COLLEGE 

TEXTBOOKS

Students Have Greater 

Access to Textbook 

Information

Report to Congressional Committees

June 2013

GAO-13-368

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-368, a report to 

congressional committees

June 2013

COLLEGE TEXTBOOKS

Students Have Greater Access to Textbook 

Information 

Why GAO Did This Study

The rising costs of postsecondary 

education present challenges to 

maintaining college affordability. 

Textbooks are an important factor 

students need to consider when 

calculating the overall cost of attending 

college. In an effort to ensure that 

faculty and students have sufficient 

information about textbooks, Congress 

included requirements in HEOA

concerning publisher and school 

disclosures, as well as publisher 

provision of individual course 

materials. HEOA directed GAO to 

examine the implementation of the new 

textbook provisions. 

This report addresses (1) the efforts 

publishers have made to provide 

textbook information to faculty and 

make bundled materials available for 

sale individually, and how these 

practices have informed faculty 

selection of course materials; and (2) 

the extent to which postsecondary 

schools have provided students and 

college bookstores access to textbook 

information, and what the resulting 

costs and benefits have been. To 

conduct this study, GAO interviewed 

eight publishers representing over 85 

percent of new U.S. higher education

textbook sales, administrators at seven 

schools, four campus bookstores, two

national campus retailers, faculty and

student groups at three schools, and 

others with relevant expertise. GAO 

also reviewed websites of a nationally 

representative sample of schools, 

complaint data from Education, and 

relevant federal laws. 

GAO makes no recommendations in 

this report. The Department of 

Education provided technical 

comments, which were incorporated as 

appropriate.

What GAO Found

Publishers included in GAO’s study have disclosed textbook information

required by the Higher Education Opportunity Act (HEOA), such as

pricing and format options, and made components of bundled materials 

available individually, but stakeholders GAO interviewed said these 

practices have had little effect on faculty decisions. While most publishers 

in GAO’s study provided all relevant textbook information, two smaller 

publishers did not provide copyright dates of prior editions, and one did 

not provide certain pricing information. Publishers communicated 

information to faculty online and in other marketing materials, and in most

cases the information was available to students and the public. In 

addition, publishers said they began making bundled materials available 

for sale individually before HEOA was passed. Faculty GAO interviewed 

said they typically prioritize selecting the most appropriate materials for 

their courses over pricing and format considerations, although they said 

they are more aware of affordability issues than they used to be. Changes 

in the availability of options in the college textbook market that are not 

related to HEOA, such as the increase in digital products, have also 

shaped faculty decisions about course materials. 

Based on GAO’s review of a nationally representative sample of schools, 

an estimated 81 percent provided fall 2012 textbook information online, 

and stakeholders GAO interviewed said implementation costs were 

manageable and students have benefited from increased transparency. 

HEOA allows schools some flexibility in whether and how they disclose 

information and an estimated 19 percent of schools did not provide 

textbook information online for various reasons, such as including 

textbook costs in tuition and fees or not posting a course schedule online. 

Representatives of most schools and bookstores, as well as others GAO 

interviewed, said implementation costs were not substantial. In addition, 

there was general consensus among students and others GAO 

interviewed that students have benefited from timely and dependable

textbook information. Specifically, representatives of student 

organizations said they had sufficient information and time to comparison 

shop for their course materials before each academic term. 

Estimated Percent of Schools That Provided Textbook Information Online

View GAO-13-368. For more information, 

contact Melissa Emrey-Arras at (617) 788-

0534 or emreyarrasm@gao.gov. 
Page i GAO-13-368 College Textbooks 

Letter 1 

Background 4

Publishers Have Disclosed Required Information and Made 

Materials Available Individually, but Stakeholders Said These 

Practices Had a Limited Effect on Faculty Decisions 11

Most Schools Provided Textbook Information Online, and 

Stakeholders Said Students Benefited from Increased 

Transparency 16

Concluding Observations 22

Agency Comments 22

Appendix I Scope and Methodology 24

Appendix II GAO Contacts and Staff Acknowledgments 28

GAO contact 28

Tables

Table 1: Common Options for College Course Materials 5

Table 2: Characteristics of Schools GAO Interviewed and Specific 

Groups Interviewed at Each School 26

Figures

Figure 1: Estimated Increases in New College Textbook Prices, 

 College Tuition and Fees, and Overall Consumer Price 

 Inflation, 2002 to 2012 6

Figure 2: Communicating Textbook Information 9

Figure 3: Illustration of Unbundling under the Higher Education 

 Opportunity ActFigure 4: The Types of Textbook 

 Information Publishers Have Disclosed to Faculty 12

Figure 4: The Types of Textbook Information Publishers Have 

Disclosed to Faculty 12

Figure 5: Estimated Percentage of Schools That Provided Textbook 

Information Online for the Fall 2012 Term, Including 

Reasons for Not Providing Information 17

 10

Figure 6: The Estimated Extent to Which Schools Provided 

Textbook Information Online for the Fall 2012 Term, 

Including Reasons for Not Providing Information, by 

Sector and Level 18

Contents 
Page ii GAO-13-368 College Textbooks 

Abbreviations

BLS Bureau of Labor Statistics 

CPI Consumer Price Index 

Education Department of Education 

HEOA Higher Education Opportunity Act

IPEDS Integrated Postsecondary Education Data System 

ISBN International Standard Book Number 

TBD to be determined

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-368 College Textbooks 

441 G St. N.W.

Washington, DC 20548

June 6, 2013

The Honorable Tom Harkin

Chairman

The Honorable Lamar Alexander

Ranking Member

Committee on Health, Education, Labor, and Pensions

United States Senate

The Honorable John Kline

Chairman

The Honorable George Miller

Ranking Member

Committee on Education and the Workforce

House of Representatives

The rising costs of postsecondary education present challenges to 

maintaining college access and affordability for students and families. 

