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DYK: GE Alternate Earnings Appeal+Disclosure Template D

April 6, 2017
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The U.S. Department of Education (ED) posted late on Monday, March 6, 2017, that it is granting additional time for submission of an Alternate Earnings Appeal to the Gainful Employment (GE) Debt-to-Earnings (D/E) rates that were released by ED on January 9, 2017.[1]  Additionally, ED is extending the deadline by which institutions must comply with the Gainful Employment (GE) disclosure requirements, and the use of the new GE Disclosure Template, that were released in GE Electronic Announcement #103 on January 19, 2017.[2] 
 
The reason stated for the extension of the deadlines was to allow time for ED to further review the GE regulations and their implementation.  The notice was made via one of its routine Electronic Announcements.
 
The new deadline by which institutions that are going to submit an Alternate Earnings Appeal must do so is July 1, 2017.  Previously, the deadline was March 10, 2017.  (The change in the deadline for submitting an Alternate Earnings Appeal did not also extend the deadline by which institutions had to submit a Notice of Intent to Appeal, which has already passed.  That deadline date for submitting the Notice of Intent to Appeal was January 23, 2017.)
 
Likewise, the new deadline by which institutions must have their GE disclosures updated is now extended to July 1, 2017.  This is the new date by which institutions must begin use of the new GE Disclosure Template (GEDT) that was released on January 19, 2017, in GE Electronic Announcement #103.  Institutions must also ensure fulfillment of the new distribution requirements associated with the new GEDT by July 1, 2017, instead of the prior date of April 3, 2017.
 
NOTE:  The extended deadline for the use of the new GE Disclosures Template does not also extend the date by which institutions that have GE programs with failing D/E rates must begin providing “Student Warnings” to a GE Program’s students and prospective students.  Such institutions must begin providing Student Warnings within 30 days of having received ED’s Notice of Determination.[3]  However, institutions that submitted an “intent to file” an Alternate Earnings Appeal by the applicable deadline are not required to provide Student Warnings for a failing program while the Secretary considers the appeal.[4]  
Institutions are encouraged to review this new GE Electronic Announcement in full, along with the prior applicable GE Electronic Announcements on IFAP, and make plans accordingly.

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