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.


Higher Ed Executives Financial Aid Consultants

Although the 2018 GE Disclosure Template is similar in both look and functionality to last year’s template, there are some modifications you should be aware of:

  • Institutions are no longer required to disclose room and board charges in the template.
  • The unsubsidized loan interest rate will be prefilled based on the selected credential level.
  • Institutions will not be required to disclose median earnings data in the template.
  • Institutions must still disclose whether a program has failed the debt-to-earnings (D/E) rates measure within 30 days of receiving a GE program’s final D/E rates from the Department. Once an institution has indicated that a warning is required on the disclosure template input, the output screen will be prepopulated with the student warnings required under 34 CFR §668.410 of the GE Regulations.
  • Institutions may add more than one accreditor job placement rate.
  • The format for reporting licensure requirements was changed; and “Foreign Country” was added as an option in the list of States.

The deadline for posting the Gainful Employment Disclosure Template is April 6, 2018.

You can get the 2018 version of the template here.