Financial aid administrators at times may wonder if a student is striving to become a professional student. But, at other times, the financial aid officer wonders if the student is ever going to complete any educational program! Interestingly, the U.S. Department of Education (ED) wants to know whether or not they have completed a program, as well—especially a “gainful employment” (GE) program.
ED has announced in the Gainful Employment (GE) Electronic Announcement #114 that it has distributed institutions’ Draft Gainful Employment “Completers Lists” to the institutionally designated Student Aid Internet Gateway (SAIG) mailbox for GE message purposes. The Draft GE Completers Lists are disseminated to an institution if it had one or more GE Programs with at least 30 program completers in a two-year cohort period consisting of award years 2011-2012 and 2012-2013. If the program had less than 30 completers in that period, the cohort will be expanded to include the 2009-2010 and 2010-2011 award years to make the cohort a four award year period rather than two award years.
NOTE: If your institution did not sign up to receive GE Notifications from SAIG (i.e., set up a designated GE SAIG mailbox), you may not have received the Draft GE Completers List in your SAIG mailbox. If this is the case, the institution will need to request the files using the “Gainful Employment Completers List (GEPDC1)” report option on the Reports tab of the NSLDS Professional Access Web site. The applicable report will be sent as a GECOMBOP message class.
Due Date for the GE Draft Completers List
The GE Completers List is used by ED to calculate an institution’s Debt-to-Earnings (D/E) rates using the debt and earnings of students who completed Gainful Employment (GE) programs during the applicable cohort periods. Institutions have 45 days to submit any necessary corrections to the Draft GE Completers Lists once the correction period begins. ED has stated that the correction period began on Monday, April 30, 2018, and continues through Wednesday, June 13, 2018. Any corrections to the GE Completers List must be submitted not later than 11:59p.m. Eastern Time (ET) on June 13, 2018.
If the designated individual who will be completing the Draft GE Completers List is new to the GE Completers List review and reporting process, or needs a refresher, it would be helpful to re-examine GE Electronic Announcement #112, as well as GE EA #114 (which announced the release of the Draft GE Completers List) and its attachments. Further, a study of Chapters 5 and 6 of the March 2018 edition of the NSLDS GE User Guide will prove beneficial. (For example, it is important to note the distinction in NSLDS between the GE Completer Add page under the “Enroll” tab and the Add GE Completer page under the “GE” tab.)
Of note, ED suggests that institutions pay careful attention to previously reported attendance dates of the student in a particular program as those dates impact the loan attribution calculations used later in the process for calculating GE Debt-to-Earnings rates and cannot be corrected or challenged later.
As was the case in the last cycle of GE Completers reporting, schools will utilize NSLDS to make any appropriate data corrections.
Description of the GE Draft Completers List in Brief
The process of completing the GE Draft Completers List involves the following:
- Review the draft GE Completers list provided by ED via your SAIG mailbox to ascertain its accuracy.
- Affirm that the students listed on the Completers List did in fact complete the program in which they are listed by ED.
- Add or delete any students as necessary, as allowed and described in the first attachment to GE EA #114.
- Make corrections as appropriate to any data needing an update or correction in accordance with guidance in the attachments to the GE EA #114 and the NSLDS GE User Guide, Chapter 6. Note that updates may be made to GE Records on the “current Program” section of the GE Completer Update page in NSLDS. Items that may be updated or corrected include the student identifiers, exclusions, attendance begin and end dates, debt amounts, and amount of tuition/fees and allowance for books and supplies. (There is an option to delete a row of information, if it is appropriate and accurate to do so.)
- Ascertain which, if any, GE program completers are ones whose debt from a lower credentialed GE program is “rolled up” into a higher credentialed GE program at the same institution. This is critical to ensuring the student is excluded from the lower-credentialed program’s D/E rate calculation. (Review the second attachment to GE EA #114 for details and examples.)
- Ensure any applicable students that are allowed to be excluded are appropriately indicated in your submission, and the appropriate documentation is included.
- Submit the necessary and applicable corrections to the Draft GE Completers List via NSLDS not later than June 13, 2018.
Deciphering the Current GE Cycle’s Schedule
While many things can change, it appears that the following diagram would picture the current estimation of how the remainder of this year’s GE cycle may play out.
Although the above illustration is a best guess of the current projected timeline for this year’s GE cycle, there are still a couple of points to keep in mind.
- First, ED may still promulgate a new Notice of Proposed Rulemaking (NPRM) on Gainful Employment since the latest Gainful Employment Negotiated Rulemaking Committee did not reach consensus on necessary points earlier this year. ED is at liberty to put out a new NPRM based upon what it sees to be a best recommendation. If ED is going to do so, it will need to be out soon—presumably not later than mid- to late-June. This time frame is necessary to allow opportunity for public comment on the NPRM and for ED to respond to the comments in the preamble to the Final Regulations and have them published by November 1, 2018, as required by statute, in order for them to be scheduled to take effect on July 1, 2019. If an NPRM is published, it is important that financial aid administrators and/or the administration of your institution provide your comments about the NPRM when ED issues it.
- Even though we are working on the Completers Lists for the GE cohort periods that will be applicable to the 2016 Debt Measure Year (2016 DMYR), it must be remembered that other key dates are on the near horizon that are applicable to the 2015 DMYR.
- As a result of ED providing a delayed time frame to implement some aspects of the regulations related to the 2015 DMYR results, institutions must not forget that the required direct distribution of the GE Disclosures and “Warnings” were delayed until July 1, 2018. However, institutions were still to have their GE Disclosure Template (GEDT) updated on their Web sites as of April 6, 2018, with the 2018 version of the GEDT. This GEDT will include the warnings if a program did not pass the DMYR D/E ratios.
- Institutions that are notified of a failing 2015 DMYR D/E rate must update their GEDT no later than 30 days after ED issues the notice of determination of the program’s status and notify their students of the required warning information in writing. (See Dear Colleague Letter GEN-15-12 for more details.)
Department of Education’s GE Completers List Webinar
To assist schools with a greater understanding of the Draft GE Completers List process, ED is conducting a GE Completer List Webinar. Each of them will be held twice:
Title: Submitting Draft GE Completers List Corrections
Date and Time: Wednesday, May 9, 2018, from 2:00 PM ET to 3:30 PM ET.
Institutions may view Dear Colleague Letter (DCL) GEN-18-07 posted on IFAP on April 17, 2018, for more details and instructions for registering for the Webinar.
The GE Completers List does require a bit of work. But, in the end, once the GE Completers List is done, you have a solid idea of whether your particular students, about whom you had question, are in fact, a “Completer.”
Should you have any questions regarding this information about the Draft GE Completers Lists and the data corrections process, please feel free to contact Customer Service through the Client Solution Center.
This material is presented for informational and educational purposes only and should not be considered to be giving legal advice.