidy and Timing
One challenge for schools to execute a price-setting strategy was year-to-year uncertainty about whether, when, and how much subsidy the legislature would approve. School personnel depended on these legislative decisions to set and advertise subsidized prices, register students, and manage payments (including payment plans) traditionally between December and March. Until the appropriations bill passed, schools could not be certain whether they would receive any funding to subsidize AP exams. To assuage some of these concerns, MDE noted past funding support in their written and verbal communication to districts. In conversations with us, MDE noted Section 94 received bi-partisan support, making defunding unlikely.
However, three facets of the funding process made school personnel uneasy. First, some school personnel perceived this year-to-year approval as precarious. As one AP Coordinator expressed, “we typically cross our fingers” [104-1] when referring to whether the state would allocate funds to offset exam costs. School personnel expressed relief that the state “come[s] through,” however delayed [104-1], but also noted that “you just don’t know” [016-1]. Another AP Coordinator shared: “[The state]… They've talked about removing the help each year for a long time now” [118-1]. Second, delays in the legislative process heightened uncertainty. For example, disagreements over the appropriations bills for FY2019 delayed its passage until December 2019, substantially altering the typical August approval (Gibbons, 2019). Third, the level of subsidization from the state sometimes fluctuated—in AY 2017–2018, the amount changed three times over a 4-month period, resulting in three memos from MDE. School personnel shared they were unclear about the state’s portion of the cost-sharing agreement, which made it difficult to set prices and order exams.
The response to these uncertainties varied by school. Some schools noted they could absorb the costs should the state not meet their share. In contrast, other schools intentionally set exam prices to create stability. A counselor from Quayle High School—that has 25% FRL—explained:
If we were one of those schools that said, we're going to charge you the $5 and then it came back to us that, no, they're not going to give it to the kids for $5, then absolutely that would affect—If I worked in a district that was higher free and reduced lunch, it would totally affect that process because how could you know what to charge the kids? But for me, luckily we, since we charge at [$]25, it doesn't affect me because I keep it pretty stable.
This participant drew attention to the ways resources and demand matter by distinguishing between Quayle and districts with greater shares of low-income kids (and arguably greater demand for fee subsidization). Especially for schools in the murky middle, if school personnel set exam prices with an assumption that past funding levels would continue, a decrease in state appropriations would necessitate additional fees or redistribution of scarce resources in order to balance the books. This counselor offered a solution to this instability in funding (whether perceived or real) by setting a price well above the minimum $5 fee, thus hedging their bureaucratic processes against potential shocks. For low-income students, however, a $25 exam fee may hinder their ability to take one—say nothing of multiple—exams.
Challenge #2: Unaccounted-for Costs
MDE calculated their per-student contribution so the presumed balance for low-income families totaled $5. This calculation used the registration fee charged by College Board (e.g., $94 in 2018–2019) as their benchmark. However, this approach did not account for the numerous, and sometimes substantial, costs associated with AP exam administration. In this section we outline two unaccounted for costs: unused test fees and the (actual) cost of test administration.
Unused Test Fees
When setting AP exam prices, some schools factored into the price an unused test fee—a penalty charged by College Board when students registered but did not attend their scheduled exam (i.e., $15 in 2018). Neither College Board nor state subsidies covered this no-show fee for low-income students. Therefore, schools could potentially absorb this required penalty fee if a low-income student did not sit for the exam.
To mitigate this potential financial risk, some schools included the price of the unused test fee when establishing their exam price. In the AP Coordinator’s Manual, College Board suggests schools can collect student deposits for the unused test fee (College Board, 2018). As one example, the AP Coordinator at Curtis High School—with 30% FRL students—historically charged low-income students $20 per exam because that amount “covers the cost of ordered tests that end up not getting used.” Collecting deposits, however, can require additional administrative burdens. After this AP Coordinator collected a deposit from low-income students, for example, the coordinator would then either collect additional fees or issue refunds depending on the final subsidization amount from the state. However, not all schools treated the unused test fee as a deposit. Polk High School (another school with 30% FRL students) charged low-income students $15 to pass along “the unused test fee, just as a precaution” but did not later issue refunds. Despite offering the unused test fee as the rationale for the price of their AP exam, in the case of Polk and others, the school did not return the fee if students sat for the exam.
