G-Q1: I have a lot of questions about the gainful employment (GE) requirements and am not sure what to do.
Institutions should review the preamble and the final regulations published in the Federal Register on October 29, 2010 and October 31, 2014. These FAQs, which are updated regularly, provide clarification and additional guidance. Additional resources, including a link to the Office of Postsecondary Education’s website and the GE Disclosure Template, are available under "Resources." Questions not answered by the Electronic Announcements or these FAQs can be sent to firstname.lastname@example.org. [February 11, 2015]
G-Q2: Are non-Title IV eligible educational programs subject to the GE requirements?
No, only Title IV eligible programs are subject to the statutory and regulatory GE requirements. [April 30, 2014]
G-Q3: My teacher certification program does not award a degree or certificate, but instead consists of a series of courses that prepares students to receive a State professional teaching credential or certification. Would my program be considered a GE Program?
No, the program as described is not a GE Program.
Gainful Employment Electronic Announcement #53 advises institutions that a teacher certification that consists of a collection of course work that is required for a student to receive a State professional teaching credential or certification but does NOT lead to the awarding of a degree or certificate by the institution is not a GE Program. However, a teacher certification program that does lead to the awarding of a certificate or other non-degree (for a for-profit institution, also a degree) credential is a GE Program, and the institution must comply with all of the GE regulatory requirements. [December 16, 2015]
G-Q4: The regulations talk about CIP and SOC codes. What are these and where can I find these codes?
The Classification of Instructional Programs (CIP) provides a taxonomic scheme that supports the accurate tracking and reporting of fields of study and program completions activity. Institutions report credentials awarded by CIP codes when completing the IPEDS Completion Survey. Institutions are also required to list individual programs by CIP on their Application for Approval to Participate in Federal Student Financial Aid Programs (E-App).
A listing of CIP codes is available at: https://nces.ed.gov/ipeds/cipcode. There is also a list of CIP codes available when completing the E-App.
G-Q5: Credential Level 07 is “First-Professional Degree.” What degrees count as a First-Professional degree?
A First-Professional Degree is one that signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor's degree. Professional licensure is also generally required. First-Professional degrees are Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), and Theology (M.Div., or M.H.L.). [April 30, 2014]
G-Q6: What Credential Level do I use for diploma programs?
Institutions should use “01-Undergraduate Certificate” as the Credential Level when completing the disclosure template for a diploma program. [April 30, 2014]
G-Q7: Moved to Disclosures.
G-Q8: Are English as a Second Language (ESL) or English for Speakers of Other Languages (ESOL) programs GE programs? If so, what CIP code and SOC codes do I assign to these programs?
To be a Title IV eligible program, an ESL or ESOL program must lead to a certificate or other credential awarded by the institution. As such, all ESL or ESOL programs are GE programs and are subject to all of the GE regulations and other requirements.
While the selection of the proper CIP code for an educational program is the responsibility of each institution, we recommend that institutions use 23.0101 [English and Literature, General] for ESL and ESOL programs. Institutions should not use CIP code 32.0109 for these programs because the 32 series is for programs of “Basic Skills and Developmental/Remedial Education” which do not correspond with any recognized occupations.
The SOC codes that an institution should use when complying with the gainful employment disclosure requirements for ESL and ESOL programs should be the SOC codes that align with the employment of the students who complete the program. [November 3, 2015]
G-Q9: Moved to Disclosures.
G-A9: See D-Q17.
G-Q10: When should an institution consider the student to have completed the GE Program?
Consistent with longstanding Title IV student aid policy, a student is considered to have completed an educational program when the student has satisfied all of the academic requirements of the program, regardless of whether the degree, certificate, or other institutional credential has been awarded to the student. [April 30, 2014]
G-Q11: Moved to Disclosures.
G-Q12: I am confused about whether a program that is at least two years in length and is fully transferrable to a four year degree program is a GE Program. Does it matter whether the two year program leads to a certificate or other credential awarded by the institution?
The short answer is only programs that are at a non-profit or public institution and are at least two academic years in length and that are specifically designed to be a transfer program and that do not lead to a certificate or other credential awarded by the institution are Title IV-eligible non-GE Programs.
Under the HEA, an eligible Title IV program must lead to a degree, certificate, or other credential awarded by the institution. There is, however, an exception for a program that is at least two-academic years in length and that is acceptable for full credit toward a bachelor’s degree. This exception is provided to allow students who are enrolled in non-credential transfer programs (generally offered by community colleges) to be eligible for Title IV aid as they prepare to transfer to a four-year degree program. These programs, while Title IV eligible under the exception, are not GE Programs.
Programs that are not designed solely for transfer purposes and that lead to a credential (usually a certificate or diploma) awarded by the institution are not included in the above exception. For example, a two-year program offered by a community college that is designed to provide students with the transfer credit hours that will be acceptable by a four-year college for transfer to a bachelor’s degree program is a non-GE Title IV eligible program. However, a two-year program that awards a certificate of its own does not fall under the transfer program exception. As such, that program is Title IV eligible only because it must lead to gainful employment in a recognized occupation (a GE Program). The program is a GE Program even if the credits earned in the program are transferrable to a four-year bachelor’s program. [April 30, 2014]
G-Q13: Are there any Title IV-eligible programs offered by proprietary institutions that are not subject to the GE requirements?