While tuition and fees are central to the cost of attendance, other 

expenses, such as the cost of textbooks, are important for students to 

consider when calculating the overall cost of attending college. In 2005, 

we reported that college textbook prices had increased steadily and could 

affect postsecondary access and affordability.1

In an effort to ensure that faculty, students, and bookstores have 

sufficient information about textbooks, Congress included requirements in 

the Higher Education Opportunity Act related to publishers and schools

While many factors affect 

textbook pricing, we found that increasing costs associated with 

developing products that accompany textbooks—including study guides 

and technology applications, such as online homework and quizzes that 

allow instructors to track student progress—best explained price 

increases.

2

 

1

GAO, College Textbooks: Enhanced Offerings Appear to Drive Recent Price Increases, 

disclosing pricing and other textbook information, as well as publishers 

making textbooks and materials sold in a bundle available as individual 

GAO-05-806 (Washington, D.C.: July 29, 2005). 

2

For purposes of this report, we use the terms “postsecondary school” and “school” to 

mean “institutions of higher education receiving federal financial assistance,” as that 

phrase is used in the Higher Education Opportunity Act.

 
 

Page 2 GAO-13-368 College Textbooks 

components.3 The Act also directed GAO to examine the implementation 

of the textbook provisions.4

In conducting this work, we interviewed representatives from eight 

publishers that develop materials for the college textbook market and 

reviewed supporting documentation from each of them. To obtain a range 

of perspectives, we selected five publishers that represented over 85 

percent of new U.S. higher education textbook sales, according to 

information they provided us, as well as three smaller publishers. In 

addition, we reviewed the websites of a nationally representative, 

stratified random sample of 150 2-year and 4-year public, private 

nonprofit, and private for-profit postsecondary schools to determine the 

extent to which they have disclosed textbook information. The sample 

was drawn from the Department of Education’s (Education) Integrated 

Postsecondary Education Data System (IPEDS), which contains data on 

over 7,200 institutions eligible for federal student aid programs. We 

assessed the reliability of the IPEDS data and determined they were 

sufficiently reliable for our purposes. In order to review comparable 

information across schools, we examined available textbook information 

for an introductory business, psychology, and biology course at each 

school in our sample.

This report addresses (1) the efforts 

publishers have made to provide textbook information to faculty and make 

bundled materials available for sale individually, and how these practices 

have informed faculty selection of course materials; and (2) the extent to 

which postsecondary schools have provided students and college 

bookstores access to textbook information, and what the resulting costs 

and benefits have been.

5

 

3

Pub. L. No. 110-315, § 112(a), 122 Stat. 3078, 3107 (2008), codified at 20 U.S.C. § 

1015b. For purposes of this report, we refer to these requirements as the textbook 

provisions.

The percentage estimates reported from this 

review have margins of error of 9 percentage points or less, unless 

otherwise noted. All statistical tests and the margins of error were 

constructed using a 95-percent confidence level. In cases where we were 

unable to find or access textbook information online for a particular 

school, we contacted the school to determine how to access it and 

followed up with representatives as appropriate to determine the reasons 

why the information was not available online. We collected complete 

4

20 U.S.C. § 1015b(g).

5

At schools where one or more of these courses were not offered, we selected similar 

alternative courses.
 

Page 3 GAO-13-368 College Textbooks 

information for all 150 schools in our sample, resulting in a response rate 

of 100 percent. While we reviewed documentation of publisher and school 

efforts to implement the textbook provisions, we did not conduct a review 

of any entity’s legal compliance. Based on the results of our review of 

school websites, we conducted follow-up interviews regarding the 

implementation of the textbook provisions and the associated costs and 

benefits with various representatives from eight schools, including seven 

groups of administrators, four campus bookstores, three faculty groups, 

and three student government groups. To select this subset of eight 

schools, we took into account characteristics such as level (2-year or 4-

year), sector (public, private nonprofit, private for-profit), and geographic 

location. We also interviewed representatives from two national campus 

retailers that operate hundreds of bookstores nationwide, a textbook 

rental company, a company that provides price comparison software for 

campus bookstores, and professional organizations that represent 

publishers, bookstores, faculty, students, and schools. Lastly, we 

reviewed relevant studies and federal laws. See appendix I for more 

information about our scope and methodology.

We conducted this performance audit from April 2012 to June 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
 

Page 4 GAO-13-368 College Textbooks 

The college textbook market is complex, with a number of parties 

involved in the development and distribution of course materials.6

Publishers produce a variety of products and services for faculty to 

choose from in selecting course materials. In addition to traditional 

textbooks, faculty can work with publishers to create customized course 

materials by adding or deleting information from a single textbook or 

multiple sources. Faculty may also select supplemental materials, such 

as workbooks, lab activities, and study guides. Supplemental materials 

and textbooks may be sold together in one package, referred to as a 

bundle, and may also be available for sale separately. In addition to print 

versions, course materials are often available as digital products that can 

be accessed on computers or e-readers. Publishers have also developed 

online interactive systems that integrate multimedia instructional material 

with supplemental materials like homework or personalized quizzes and 

tutorials.

First, 

publishers develop and produce textbooks and accompanying materials 

for faculty and students. Publishers then market their materials to faculty, 

school administrators, and sometimes academic departments that make 

decisions about what course materials to assign to students. Publishers 

employ sales representatives who often speak with instructors in person 

to discuss product options. They also provide instructors with free sample 

materials for their consideration. 

Faculty or other designated parties select course materials and submit 

orders for them according to the process and time frames established by 

their school. Upon receiving information about selected materials and 

enrollment numbers from the school, campus bookstores determine how 

many to order and stock. These school-affiliated bookstores may include 

independent booksellers and large retail chains. They generally sell both 

new and used books, and some offer digital products and textbook rental 

programs. Many campus bookstores also have websites through which 

students can purchase or rent textbooks online. In addition to campus 

bookstores, students may be able to obtain course materials from a 

variety of sources. For example, students may purchase or rent course 

 

6

For an expanded description of the college textbook market and the typical life cycle of a 

college textbook, see GAO-05-806. 