The (Actual) Cost of Test Administration
A potentially larger challenge to implementing Michigan’s $5 exam subsidization policy, we found, was that the state-calculated subsidization level (e.g., $48 in 2018–2019) did not account for additional costs of test administration. In order to be compliant with College Board regulations around the examination process, schools must have proctors administer and supervise the exams and secure spaces in which students can take their exams undisturbed by bells or announcements (College Board, 2018). Due to these exam-testing parameters, some schools incurred additional costs (e.g., hiring proctors or renting space) to administer AP exams.Footnote 5 At Hobart High School, a school with few FRL students (10%), the AP coordinator detailed that with over “600” test-takers for one exam, they need “in the ballpark of 30 proctors.” Due to the growth in test-takers at this school, they had to “rent these janky tables” and have students test in other parts of the school (e.g., gym), which cost “thousands of dollars.” Their response underscored the increased complexity and cost for high schools that administer many exams. Indeed, many schools passed these costs onto examinees. At Hobart, non-FRL students paid $100 per exam, while data from school websites showed that some charged as much as $115 per AP exam.Footnote 6
Schools receive some assistance for test administration. College Board issues schools a rebate of $9 per exam specifically to help cover such costs after the final invoice is settled. However, College Board policy does not permit rebates for low-income students, presumably because College Board already subsidizes part of the exam cost. However, regardless of whether the exam is subsidized, schools bear the financial costs for low-income students that a rebate would cover otherwise. As the AP Coordinator from Hobart High School underscored, “That is just money we’re not getting.” In other words, for a school charging $115 per exam, the $48 state subsidy does not account for the additional $19 the school added to the $94 College Board price. If such a school passes this cost down to low-income students ($5 student fee plus $19 cost of test administration), the student would pay nearly five times the state-intended price ($24).
The ways in which schools handled administration costs varied. Some schools either incurred the costs or sought ways to reduce the overhead to administer exams. For schools in the murky middle, the decision to upcharge low-income students also depended on the school personnel’s focus on affordability and inequality. As the AP Coordinator at Washington High School, which has a sizeable FRL population (45%) explained, “We go bare minimum and if we have to do it, we have to do it, and we will find a way to make that extra money up somehow. We don't want to ever charge parents or families any more than we have to.” Washington High School did so by differentiating the price between free ($5) and reduced-price ($15) lunch students. However, another school (Fillmore) in the murky middle (50% FRL) upcharged both FRL and non-FRL students (to $20 and $100 per exam, respectively), so they could ensure there was “a little bit extra… in the kitty of the fund” just in case “the [state] funds weren’t there” when they had to settle the final AP bill. Thus, in the absence of additional resources and depending on the personal philosophy of school personnel in charge of exam-price setting, some schools in our study bundled these extra expenses in students’ exam fees, including those of low-income students.
Challenge #3: Un(Enforceability and Accountability) of AP Exam Price-Setting
Finally, a key challenge to implementation was the lack of enforceability and accountability of Section 94. First, MDE officials remained largely unaware that schools upcharged AP exams for low-income students. One state official noted that, with the exception of one school that reported adding a credit card processing fee:
If the school's adding additional costs, neither us nor College Board is picking up, and they shouldn't be charging the student… Now again, if I knew of schools that were doing that I'd probably have to give ‘em a call and say, ‘What are you doing?’
Because the state received the final invoice from College Board, they only saw the number of low-income students that registered for an AP exam. Therefore, the state does not know key facets of individual schools’ processes—from the fees charged and collected by school personnel to how they communicate about or identify low-income students for the subsidy.Footnote 7 Therefore, the state had no mechanism to know whether or how much schools charged low-income students and no way to hold schools (or districts) accountable.