Generally, all Title IV-eligible programs offered by a for-profit institution are GE Programs, and therefore subject to all of the GE regulatory requirements. However, there are three exceptions. First, as described in Electronic Announcement #34, a course of study that is designed to provide students with the necessary coursework for enrollment in a degree or certificate program, and does not lead to a credential awarded by the institution, is not a GE Program.
Second, approved Comprehensive Transition and Postsecondary Programs for students with intellectual disabilities (as defined in 34 CFR 668.231) are not considered GE programs.
The third exception applies to a liberal arts bachelor's degree program that has been continuously provided by the for-profit institution since January 1, 2009 and the for-profit institution has been continuously accredited as a for-profit institution by a recognized regional accrediting agency since October 1, 2007.
If a for-profit institution acquires a liberal arts bachelor's degree program (either by purchase, merger, or any other transaction) after January 1, 2009, the exception does not apply since the program was not continuously provided by the for-profit institution since that date. Therefore, the liberal arts program must be one that leads to gainful employment in a recognized occupation. [July 27, 2016]
G-Q14: Moved to Debt to Earnings Rates D/E-Q7
Moved to Debt to Earnings Rates D/E-A7.
D/E-Q1: My GE Draft Completers Lists was sent to my SAIG Mailbox (message class – GECOMBOP). Do I also need to request my GE Draft Completers Lists from NSLDS (message class GECOMPOP)?
Not necessarily. The two GE Draft Completer Lists file message classes distinguish between Draft Completers Lists sent directly to an institution’s SAIG mailbox (GECOMBOP) on June 1, 2016, and Draft Completers Lists sent following an institution’s request using the NSLDS website (GECOMPOP). [June 21, 2016]
D/E-Q2: Because my GE Program had fewer than 30 completers in the 2-year cohort period the 4-year cohort was used. Why am I seeing 2YR indicated for some students on the GE Completers List Viewer Tool?
On the GE Completers List Viewer Tool, the “Eval Term” column refers to whether the program is being evaluated with a 2-year or 4-year cohort group. The “Qual Term” column refers to whether the student is part of the 2-year cohort group (and thus also the 4-year), or whether the student is only part of the 4-year cohort group. [June 21, 2016]
D/E-Q3: What does it mean when I see AYR instead of 2YR or 4YR on the GE Completers List Viewer Tool?
AYR in the “Eval Term” column means that all of the completers in the GE Program have been excluded for one or more of the regulatory exclusion reasons. If AYR is included for all of an institution’s GE Programs and you think that, for at least some of the programs, there should be some non-excluded students, it is likely that the GE Completers List Viewer Tool has accessed an incorrect file. Requesting a new Gainful Employment Completers List using the report option on the Reports Tab of the NSLDS website should resolve this error. [June 21, 2016]
D/E-Q4: There are students on my Draft GE Completers List that I believe should not be included in the debt-to-earnings calculation. How do I correct this through the 45-day corrections process?
Depending on the situation you may need to either exclude the student or delete the student from the Draft GE Completers List.
A student should be excluded only if the student actually did complete the GE Program but qualifies for one of the regulatory exclusion reasons (as discussed in GE Electronic Announcement #78). In these cases, the student does belong on the list but marked as an exclusion so that the student is removed from the debt-to-earnings calculations. When submitting an exclusion request, you will need to enter in the Comment box the required information based on your documentation for the exclusion (as described in the attachment to Gainful Employment Electronic Announcement #78).
However, if your institution did not report the student to NSLDS correctly because the student did not complete the GE Program in the 2-year or 4-year cohort, the student should be deleted from the Draft GE Completers list. As above for exclusions, the reason must be entered in the Comment box. [June 21, 2016]
D/E-Q5: Institutions must provide a comment with any correction requested during the 45-day Draft GE Completers List corrections period. Where is information on what institutions are to enter in the comment field?
Information on what is required in the comment field by type of correction is available in the attachment to Gainful Employment Electronic Announcement #78 titled “Submitting GE Completers List Corrections”. [June 21, 2016]
D/E-Q6: Where is information on when students should be excluded from the Draft GE Completers List due to the student’s completion of a Higher Credentialed GE Program at my school?
A fact sheet on the Higher Credential Program exclusion and when that exclusion applies is available as an attachment to Gainful Employment Electronic Announcement #80 titled “GE Higher Credentialed Program Overview”. [June 21, 2016]
D/E-Q7: What is the impact on a GE program if there are not at least 30 completers in the applicable cohort? Are Debt-to-Earnings rates (D/E rates) calculated for a transitional period if the cohort of completers for that period is less than 10?
If there are fewer than 30 completers in the 2-year cohort period for a GE program, the Department will look at the 4-year cohort period to calculate the D/E rates. If there are fewer than 30 completers in the 4-year period, D/E rates will not be calculated for the program.
If a program’s D/E rates are not calculated or issued for an award year, the program’s status under the D/E rates measure is unchanged from the last year for which D/E rates were calculated for the program. After four consecutive years for which D/E rates are not calculated, the Department will not consider any prior D/E rates when determining the GE program’s Title IV eligibility.
If there are D/E rates calculated for a GE program and those rates result in the program either failing or in the zone, the Department will attempt to calculate a transitional rate, as provided in the regulations. If a transitional rate cannot be calculated because there are fewer than 10 students in the transitional period cohort, the program’s original failing or zone rate for the 2-year-period or 4-year-period, as applicable, will be the official rate for the GE program. [April 27, 2015]
D-Q1: Our institution has two programs with the same 6-digit CIP code and same Credential Level but with different specializations and different program names. They each have a home page on our website. Should we disclose the median debt separately by specialization/program name or should we combine the students in the two programs and disclose as one program?