Background 

The College Textbook 

Market
 

Page 5 GAO-13-368 College Textbooks 

materials from online retailers, publishers, or through peer-to-peer 

exchanges, among other outlets. They may also borrow materials from 

libraries or peers. An emerging source of course materials is the open 

source model, in which textbooks and other materials are published under 

a license that allows faculty to personally adapt materials and students to 

access them for free or for a nominal cost. Table 1 below summarizes 

common options available for obtaining course materials.

Table 1: Common Options for College Course Materials

Type • Textbook

• Supplemental material

• Interactive system

• Customized textbook

Format • New print (including loose-leaf and other lower-cost options)

• Used print

• Digital book (including PDFs and books for e-readers)

Delivery channel • Campus bookstore (online or physical store)

• National online retailer

• Other bookstore (not school-affiliated)

• Open-source provider

• Publisher

• Library

• Peer exchange

Transaction method • Purchase

• Rent

• Borrow 

• Download free of charge

Source: GAO analysis of industry information.

After completing a course, students may be able to offset their costs by 

selling back their course materials to the campus bookstore, online 

retailers, or wholesale companies.7

 

7

Wholesale companies facilitate the circulation of used textbooks by purchasing used 

books from retailers and directly from students to distribute to other retailers in need of 

used textbooks. 

Bookstores generally buy as many 

used textbooks from their students as possible, but there are limits to 

what students can sell back. For example, electronic products are 

generally not eligible for resale because they are accessible through onetime access codes or downloading. Opportunities to sell back customized 
 

Page 6 GAO-13-368 College Textbooks 

course materials may also be limited given their uniqueness to a 

particular course on a particular campus. 

In 2005, based on data from the Bureau of Labor Statistics, we reported 

that new college textbook prices had risen at twice the rate of annual 

inflation over the course of nearly two decades, increasing at an average 

of 6 percent per year and following close behind increases in tuition and 

fees.8

Figure 1: Estimated Increases in New College Textbook Prices, College Tuition and 

Fees, and Overall Consumer Price Inflation, 2002 to 2012

More recent data show that textbook prices continued to rise from 

2002 to 2012 at an average of 6 percent per year, while tuition and fees 

increased at an average of 7 percent and overall prices increased at an 

average of 2 percent per year. As reflected in figure 1 below, new 

textbook prices increased by a total of 82 percent over this time period, 

while tuition and fees increased by 89 percent and overall consumer 

prices grew by 28 percent.

 

8

These price increases occurred from December 1986 to December 2004. 

See GAO-05-806. 

Pricing and Spending
 

Page 7 GAO-13-368 College Textbooks 

While the Bureau of Labor Statistics publishes data annually on college 

textbook pricing, there are no comparable, nationally representative data 

sources that estimate student spending. Given the range of options for 

format and delivery of course materials, students are not limited to 

purchasing new, print books. Students may lower their costs by 

purchasing used or digital textbooks, renting materials, or taking 

advantage of other affordable options. However, the price of new, print 

books often drives the prices of other items. Specifically, as we reported 

in 2005, used textbook prices are directly linked to new textbook prices in 

that retailers typically offer used books for about 75 percent of the new, 

print price.9

In part to ensure that students have access to information about selected 

course materials, Congress included several provisions related to 

textbook information in the Higher Education Opportunity Act (HEOA), as 

described below.

Similarly, digital textbooks and textbook rentals are generally 

offered at a discount based on the new, print price. Thus, while students 

may be able to find lower-priced options, increasing prices for new, print 

books will likely lead to similar price increases for other related course 

materials. 

10

• When publishers provide faculty or others responsible for selecting 

course materials at schools with information about textbooks or 

supplemental material, they are required to provide the price at which 

they would make the textbook or supplemental material available to 

the school’s bookstore (often referred to as the net price) and, if 

available, to the public (often referred to as the retail price or the list

price).11

 

9

While each store determines its own retail pricing model, many utilize a similar approach. 

See 

 They are also required to provide a description of substantial 

content revisions between the current and prior edition, the copyright 

dates of the three prior editions, if any, and any alternate formats 

available, along with their net prices and retail price, if available.

GAO-05-806. 

10In addition to HEOA, several states have enacted legislation related to textbook 

affordability.

1120 U.S.C. § 1015b(c). While publishers may suggest retail prices, retailers determine the 

final price at which to sell the materials. 

The Higher Education 

Opportunity Act
 

Page 8 GAO-13-368 College Textbooks 

• Schools are generally required to disclose information on textbooks to 

students and campus bookstores.12 Specifically, to the maximum 

extent practicable, in their online course schedules, schools are to 

provide the International Standard Book Number (ISBN) and retail 

price for required and recommended material for each course listed in 

the schedule used for preregistration and registration purposes, with 

some exceptions. If the ISBN is not available, schools are to provide 

the author, title, publisher, and copyright date in the schedule. If 

disclosing the required information is not practicable, the school is to 

list it as “to be determined” (TBD) on the course schedule. In addition 

to making these disclosures on the course schedule, schools are to 

provide their affiliated bookstores with the same information, along 

with enrollment data for each course as soon as practicable upon the 

request of the bookstore. Beyond these requirements, HEOA 

encourages schools to provide information to students about 

institutional textbook rental programs, buyback programs, and any 

other cost-saving strategies.13

Figure 2 illustrates the types of information communicated throughout the 

process of selecting and ordering course materials. 

 

1220 U.S.C. § 1015b(d), (e).

1320 U.S.C. § 1015b(f).
 

Page 9 GAO-13-368 College Textbooks 

Figure 2: Communicating Textbook Information 

a

This process is not governed by the Higher Education Opportunity Act.

In addition to the disclosure requirements, HEOA requires publishers to 

make college textbooks and materials sold together in a bundle available 

for sale individually,14 a practice referred to as unbundling (see fig. 3). 

While each component must be available individually, publishers may 

continue to sell course materials in bundles. This requirement does not 

apply in the case of integrated textbooks.15

 

1420 U.S.C. § 1015b(c).

These are books with related 

15See 20 U.S.C. § 1015b(b)(6), (c)(2).
 

