gainful employment disclosures and reporting: an … · gainful employment disclosures and...

For discussion purposes only WFAA Conference October 2016

Kim Wells US Department of Education 1

Kim Wells

U.S. Department of Education

WFAA Conference 2016

Gainful Employment Disclosures and Reporting: An Overview

Gainful Employment (GE) Regulations

• Negotiated Rulemaking - three sessions of negotiations held without consensus

• Notice of Proposed Rulemaking published March 25, 2014

• Over 95,000 comments received

• Final Rule published in Federal Register on October 31, 2014

• Effective date July 1, 2015, including new reporting requirements

• Disclosures will be made under the current regulations until December 31, 2016

• Institutions must comply with new disclosure requirements beginning January 1, 2017

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Gainful Employment Disclosures



Currently Required Disclosures

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• Occupations (names and SOC codes)

• Normal time to complete program

• On-time graduation rate for completers

• Tuition & fees, books & supplies, room & board

• Placement rate for completers (as determined by State or Accreditor methodology)

• Median loan debt

• Percentage of students who received a TIV loan or private loan for enrollment in program

Occupations

• Occupations – 34 CFR 668.6(b)(1)(i) • Must list occupations by name and Standard Occupational

Classification (SOC) codes that the GE program prepares students to enter

• Must link to occupational profiles on O*NET http://www.onetonline.org/

• Use a representative sample if more than 10 possible occupations

• See GE Electronic Announcement #25 regarding multiple programs with the same occupational purpose(s)

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Normal Time to Completion

• How long does it take to complete the program? • Report in weeks, months, or years

• 100% of time it takes to complete, not 150% !

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http://www.onetonline.org/



On-Time Graduation Rate

Includes completers only and reflects leaves of absence and withdrawals

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200

150

Total number of students who completed in 2015-16 AY

Number of students who completed within normal time

0.75 200 ÷150

75% 100 × 75.0

Program Costs

• Tuition & fees charged for completing program within normal time

• Typical costs for books & supplies (unless included in tuition and fees)

• Room & board, if applicable

• Other expenses are optional, but provide link/access to program cost information

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Placement Rates for Completers

• Disclose accrediting agency and/or State placement rates and methodologies

• If not required by accrediting agency or State, then not currently required to disclose placement rate

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Median Loan Debt

• Three categories of debt 3 medians!

• Title IV, HEA program loans

– Exclude: Perkins Loans, Parent PLUS Loans, and TEACH Grants converted to Unsubsidized Direct Loans

• Private education loans

• Institutional financing plans – Outstanding debt at time of completion

• Specify median (not mean/average) debt incurred by students who completed program

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• Released in September 2014

• Link to Disclosure Template http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-

summerfall.html

• Deadline to update disclosures with 2016-17 information using template is January 31, 2017

• Template is an application that creates standardized Web page (HTML) with GE disclosure information

• Web page must be hosted on school’s site

• Prominently display direct links to template on • GE program home page

• Other school web pages about GE program

Disclosure Template

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Disclosure Template

• If offer multiple programs with same CIP Code and Credential Level, consider separate disclosure templates if significant difference in

• Published length of program

• Tuition, fees, or other costs

• Placement rate calculations (e.g., offered in different States)

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http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html





Disclosure Availability

• Include template in all promotional materials about GE program

• Promotional materials include invitations, ads, course catalogs, social media, etc. that mention or otherwise refer to specific GE program

• If not feasible to include template, include live link or URL to it and clearly explain what is available at that web page

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Disclosures to Prospective Students

• 34 CFR 668.412 (e) states

• Before a prospective student signs an enrollment agreement, completes registration, or makes a financial commitment to the institution, the institution must provide the prospective student or a third party acting on behalf of the prospective student, as a separate document, a copy of the disclosure template

• Can be hand-delivered or emailed

• Must maintain evidence information was received by prospective student

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New Final Disclosure Rules

• Institutions must comply with new disclosure requirements beginning January 1, 2017

• Through December 31, 2016, current disclosure requirements remain in effect

• Delay in effective date of new disclosure requirements gives Department time to conduct consumer testing and prepare new disclosure template

• Focus groups • Public comment • Technical guidance

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Potential Future Disclosure Items

• Primary occupations (SOC Codes)

• Program’s completion and withdrawal rates

• Full-time and less-than-full-time students

• Length of the program

• Number of clock-hours, credit-hours or equivalent, as applicable, in the program

• Total number of individuals enrolled in the program during the most recently completed award year

• Loan repayment rate • for any one or all of the

following groups of students who entered repayment on Title IV loans during the two-year cohort period: − All students who enrolled in the

program − Students who completed the

program − Students who withdrew from

the program

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• Total cost of tuition and fees, books, supplies, equipment, and room and board that student would incur for on-time completion

• Placement rate for program, if school is required to calculate

• Whether program is programmatically accredited and name of accreditor

• Percentage of enrolled students who received Title IV or private loan for enrollment in program