Institutions may make separate disclosures for programs that have the same CIP Code and Credential Level if doing so more accurately reflects each program's characteristics. In these cases, separate disclosures will provide more useful information for prospective students and their families. However, institutions must create separate disclosures for programs that have different lengths (such as a full-time day version of a program with a normal time to complete of 9 months versus a part-time night version of the same program with normal time to complete of 15 months). Institutions may create separate disclosures for versions of a program with different formats or locations (clearly identified as such) if doing so would result in clearer disclosures.
We remind institutions that they should carefully review each of their educational programs to ensure that the appropriate CIP code has been assigned. The full listing of CIP codes is available at https://nces.ed.gov/ipeds/cipcode/browse.aspx?y=55. [May 12, 2017]
D-Q2: The GE regulations require that all promotional materials for a program include the required information specified in the regulations at at 34 CFR 668.412(d). How does that requirement apply to postcards, invitations, flyers, billboard and transit advertising, radio, television, web and similar advertising and solicitations?
If the invitation, advertisement, or solicitation mentions or otherwise refers to a specific GE Program or programs, the disclosure information must be included whenever feasible. If providing the information is not feasible because of the size or format of the invitation, advertisement, or solicitation, the institution may display the URL or provide a live link to the webpage where the required information is located, with a clear explanation of the information that is available at that webpage. The link must be identified as “Important information about the educational debt, earnings, and completion rates of students who attended this program.” For promotional materials that advertise more than one GE Program, institutions have the option of (1) providing one link on the promotional material where prospective students can be redirected to a list of the web links for all of the GE Programs webpages, or (2) providing a direct link for each program on the promotional material. This single webpage is in addition to the disclosure information placed on each program's web page. [May 12, 2017]
D-Q3: How do I calculate the median loan debt for purposes of the GE disclosures?
The median is the middle value in a distribution of values, above and below which lie an equal number of values. To calculate the median loan debt for a program, an institution would follow these steps.
Step 1: Determine the debt amount for each of the students who were included in the disclosure template’s completion calculation who completed the program in normal time.
Step 2: Arrange each student’s debt in ascending order, including students with zero debt.
Step 3: Identify the middle value since the median is the middle value in the distribution of all values. If there is an even number of values in the distribution and thus there is no middle value, the median value is the mean (average) of the two values at the halfway point.
Example A: The following are the loan debt values for nine (9) students listed in ascending order:
Since this distribution includes an odd number of values, the median loan debt is $2343 because the fifth value is the “middle” number when these debts are ranked in ascending order.
Example B: The following are the loan debt values for twelve (12) students listed in ascending order:
Since this distribution includes an even number of values, to determine the median loan debt for these twelve students the institution must calculate the mean of the sixth and seventh values ($3000 + $4000 = $7000; $7000 ÷ 2 = $3500). The median loan debt for this cohort of twelve students is $3500. [May 12, 2017]
D-Q4: What debt needs to be included in the calculation of the GE Program’s median loan debt?
All debt that the student incurred for attendance in the GE program (Title IV loans, private education loans, and institutional debt) must be included in the median debt calculation.
For Title IV loan debt, all loans made under the Federal Family Education Loan (FFEL) Program, the William D. Ford Federal Direct Loan (Direct Loan) Program, and the Federal Perkins Loan Program are to be included in the calculation, except for Parent PLUS loans and TEACH grants that may have been converted to Unsubsidized Direct Loans.
The Truth-in-Lending regulations at 12 CFR 226.46(b)(5) provide the definition of a private education loan. Examples of private education loans include, but are not limited to, loans made expressly for educational expenses by financial institutions, credit unions, institutions of higher education or their affiliates, and States and localities.
For institutional debt, include any loan, extension of credit, payment plan, or other financing mechanism that would otherwise not be considered a private education loan but that results in a debt obligation that a student must pay to an institution after completing the program. For more information about institutional debt, please see question G-Q11. [May 12, 2017]
D-Q5: When calculating on-time completion rates for disclosure purposes, how do we determine “normal time”?
Normal time is defined in 34 CFR 668.41(a) as the amount of time necessary for a student to complete all requirements for the degree or certificate as provided in the institution’s catalog or other promotional materials. This is typically four years for a bachelor’s degree program in a standard term-based institution, two years for an associate degree program in a standard term- based institution, and the scheduled time for certificate programs as provided in the institution’s publications.
For clock hour programs, it is the time, measured in weeks or months, provided in the institution’s catalog or other promotional materials stating how long it takes a student to complete the program. For example, an institution’s materials may state that the normal time to complete a 1500 clock hour program is 50 weeks.
Note that in all instances, “normal time” is not 150% of the published time nor is it the timeframe used in the calculation of completion rates for Student Right to Know disclosures.[May 12, 2017]
D-Q6: What placement rate do we disclose if our institution is not required by our accrediting agency or State to calculate a placement rate?
If there is no requirement by the State or an accreditor to calculate a placement rate for either the institution as a whole or for the specific GE Program, the institution does not need to disclose a placement rate. The National Center for Education Statistics (NCES) was charged with developing a methodology that will be used to calculate placement rates for GE Programs. We will inform institutions of their responsibility to use that methodology once NCES develops the placement rate methodology. Institutions will have sufficient time to implement the methodology. See Gainful Employment Electronic Announcement #31 for more information. [April 30, 2014]
D-Q7: Our institution is required to calculate placement rates for both our State and for our accrediting agency; must we include both rates in our disclosures?