Page 10 GAO-13-368 College Textbooks 

materials that are either governed by a third-party contract that prohibits 

their separation, such as those produced by another company, or are so 

interrelated that the components would be unusable on their own. For 

example, a computer software textbook may include multimedia content 

that is essential to understanding the book.

Figure 3: Illustration of Unbundling under the Higher Education Opportunity Act

HEOA prohibits Education from issuing regulations related to the textbook 

information section of the law.16 While Education therefore has a limited 

role in this area, it provided some early nonregulatory guidance to help 

publishers and schools understand the textbook provisions. In addition, 

Education encourages students to consider textbook costs in preparing 

for college and collects student complaints, including those related to 

textbooks.

 

1620 U.S.C. § 1015b(i).
 

Page 11 GAO-13-368 College Textbooks 

The eight publishers included in this study have disclosed textbook 

information including retail prices, available alternative formats, and 

descriptions of substantial content revisions between editions.17 Seven 

publishers also provided net prices and six provided information on prior 

copyright dates to faculty. Two smaller publishers told us they did not 

have a practice of disclosing prior copyright dates, and one said net 

pricing was not part of its business practices.18

Publishers included in this study have communicated this information to 

faculty online and in other marketing materials, as well as in the course 

materials themselves. In most cases, publishers’ textbook information 

was available to students and the public, in addition to faculty. For 

example, all eight publishers chose to disclose retail prices and format 

options in publicly accessible areas of their websites. Representatives 

from one of these publishers stated the company’s intent in making the 

information publicly available was to increase transparency. Another 

publisher chose to disclose net pricing information to faculty on a 

restricted-access website—a decision representatives said was meant to 

 

 

17While we reviewed documentation of publisher efforts to implement the textbook 

provisions, we did not conduct a review of publishers’ legal compliance.

18These publishers told us they were unaware of the HEOA textbook provisions but were 

already disclosing some textbook information to faculty, independent of HEOA. When we 

notified the publishers of the requirements, they said they would begin providing this 

information. 

Publishers Have 

Disclosed Required 

Information and Made 

Materials Available 

Individually, but 

Stakeholders Said 

These Practices Had a 

Limited Effect on 

Faculty Decisions

Publishers Have Disclosed 

Required Information 

Online and in Other 

Marketing Materials
 

Page 12 GAO-13-368 College Textbooks 

avoid public confusion about the difference between net and retail prices. 

Instead of using a website, representatives from another publisher said 

they primarily use marketing materials distributed directly to faculty to 

disclose net pricing and format information. In addition, publishers 

provided some required information in the course materials themselves. 

For example, five of eight publishers disclosed prior copyright dates on 

the inside pages of textbooks. See figure 4 for the types of information 

publishers disclosed and the methods they utilized for doing so.

Figure 4: The Types of Textbook Information Publishers Have Disclosed to Faculty

a

One smaller publisher told us it does not use net pricing. 

b

Two smaller publishers told us they do not have a practice of disclosing prior copyright dates. When 

we notified the publishers of the requirements, they said they would begin providing this information.

Note: Partial shading represents multiple disclosure methods used by the same publisher. 

Representatives of the majority of publishers included in our study said 

disclosing required textbook information involved process changes that 

took initial investments of time and financial resources. Some publishers 

told us they made changes to their technology and production systems, 

as well as their marketing practices. For example, representatives from 

two publishers said they had to change their internal databases to include 

all the textbook information specified in HEOA. Four publishers also told 

us they conducted extensive training with staff about HEOA 

implementation. Despite the changes publishers made to disclose 

required textbook information, four publishers did not view the costs 

directly associated with implementing HEOA as substantial.
 

Page 13 GAO-13-368 College Textbooks 

All publishers included in this study have made bundled materials 

available for sale individually, which is a requirement of HEOA. In some 

cases, publishers said they began phasing out bundles before HEOA’s 

passage in 2008, which we also noted in our 2005 report.19

Offering individual components for sale gives students more options when 

selecting their course materials, but several bookstores, faculty, students, 

and national associations told us that some market conditions may limit 

the potential for savings or student choice. For example:

For example, 

one publisher told us it made the decision to make its bundled products 

available for sale individually prior to HEOA’s enactment because it 

wanted to be more transparent about its product offerings. Another 

publisher said that most of its bundled materials were available for sale 

individually by 2004, and in response to HEOA, it only had to change its 

external website to allow faculty to view the individual components. In 

contrast, another publisher noted that in response to HEOA, it had to 

begin setting prices for all bundled components and change its process 

for storing them. In order to make faculty aware that bundled materials 

are available individually, publishers use the same methods they use for 

disclosing information about other course materials. For example, five 

publishers display options for supplemental materials or bundles on their 

public websites. These pages include lists of each component, 

sometimes with individual prices or ISBNs.

• As we reported in 2005, buying individual components may not be 

cheaper for students, as bundled products may be offered at a 

discount compared to the price of buying each component separately. 

Some publishers said that the discounts available on bundles are a 

selling point with faculty.20

• Students may have limited options for obtaining unbundled 

components. When faculty select bundles, campus bookstores may 

Several faculty, students, and bookstore 

representatives we spoke with for this study told us that the price of 

individual components, particularly electronic course materials, is 

often higher than it would have been in a bundle. This pricing 

structure may limit students’ ability to reduce their costs by purchasing 

less expensive used books and choosing which supplements to 

purchase.

 

19GAO-05-806. 

20GAO-05-806. 

Publishers Have Made 

Bundled Materials 

Available for Sale 

Individually 
 

Page 14 GAO-13-368 College Textbooks 

choose not to stock all the individual components, according to 

representatives from two campus bookstores and a national campus 

retailer. In addition, publishers may not make some separate 

components available for sale through campus bookstores, according 

to representatives from an industry trade group and a national 

campus retailer. In such cases, students wishing to obtain individual 

components would need to seek other outlets, such as publisher 

websites or online retailers.

