The Gainful Employment (GE) “Disclosures” requirement is not the same as the GE “Reporting” requirement
Now that the U.S. Department of Education (ED) has come out with its Gainful Employment Disclosure Template (GEDT) in the November 22, 2013 GE Electronic Announcement #46, many have experienced confusion as to what is required.
First, and foremost, it is important to understand the difference between GE disclosure requirements and GE reporting requirements. As schools will recall, there was much legal battling that occurred over the October 29, 2010 Gainful Employment regulations and related guidance. The 2012 Court decisions “vacated”, or invalidated, the section of the regulations that required schools to “report” GE data. Specifically, schools do not have to report the information that was previously required the one time back in November 2011 (which included the reporting of several prior years’ data all at once). As stated in the GE Electronic Announcement #39 on July 6, 2012, “…the Court’s decision vacated the gainful employment reporting requirements in 34 CFR 668.6(a). Therefore, institutions are not required to submit gainful employment reports….” This decision has not been preempted by any subsequent changes in regulation or Court cases. Therefore, schools are not currently required to report data through NSLDS for the purpose of calculating their GE debt-to-income ratios or loan repayment rates. An institution may voluntarily choose to correct any previously reported GE data for prior years if they choose to do so. But, currently, that is not a requirement either since the resulting data is not being used by ED.
However, schools are indeed still required to submit the required information for the GE disclosure requirements. The deadline for disclosing an institution’s 2012-2013 GE disclosure information is January 31, 2014. This is, therefore, where the GEDT comes into play. But, the template is not collecting data that is reported through NSLDS. It is strictly asking the school for information that is then used to disclose on the school’s Web site. This disclosure process requires schools to enter data in the GEDT related to the school’s GE programs. This includes information related to each specific GE program. Data requested when completing the GEDT include:
- CIP codes,
- Credential level
- SOC codes
- total program cost, and
- Median debt information for program completers (which is to be disclosed separately by Title IV loans, private loans, and institutional financing). This data will require schools to have the data for the number of students who successfully completed the program during the applicable award year, in this cased July 1, 2012 through June 30, 2013.
- Normal program completion time
- Job placement rate as reported to the State or accrediting agency (if applicable)
Schools will note in the November 22, 2013 GE Electronic Announcement #46 that there is no mention of accessing NSLDS for the purpose of utilizing the GE Disclosure Template. A school will use the output file created from the GEDT to upload to their own institution’s Web site. This is a very similar process as schools use for uploading their Net Price Calculator information. Schools should follow the instructions carefully that are provided in the Gainful Employment Disclosure Template Quick Start Guide. This Guide is accessible from the link in the GE Electronic Announcement #46 which takes the user to ED’s GEDT Web page. Schools may also find ED’s Gainful Employment Frequently Asked Questions Web page to be helpful as well.