Frequently Asked Questions

These Frequently Asked Questions (FAQs) provide information and operational guidance on the requirements of the new Financial Value Transparency and Gainful Employment (FVT/GE) regulations. Institutions must review the final regulations as published in the Federal Register on October 10, 2023, to ensure that they are in compliance with all of the FVT/GE requirements.

The listing of FAQs will be updated periodically and include the date of the update. New and/or updated questions and answers will be marked NEW or UPDATED. If you have questions that have not been addressed, please submit them to the FVT/GE Questions mailbox at GE24@ed.gov and include the name and OPE ID number of the institution.

The questions below are grouped by the following categories: 

General [G]

Only Title IV-eligible programs and, in some cases, previously-eligible programs are subject to the statutory and regulatory FVT/GE requirements.

The FVT/GE reporting requirements apply to an institution’s currently eligible programs and to any of its previously eligible programs for which the Department has data in the National Student Loan Data System (NSLDS).

The Department will calculate and publish D/E rates and EP metrics for all educational programs for which data are available except for certain exceptions noted below. The Department will only discontinue the eligibility of failing GE programs that are currently Title IV-eligible.

The Department’s regulations also limit an institution’s ability to add new programs within the same 4-digit CIP code range (referred to as “substantially similar programs”) during the three-year period following the voluntary withdrawal of a previously eligible educational program.

The Classification of Instructional Programs (CIP) published by ED’s National Center for Education Statistics provides a six-digit 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.

Standard Occupational Classification (SOC) codes are published by the Department of Labor and are available at http://www.bls.gov/soc. There is a crosswalk between CIP and SOC codes that can be found at: https://www.onetonline.org/crosswalk/CIP.

Note that the CIP codes for some institutional programs may have changed since the prior GE regulations were in effect. Additional information about the 2020 changes to CIP codes may be found at: https://nces.ed.gov/ipeds/cipcode/Default.aspx?y=56.

A First-Professional Degree is the first degree 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.) (see 34 CFR 668.2 “Professional degree”).

No. The program as described is neither a GE Program nor an Eligible Non-GE Program that the institution is required to report on.

A postbaccalaureate 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 subject to GE accountability requirements and is not an Eligible Non-GE Program subject to reporting requirements because it does not lead to a credential awarded by the institution.

Note, however, that if an institution provides a credential for a non-degree postbaccalaureate teacher training program, the program is considered a GE program that is subject to the FVT/GE requirements. See 34 CFR 668.32(a)(1)(iii) and 34 CFR 690.6(c).

No. The program as described is neither a GE Program nor an Eligible Non-GE Program that the institution is required to report on.

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. Such programs are also not Eligible Non-GE Programs because they do not lead to a recognized credential provided by the institution.

Programs that are not designed solely for transfer purposes and that lead to a recognized nondegree 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 an Eligible Non-GE Program. See 34 CFR 668.8I(2).

Yes. A two-year program that leads to a certificate or other recognized nondegree credential (not a degree) of its own does not fall under the transfer program exception described above. As such, because the program does not lead to a degree, it 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 transferable to a four-year bachelor’s program.

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 eligible ESL or ESOL programs offered by proprietary institutions and all certificate or other recognized non-degree credential ESL or ESOL programs are GE programs. All eligible ESL or ESOL programs, including degree programs at nonprofit and public institutions, are subject to the FVT requirements, including reporting.

While the selection of the proper CIP code for an educational program is the responsibility of each institution, we recommend that institutions use 16.1701 [English as a Second Language] for ESL and ESOL programs, which was added to the CIP code list in 2020, and covers programs for academic credit towards a postsecondary credential. 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.

A student is considered to have completed a GE or Eligible Non-GE program if the student meets the requirements for the institution to report a student as “graduated” in NSLDS.

Generally, all Title IV-eligible programs offered by a proprietary institution are GE Programs, and therefore subject to all of the GE regulatory requirements. However, there are several exceptions. First, 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(a)) are excluded from the GE requirements.

The third exception applies to a liberal arts bachelor's degree program that has been continuously provided by the proprietary institution since January 1, 2009 and the proprietary institution has been continuously accredited as a proprietary institution by a recognized regional accrediting agency since October 1, 2007.

If a proprietary 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 proprietary institution since that date. Therefore, the liberal arts program must lead to gainful employment in a recognized occupation to be eligible for Title IV aid and is considered a GE program.

Note that although these legacy liberal arts bachelor’s degree programs are not GE programs, all such programs (except for Comprehensive Transition and Postsecondary Programs) are subject to reporting and other requirements under the FVT regulations.