Yes, the institution must disclose both rates. The regulations at 34 CFR 668.412(a)(8) provide that the disclosure template includes “The placement rate for the program, if the institution is required by its accrediting agency or State to calculate a placement rate either for the program or the institution, or both, using the required methodology of that accrediting agency or State.” Regardless of what methods are used, explanations must be included on the methodology page, further explained in FAQ D-19. [May 12, 2017]
D-Q8: In some instances existing CIP codes do not crosswalk to one or more SOC Codes. Can we expect updates to this area? May we select a SOC Code that may not crosswalk to the selected CIP code?
The last update to the CIP/SOC crosswalk was completed in 2010 and can be found at http://www.onetonline.org/crosswalk/.
Institutions are required to disclose the SOC codes that correspond to the selected CIP codes on the O*NET Crosswalk website that best match the jobs program graduates get after completion of the program.
For CIP codes that do not crosswalk to one or more SOC codes, institutions can add a SOC code that aligns significantly and substantively with the program learning outcomes, provided that the institution has evidence that graduates of the program found employment in that field. [April 30, 2014]
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D-Q10: If a student took an approved leave of absence, may I only use the student’s actual enrollment time to determine if this student completed within the normal time for the GE Program?
No. Leaves of absence are to be included when determining whether a student completed a GE Program within normal time. For example, if the normal time to compete a GE Program is 2 years and a student took 2.5 years to complete because of a 6 month leave of absence, the student would NOT be one that can be included as having completed the GE Program within normal time when calculating the GE Program’s completion rate. Thus, students who do not complete the GE Program in normal time because of a leave of absence (or any other reason) are to be included in the denominator of the completion rate fraction but not in the numerator. [April 30, 2014]
D-Q11: Should median debt that must be disclosed include loan amounts that exceeded a student’s institutional charges?
Yes, when calculating the median Title IV debt and private educational loan debt for a GE Program’s disclosure information, the total amount that each student received for attendance in the GE Program, without regard to how much went to institutional charges, is to be included. For debt from institutional financing plans, the amount to be used in the calculation is the amount the student has outstanding upon leaving the program.
For example, a student may have received a loan totaling $10,000 for attendance in a GE Program where $6,000 went to pay institutional charges and $4,000 was provided to the student to meet other educational expenses (e.g., books and supplies, living expenses). When calculating the median loan debt for the disclosures, this student would be considered to have $10,000 in loan debt. [May 12, 2017]
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D-Q14: When I determine whether a student who completed a GE Program at my institution did so in normal time, do I account for the time the student was enrolled at another institution? Does it matter whether my institution accepted all or any of the credits earned by the student at the other institution?
Generally, when determining whether a student who was previously enrolled in an educational program at a different institution completed the GE Program in normal time, you do not include the time the student was enrolled at the other institution, regardless of whether credits were transferred.
For example, consider a student who had been enrolled in a one-year certificate program at another institution before transferring into a two-year certificate program at your institution. When determining if the student completed the two-year program at your institution in normal time, you do not include the time the student was enrolled at the other institution and begin with the date the student began the two-year program at your institution. [April 30, 2014]
D-Q15: When disclosing information about our GE Programs, can my institution include all the information on one central webpage?
No. Disclosure information about a GE Program must be a direct link from the home page of the specific GE Program as well as in any promotional materials made available to prospective students. Institutions must provide a prominent and direct link on any other webpage containing general, academic, or admissions information about the program, to the GE Program’s webpage that contains all the required information. Please see D-Q2 for more about disclosures on promotional materials. [April 30, 2014]
D-Q16: How does an institution comply with the GE disclosure requirements when it promotes the GE Program using social networks and other new media such as microblogs?
For institutions that use new media channels, such as social networks and microblogs (e.g., Twitter), to promote a GE program, that messaging must include a direct link to the program’s gainful employment disclosure information using the suggested text included in D-A3. If, because of limitations of the specific technology (e.g., character limitations), it is not feasible to provide the suggested text and/or the full hyperlink the institution may use a URL shortener, as long as that shortener will lead directly to the GE Program’s home page where the required disclosure information is located. Furthermore, institutions (or their officials) that repost an update that promotes a GE program from an outside party must include a direct link to the program disclosures on the reposted update regardless of whether the original update contained a link to the disclosure information.
We remind institutions that individuals affiliated with the institution who provide information about a GE program, whether or not they are acting in an official capacity of the institution, must inform prospective students about where the disclosure information can be found and provide a direct link to the program disclosures. For example, a faculty member who promotes an institution’s GE Program on his or her personal blog is required to provide a direct link to the program disclosures on the blog posting. This requirement, however, does not apply to students or former students unless those persons are acting under the auspices of the institution. [April 30, 2014]
D-Q17: Can the Department guide us on how to calculate tuition and fees for disclosure purposes when students are charged on a term-by-term basis?
Institutions must disclose for each of their GE Programs the total tuition and fees for the program. The amount disclosed must be the amount that will likely be charged to students for completing the program within normal time. For example, if the normal time for a student to complete a GE Program is four semesters over two years and the tuition and fees are $1,000 for each semester, the amount to be disclosed is $4,000. When tuition and fees may change over time, institutions should disclose the tuition and fees using either the current rate or an estimated amount. In either instance, the template will include a disclaimer noting that the amounts may change. Fees include any fees and expenses that must be paid to the institution as a condition of enrollment or attendance. [April 30, 2014]
D-Q18: Can the Department provide more guidance on institutional debt?