Second and most importantly, MDE cannot mandate schools charge low-income students exactly $5. While the state legislature required a nominal fee from low-income students, MDE noted that the $5 is more of a “guideline” because “if we dictate it under school law, then whatever we say is a requirement we have to fund.” Given this inability to enforce a $5 fee, there were no consequences for schools that charged low-income students more than $5—including those who planned to charge 10 times the recommended price.
Together, (1) uncertainty of legislative subsidy and timing, (2) unaccounted for costs, and, (3) lack of enforceability and accountability of AP exam price-setting made it difficult to implement Section 94 and created conditions where school personnel wielded a great deal of discretion over setting AP exam fees. School personnel, as street-level bureaucrats, need to complete the complex and multi-faceted tasks of test registration and administration. Lipsky (2010) argues SLBs will privilege the organization and process above equitable access to services and goods. As such, they provide services so long as their own processes are not compromised. This perspective is perhaps most salient for SLBs situated in resource-strapped institutions (and a sensible explanation for why we observed price-setting that aligned with the cost for no-show exams). In the presence of ambiguous, unenforceable policies, they turned to values-based street-level policymaking. The resultant systems they devised, however, were not always in the best interest of low-income students.
SLBs Flex Their Rationales in AP Exam Fee Subsidization
SLBs will cope with their inability to service all clients adequately and the burden of having to ration services and deny clients through their own sense making (Chase, 2016; Lipsky, 2010). One way of doing so is to rationalize the process or subsidized price. In addition to the bureaucratic rationales provided in the section above that focused on their administrative tasks and budgets, school personnel also offered reasons based on their personal perspectives on subsidization and who should receive it. We start each section below by highlighting high schools emblematic of the skin in the game, outsized benefits, and fairness rationales, respectively. We selected these high schools to underscore the unintended consequences of ambiguous policymaking and the power that SLBs possess. We present these as a set of (rather than discrete) rationales upon which counselors drew, as our study participants oftentimes offered multiple reasons for their AP exam-fee policies.
Skin in the Game
Hobart High School has a robust selection of AP course offerings and roughly one-third of students take AP courses. With about one in every 10 students qualifying for free-or-reduced-price lunch, Hobart has a relatively small FRL population. The AP Coordinator at Hobart described their rationale for setting the exam fee at $15:
So we've set it at $15 per test for any students on free or reduced lunch, or any students that we're aware of…any additional financial hardship. Our thought there is it's a very discounted price and at least there's some kind of commitment to, ‘I'll be there. This is important.’ That idea that at least there's—usually, that's acceptable. And if there's any problem with that, too, we can work with the student, but that's what we set it at, $15.
Here, they rationalize that paying a nominal fee signals to students the exams should be taken seriously and solidifies a commitment to “show up.” The participant further explains, “I mean, if I'm generalizing, not that it's true with everybody, but some people, if it's just like, ‘Yeah, sign me up. It's free,’ then it's, even up to that day before, it's like, ‘It's no big deal if I don't show up.’” In referencing a hypothetically free exam, the AP Coordinator at Hobart suggests exam take-up would increase from less-serious low-income students. As such, the fee acts as an intentional barrier for students, which the coordinator suggested they can choose to remove for students (who qualify for free-or-reduced-price lunch or not) who absolutely cannot afford it.
Invoking the specter of moral hazard and requiring low-income students to have “skin in the game” was the most common rationale for charging low-income students for AP exams among our participants. Questioning low-income people’s morality, motivation, and deservingness can be one way SLBs cope with the rationing of services. For school personnel, this rationale was undergirded by the idea that without some “investment,” students would not take the exam seriously because they themselves were not paying for it—either they would be induced to sign up but perform poorly or register but not sit for the exam.