If there are fewer than 30 completers in the 2-year cohort period for a GE or Eligible Non-GE Program, the Department will look at the 4-year cohort period to calculate the Debt-to-Earnings (D/E) or Earnings Premium (EP) rates. If there are fewer than 30 completers in the 4-year period, neither of those rates will be calculated for the program.

Since the number of program completers may vary by year, the Department may use cohort periods of different lengths to calculate the rates for the same program in different years. For example, the Department may use the 4-year cohort period data to calculate the rates for a program in one year and it may use the 2-year cohort period data to calculate the rates for the same program in another year.

If a program’s D/E or EP rates are not calculated or issued for an award year, the program remains in the same status from the last year for which the rate was calculated for the program, with respect to warning and acknowledgement requirements and the number of years of failures for program eligibility purposes. Rates more than five years old are not considered when determining the program’s Title IV eligibility or whether it is subject to warnings or acknowledgements.

When an institution considers selecting transitional reporting and transitional metrics as allowed under 34 CFR 668.408(c), it is making one decision for all of its programs: either all of its programs will be subject to the standard reporting obligations and standard rate calculations, or all of its programs will use the transitional reporting option and transitional rate calculations.

Electing to use transitional reporting and rates allows an institution to limit its prior year reporting of private loan debt, tuition, fees, books and supplies, and institutional grants and scholarships to cover only the 2022-2023 and 2023-24 award years, as opposed to earlier award years. Reporting for prior years and for award year 2023-2024 will be due October 1, 2024 for all programs. Subsequent award years will have an October 1 deadline for reporting data for the most recently completed award year (e.g., the reporting deadline for 2024-2025 data is October 1, 2025, and so on).

Institutions opting to use transitional reporting and metrics must remain with transitional rates for the first six years of calculation, and institutions that did not elect to use the transitional option in the first year of calculations will remain with standard rate calculations. Regardless of which option a school selects, after the first year of reporting, subsequent reporting after the first year will only cover the most recently completed award year.

In calculating the transparency metrics for programs opting to use transitional reporting and metrics, earnings data is determined for completers from the same award years that are used in calculating standard rate metrics. Debt data and the Annual Loan Payment amount are determined for completers from the two most recently completed award years, which are 2022-2023 and 2023-2024 in the first set of calculations. A minimum of 30 completers is required for each group for metrics to be calculated and for corresponding debt and earnings data to be published.

For programs using standard reporting, 30 completers would be required for the 2-year cohort or the 4-year cohort for metrics to be calculated and debt and earnings data to be published. For programs using transitional rates, this would mean that there must be at least 30 completers in the 4-year cohort for earnings and at least 30 completers in the two most recently completed award years for debt. Both debt and earnings cohorts must meet the minimum size of 30 completers for transitional D/E rates to be calculated and released.

If a program using transitional calculations has sufficient completers in the debt cohort but not the earnings cohort, D/E and earnings premium metrics will not be calculated for the program, but the program’s median debt information will still be included on the Department’s program information website. If a program using transitional calculations has sufficient completers in the earnings cohort but not the debt cohort, the Earnings Premium metric will be calculated and included with median earnings information on the program information webpage. A program receiving an EP result without D/E rates is still subject to the same potential consequences for failing the EP metric. Programs do not need to have a result for both EP and D/E metrics for assessing potential consequences under the regulation.

No. The Department will not calculate rates for a program if it does not have data for a sufficient number of completers for the cohort period. This would include situations in which an institution does not use the transitional reporting process and did not report completers for a particular program during all or part of the cohort period because it was not required to report enrollment at the program level during that period.

A Qualifying Graduate Program is a program in certain fields for which required postgraduation training requirements apply for licensure. It is a recognition that that certain graduate programs, mostly concentrated in medical and clinical fields, are associated with an initial period of depressed graduate earnings while graduates complete a required period of postgraduate clinical or residency work necessary to obtain a professional licensure, after which graduates realize significant earnings growth.

Therefore, for purposes of calculating the D/E rates and EP measure, the Department extends the earnings measurement period for such Qualifying Graduate Programs when compared to other postsecondary programs.

To be treated as a Qualifying Graduate Program, a program must meet three specific and rigorous criteria:

  1. First, the program must be a graduate program (credential levels 05, 06, 07, or 08) identified under the CIP code list published on June 28, 2024 in the Federal Register (89 FR 53986) as being potentially eligible to be considered a qualified graduate program. These CIP codes cover areas in medicine, osteopathy, dentistry, clinical psychology, marriage and family counseling, clinical social work, and clinical counseling.