As previously discussed, the HEOA requirement to make materials 

available for sale individually does not apply in the case of integrated 

textbooks, which either are governed by a third-party contract that 

prohibits separation or would be rendered useless if separated. For 

example, one publisher reported that it is not authorized to separately sell 

a listening component that accompanies a music book under the terms of 

the contract it has with the company that produced the music. While 

representatives of one industry trade group expressed concern that the 

exemption for integrated textbooks offered a way around the requirement 

to ensure all products in a bundle are available for sale individually, the 

five large publishers we spoke with said they offer very few of these 

materials. For example, one publisher estimated that integrated textbooks 

make up 2 percent of its inventory, while representatives of another said 

they offer one integrated textbook.

Representatives of faculty groups, bookstores and publishers we 

interviewed said the availability of information and unbundled materials 

has had little effect on college textbook selection decisions. Faculty told 

us they typically prioritize selecting the most appropriate materials for 

their courses over pricing and format considerations. One faculty group 

we spoke with explained that the quality and relevance of the materials 

are the key factors in finding the best match for the course. Another group 

said they need to determine whether the material is at a level suitable for 

the students likely to enroll and comprehensive enough for the content 

they plan to cover. Only after they have identified the most appropriate 

course materials will faculty consider pricing and format options, 

according to stakeholders. For example, a representative of a national 

campus retailer said faculty ask about cost-saving options like digital 

formats and textbook rentals after they have identified the best materials 

to help their students master the necessary concepts.

Changes in technology and available options in the college textbook 

market—factors unrelated to HEOA—have also shaped faculty decisions 

Stakeholders Said the 

Availability of Information 

and Unbundled Materials 

Has Had Little Effect on 

Faculty Textbook 

Decisions
 

Page 15 GAO-13-368 College Textbooks 

about course materials. For example, representatives from a publisher 

and a national campus retailer noted there is growing interest in digital 

assessment tools that allow faculty to track student progress in an effort 

to improve student outcomes. In 2005, we reported that publishers were 

developing these types of digital products to help enhance faculty 

productivity and teaching. Currently, publishers are expanding these 

offerings with interactive products like online interactive systems, which 

may include some combination of instructional material, adaptive 

homework questions, exams, worksheets, or tutoring programs in one 

system. Representatives of two campus bookstores and a faculty group 

told us that online interactive systems are becoming more popular at their 

schools.

Although HEOA requires publishers to make textbooks and supplemental 

materials available for sale individually, faculty can still select bundled 

products for their courses. Some publishers and bookstores told us there 

was initial confusion about whether the law constrained faculty choice in 

selecting bundles, and they employed various communication efforts to 

help clarify the issue. Our review of a nationally representative sample of 

school websites shows that bundles continue to be assigned for some 

courses. More specifically, in cases where schools provided textbook 

information online, we found that an estimated 58 percent included 

required materials that appeared to be bundles for at least one of the 

three courses we reviewed.21

Although faculty decisions about textbook selections have not changed 

much in response to publisher practices, representatives of faculty groups 

told us they are more aware of affordability than they used to be. For 

example, faculty we spoke with at a public school expressed a strong 

interest in finding appropriate textbook options that also save students 

money because they often serve low-income students who work parttime. They added that a new textbook could cost over $200, which is 

more than the course fee of $136. These faculty also said that as a result 

of HEOA, more faculty are providing information about textbook 

selections in their syllabi as early as possible, and are putting books on 

reserve in the library. In addition, several faculty from different schools 

reported using the same textbook for multiple semesters, which allows 

 

21An estimated 81 percent of schools provided textbook information online for the fall 2012 

term. To identify bundles when reviewing school websites, we looked for textbooks that 

were packaged with supplemental materials such as access codes or workbooks for a 

single price, with a single ISBN. 
 

Page 16 GAO-13-368 College Textbooks 

students to buy a used version at a reduced price. At one public school, 

faculty told us their school’s guidelines encourage them to consider both 

the price of course materials and the use of the same edition of a 

textbook for as long as possible. With regard to other cost-saving 

solutions, a few faculty told us they have developed their own course 

materials. For example, one professor said a lab manual for his course 

could cost $50-$60 when developed by a publisher; instead, he created 

his own, which costs students about $10 in printing fees. A music 

professor said that with the advent of free online videos, he can teach his 

class almost entirely by assigning links to websites.

Based on our review of a nationally representative sample of school 

websites, most schools provided students and college bookstores with 

the textbook information specified in the HEOA provisions. We estimate 

that 81 percent of schools, serving an estimated 97 percent of college 

students nationwide, made textbook information—such as the ISBN or 

retail price—available online in time for the fall 2012 term. In addition, an 

estimated 93 percent of these schools made the information publicly 

available without the use of a password, allowing both current and 

prospective students to view it.

Schools are structured and operate in various ways, and HEOA allows 

some flexibility in whether and how they disclose textbook information. An 

estimated 19 percent of schools did not provide textbook information 

Most Schools 

Provided Textbook 

Information Online, 

and Stakeholders Said 

Students Benefited 

from Increased 

Transparency 

Most Schools Provided 

Textbook Information 

Online 
 

Page 17 GAO-13-368 College Textbooks 

online.22 When we contacted all such schools in our sample to inquire 

why they did not provide that information, representatives from 62 percent 

said they included the cost of textbooks in tuition and fees or assessed 

students a separate fee for textbooks. 23

Figure 5: Estimated Percentage of Schools That Provided Textbook Information Online for the Fall 2012 Term, Including 

Reasons for Not Providing Information

Other reasons cited included not 

posting a course schedule online and supplying required materials 

through the school’s library (see fig. 5).

Note: We did not evaluate schools’ compliance with the Higher Education Opportunity Act textbook 

information provisions. Because schools are generally required to disclose information “to the 

maximum extent practicable,” schools that do not provide textbook information online are not 

necessarily out of compliance. 