Institutions are required to calculate a median of the total debt students incurred for attendance in the GE program. Unlike Title IV loan debt or private loan debt where institutions use the total amount the student received for attendance in the GE Program, the amount used for institutional debt is the amount owed by the student as of the day the student completed the GE program.
Any loan, extension of credit, payment plan, or other financing mechanism that was provided by the institution or by a related party for attendance in the GE Program, and that otherwise is not a private education loan, that results in a debt a student must repay to the institution or the related party, after withdrawing from or completing the GE Program is considered part of an institutional financing plan. Also, any charge that is attributable to the student’s attendance in the GE Program that a student owes to the institution after withdrawing from or completing the GE Program should also be included as an institutional debt. This may include unpaid library fees, parking tickets, or other outstanding obligations due to the institution after the student completes the GE program.
Finally, over awards and other Title IV student aid owed to the institution by the student, including as a result of a Return of Title IV (R2T4) calculation should not be used in the calculation. [May 12, 2017]
D-Q19: What information is required in the field “Placement Rate Methodology” on the GE Disclosure Template?
In addition to the placement rate itself, the GE Disclosure Template includes a Placement Rate Methodology field that must be populated with a website URL that links to a page with clear and complete information on the methodology used to calculate the GE program's placement rate.
Job placement rate methodologies required by accreditors and/or states commonly allow certain categories of students, such as those who are incarcerated, serving in the military, or experiencing debilitating health conditions, or who transferred to another institution, to be excluded from the placement rate calculation. The placement rate methodology page must include information about any excluded groups.
The placement rate methodology page must specify not just whether exclusions were made, but which exclusions were made by category and how many students were excluded for each as well as the total number of students who were excluded from the placement rate calculation. However, if fewer than ten students were excluded for any one category, the disclosure should only include the total of all excluded students if that total is at least ten. If the calculation excluded fewer than a total of ten students the institution should state that it excluded students on the basis of each condition, and note that the number of total exclusions were fewer than 10 and therefore cannot be disclosed. [February 24, 2016]
D-Q20: Do I need to disclose information on students in a GE program if only a few students completed the program during the award year? What if no students are currently enrolled?
If fewer than 10 students completed a GE Programs during the award year, for privacy reasons, the school should not disclose to the public:
Median debt amounts (Title IV debt, private educational loan debt, and debt from institutional financing)
On-time completion rate
Placement rates, if aligned with the requirements of the accreditor or State
Schools must disclose all of the following, regardless of the number of students who were enrolled in or completed the program:
The occupations (by names and SOC codes) that the program prepares completers to enter
Tuition/fees charged to complete the program in normal time; typical costs for books and supplies (unless those costs are included as part of tuition and fees); and costs of room and board, if applicable
Program Length (in weeks, months or years) [July 18, 2016]
D-Q21: The Gainful Employment Disclosure Template asks me to enter the median earnings most recently provided by the Department for the program. Where can I find my program’s earnings?
Earnings data returned by the Social Security Administration (SSA) can be found on the FSA Data Center site’s Gainful Employment Information page on the spreadsheet of GE program earnings data (see the link below). Because Debt-to-Earnings (D/E) rates were only calculated for programs having at least 30 completers in the applicable cohort period, and earnings data was returned by SSA for programs having at least 10 completers in the applicable cohort period, you may have earnings data for programs that did not receive D/E rates. You are required to list this data, if it is provided. If your program has an alternate earnings appeal pending you should answer the questions listed below the earnings data field, but only the number provided by the Department should go in the top field. If your program has too few completers for SSA to have returned earnings information, you should mark the checkbox labeled “Check here if the Department has not provided earnings data for this program.” [February 24, 2017]
D-Q22: The regulations state that if I choose to fulfill my institution’s direct distribution requirements by emailing a disclosure template to prospective students or third parties, the disclosure template must be the only substantive content in the email and I must receive electronic or other written acknowledgment from the prospective student or third party that they have received the email. How do I fulfill this requirement?
Institutions should use a method that verifies the student or third party has read the message, whether it is passive or whether they must click to confirm receipt. An email read receipt would be acceptable, or the institution could have the prospective student or third party physically or electronically sign a statement that they have received their disclosure template, include a link at the bottom of the email for the prospective student or third party to click to indicate receipt (using a custom URL for each student, directing them to a webpage where they can enter in their information, etc.), or use a similar method. Regardless of whether the disclosure was hand-delivered or emailed, the institution should verify documentation of the prospective student’s receipt of the disclosure template before allowing the prospective student to sign an enrollment agreement, complete registration, or otherwise make a financial commitment to the school. [February 24, 2017]
D-Q23: The Debt screen on the Gainful Employment Disclosure Template instructs me to enter the applicable interest rate. What interest rate should I be using?
This year, the correct interest rate is 6.8% for all programs. [February 28, 2017]
R-Q1: What is the deadline for submitting data on GE Programs to NSLDS?
Institutions must report data on all Title IV students enrolled in GE programs from the 2008-2009 to the 2013-2014 award years by July 31, 2015. Programs that have required medical or dental residencies must report an additional year of data, the 2007-2008 award year, by the same July 31, 2015 deadline. Data for the 2014-2015 award year, was due by October 1, 2015. Data for the 2015-2016 award year will be due October 1, 2016. [July 18, 2016]
R-Q2: How does an institution report if a student withdrew from a GE Program and then reenrolled in the same GE Program within the same award year?
