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Session 47 . Gainful Employment Disclosures. Jessica Finkel and Cynthia Hammond | Nov. 2012 U.S. Department of Education 2012 Fall Conference. What We Will Cover. Status of GE Regulations Which Programs are GE Programs Required Disclosures Disclosure Availability Compliance Tips

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Gainful employment disclosures

Session 47

Gainful Employment Disclosures

Jessica Finkel and Cynthia Hammond | Nov. 2012

U.S. Department of Education

2012 Fall Conference


What we will cover

What We Will Cover

  • Status of GE Regulations

  • Which Programs are GE Programs

  • Required Disclosures

  • Disclosure Availability

  • Compliance Tips

  • GE Resources


Status of ge regulations

Status of GE Regulations

U.S. District Court Decision

  • On 6/30/2012, the Court upheld the Department’s authority to regulate on gainful employment but vacated most of the GE regulations

  • The Court found that ED failed to adequately justify setting the Repayment Rate threshold

  • Because of the interrelationship of the GE requirements, the Court vacated most of the GE regulations, including the GE Metrics, GE Reporting, and Adding New GE Programs

  • The Court left in place the GE Disclosure Requirements

  • ED has asked the Court to restore the GE Reporting regulations and is awaiting the Court’s decision


Which programs are ge programs

Which Programs are GE Programs

The HEA provides that to be Title IV eligible an educational program must be offered by:

  • A public or non-profit postsecondary educational institution and leads to a degree; or

  • Any institution and “to prepare students for gainful employment in a recognized occupation”

  • Generally, all non-degree programs must lead to gainful employment

  • Generally, most programs at for-profit institutions must lead to gainful employment


Which programs are ge programs1

Which Programs are GE Programs

At proprietary institutions all programs are GE Programs except for –

  • Preparatory coursework necessary for enrollment in an eligible program

  • Bachelor’s degree programs in liberal arts offered since January 2009 that are offered by a proprietary institution that has been regionally accredited since October 2007


Which programs are ge programs2

Which Programs are GE Programs

At public institutions and not-for-profit institutions all programs are GE Programs except for –

  • Programs that lead to a degree

  • Programs of at least two years in length that are designed to be fully transferable to a bachelor’s degree program

  • Preparatory coursework necessary for enrollment in an eligible program


Which programs are ge programs3

Which Programs are GE Programs

GE Programs include –

  • Teacher certification programs leading to a certificate awarded by the institution

  • ESL programs


Which programs are ge programs4

Which Programs are GE Programs

GE Programs do not include –

  • Teacher certification coursework that does not lead to a certificate awarded by the institution

  • Preparatory coursework necessary for enrollment in an eligible program (Loans only)

  • At public and private non-profit institutions, programs of at least two academic years that are designed to be fully transferrable to a bachelor’s degree program and do not lead to a credential awarded by the institution


Required disclosures

Required Disclosures

Outlined at 34 CFR §668.6(b)(1)

  • Disclosures must be made for each GE program

    Disclosure items:

  • Occupations

  • Normal time to complete program

  • On-time graduation rate for completers

  • Tuition and fees, book and supplies, room and board

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

  • Median loan debt

  • Any other information the Secretary provided to the institution about that program


Required disclosures1

Required Disclosures

Occupations – 34 CFR 668.6(b)(1)(i)

  • Must list occupations by name and SOC codes that the GE program prepares students to enter

  • Must link to occupational profiles on O*NET (http://online.onetcenter.org/crosswalk/)

  • Use a representative sample if >10 possible occupations

  • See GE Electronic Announcement #25


Required disclosures2

Required Disclosures

Normal Time

  • Defined in regulation at 668.41(a)

  • In weeks, months, or years

  • Not 150% of normal time


Required disclosures3

Required Disclosures

On-time graduation rate for completers – 34 CFR 668.6(b)(1)(ii)


Required disclosures4

Required Disclosures

Example: On-time completion rate if 200 students completed in most recent Award year

Number of students who completed within normal time

Total number of students who completed in the 2010-2011 AY


Required disclosures5

Required Disclosures

On-time graduation rate for completers includes:

  • Leave of absence

  • Time if a student withdrew and then returned

  • Enrollment in other programs if the student did not complete the other program


Required disclosures6

Required Disclosures

Educational costs – 34 CFR 668.6(b)(1)(iii)