Note: The percentage estimates in the larger pie chart have margins of error of 9 percentage points 

or less, while estimates in the smaller pie chart have margins of error of 19 percentage points or less.

The extent to which schools provided textbook information online varied 

by school sector and level (see fig. 6). The vast majority of public and 

private nonprofit schools provided information compared to about half of 

private for-profit schools, while 4-year schools provided information more 

often than 2-year schools. In turn, we found the practice of including the 

cost of textbooks in tuition and fees or assessing students a separate fee 

 

22We did not evaluate schools’ compliance with the HEOA textbook information 

provisions. Because schools are generally required to disclose information “to the 

maximum extent practicable,” schools that do not provide textbook information online are 

not necessarily out of compliance.

23This estimate has a margin of error at the 95-percent confidence level of 20 percentage 

points.
 

Page 18 GAO-13-368 College Textbooks 

for textbooks occurred at private for-profit schools more often than at 

public or private nonprofit schools, and at 2-year schools more often than 

at 4-year schools. Representatives we spoke with at one such private forprofit, 2-year school that offers medical, business, and technical programs 

told us the school has a centralized curriculum and standardized 

textbooks for each program across its 10 campuses, allowing it to 

purchase textbooks and materials in bulk at lower prices and pass the 

savings on to its students. This is a common practice among schools with 

specialized or technical programs of study, according to a higher 

education association we interviewed.

Figure 6: The Estimated Extent to Which Schools Provided Textbook Information Online for the Fall 2012 Term, Including 

Reasons for Not Providing Information, by Sector and Level

Note: We did not evaluate schools’ compliance with the Higher Education Opportunity Act textbook 

information provisions. Because schools are generally required to disclose information “to the 

maximum extent practicable,” schools that do not provide textbook information online are not 

necessarily out of compliance.

Note: The percentage estimates for public and 4-year schools have margins of error of 9 percentage 

points or less, while estimates for private nonprofit, private for-profit, and 2-year schools have 

margins of error of 16 percentage points or less.

Note: Totals may not add to 100 percent due to rounding.

An estimated 80 percent of schools that provided textbook information 

online to students and bookstores included the primary elements 

specified in HEOA for all textbooks listed for the three courses we 

reviewed. In doing so, almost all of these schools provided the ISBN or 

alternative information outlined by HEOA (title, author, copyright date, and 

publisher) and some retail pricing information (i.e., new, used, rental, or 
 

Page 19 GAO-13-368 College Textbooks 

other price) for all courses that required textbooks.24 A small share of 

schools indicated textbook information was “to be determined” for one or 

more of their courses.25

Schools also provided additional information—such as information on 

textbook rental programs, used books, and digital products—to students, 

as encouraged by the HEOA provisions. Of the estimated 81 percent of 

schools that provided textbook information online for the fall 2012 term:

Of the remaining 20 percent of schools that 

provided textbook information online, most included the primary elements 

specified in HEOA for all textbooks listed for one or two courses we 

reviewed, and almost all included some information that could assist 

students in shopping for their textbooks, such as the titles or authors. 

• an estimated 67 percent had an institutional textbook rental 

program;26

• an estimated 73 percent provided some used textbook pricing 

information for at least one course; and

• an estimated 40 percent provided other pricing information—almost 

always for digital products—for at least one course.

Representatives of all campus bookstores and national campus retailers 

we spoke with said they have ramped up their rental programs in the last 

few years, and cited discounts for renting textbooks, ranging from 14 to 

60 percent over the new retail price. They also reported their stores carry 

used and digital books to provide students with additional options. One 

campus bookstore reported that its students saved more than $150 per 

semester, on average, after it introduced textbook rental and digital book 

programs.

 

24At a small share of schools, we found that textbooks were not required for one or more 

of the three courses we reviewed. 

25If disclosing information for a particular textbook is not practicable, HEOA allows schools 

to note that information is “to be determined.” 20 U.S.C. § 1015b(d)(1)(B).

26Based on our review of school websites, we estimate that 55 percent of all schools had 

an institutional textbook rental program for the fall 2012 term. 
 

Page 20 GAO-13-368 College Textbooks 

Representatives of schools, bookstores, and higher education 

associations we spoke with said the costs to schools and bookstores of 

implementing the HEOA provisions were manageable. Administrators and 

campus bookstore representatives of six schools, as well as a national 

campus retailer, said they invested some time or money to implement the 

HEOA provisions—for example, by linking up school and bookstore 

databases and convening internal meetings—but that their costs were not 

substantial. Representatives of another national campus retailer we 

spoke with said their costs were more considerable because they 

developed software to help their schools comply. We also heard from 

representatives of two higher education associations, which represent 

over a thousand schools nationwide, that implementation of the HEOA 

textbook information provisions had gone smoothly and that they did not 

hear about any complaints from their member schools.

Schools varied in their approach to implementing the HEOA provisions. 

Some schools that provided textbook information online relied on their 

campus bookstores to provide it, according to school administrators and 

national campus retailers. For example, administrators we spoke with at 

four schools said they provided textbook information to students by 

adding links from their schools’ online course schedules to their 

bookstores’ websites, which in some cases involved linking school and 

bookstore databases so that students could go directly from the course 

schedule to the bookstore’s list of textbook information for each course. 

Administrators at two of these schools said this approach was simpler 

and more cost-effective than other options they considered. Another 

school went a step further and provided textbook information directly on 

the school’s course schedule. Specifically, administrators said they used 

a web-based tool from the company that managed their bookstore to 

display textbook information directly on the school’s online course 

schedule, at no additional cost to the school. A student at this school told 

us it was helpful to have course and textbook information available in one 

place. However, administrators at another school that considered this 

approach, but ultimately included a link to the bookstore website instead, 

said it would have required substantial resources and maintenance to 

implement. Besides providing textbook information to students, schools 

also submitted the number of students enrolled in each course to their 

campus bookstores, as outlined by HEOA. Administrators at four schools 

we spoke with said they provide this information electronically by 

transferring it from their course registration database to the campus 

bookstore’s database.

