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The concept of disclosure is one which is important when it comes to our postsecondary institutions. That idea became all the more prevalent with the implementation of the Program Integrity regulations back on October 29, 2010. Accordingly, each year institutions have been obliged to complete and utilize the Gainful Employment Disclosure Template (GEDT) since it first was revealed back on November 22, 2013. Since then, institutions have intently awaited each year’s release of the latest edition.
The 2019 GE Disclosure Template (GEDT)
The U.S. Department of Education (ED) announced the awaited release of the 2019 GEDT on the Information for Financial Aid Professionals(IFAP) Web site via GE Electronic Announcement #119 on Friday, May 9, 2019. This later-than-normal release comes as a result of the public comment period that was held from late last fall through February of this year. Although historically GE Disclosure information was required to be posted and distributed by January 31 of each year following the most recently completed award year, that is not the case this year due to the later release date of the GEDT. Since this year the GEDT was just released in May, institutions have a later date for the mandatory update of information. The deadline for an institution to update its 2019 GEDT is July 1, 2019.
The announcement provides the Web address (URL) to the 2019 GEDT page at https://www2.ed.gov/about/offices/list/ope/ge-template.html. Upon arriving at the page of that URL, you will need to select the “U.S. Department of Education Gainful Employment Disclosure Template” under the heading, “Template.” Once you have selected that option/link, it will open up a Microsoft Word document as the template. It is entitled, Gainful Employment Disclosures – 2019.
Distinctives of the GEDT for 2019
This year, 2019, ED made further modifications to the GEDT format. As ED states, the GEDT has been “simplified and streamlined” to only provide the data believed to be “especially meaningful” to students. The new GEDT will now contain:
- Normal time to complete the program;
- Total program costs if completing the program within normal time (including tuition and fees plus books, supplies, and equipment—while excluding room, board, or other expenses);
- Median cumulative debt for Title IV students completing the program within normal time (including Federal, private, and institutional debt);
- Licensure information for the program’s target occupation;
- URL for the College Scorecard (see discussion under “Delving Deeper” below); and,
- Warning language if required under 34 CFR 668.410.
Of note is that the 2019 GEDT is not Web-based. That is, there is not a form-type tool that generates a completed template that is uploaded to the applicable GE program’s Web page. Rather, as a Word document template, the institution simply copies the provided text and fills in the appropriate data elements specified by the text. Note that the “instructions” for the template are provided in italicized font on the Word template itself. Importantly, since the template does not create a Web-based template to upload as in past years, the institution will need to post the applicable GEDT to the relevant GE program’s Web page on the institution’s Web site.
Important points to keep in mind are that:
- You will need to complete a GEDT for each GE program at your institution.
- Any Web page containing academic, cost, financial aid, or admissions information about a GE program must include the GEDT for that program, or a prominent, readily accessible, clear, conspicuous, and direct link to the program’s disclosure template.
- It is key to being compliant to make sure the links to the GEDTs are very clear, conspicuous, and readily accessible. It is important not to bury or hide the links.
This is the third year that institutions must use the GEDT developed and distributed by ED to disclose the required information about their GE Programs in order to be in compliance with the GE Program regulatory requirements.
Deadline for Implementing the New GEDT
To re-emphasize, the due date for updating the GEDT for 2019 is different than past years. ED specified in this GE Electronic Announcement#119 that institutions have until July 1, 2019, to update disclosures for each of their GE programs, using the 2019 GEDT.
Dissemination of the GEDT
Per ED’s direction, “any web page containing academic, cost, financial aid, or admissions information about a GE program must include the GE Disclosure Template for that program or a prominent, readily accessible, clear, conspicuous, and direct link to the program’s disclosure template.” See the GE Frequently Asked Questions on IFAP for additional information about disclosure requirements.
Again, the GEDT, once completed, no longer generates a zip file that contains the GE program’s disclosure page for uploading to the institution’s Web site. Rather, the institution hosts the GE program’s disclosure page on its GE program’s Web page.
