2019 GAINFUL EMPLOYMENT TEMPLATE AND GE COMPLIANCE DEADLINES

The 2019 Gainful Employment Disclosure Template was released recently. Schools, colleges and universities with Gainful Employment programs are required under current law to provide information about their gainful employment programs on their website. According to an electronic announcement from Federal Student Aid, the 2019 GE Template is a simple MS Word document that school users can simply fill in and then post on the website for each respective GE program. Seems simple. Additionally, there are several new data elements that must be disclosed including:

  • Normal time to complete the program
  • Total program costs if completing the program within normal time (including tuition and fees plus books, supplies, and equipment; excluding room, board, or other expenses)
  • Median cumulative debt for Title IV students completing the program within normal time (including Federal, private, and institutional debt)
  • Licensure information for the program’s target occupation
  • URL for the College Scorecard
  • Warning language if required under 34 CFR 668.410.

Speaking of warning language, FSA notes that under the GE regulations, institutions must provide warnings for programs that could become ineligible for Title IV aid based on the next round of final D/E rates. Loss of eligibility results after receiving overall “fail” ratings in any two (2) out of three (3) consecutive award years for which rates are calculated or after receiving a combination of “fail” and “zone” ratings for four (4) consecutive award years for which rates were calculated. Warning requirements are suspended for programs with an alternate earnings appeal currently under consideration. Following the first year of D/E rates, warnings are required for programs with an overall “fail” rating for their 2014-2015 rates without a pending earnings appeal. Following the withdrawal or rejection of a program’s appeal, an institution has 30 days to revise its GE Disclosures to include the warning.

Although the Department of Education recently completed Negotiated Rulemaking and is expected to rescind these rules, institutions are required to comply with these requirements by July 1, 2019.

Beginning on July 1, 2019 institutions must be sure their templates are updated and that all promotional materials are updated with accurate and current GE disclosure info.  Additionally, institutions must begin providing a copy of the GE disclosures to prospective students before they commit to enrolling, registering or making a financial commitment to the institution. Schools have some leeway in determining how to provide these disclosures to prospective students.

GAINFUL EMPLOYMENT REPORTING TIPS

Whether you’re getting ready to report Gainful Employment Program Data for the first time or a seasoned pro, use these simple tips to ensure you are reporting accurate information.

  • Report only students who received Title IV aid to attend your GE Programs.
  • Title IV loan debt, including Perkins loan debt, is not private loan debt and is not institutional debt. When calculating GE rates, the Department will include Title IV debt obtained from NSLDS. If an institution reports Title IV loan debt as part of private or institutional debt, the Title IV loan debt will be double-counted.
  • Carefully review your GE data during the reporting process to ensure that it is correct. If you find errors from previous years, go back and fix them promptly. Note that institutions are not limited to award year 2017-2018 for correcting errors – any errors in GE data previously reported must be corrected promptly after the errors are discovered.
  • GE Program Tracking functionality will remain unavailable for this upcoming reporting cycle. Institutions should review disbursement records sent to the Common Origination and Disbursement (COD) System, enrollment records sent to NSLDS, and the GE programs listed on their Program Participation Agreement (PPA) to ensure that they are reporting for all Title IV students enrolled in all GE programs by October 1, 2018.

REMINDER – GAINFUL EMPLOYMENT REPORTING DUE OCTOBER 1

Although the Department recently announced they were proposing to rescind the Gainful Employment regulations, institutions are still required to report program data annually until new regulations are issued. October 1st, 2018 is the deadline for institutions to report GE Program Information for the recently ended 2017-2018 award year.

All the GE reporting options, data elements and definitions are the same as in previous years. Schools can submit the information using the GE online reporting option under the Enrollment tab of the NSLDS® Professional Access Web site; the GE batch file submission process through the Student Aid Internet Gateway (SAIG); or by using the NSLDS Gainful Employment Spreadsheet Submittal Format (online upload process).

Detailed information about the use of NSLDS for reporting GE data is provided in the NSLDS Gainful Employment User Guide, available on the NSLDS User Documentation page of the Information for Financial Aid Professionals (IFAP) website, as well as from the “Resources” section of the Gainful Employment Information Page. Institutions should use information in the guide, most recently updated on March 21, 2018, to submit required GE information to the Department.

NOTICE OF PROPOSED RULEMAKING FOR GAINFUL EMPLOYMENT

Despite being labeled as “#FakeNews” by President Donald Trump, it appears that a memo leaked to the New York Times was the real deal. On August 14, the Department published a Federal Register notice of proposed rulemaking to rescind the gainful employment regulations which were enacted to ensure that certain programs lead to employment in a recognized occupation. Although the rules applied mostly to public community colleges and for-profit private colleges, opponents have long called for an elimination of the regulations and to have them apply to all college programs, including those at public and private colleges and universities. This has prompted Education Secretary Betsy DeVos to not only rescind the current regulations, but to update the College Scorecard, or a similar web-based tool, to provide program-level outcomes for all higher education programs, at all Title IV participating institutions regardless of their tax status or governance.

The public will have 30 days, until September 13, 2018 to provide comments on the subject. The only question is whether ED will try to produce final regulations by the October 31st master calendar deadline or not. If they produce final rules by then, they will have an effective date of July 1, 2019…Otherwise the can might just get kicked down the road for good.

ED PRESS RELEASE SUMMARIZES GAINFUL EMPLOYMENT NPRM

The U.S. Department of Education’s Press Office released an official statement on the Department’s proposal to overhaul the Gainful Employment Regulations. The “draft” Notice of Proposed Rulemaking was published this morning after the document cleared the Office of Management and Budget.  The official notice will kick off a 30-day public comment period when it arrives in a few days.

U.S. Department of Education Proposes Overhaul of Gainful Employment Regulations

New approach will provide useful, transparent higher education data to students and treat all institutions fairly

WASHINGTON—The U.S. Department of Education today announced a Notice of Proposed Rulemaking (NPRM) that proposes to rescind Gainful Employment (GE) regulations in order to provide useful, transparent higher education data to students and treat all institutions of higher education fairly.

“Students deserve useful and relevant data when making important decisions about their education post-high school,” said U.S. Secretary of Education Betsy DeVos. “That’s why instead of targeting schools simply by their tax status, this administration is working to ensure students have transparent, meaningful information about all colleges and all programs. Our new approach will aid students across all sectors of higher education and improve accountability.”

The Department continues to believe that data such as debt levels, expected earnings after graduation, completion rates, program cost, accreditation, and consistency with licensure requirements are important to consumers, but not just those students who are considering enrolling in a gainful employment program.  Therefore, in the NPRM the Department invites public comment concerning whether or not the Department should require institutions to disclose, on the program webpage, information about the program size, its completion rate, its cost, whether or not it is accredited, and whether the program meets the requirements for licensure in the State in which the institution is located.

In addition, to provide prospective students with important, actionable, and accurate information that could be used in college enrollment and borrowing decisions, the Department plans to update the College Scorecard or a similar web-based tool to provide program-level outcomes including, at a minimum, median debt and median earnings for all higher education programs, at all title IV participating institutions.  The Department believes that this will improve transparency by providing comparable information for all programs and helping students understand what earnings they might expect based on those of prior graduates.  This would also increase accountability of institutions by making it more difficult for institutions to misrepresent program outcomes, such as the earnings of prior graduates, since prospective students would have access to accurate data provided by the Secretary of Education.

The 30-day public comment period for these proposed regulations will begin once published in the Federal Register.  In the interim, an unofficial version of the proposed rule can be found here.