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January 31, 2014 is the deadline for disclosing 2012-2013 award year information via the Gainful Employment Disclosure Template

January 7, 2014
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The long-anticipated Gainful Employment (GE) disclosures template has finally been released by the U.S. Department of Education (ED). This template was a requirement of the historic Program Integrity regulations of October 29, 2010. As schools are aware, there was much legal battle over the concept of the GE regulations. However, the Court’s decision resulted in the GE disclosures requirement being upheld. Therefore, schools have been responsible for providing the stipulated disclosures related to GE programs at their institution. Heretofore, in the absence of the ED-developed template, schools were obligated to determine the best means of collecting and, within certain parameters, disseminating the disclosure information.

With the release of ED’s template for GE disclosures on November 22, 2013, schools are now mandated to utilize this tool. The deadline for disclosing information for the 2012-2013 award year is January 31, 2014.

The template was made public in the Gainful Employment Electronic Announcement #46. As instructed in the announcement, schools may access the template at the URL given for the 2009-2010 Negotiated Rulemaking Web page. (The URL for direct access to this page is http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html.) Currently, the GE Disclosure Template (GEDT) is the first item discussed on that page. There are also two different “Quick Start Guides” available on that page—one for Internet Explorer 7.0 (and higher) and one for Mozilla Firefox 3.0 (and higher). These guides give a walk-through of the information requested for the template. The direct link to the template itself is simply http://ope.ed.gov/GainfulEmployment.

Given that most schools have become acquainted with the Net Price Calculator (NPC) template since the 2011 requirement for posting an NPC, the look and feel of the GEDT will seem very familiar, as will the process for completing the template also. Therefore, the process of completing the template should not be difficult. Schools will simply need to ensure that they have gathered the information necessary to respond to the questions and data points of the template. Of note is the fact that, unlike the NPC template where schools could choose to use ED’s template or a template developed by a third-party, for the GE disclosures all schools must use the GEDT developed by ED. Alternative templates are not authorized or allowed.

Schools will find that use of the GEDT will result in an output document (a Web page) that covers all of the required GE disclosures. Of special interest is that use of the template will warrant that the GE information disclosed is in the appropriate “open format” making it simple to use and allowing for ease in re-using the information. Moreover, use of the template ensures that the output will be accessible to individuals with disabilities in accordance with Section 508 of the Rehabilitation Act. Similar to the NPC template, the GEDT will likewise allow for boxes where schools may add further explanatory comments and information. Additionally, it simplifies the process for determining the Standard Occupational Classification (SOC) codes by providing a link to the applicable O*NET profiles.

Of interest is that the use of the GEDT will require the same categories of data as schools have previously provided. Schools will still need to have the critical data available to input in the template. Those items remain the same as in recent years: program length, the appropriate SOC code based upon the program’s CIP code, the cost of the program (the entire program), information necessary to calculate an on-time completion rate, median debt information, and the job placement rate if applicable to the program.

A slight variation from guidance in prior years is that with this year’s template and disclosures, schools will need to utilize a direct link from the GE program’s home page to the program’s disclosure page generated by the template. Any other pages on the school’s Web site containing information about the GE program (e.g., general informational page, academic page, or admissions, etc.) must also have a prominent link to the GE program’s home page or GE disclosure page. Note that for this year, the required GE disclosures are not displayed directly on the GE program’s home page, but rather the program’s home page must provide a link to the disclosure information from the template.

Once more, schools are reminded that January 31, 2014 is the deadline for disclosing 2012-2013 award year information via the Gainful Employment Disclosure Template.

(EA11222013)

The information provided to you is FAME’s opinion based upon our interpretation of the issues and details provided, and our interpretation of the Title IV regulations, legislation, and U.S. Department of Education guidance, as applicable. FAME shall not be liable for any error contained herein or for any damages whatsoever arising out of or related to the use of this information.

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