Stakeholders Said School 

and Bookstore HEOA 

Implementation Costs 

Were Manageable, and 

Students and Others Cited 

Benefits of Greater 

Transparency
 

Page 21 GAO-13-368 College Textbooks 

Some bookstores moved up their deadlines for faculty to submit their 

textbook choices as a result of implementing the HEOA provisions. 

Specifically, representatives from an industry trade group representing 

school bookstores said some of their members moved their fall deadlines

up by as many as 2 months to provide textbook information to students at 

the time of preregistration. Representatives of two campus bookstores 

and both national campus retailers we spoke with reported that getting 

faculty to submit their textbook choices by the deadlines had already 

been a challenge prior to HEOA. However, faculty we spoke with at one 

school, as well as representatives from two campus bookstores and an 

industry trade group, acknowledged there may be legitimate reasons why 

textbook choices are not submitted by the deadline, such as a given 

course having no instructor assigned.

Students, faculty, school administrators, and most other stakeholders we 

spoke with said students have benefited from having timely and reliable 

textbook information. As faculty submit more complete and timely 

textbook information, schools are better able to provide that information to 

students, according to faculty at one school and representatives from a 

campus bookstore and an industry trade group. Representatives of

student organizations at three schools said they now have sufficient 

information and time to shop for their course materials before each 

academic term. Students told us they use ISBNs found on their campus 

bookstore’s website to actively research textbook prices at both the 

campus bookstore and other retailers, and that they make better 

spending decisions as a result. Students at one school said researching 

their options to find the highest quality materials for the lowest cost is 

easy and worth the little time it takes. For example, one student estimated 

she saves about $150 per semester by being able to compare prices 

among multiple retailers. Students at one of the three schools said their 

campus bookstore includes competitors’ prices on its website, allowing 

students to see which retailer offers the lowest price for a given textbook. 

While students said price is the biggest factor affecting their decisions 

about obtaining textbooks, they also consider how they want to use the 

books and how long they want to keep them. For example, students at 

three schools mentioned that some students prefer to highlight or take 

notes in print versions of books rather than mark up digital books. 

Students also said they are able to obtain ISBNs and other information in 

enough time to acquire their required textbooks by the first day of class. 

Students further benefit from increased information on the options for 

obtaining textbooks, such as institutional rental programs, according to 

representatives from one bookstore and an industry trade group we 

interviewed. In addition to talking to students and other stakeholders, we 

reviewed 153 entries from Education’s Program Compliance Complaints 
 

Page 22 GAO-13-368 College Textbooks 

Tracking System from July 2010 through April 2012 that mentioned the 

word “book.” While we found several entries related to the timing of 

financial aid for purchasing books, our review yielded no complaints 

related to the HEOA textbook provisions.

As the cost of attending college continues to rise, students and their 

families need clear and early information about the cost of textbooks. In 

implementing HEOA’s textbook provisions, publishers and schools have 

provided them with increased access to such information. Greater 

transparency of information alone, however, does not make textbooks 

less expensive, as the affordability of course materials results from the 

complex market forces that drive prices. Moreover, the textbook market is 

different from other commodity markets; although students are the end 

consumers, faculty are responsible for selecting which textbooks students 

will need, thereby limiting students’ ability to allay costs. Nevertheless, the 

proliferation of new products, formats, and delivery channels has left 

students with many options for obtaining course materials. For example, 

students can now choose whether to realize savings upfront by selecting 

digital or rental options, or on the back end by reselling books in the used 

book market. In light of the increased complexity of students’ options, the 

information schools have provided in implementing HEOA has proven 

useful to students in making informed decisions. As a result, even though 

students cannot directly control the cost of their textbooks, they can better 

manage these costs by comparison shopping and making deliberate 

decisions about what to purchase, and from where.

We provided a draft of the report to the Department of Education for review 

and comment. Education provided technical comments, which we 

incorporated as appropriate.

We are sending copies of this report to the Secretary of Education, 

relevant congressional committees, and other interested parties. In 

addition, the report is available at no charge on the GAO website at 

http://www.gao.gov. 

Concluding 

Observations 

Agency Comments
 

Page 23 GAO-13-368 College Textbooks 

If you or your staff have any questions about this report, please contact 

me at (617) 788-0534 or emreyarrasm@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix III.

Melissa Emrey-Arras

Director, Education, Workforce, 

 and Income Security Issues
Appendix I: Scope and Methodology

Page 24 GAO-13-368 College Textbooks 

To examine publishers’ efforts and faculty decision-making, we 

interviewed representatives from eight publishers that develop materials 

for the college textbook market and reviewed supporting documentation 

from each of them, including documents from their websites and ones 

obtained at the interviews. To obtain a range of perspectives, we selected 

five publishers that represented over 85 percent of new U.S. higher 

education textbook sales, according to information they provided us, as 

well as three smaller publishers. The views of publishers we spoke with 

cannot be generalized to all publishers. While we reviewed 

documentation of publisher efforts to provide information to faculty and 

make bundled materials available for sale individually, we did not 

evaluate whether these practices, as supported by documentation or 

described to us in interviews, were in compliance with the law. We also 

interviewed others with relevant expertise, including faculty groups at 

three schools, two national campus retailers that operate hundreds of 

bookstores nationwide, a textbook rental company, a company that 

provides price comparison software for campus bookstores, and 

professional organizations that represent publishers, bookstores, faculty, 

students, and schools.

To determine the extent to which postsecondary schools have provided 

students and college bookstores access to textbook information, we 

reviewed websites of a nationally representative, stratified random 

sample of 150 schools to determine the extent to which they disclosed 

textbook information in their fall 2012 course schedules.1

 

1

We did not evaluate schools’ compliance with the HEOA textbook information provisions. 

Because schools are generally required to disclose information “to the maximum extent 

practicable,” schools that do not provide textbook information online are not necessarily 

out of compliance.

