What is the next step in the Gainful Employment Process?

Next Steps for Gainful Employment Regulations
Now that you all have successfully confirmed your institutions final submission of the Gainful Employment Completers List Corrections (was due July 28, 2016 – See here if you didn’t: http://tinyurl.com/jpdykzj), many are asking, what’s the next step? Good question, because there are a lot of moving parts. Here’s the scoop.

First – let’s just cover the next two deadlines you’ve got so they’re on your radar.

• Reporting – Deadline for 2015-2016 Reporting in October 1st 2016.

• Disclosure – The New Disclosure Requirements go into effect on January 1, 2017. Until then, institutions must continue to comply with the current disclosure requirements by updating their disclosures each year using the Department’s GE Disclosure Template.

The completion of the first set of completers lists by schools, Ed can begin calculating the rates for those students in each of the relevant time periods. And now here’s where the rubber begins to meet the road vis-à-vis Debt-To-Earnings Rates Calculations. Sometime soon (ED delays not withstanding) Draft D/E Rates will be coming out. These rates will be calculated by the Department which will apply debt information from NSLDS, as well as earnings information from the Social Security Administration to each completer.

If you are concerned about using the Department’s supplied average earnings of graduates you’ll be able to appeal the Draft Rates through the recently launched Recent Graduates Employment and Earnings Survey (RGEES) Alternative Earnings Survey. These appeals can be very useful for schools with programs where graduates may earn money in tips that never get reported as income like Massage Therapy, Hairdressing, Cosmetology, Esthetics, Barbering and others.

By demonstrating that that their graduates’ true earnings are greater, a school may be able to more accurately portray their GE Program Debt-to-Earnings (D/E) rate calculations, possibly even avoid sanctions. As with anything else, there are a number of resources available to you to help you understand the best practices in conducting alternative earnings surveys and necessary standards for ensuring the integrity of the data the school reports. As you can imagine, appeals will be highly scrutinized, so saving verifiable source documentation is key for those who intend to pursue it.

When are the Draft D/E Rates coming – at this point, it’s anyone’s guess. Perhaps this Fall or Early 2017. If the Draft D/E Rates are delayed, the Final GE Rates will be delayed and the timeframe for warnings and sanctions could even be delayed as well. Could. Didn’t say would.

Want to know more about the RGEES Alternative Earnings Survey – Click it: http://bit.ly/2aGOf0w