Gaining the Upper Hand on Gainful Employment – Key Dates Lie Ahead
Time stands still for no one! It seems as though reporting of gainful employment (GE) data to the U.S. Department of Education (ED) was just completed—with hopes that everything was reported accurately. And, here we are again, talking about GE! All of that information that you have worked with in the last few months since the first “new” GE reporting in July, now comes into play again. With that being the case, it is no time to let one’s guard down. Rather it is time to ensure you have gained the upper hand on the upcoming GE requirements. There are at least three key items to keep in mind in the coming months regarding GE.
GE Transitional Certifications Due By December 31, 2015
This topic has been discussed in various venues since the advent of “GE 2.0.” But, part of the regulatory requirements pertaining to GE is that schools must ensure they have certified that all of their Title IV-eligible gainful employment programs meet the requirements of 34 CFR 668.414. The certification must be completed by not later than December 31, 2015. The certification includes:
- affirming that all of the GE programs are approved by a recognized accrediting agency, or that they are otherwise included in its institutional accreditation by an approved accrediting agency. For those institutions that are a public postsecondary vocational school, the institution may alternatively, in lieu of accreditation, be approved by the authorized State agency that carries that responsibility in the institution’s State.
- certifying that each GE program is programmatically accredited if that is required by a Federal or State governmental entity in the State in which the school is located or in which the school is otherwise required to get the State’s approval under Title IV regulations (see 34 CFR 600.9).
- confirming that for the States in which the institution is located (or the State in which it otherwise has to receive State approval), it meets the educational prerequisites for the professional licensure requirements or certification in that State so that a student who completes the program and desires employment in that State qualifies to take the specified certification or licensure examination required for the student to be able to be employed in an occupation that the GE program trains students to enter.
There are a couple of instances where ED has indicated that a school may make the certification that the program meets the regulatory requirements prior to actually receiving programmatic accreditation for a GE program. Even in these limited situations, the institution has to be able to certify that the State allows the institution to offer the GE program in the State as of the date of certification, and that the State would permit graduates from the program to apply for licensure applicable to the program. (See ED’s GE Electronic Announcement #66 at IFAP.ed.gov for more details on these limited situations.)
An institution with GE programs must submit the certification that has been signed by the institution’s most senior executive officer not later than December 31, 2015. (It may be submitted earlier than this deadline.) ED’s GE Electronic Announcement #54 on IFAP provides a sample Transitional Certification that may be utilized. NOTE: The Department does state in GE Electronic Announcement #70 that if “an institution has submitted an E-App that resulted, or will result, in a new Program Participation Agreement (PPA) issued to the institution after July 1, 2015, and before December 31, 2015, those PPAs will have the required GE program certification included; therefore no Transitional Certification will be required.”
GE Completers List
In a Webinar entitled, “Gainful Employment: Interpreting the GE Completers List,” on November 18, 2015, ED indicated that its plans were to generate the draft of the GE Completers List in November, 2015. The data contained in this list is what forms the basis for the calculation of the debt-to-earnings rates used in determining if a program leads to gainful employment. Once the Completers List is released, schools have a 45-day period in which to challenge the data on the list. The Completers List is one that details the Title IV aid recipients that the school reported as completing a GE program during the cohort period via NSLDS.
The GE Completers List will be sent to the institution’s TG mailbox. The file containing the Completers List will be associated with the Batch Gainful Employment Notification Package. The message class of the list will be GECOMBOP.
Once the draft Completers List is received, the school must review it for accuracy. (Ensure that only students who were Title IV aid recipients are included since ED is not authorized to collect the GE data on non-Title IV aid recipients.) Upon the school’s review of data in the draft Completers List, the school will be able to utilize ED’s new Data Challenges and Appeals Solution (DCAS) to challenge their self-reported data, as well as the metrics that ED calculates. Initially, the DCAS will allow institutions the ability to correct data in the GE Completers List, as well as the ability to add or remove any students that should be. A separate Webinar entitled “How to Submit a Challenge to the GE Completers List” was conducted on November 19, 2015. This presentation discussed the process of submitting a challenge to the draft GE Completers List. It is currently anticipated that the challenge period will end in January 2016 (depending upon the actual release date of the draft GE Completers List). It is important that all data in the GE Completers List is accurate. Therefore, if data is not accurate in the draft version of the Completers List, it is crucial to make the necessary challenges and/or updates to data. It is projected that the draft debt-to-earnings rates will be released in the summer of 2016 based upon data contained in the Completers List (after the end of the challenge period).
If schools have not yet done so, they should ensure their institution’s TG mailbox is signed up for the Batch Gainful Employment Notification Package at the SAIG Enrollment Web site. The URL for SAIG enrollment is https://fsawebenroll.ed.gov. If institutions are not signed up for the Notification Package, they will not receive the draft GE Completers List. If this occurs, schools can still request the GE Completers List via the NSLDSFAP Web site.
The details of the GE Completers List and information related to submitting challenges are addressed in the latest edition of the NSLDS Gainful Employment User Guide, the Gainful Employment Operations Manual, and the upcoming Data Challenges and Appeals Solution (DCAS) User Manual (which is yet to be released) on IFAP.
The transcripts and handouts of the two Webinars about the GE Completers List and submitting challenges to the list via DCAS are reportedly to be available in the early half of December 2015 on ED’s “Training for Financial Aid Professionals” page on IFAP, based upon comments the presenters made during the Webinars.
GE Disclosure Information Template
Schools are required to update their GE Disclosure Information each year by not later than January 31. Therefore, institutions must update their Web sites with the 2014-2015 GE disclosure information applicable to each GE program by not later than January 31, 2016. ED released the updated GE Disclosure Template on IFAP via the October 23, 2015, GE Electronic Announcement #65. In addition to it being important to update this information for the benefit of prospective students deciding on a school to attend, the correct year’s GE Disclosure Information is an item subject to review in audits and program reviews.
So, although much activity occurred recently when reporting gainful employment data to ED, there is still much to keep in focus related to GE. It is always important to ensure you gain the upper hand on gainful employment data! It is too important to let GE data slide by and take the upper hand over you.
[EA 06112015; EA 10232015(2); EA 11202015]
This material is presented for informational and educational purposes only and should not be considered to be giving legal advice.