It’s Time to Disclose
It is time to commence the annual ritual, of recent years, for many postsecondary schools. That is, it is time for the annual update of institutions’ Gainful Employment (GE) Disclosure Templates, or the GEDT. The U.S. Department of Education requires all postsecondary institutions that have GE programs to disclose applicable information via the GEDT.
The 2018 GE Disclosure Template (GEDT)
ED announced the release of the 2018 GEDT on the Information for Financial Aid Professionals (IFAP) Web site via GE Electronic Announcement #110 on Friday, January 19, 2018. For a number of years, the GEDT had been made available in the fall of each year so that schools could ensure they had their GE Disclosure Information posted and distributed by January 31 of each year following the most recently completed award year. However, last year, and again this year, the GEDT has been released in January following the end of the preceding award year end date (June 30).
The announcement provides the Web address (URL) to the 2018 GEDT page at https://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html. (This URL given here in this FAME Regulatory Bulletin is hyperlinked to the applicable page. Note, however, that the URL given in the GE Electronic Announcement is not hyperlinked to the page. One must copy and paste the URL given into a Web browser, or “right click” on the link and open it in a new window.) The new GEDT will allow institutions to update their GE Disclosure Information for the award year ending June 30, 2017.
Modifications to the GEDT for 2018
This year, 2018, ED made further modifications to the GEDT from the format of last year’s template. It is noted that the look and functionality of the 2018 GEDT will still be similar to that of last year. Nevertheless, there are a number of changes worth noting:
- Institutions are no longer required to disclose room and board charges in the template.
- The unsubsidized loan interest rate will be prefilled based on the selected credential level.
- Institutions will not be required to disclose median earnings data in the template.
- Institutions must still disclose whether a program has failed the debt-to-earnings (D/E) rates measure within 30 days of receiving a GE program’s final D/E rates from ED. Once an institution has indicated that a warning is required on the disclosure template input, the output screen will be pre-populated with the student warnings required under 34 CFR §668.410 of the GE regulations.
- Institutions may add more than one accreditor’s job placement rate.
- The format for reporting licensure requirements was changed; and “Foreign Country” was added as an option in the list of States.
This is the second 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
ED specified in the GE Electronic Announcement #110 that institutions have until April 6, 2018, to update disclosures for each of their GE programs, using the 2018 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.
The GEDT, once completed, generates a zip file that contains the GE program’s disclosure page. The institution hosts the GE program’s disclosure page on its GE program’s Web page. Institutions will likely find the GE Disclosure Template Quick Start Guide to be beneficial in understanding and using the GEDT. It is available on the GEDT page on ED’s Web page given above with the GEDT address.
It is important to recall the extension of time, until July 1, 2018, for institutions to comply with 34 CFR 668.412(d) and (e). As a reminder, these regulatory requirements stipulate that the GEDT must be included in all promotional materials, as well as a direct distribution of the GEDT to prospective students. This additional time frame granted for these requirements does not extend to student warnings requirements.
GE Student Warning Requirements
The GE Electronic Announcement reiterates that under the GE regulations, institutions must provide warnings for programs that could become 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.
If an institution appropriately and timely notified ED that it would be submitting an alternate earnings appeal for one or more of its GE programs, the deadline for submitting an alternate earnings appeal is Thursday, February 1, 2018. After the first year of D/E rates, warnings are required for programs with an overall “fail” rating 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.
Reminder of Important Steps
To be ready for completing and posting the 2018 GE Disclosure Template and any necessary student warning requirements, it will be helpful to consider the following points:
- Check your ED Student Aid Internet Gateway (SAIG) mailbox regularly for any anticipated (or, unanticipated) Notice of Determination that the school’s program(s) may become ineligible based upon subsequent D/E rates measures.
- Plan now your method and procedures for disseminating required student warnings to current and prospective students if a program fails the GE D/E rates.
- Decide on your approach for the timely updating of your 2018 GE Disclosure Templates to include the GE program student warnings if your school is informed of the need to do so via a Notice of Determination from ED after updating your disclosures using the 2018 GEDT.
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.