  • Tuition and fees charged for completing the program within normal time

  • Typical costs for books and supplies

    • Unless included in tuition and fees

  • Room and board, if applicable

  • Other expenses (such as living expenses or transportation) are optional

    • But must link to/provide access to program cost information under 34 CFR 668.43


Required disclosures7

Required Disclosures

Placement rates – 34 CFR 668.6(b)(1)(iv)

  • For students who complete the program

  • To be determined using NCES methodology, once available. Until then:

    • Disclose/use accrediting agency and/or state rates or methodologies or

    • If not required by an accrediting agency or state, then placement rate disclosure not required until NCES methodology is available


Required disclosures8

Required Disclosures

Median loan debt – 34 CFR 668.6(b)(1)(v)

  • Median (not mean) incurred by students who completed the program

  • Must separate median loan debt

    • Title IV, HEA program loans

    • Private education loans

    • Institutional financing plans


Required disclosures9

Required Disclosures

Median loan debt categories:

  • Title IV Debt - FFEL and Direct Loans do not include Perkins or Parent PLUS

  • Private Loan Debt - Examples include, but are not limited to loans made expressly for educational expenses by:

    • Financial institutions or credit unions

    • Institutions of higher education or their affiliates

    • States and localities

  • Institutional Debt - the amount owed as of the day the student completed from the GE Program


Required disclosures10

Required Disclosures

  • Any other information the Secretary provided to the institution about that program

  • What information this will include may be determined by an upcoming Court decision

  • We will provide information as it becomes available


Disclosure availability

Disclosure Availability

  • Requirements outlined in 34 CFR 668.6(b)(2)

  • Disclosures must be in promotional materials made available to prospective students

    • Promotional materials include invitations, advertisements, or solicitations that mention or otherwise refer to a specific GE Program or Programs

    • Includes course catalogs and Social Media

    • May display the URL or provide a live link to the webpage where the required information is located, with a clear explanation of the information that is available at that webpage


Disclosure availability1

Disclosure Availability

  • Disclosures must be posted on institution’s Website

    • Prominent on program home page of relevant GE program

    • Accessible via direct, prominent link from other institutional webpages about the program

    • Prepared in an open format that can be easily searched by common web search applications

  • Schools must use template, when available (not yet released; date TBD)


Compliance tips

Compliance Tips

  • Who should I include in my calculations?

    • Students who completed the program in the most recently completed award year

    • Regular Students

      • If high school student is a “regular student” then you should include that student

    • If no SSN, do not include that student in disclosure calculations


Compliance tips1

Compliance Tips

  • If the number of students who completed a GE Program during the award year was less than 10, the school should not disclose to the public:

    • Median debt amounts

    • On-time completion rate


Compliance tips2

Compliance Tips

  • Schools must disclose the following, regardless of the number of students who were enrolled in or completed the program:

    • The occupations (by names and SOC codes) that the program prepares completers to enter

    • Normal time to complete the program

    • Tuition/fees charged to complete the program in normal time

    • Placement rates if doing so aligns with the requirements of the accreditor or state on “small numbers”


Compliance tips3

Compliance Tips

Electronic Announcement #25 - Disclosures by Educational Program

  • Length of Programs – Is there a significant difference in the published length of the programs?

  • Tuition and Fees – Is there a significant difference in the tuition, fees, or other costs for the programs?

  • Programs Offered in Different States – Are programs offered in different states that require different placement rate calculations and different minimum requirements?


Ge resources

GE Resources

  • GE Information Page on IFAP - http://ifap.ed.gov/GainfulEmploymentInfo

    • Regulations

    • Dear Colleague Letters and Electronic Announcements

    • FAQs

    • Training

    • Resources


Ge resources1

GE Resources


Ge resources2

GE Resources

  • If you still have questions after reviewing the Dear Colleague Letter, Electronic Announcements, and FAQs, send your questions to [email protected]


Contact information

Contact Information

  • Jessica Finkel, Office of Postsecondary Education

    • Phone: 202-502-7647

    • E-mail: [email protected]

  • Cynthia Hammond, Federal Student Aid

    • Phone: 202-377-4236

    • E-mail: [email protected]


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