Importantly, there was little evidence from our study or others that subsidizing fees introduces moral hazard. The Fillmore AP Coordinator reported only 2 to 3 no-shows a year, adding it was usually the kids who were “paying the lower price” (i.e., low-income students). Moreover, although Quayle High School required parents to sign contracts that acknowledged the unused test fee and threatened to withhold report cards if fees went unpaid,Footnote 8 the counselor felt “lucky” that the students and families “[were] committed” and never missed an exam “on purpose.” This lack of evidence of moral hazard might be due to the subset of students that school personnel were concerned about—low-income students enrolled in the school’s hardest courses—would arguably have higher levels of motivation when engaging in college preparatory activities than most students. Nonetheless, the narrative of lack of commitment and no-shows was prevalent, despite very low cases or counselors not having “really assessed it or done any evaluation on it” [129-1]. In the eyes of resource-strapped school personnel, the possibility of these behaviors had consequences for their workload and ability to ration resources. Therefore, “skin in the game” rationales serve as a type of insurance to protect school personnel and their budgets.
The insurance is not only financial, but in the case of Fillmore High School, one of achievement.
I think the main reason why I wanted [the fee] to be a little higher was just, like I said, so there's some skin in the game. And then it put more seriousness on the test. Like kids, other students would be like, ‘Wow, it's only going to cost me…20 bucks to take it, you know, and I'll just try it. Whatever.’ …those are the ones that usually end up getting like ones and twos on the test. They don't score well… the kids who were more dedicated, paid full price.
Here, students’ income and academic ability are intertwined, and the participant equates dedication with ability to pay the full price. Because passing rates are a common metric used to judge high schools (e.g., on high school profiles used in college admission or on state data dashboards), such deficit perspectives of low-income student ability can manifest into pernicious pricing strategies that aim to keep low-income students out of the testing pool.
Fillmore High School serves a predominantly suburban, working-class community, with over half of students eligible for free-or-reduced-price lunch. Overall, they have very low AP course participation despite offering over 10 AP courses, and about two-thirds of AP course-takers sit for at least one exam. During our first interview, the AP Coordinator shared that she planned to charge low-income students $50 per exam that academic year. During our follow-up interview 13 months later, however, the AP coordinator revealed the subsidized exam fee was adjusted down to a more affordable $20 instead.
I wanted it to be different [$50]. But it was basically, we were trying to find a number that would be useful for our kids that would be within paying for the test…I think we felt like the $20 was a relatively good price for that range. And that's what we had to kind of match whatever the other high school was doing with our sister school. So I originally wanted it to be $50 because I think just part of me is like, ‘You're paying potentially for a college course, so that's pretty cheap.’
Another approach SLBs can use to cope with their rationing of services and goods is to abandon consideration of one’s ability to pay and focus on one’s ability to benefit. We found this rationale deployed when counselors shifted the frame from whether the exam fee was affordable for low-income families to the benefits of accruing college credits. When comparing a $15-to-$50 fee with the potential of earning college credits priced at thousands of dollars, some concluded the exam price was a bargain. When considering whether to price exams at $5, the counselor at Quayle High School rationalized,
But I do feel that there's that investment piece there that the parents are like, ‘Yeah, $25, this is what potentially my student could gain, and this is the comparison, $1500 at a community college or three grand at a four-year university, and this is what's saving them from it.’
The resultant fee was then deemed an acceptable price point—regardless of whether a low-income family can afford it.
However, this logic is faulty when the ability to benefit is conditional on successfully completing several interim steps (and, therefore, benefits are not guaranteed). In the case of AP exams, college credit can only be accrued if students are admitted to and enroll in a college that accepts their exam scores. However, the opportunities of successful completion of all these steps are structured differently across schools. In high schools with low or moderate exam-passing rates, few students will have the opportunity to realize the credit-bearing benefits of AP exams. Therefore framing AP exam fees in these schools as an outsized benefit is particularly problematic.