The sample was 

drawn from Education’s 2010-2011 Integrated Postsecondary Education 

Data System (IPEDS), which contains data on over 7,200 institutions 

eligible for federal student aid programs authorized under Title IV of the 

Higher Education Act of 1965, as amended. We assessed the reliability of 

the IPEDS data by reviewing Education’s quality control procedures and 

testing the data electronically. We determined the data were sufficiently 

reliable for our purposes. Our sampling frame consisted of all public, 

private nonprofit, and private for-profit 2-year and 4-year degree-granting 

postsecondary schools that participated in Title IV federal student aid 

programs, had undergraduate programs, were not U.S. military 

academies, and had at least 100 students, yielding a universe of 4,293 

schools. We created six strata to stratify the sampling frame by sector 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 25 GAO-13-368 College Textbooks 

(public, private nonprofit, and private for-profit) and level (2-year and 4-

year). This sample of schools allowed us to make national estimates 

about the availability of textbook information, as well as estimates by 

sector and level. The percentage estimates reported from this review 

have margins of error at the 95 percent confidence level of 9 percentage 

points or less, unless otherwise noted. In order to review comparable 

information across the sampled schools, we developed a standardized 

web-based data collection instrument and pre-tested it in July 2012. 

Using the finalized data collection instrument, we examined available 

textbook information for an introductory business, psychology, and 

biology course at each school in our sample.2

Based on the results of our review of school websites, we conducted 

follow-up interviews regarding the implementation of the HEOA textbook 

provisions and the associated costs and benefits with various 

representatives from eight schools in our sample, including seven groups 

of administrators, four campus bookstores, three faculty groups, and 

three student government groups. (See table 2 for a list of schools.) To 

select this subset of eight schools, we took into account characteristics 

such as sector, level, and geographic location.

We judgmentally selected 

these subjects because they are among the top 10 undergraduate majors 

for degree-completing students, according to IPEDS data. In addition, 

these courses likely affect a larger number of students than upper division 

courses. We reviewed school websites from July through September 

2012, as students would be obtaining textbooks for their fall 2012 term 

courses. In cases where we were unable to find or access textbook 

information online for a particular school, we contacted the school to 

determine how to access it and followed up with representatives as 

appropriate to determine the reasons why information was not available 

online. We recorded and verified the information we obtained in the webbased data collection instrument to facilitate the analysis across schools. 

We collected complete information for all 150 schools in our sample, 

resulting in a response rate of 100 percent.

 

2

At schools where one or more of these courses were not offered, we selected similar 

alternative courses.
Appendix I: Scope and Methodology

Page 26 GAO-13-368 College Textbooks 

Table 2: Characteristics of Schools GAO Interviewed and Specific Groups Interviewed at Each School

School

Sector and 

level Location

School 

administrators

Campus 

bookstore 

representatives Faculty group

Student 

government 

organization

Broome 

Community 

College

Public, 2-year Binghamton, NY x x x 

Cuyamaca College Public, 2-year El Cajon, CA x 

Daymar Institute – 

Murfreesboroa Private for-profit, 

4-year

Murfreesboro, TN x 

Dickinson College Private 

nonprofit, 4-year

Carlisle, PA x x x x 

Dunwoody College 

of Technology

Private 

nonprofit, 4-year

Minneapolis, MN x 

Iowa State 

University

Public, 4-year Ames, IA x x x 

San Joaquin Valley 

College – Rancho 

Cordova

Private for-profit, 

2-year

Rancho Cordova, 

CA

x 

Towson University Public, 4-year Towson, MD x x x 

Source: GAO and Education’s Integrated Postsecondary Education Data System (IPEDS)

a

School provided written responses in lieu of an interview.

To provide background information on changes in the prices of textbooks 

over time, we reviewed public data from 2002-2012 from the Consumer 

Price Index (CPI) published by the Department of Labor’s Bureau of 

Labor Statistics (BLS). The CPI data reflect changes over time in the 

prices paid by urban consumers for different goods and services. 

Specifically, we reviewed CPI data for three expenditure categories: 

college textbooks, college tuition and fees, and overall prices. The college 

textbooks data are limited to the price of new print and digital books.3

 

3

Digital products account for 5 percent of the index, and used and rental prices are not 

reflected. 

In 

addition, the timeframes for collecting price information in the field vary, 

so different textbooks may be priced at different times. We assessed the 

reliability of these data by reviewing documentation of the CPI data and 

interviewing BLS officials about the methodology used to calculate the 

data. We determined that these data were sufficiently reliable for the 

purposes of our study. We provided BLS with an opportunity to review our 

use of the CPI data.
Appendix I: Scope and Methodology

Page 27 GAO-13-368 College Textbooks 

In addition, we reviewed complaints submitted to Education to determine 

whether any were related to the information provided by schools about 

required textbooks. Specifically, Education provided GAO with an excerpt 

from its Program Compliance Complaints Tracking System containing any 

complaints in which the word “book” appeared. There were 153 such 

complaints from July 2010, when the HEOA textbook provisions went into 

effect, through April 2012. We took steps to verify the reliability of the 

data. We interviewed Education officials about the methodology used to 

calculate the data and determined they were sufficiently reliable for our 

purposes. We also reviewed relevant studies and federal laws.
Page 28 GAO-13-368 College Textbooks

Melissa Emrey-Arras, Director, (617) 788-0534 or emreyarrasm@gao.gov

In addition to the contact named above, Debra Prescott (Assistant 

Director), Lara Laufer, Jeffrey G. Miller, Amy Moran Lowe, Michelle 

Sager, Najeema Washington, and Rebecca Woiwode made significant 

contributions to this report. Also contributing to this report were David 

Barish, James Bennett, Deborah Bland, David Chrisinger, Daniel 

Concepcion, Jennifer Cook, Rachel Frisk, Alex Galuten, Bill Keller, 

Ying Long, Jean McSween, Karen O’Conor, and Betty Ward-Zukerman.

Appendix II: GAO Contacts and Staff 

Acknowledgments 

GAO contact

Staff Acknowledgments

(131168)
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