IMPORTANT: It is critical to recall the extension of time, until July 1, 2019, for institutions to comply with 34 CFR 668.412(d) and (e). Because the deadlines for compliance with these provisions had been extended twice before, some may have thought that they might be extended again, especially in light of the GE negotiated rulemaking that occurred late last year. But, ED’s GE Electronic Announcement #120, dated May 23, 2019, clarifies that the deadline for compliance with these provisions of the regulations remains July 1, 2019.
As a reminder, these regulatory requirements [668.412(d) and (e)] stipulate that the GEDT must be included in all promotional materials, as well as a direct distribution of the GEDT to prospective students before they sign an enrollment agreement, complete registration, or make a financial commitment to the institution. It is recommended that this latest GE Electronic Announcement #120 be read carefully for ED’s guidance regarding methods for disseminating the GEDT to prospective students.
Divulging GE Student Warnings
The GE Electronic Announcement #119 reiterates that under the GE regulations, institutions must provide warnings for programs that couldbecome ineligible for Title IV aid based on the next round of final D/E rates. Loss of eligibility results after receiving overall “fail” ratings in any two (2) out of three (3) consecutive award years for which the GE D/E rates are calculated or after receiving a combination of “fail” and “zone” ratings for four (4) consecutive award years for which rates were calculated. Warning requirements are temporarily suspended for programs with an alternate earnings appeal currently under consideration.
After the first year of D/E rates, warnings are required for programs with an overall “fail” rating for their 2014-2015 rates without a pending earnings appeal. If an institution withdraws its GE program’s earnings appeal, or ED rejects it, the institution has 30 days to revise its GEDT to include the required warning.
It quickly becomes evident that this year’s GEDT has a few differences from the past years’ templates and instructions.
- The 2019 GEDT does not specify which year’s data is to be used for completing the GEDT. Per written guidance we have received from ED, institutions should “simply base their calculations on students who completed the program within 100% of normal time during the most recently completed award year (2017-2018).”
- Note that there is no longer a GE “Quick Start Guide” as in past years. (Although when you go to ED’s GEDT page on the ED Web site, in the paragraph labeled “Related Files,” there is a link to the Quick Start Guide, it is not applicable to the GEDT for 2019. That link still takes you to the Guide for 2018.) Per our dialog with ED, “with the new text-based format of the GEDT, schools no longer need instructions for how to upload specific HTML code output to their program webpages in a way that maintains formatting, so a Quick Start Guide was not created. Instructions for GEDT content are included directly in the document and schools with further questions may direct them to email@example.com.”
- Also, per ED (in case you printed a copy of it), the second URL in the originally disseminated GEElectronic Announcement #119 on May 9, 2019, that directed to the 2018 GE Disclosure Template was included in error and has since been removed. Now only the correct link leading to the 2019 GEDT Web page remains in the GE Electronic Announcement #119.
- ED has confirmed that the College Scorecard link and introductory language are mandatory for the 2019 GEDT. ED expanded the College Scorecard earlier this year and anticipates expanding it further in the future. Some schools that offer only certificate-level programs had indicated that they could not find their institution when searching for it on the College Scorecard when the GEDT was first released. This appears to be resolved at this point so that at least basic information comes up for the institution when searching for a certificate-level only school.
- ED confirmed to us that “schools may add additional information to their GE Disclosure Template page so long as the required elements are all present and meet any accessibility requirements. The required elements must be displayed in a manner that is prominent, readily accessible, clear, conspicuous, and direct.” Prior to ED’s clarification and expansion of the information and guidance about the College Scorecard site, some schools may have elected to add something along the lines of, in addition to the College Scorecard link, students may wish to also review data at the College Navigator Web site at: https://nces.ed.gov/collegenavigator. (Note that this additional information link to College Navigator is not required for the GEDT, but may be useful to students.)
The GE Disclosure and warning information is critical to an institution meeting ED compliance requirements. Taking timely appropriate steps now, as ED has indicated, helps ensure the basic GE stipulations are met and enhances institutional compliance.
This material is presented for informational and educational purposes only and should not be considered to be giving legal advice.