At Quayle High School—a small school that served a moderate level of low-income students (25% FRL)—school personnel upcharged the AP exam price for FRL students (to $25) while simultaneously discounting the fee for non-FRL students (to $60). Unlike other schools that passed down exam administration costs to students, Quayle—perhaps due to their small test-taking population—did not report any additional exam administration costs that may have strained the school’s available resources. Rather, their subsidization practices reflected a complex philosophy about fairness, uncertainty of state funding, and “skin in the game” rationale. As the counselor reasoned:
We discount it to $60…per test for students, regular students, and then we discount it to $25 for free-and-reduced lunch. Part of that reasoning is because last year we didn't know how much the state would supplement, and they ended up supplementing it to I think $5, but we still choose to do the $25 just because it's the investment of the family.
When asked whether FRL students received a refund after the school knew the state’s final subsidization level, this counselor stated: “We do not give them a refund. So we just charge the $25 as a part of their price.” Concerns over state funding contributed to the upcharge, but other philosophical reasons were the main drivers of this school’s price-setting decision, such as the “investment of the family.” With no test administration overhead, it is possible that the school may have profited from each test taken by an FRL student.
Notably, price-setting at this school did not just involve surcharges on FRL students, but also subsidization for non-FRL students. When asked where the funds for the $34 subsidy for “regular” students came from, the counselor explained:
I honestly don't know where the funding comes from…when I got this job they said, ‘We will discount the AP test as part of those funds.’ I'm sure it had something to do with state funding.
Importantly, the counselor at Quayle did not have a strong understanding of who “state funding” was intended to target. Although state funding played a role in AP exam cost-sharing for FRL students, the school’s fee structure was a large departure from the intended subsidization plan. Because Quayle may have netted funds from FRL student exams, it was possible these funds could then be used to cover exams for non-FRL students. When surcharges on FRL students effectively subsidize non-FRL students, they function like a regressive tax—a practice we deem “Reverse Robin Hood.”
The extent to which policymakers consider “fair” and efficient ways to allocate limited resources is the essential work of policymaking (Stone, 2011). Concerning fairness in subsidization, the goal is to distribute resources in a way that removes financial barriers for those unable to pay while charging everyone else full price. Conceptually, however, there may be a point at which the difference between fee subsidization and full cost is so large that the full-pay price is perceived as unfair. At this point, the notions of fairness are turned on their head, whereby the focal point becomes the harm incurred by the unsubsidized. At nearly $100 per exam, AP exam fees are ripe for such challenges to fairness, as many counselors believe the full cost of exams are unreasonably high. Particularly if students take multiple exams, paying several hundred dollars in exam fees might make it “difficult for some families that want to take full advantage of the program and have the opportunity to take more than one exam” [016-1]. Moreover, given the dichotomous nature of the eligibility requirements for the subsidy, students of moderate means who fell just above the free-or-reduced-price lunch cutoffs would struggle to afford the full-price exam fee, as the AP coordinator from Fillmore High School explained:
The kids that are not free and reduced lunch aren't rich... it's a hurt for them too. So it's hard for [parents] to hear, ‘Well, my kid has to pay 100 bucks…but because I make five grand more a year than my neighbor, they're only paying 20 bucks.’ ...There are a lot of kids who truly can't afford it. And there are a lot of kids who are just, they're maybe middle, like lower middle class, but just make enough money to be able to afford it.
We found some school personnel drew upon these notions of fairness and the cost of the full exam to consider the extent of their subsidy, as did the AP coordinator in Fillmore: “Let's make it somewhere more within reason. $50 is still half off. Where else do you get 95% off on something, ever?” Here, she perceived the subsidy as a “huge discount.” School personnel at Quayle High School took it one step further to actively find ways to close that gap between the two price points by potentially rerouting resources that could have otherwise gone towards low-income students to subsidizing full-pay students, while charging low-income students five times the state-recommended price. Together, counselors in some high schools leveraged their beliefs about skin in the game, the outsized benefits of AP exam-taking, and fairness to craft narratives and set pricing policies that ultimately harmed low-income students’ opportunities.