Two records would be reported for a student who began enrollment in a GE Program, withdrew from that program and then reenrolled in that same GE Program all within the same award year (some institutions refer to this as a student who "stopped out"). The first record would report the student’s first enrollment, including a "W" for Withdraw in Field 17, Program Attendance Status During Award Year, and the withdrawal date in Field 18, Program Attendance Status Date. The second record would include the date the student began the second enrollment in Field 16, Program Attendance Begin Date for this Award Year. [February 11, 2015]
R-Q3: If my institution currently has a Student Aid Information Gateway (SAIG) TG Mailbox to send and receive information using EDconnect, can we use the same TG Mailbox for GE Program reporting?
Yes, institutions may choose which TG Mailbox they want to use for GE Program reporting. The GE Reporting List option on NSLDS is no longer available because the SAIG Enrollment Site on https://fsawebenroll.ed.gov includes GE as well as other FSA services. The institution can choose the option to modify existing services and under NSLDS Batch, select Gainful Employment Reporting. [February 11, 2015]
R-Q4: If a third party servicer is used to report our school’s enrollment data, can I use the same TG Mailbox to report GE information?
The TG Mailbox associated with the servicer could be used for GE Program reporting if you have contracted with the same servicer to provide GE reporting on your behalf. Please contact your servicer to determine which TG Mailbox it would like you to use for GE Program reporting. As a reminder, when using a servicer to report to NSLDS, there must be at least one user at your institution with NSLDS online access to designate which TG Mailbox your institution will use for GE Program reporting and to make corrections to information initially reported by the servicer. [February 11, 2015]
R-Q5: How should an institution report students who are enrolled in a summer term that crosses award years?
Since the student was enrolled in both award years, the institution should report the student separately in both award years’ submissions. The ‘Program Attendance Status During Award Year’ field for such a student would be ‘E’ (Enrolled) in the first award year’s submission and either ‘E’ (Enrolled), ‘W’ (Withdrew), or ‘G’ (Graduated) for the subsequent award year’s submission, whichever is the appropriate status for the student in that award year. Note that reporting students in GE Programs in both award years for a summer crossover term does not change how institutions award Title IV aid for a crossover payment period. [February 11, 2015]
R-Q6: How should an institution report a student who is not technically enrolled on June 30 in an award year, but has not withdrawn from the program because the student is expecting to return in the fall?
As with regular enrollment reporting to NSLDS, students are to be considered as in school and continuously enrolled during holiday and vacation periods, as well as during the summer between academic years (even if not enrolled in a summer session), as long as the institution has no reason to believe that the student will not return following the holiday, vacation, or summer period. For example, the ‘Program Attendance Status During Award Year’ field for such a student would be ‘E’ (Enrolled) and not ‘W’ (Withdrew) at the end of the spring term if the student is expected to re-enroll for the fall term. If the student does not return as expected, the ‘Program Attendance Status During Award Year’ field must be changed to ‘W’ (Withdrew) and the ‘Program Attendance Status Date’ should be completed with the last date of attendance. [February 11, 2015]
R-Q7: May an institution use a third-party to prepare, submit, or otherwise meet the GE reporting requirements?
Yes, as with most Title IV requirements, an institution may use a third-party to meet its GE reporting requirements. However, the 'third-party servicer' requirements of 34 CFR 668.25 would apply where both the third-party servicer and the institution are responsible for ensuring that information is reported timely and accurately. Failure to report GE data timely and accurately could result in liabilities applying to both the servicer and the institution. Additionally, under the regulations, the third-party servicer must follow the audit submission requirements of the regulations. See Dear Colleague Letter GEN-15-01 for more information on third-party servicers. [February 11, 2015]
R-Q8: Can you explain the difference between the “Program Attendance Begin Date” and the “Program Attendance Begin Date for this Award Year”?
The “Program Attendance Begin Date” and the “Program Attendance Begin Date for this Award Year” may differ because the student may have started the GE Program in an earlier award year.
For example, consider a student who began a GE Program on May 15, 2009 (enrolled in the 2008-2009 award year) and continued to be enrolled in that GE Program until he completed the GE Program on June 23, 2010 (enrolled in the 2009-2010 award year). The institution will report the following:
For the 2008-2009 award year reporting –
“Program Attendance Begin Date” is May 15, 2009
“Program Attendance Begin Date for this Award Year” is May 15, 2009
For the 2009-2010 award year reporting –
“Program Attendance Begin Date” is May 15, 2009
"Program Attendance Begin Date for this Award Year” is July 1, 2009
[February 11, 2015]
R-Q9: Can a school report the amount of tuition and fees remaining on a student's account after scholarships and other non-title IV aid awards are applied? In other words, can a school report the net amount of tuition and fees?
No. A school must report the total amount of tuition and fees charged the student for the program before any aid or other credits are applied to the student’s account. [February 11, 2015]
R-Q10: The OPEID for our institution that will be in effect on 7/1/2015 is different in the prior years for which I must report student data. Which OPEID should I use when I report the GE program for those prior years?
You should use the current OPEID to report the GE program for all years that you are reporting data. [February 11, 2015]
R-Q11: Can the Department provide more guidance on reporting institutional debt?
