The Department of Education’s proposed regulation Improving Income-Driven Repayment for the William D. Ford Federal Direct Loan Program (Docket No.ED-2023-OPE-0004-0001) includes several changes likely to generate significant benefit for limited cost, but several changes where the costs are likely to outweigh the benefits. Focusing on improving student loan repayment outcomes for borrowers who could benefit from IDR but do not enroll would produce greater benefits at a lower cost than the proposed regulation.