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.