• Median loan debt for students who completed or withdrew

• Most recent program cohort default rate

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• Mean or median earnings of any one or all of following groups of students • Students who completed

program during cohort used by ED to calculate most recent debt-to-earning rates for program

• Students who were in withdrawn status at end of cohort period used by ED to calculate most recent debt-to-earning rates for program

• Most recent annual earnings

rate

• Whether program does or does not satisfy • Applicable educational

prerequisites for licensure or certification in each State within the school’s MSA

• Applicable educational prerequisites for professional licensure or certification in any other State for which school has made determination regarding such requirements

• For any State not described above, statement must be included that school has doesn’t have determination about licensure or certification requirements in those states

• Link to ED’s College Navigator website or similar federal resource

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GE Disclosure Resources

• GE Disclosure Template http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html

• Requirement

• Template application

• Quick start guides

• Bulk data file upload tool

• Help desk: 855-359-3697, [email protected]

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Gainful Employment Reporting

Reporting Timeline

• GE reporting began in early 2015

• Should have reported 2015-16 award year by October 1, 2016

• Including updates to previously reported information

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• Only submit data for

• Students enrolled in GE program

• Title IV aid recipients

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GE Data to Report

GE Data to Report: Categories

• Institution Information

• GE Program Information

• Student Demographic Data

• Student Financial Data

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GE Data to Report: Institution Information

• Institution OPEID

• Institution Name

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GE Data to Report: GE Program Information

•Program Name

•Award Year

•CIP Code

•Credential Level

•Medical and Dental Internship or Residency

•Length of GE Program

•Length of GE Program Measurement

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Reporting GE Data: Credential Level

• Credential Level of program in which student was enrolled during award year

• ‘01’ (Undergraduate certificate or Diploma Program)

• ‘02’ (Associate’s degree)

• ‘03’ (Bachelor’s degree)

• ‘04’ (Post baccalaureate certificate)

• ‘05’ (Master’s degree)

• ‘06’ (Doctoral degree)

• ‘07’ (First professional degree)

• ‘08’ (Graduate / professional certificate)

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Reporting GE Data: Program Information

• Length of GE Program

• length of instructional program in years, months, or weeks as published by school

• Format “nnnnnn”, with implied decimal point between third and fourth digits

• Length of GE Program Measurement

• unit of measure for length of instructional program as published by school

• ‘W’ (Weeks)

• ‘M’ (Months)

• ‘Y’ (Years)

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GE Data to Report: Student Demographics

• Social Security Number

• First Name, Middle Name/Initial, and Last Name

• Date of Birth

• Enrollment Status as of First Day of Enrollment in Program

• Program Attendance Begin Date

• Program Attendance Begin Date for Award Year

• Program Attendance Status During Award Year (Graduated, Withdrew, Enrolled)

• Program Attendance End Date

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Reporting GE Data: Program Attendance Status

• ‘G’ (Graduated) If student graduated from educational program at any time during award year

• ‘W’ (Withdrew) If student withdrew from educational program at any time during award year

• ‘E’ (Enrolled) If student was enrolled in educational program on last day of award year, June 30

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GE Data to Report: Student Financial Data

•Private Loans Amount

• Institutional Debt

•Tuition and Fees Amount

•Allowance for Books, Supplies, and Equipment (from Cost of Attendance)

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QUESTIONS?

Gainful Employment Information Page: http://www.ifap.ed.gov/GainfulEmploymentInfo/indexV2.html

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GE Information Page

• Federal Register Notices including Regulations

• DCLs and Electronic Announcements

• FAQs

• Webinars and Presentations

• Resources

http://www.ifap.ed.gov/GainfulEmploymentInfo/indexV2.html

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GE Information Page

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Customer Support Center: • Phone: 800-999-8219

• Toll: 785-838-2141

• Fax: 785-838-2154

• Web: www.nsldsfap.ed.gov

• E-mail: [email protected]

• Policy Questions: [email protected]

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NSLDS Contact Information

Inovas Contact Information

• GE Disclosure Template

• Template application

• Quick start guides

• Bulk data file upload tool

• Help desk: 855-359-3697, [email protected]

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GE Support

• If you still have questions after reviewing the DCLs, electronic announcements, and FAQs, send questions to [email protected]

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http://www.nsldsfap.ed.gov/

mailto:[email protected]











ED Contacts

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Research and Customer Care Center

800.433.7327

[email protected]

Reach FSA

855.FSA.4FAA – 1 number to reach 10 contact centers!

Campus-Based Call Center eZ-Audit

COD School Eligibility Services Group

CPS/SAIG Foreign Schools Participation Division

NSLDS Research and Customer Care Center

G5 Nelnet Total & Permanent Disability

Regional Contacts

• Suzanne Scheldt

[email protected]

206.615.2583

• Kim Wells

[email protected]

206.615.2174

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Training Feedback

To improve our training, we ask all participants to complete an online session evaluation

• Go to https://www.surveymonkey.com/r/KimberlyWells

• Additional feedback about training can be directed to [email protected]

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https://www.surveymonkey.com/r/KimberlyWells

https://www.surveymonkey.com/r/KimberlyWells



Thank you!

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