The gainful employment regulations at 34 CFR 668.404(d), which go into effect on July 1, 2015, define the term institutional debt as “The amount outstanding, as of the date the student completes the program, on any other credit, (including any unpaid charges) extended by or on behalf of the institution for enrollment in any GE program attended at the institution that the student is obligated to repay after completing the GE program . . . ” Therefore, in addition to institutional loans and other forms of institutional financing, institutional debt also includes debt arising from any other outstanding obligations the student owes at the time the student withdraws from or completes the GE program. Examples of these other financial obligations include library fees, graduation or withdrawal fees, laboratory fees, etc.
Amounts owed by students to the institution under the Federal Perkins Loan Program should not be reported as institutional debt. Perkins Loans will be counted as Title IV debt in the Debt-to-Earnings calculations.
Note that overawards and other Title IV student aid owed to the institution by the student, including as a result of a Return of Title IV (R2T4) calculation, are not considered institutional debt and therefore should not be reported as part of institutional debt. However, amounts owed to the school for unpaid tuition, even where those amounts are the result of funds returned by the institution to the Title IV programs under an R2T4 calculation, should be included.
For example, a student enrolls in a 900 clock hour program, incurring direct charges of $10,000 (assume the institution bills up front for the entire program). Her financial aid package includes a Federal Pell Grant of $5,775 and a Direct Subsidized Loan for $3,500 ($3,462 net disbursement amount). She is placed on an institutional financing plan for the remaining $763 of institutional charges. After all of the student’s Title IV aid has been disbursed and with $363 remaining to be paid under the institutional financing plan, the student withdraws from her program of study. As the result of an R2T4 calculation, the institution must return $1,050 in Title IV funds. The student now has a balance due the institution of $1,413 that is made up of the $363 remaining under the original institutional financing plan and the $1,050 she now owes as the result of that amount having been returned by the institution to the Title IV programs. The institution should report the entire amount of $1,413 as institutional debt. [April 8, 2015]
R-Q12: If an institution does not know or does not retain a student's enrollment status as of the beginning of the student's enrollment in that program but rather only at the end of an add/drop period or other census date, can the institution report the student’s enrollment status as of the date of the end of the add/drop period or as of the census date?
In these instances, institutions may report a student’s enrollment status as of the end of the established add/drop period or as of the census date. [April 27, 2015]
R-Q13: A student was enrolled in a GE program for an award year, but did not receive Title IV aid until a subsequent award year. Should the institution report the student as enrolled in the GE program for the first award year of enrollment even though no Title IV aid was received for that award year?
No. Institutions should only report a student beginning with the award year when the student first received Title IV aid for attendance in the GE program. However, when reporting the "Program Attendance Begin Date", the institution would report the date when the student began the GE program, even if that was in an award year when the student did not receive Title IV aid. For example, consider a student who first enrolled in a GE program on September 1, 2010 - during the 2010-2011 award year - but did not receive any Title IV aid for that award year. The student did receive Title IV aid for the 2011-2012 award year. The institution would not report the student for the 2010-2011 award year but would report beginning with the 2011-2012 award year. The "Program Attendance Begin Date" field included in the 2011-2012 reporting would be September 1, 2010, the date of the student's first enrollment during the 2010-2011 award year. However, if the student in this example did receive Title IV aid in 2010-2011, he or she would be reported for both award years. In other words, schools should report the student in the award year he or she first received Title IV aid and all subsequent award years.
Also, for students who completed or withdrew from the program, the institution would include in its reporting for the award year when the student left school, financial data (i.e., private loans, institutional debt, tuition and fees, and books and supplies and equipment) for the student's entire enrollment in the program, including any years when the student did not receive Title IV aid. [July 15, 2015]
R-Q14: How should we report the amount of private loans and institutional debt for a student who was enrolled in more than one educational program at the institution?
As provided in the NSLDS Gainful Employment User Guide, institutions must report amounts of private student loans and institutional debt for students who, during the award year, had either withdrawn or completed the GE Program.
If the student was enrolled in more than one educational program, the institution has two options for attributing the private loan or institutional debt amounts – attribute the amounts evenly among the GE Programs or use the actual amounts applied to each GE program.
Under the first option, if all of the programs the student was enrolled in were GE Programs, the institution may simply divide the total amount received (or owed for institutional debt) by the number of GE Programs and use the result for reporting. Note that under this option amounts are not attributed to a non-GE Program. For example, if a student took out $10,000 in private loans for enrollment in two GE Programs, $5,000 is attributed to each of the two GE Programs. However, if one of the educational programs was not a GE Program, the full $10,000 is attributed to the one GE Program.
Under the second option, if the institution can document the actual amount of private loans or institutional debt that that was used to cover educational costs for each program, it may attribute that amount to each program. For example, if a student took out $20,000 in private loans while enrolled at the institution and the institution has documentation that $12,000 of that amount was used to cover educational costs for a non-GE Program, only the remaining $8,000 is attributed to the GE Program. Institutions choosing this option must maintain the documentation so that it is available upon request.
As provided in the NSLDS Gainful Employment User Guide, institutions do NOT report the amount of Title IV Loan Debt. Those amounts are determined by the Department from NSLDS data. [May 5, 2015]
R-Q15: For GE reporting to NSLDS, when must an institution report a student’s assessed tuition and fees and the amount for the student’s books, supplies, and equipment?
