Posted Date:August 13, 2010
|Author:||David Bergeron, Office of Postsecondary Education|
Subject: Release of Data and Technical Documentation for NPRM on Gainful Employment
On August 11, 2010 we held a public conference call to discuss the recently published Notice of Proposed Rulemaking (NRPM) related to the requirement that certain academic programs lead to "gainful employment in a recognized occupation" in order for students in such programs to be eligible for Title IV student assistance. On that call, we indicated that we would be releasing data and technical documentation behind the Department’s estimates of the impact of the proposed regulation. That information can be found at the url listed below.
It is important to note that it is not possible to use these data to determine the impact of the proposed rule on any particular institution. This is true for several reasons including that income information needed to calculate the debt-to-income ratio is only available for certain institutions and has been released anonymously.
We are providing data so that institutions, and other interested parties, can estimate the impact of the proposed rule as they prepare comments on the NPRM. To gain a true picture of the impact of the proposed rule, institutions will likely need to combine this information with information that they have on the placement rate and earnings of graduates. In this regard, we encourage other parties to exercise great care in interpreting these data. Several cautions are appropriate in interpreting the repayment rate data:
The data are provided for all institutions of higher education, even though some or all programs at many institutions are not affected by the proposed rule. The rule covers programs offered by for-profit institutions (except for certain liberal arts degrees) and programs leading to certificates offered by public and non-profit institutions. The corporate form and eligible programs of any particular institution can easily be determined at the Department’s College Navigator web site.
While the proposed rule determines eligibility on a program-by-program level, because of the lack of program specific data, these data are presented institution-by-institution.
Two sets of repayment rate data are being made available. These repayment rates were derived from the same analysis of data from the National Student Loan Data System but differ in the level of aggregation of these data.
The first data set includes only repayment rate information. These data are available at the level of the organization that signed the Program Participation Agreement (PPA) with the Department. However, this data set does not include other variables available to the Department from the Integrated Postsecondary Education Data System (IPEDS) because such data is often reported differently than at the level of the PPA entity.
The second data set includes data from IPEDS and is aggregated at the level necessary to support the inclusion of data from both sources.
It is important to note that some institutions with low repayment rates do not face any impact from the proposed rule. Some institutions may be public or non-profit institutions that offer only programs leading to degrees. At other institutions, including some community colleges, the large majority of students do not take out any student loans. These programs are not threatened by the proposed rule because any program where the majority of students do not borrow will automatically pass the debt-to-income ratio, which is based on the median level of debt of program completers.
Comments to the NPRM should be submitted using the process published in the NPRM.