As provided in the regulations and described in the NSLDS Gainful Employment User Guide, institutions report the amount of tuition and fees and the amount for books, supplies, and equipment for the award year when the student completed the program (graduated) or withdrew from the program – that is, when “Program Attendance Status During Award Year” is reported as graduated (‘G’) or withdrew (‘W’). If the student did not complete or withdraw from the program during the award year – that is, if “Program Attendance Status During Award Year” is reported as enrolled (‘E’) – the institution leaves the tuition and fees and books, supplies, and equipment fields blank or enters spaces. [July 17, 2015]
R-Q16: How does an institution determine the amount of assessed tuition and fees and the amount for books, supplies, and equipment?
Institutions must report the total amount of tuition and fees assessed the student for the student’s entire enrollment in the GE program, not just the amount for the award year in which the student completed or withdrew. Similarly, the amount for books, supplies, and equipment to be reported is the amount that was included in the student’s cost of attendance (COA) for all periods of the student’s attendance in the GE program. [July 17, 2015]
R-Q17: How are amounts for tuition and fees and books, supplies, and equipment calculated if the student enrolled in a GE program, withdrew, re-enrolled, and then completed (or withdrew again) all during the same award year?
The institution would submit two records for that student for the award year. The first record would be for the period up to the withdrawal and the second would be for the student’s re-enrollment. For the first record, institutions should report the total amount of tuition and fees assessed the student and the amount for books, supplies, and equipment included in the student’s COA for all of the student’s enrollment in the program up until the point the student withdrew. For the second record, the institution reports the aggregate amounts. For example, in the 2011-2012 award year a student was enrolled in a GE program until she withdrew in December of 2011. The institution had assessed the student $5,000 in tuition and fees and had included a total for books, supplies, and equipment of $800 in the student’s COA up to the student’s withdrawal. Those are the amounts that should be reported in the first record. The student then re-enrolled in the same program in March of 2012 and graduated the following June, all in the same 2011-2012 award year. The institution assessed the student an additional $2,000 in tuition and fees for the new enrollment and included an additional $200 for books, supplies, and equipment in the student’s COA for the new enrollment.
For the second record, the institution will report the aggregate amount of $7,000 for tuition and fees and a total of $1,000 for books, supplies, and equipment. [July 17, 2015]
R-Q18: How are amounts for tuition and fees and books, supplies, and equipment calculated if the student enrolled in a GE program, withdrew, and then re-enrolled and completed (or withdrew again) during a subsequent award year?
The answer to this question is the same as R-A17 except the records are for two different award years. [July 17, 2015]
R-Q19: How are amounts for tuition and fees and books, supplies, and equipment calculated if the student was enrolled in one or more other GE programs during all or some of the time when the student was enrolled in a GE program for which tuition and fees and books, supplies, and equipment must be reported?
If a student was enrolled in one or more other GE programs during any period when the student was enrolled in the GE program from which the student graduated or withdrew (the relevant GE program), the institution’s enrollment and financial records should allow the institution to determine the amount of tuition and fees assessed as well as the COA amounts for books, supplies, and equipment for enrolling in the relevant GE program and that amount should be reported. The institution must maintain that documentation.
If the institution’s records cannot make this attribution (perhaps because the institution charges students a flat amount for tuition and fees regardless of how many programs the student is enrolled in), the institution must divide the assessed tuition and fees as well as the COA for books, supplies, and equipment, by the number of GE programs the student was enrolled in. [July 17, 2015]
R-Q20: How are amounts for tuition and fees and books, supplies, and equipment calculated if the student was enrolled in one or more non-GE programs during all or some of the time when the student was enrolled in a GE program?
If a student was enrolled in multiple programs, the institution’s enrollment and financial records should allow the institution to determine the amount of tuition and fees assessed as well as the COA amounts for books, supplies, and equipment for enrolling in each of the programs. The institution must maintain that documentation.
An institution that is unable to determine the amount of tuition and fees and the COA amounts for books, supplies, and equipment that are attributable to a GE program and any non-GE programs, must attribute and report all of the charges assessed the student and COA amount for books, supplies, and equipment to the GE program for the purpose of reporting. For example, if the institution charged a student a flat tuition of $12,000 for enrolling in a GE program and in a non-GE program, the institution must report all $12,000 for the GE program. Institutions do not report data for non-GE programs under the GE regulations. [July 17, 2015]
R-Q21: After completing reporting and sending its GE information to the Department’s NSLDS, how will the institution know that the information was transmitted successfully and accepted by NSLDS? What if NSLDS determines that there are errors that need to be corrected?
As noted in the NSLDS Gainful Employment User Guide, when an institution sends a “GE Submittal File” using the batch process, NSLDS will return to the institution a “GE Response Error/Acknowledgement” file within 36 hours. Information about any submitted records with errors that are detected by NSLDS are included in this file. The institution must correct and resubmit those records within 10 days of its receipt of the “GE Response Error/Acknowledgement”. If the institution’s file was received and NSLDS did not find any errors, the “GE Response Error/Acknowledgement” file will not include any error notations. If the institution does not receive a “GE Response Error/Acknowledgement” file the information was either never received by NSLDS or it could not be processed. If that happens, the institution must determine the error and resubmit the file. The NSLDS Customer Support Center is available to provide assistance at 800-999-8219 or by e-mail at email@example.com.
When, instead of using the batch process, the institution sends GE data using either the “GE Submittal Spreadsheet” or “Online” method, errors will be noted and displayed before the file/record can be submitted. These errors must be corrected and then the file submitted. [July 30, 2015]
R-Q22: What if I find an error in my data after my GE records were submitted to NSLDS?
Any errors must be corrected as soon as they are detected. [July 30, 2015]