  2. Second, the program must be one whose students must complete a “required postgraduation training program” to obtain licensure, which is a supervised training program that (1) requires the student to hold a degree in one of the qualifying fields and (2) must be completed before the student may be licensed by a State and board certified for professional practice or service.

  3. Third, the school must be able to attest in submitting its report that at least half of the program's graduates obtain licensure in a State where the postgraduation training requirements apply, and that, if necessary for licensure, the graduate program is accredited by an accrediting agency that meets State requirements.

If the program meets these criteria, the school may use the indicator in reporting program data. If the program meets these criteria at an institution choosing standard reporting instead of transitional reporting, an additional award year (2016-2017) of student-level reporting for that program must be submitted.

Because FVT/GE calculations treat a CIP code and credential level combination as one program, even if it covers more than one distinct academic program, it is possible that an institution has a CIP code and credential level combination covering one program that would be a Qualifying Graduate Program and one program that would not be a Qualifying Graduate Program based on whether the program meets the 50% threshold for postgraduation training requirements.

If this is the case, the school should make its determination based upon the student populations combined, dividing the number of completers at that CIP code and credential level who obtain licensure in a State with postgraduation training requirements by the total number of completers at that CIP code and credential level. If there are more completers who obtain licensure in a State where the postgraduation training requirements apply and all other conditions are met, the program would be considered a Qualifying Graduate Program.

No. The Department currently does not maintain information about an individual’s receipt of FWS and these students therefore cannot be included on an institution’s completer’s lists. Therefore, until such time as the Department can include such individuals using the data in its system, institutions are not required to take any action related to individuals who receive only FWS, including reporting. We will notify our partners when reporting becomes required for FWS-only students.

Debt-to-Earnings Calculation [DE]

No debt will be included for a student in a D/E calculation if the student received an amount of institutional grant and scholarship funds that is equal to or greater than the amount of charges the student incurred for tuition, fees, books, and supplies.

In the first year that the D/E metric is calculated, the Department will not calculate a D/E rate for a program if the institution is using the transitional reporting method and does not have at least 30 completers to report on for the two most recently completed award years. However, in subsequent years, the Department will include students from up to four award years prior to the reporting date to determine whether at least 30 completers are present in the program, and will publish a D/E rate for the program if there were 30 completers reported on in the four most recently completed award years.

For example, if during the first year of reporting the institution is unable to identify at least 30 completers to report on from the 2022-23 and 2023-24 award years, the Department will not calculate a D/E rate for the program. However, in the following year, when the institution reports data for the 2024-25 award year, the Department will calculate a D/E rate for the program if there was a total of at least 30 completers in the program during the 2022-23, 2023-24, and 2024-25 award years.

Earnings Premium Calculation [EP]

The Department uses address information provided by the student on their initial FAFSA submission to determine whether the student is from the State in which the institution is located.

Warnings [W]

Beginning on July 1, 2026, institutions must begin providing warnings to prospective students in any GE program if the has been notified that the program has failed either the D/E or EP measures prior to that date. Institutions must also provide warnings to all enrolled students in a program that has failed one of the metrics by the later of July 1, 2026 or 30 days after the date that the Department notified the institution that the program had failed.

Disclosures and Acknowledgements [DA]

The acknowledgement requirements will become effective on July 1, 2026 after the Department has established the program information website.

No. Undergraduate degree programs are not subject to the acknowledgement requirements.

Yes. Only prospective students enrolled in certificate programs or graduate programs that have received a failing D/E rate are subject to the acknowledgement requirement.  A prospective student must provide the acknowledgment before the institution enters into an agreement to enroll the student in one of these programs.  Undergraduate degree programs are not subject to the acknowledgement requirements.

Prospective students must be provided such acknowledgments until the Department notifies the institution that the program has passing D/E rate or three years after the institution was last notified that the program had failed, whichever is earlier.

Reporting [R]

New reports will be available before the reporting window opens in NSLDS to identify these students. The Department uses an institution’s existing enrollment reporting to construct the list of students who have completed or withdrawn from the program.

Yes. An institution will be provided 60 days to correct the information from the date that the Department provides the list to the institution. Institutions will make these corrections by amending their original NSLDS enrollment reporting.

All required data should be reported by October 1 following the end of an award year.

The institution would report the student as currently enrolled if the student was enrolled at the end of the award year.

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. The ‘Program Attendance Status During Award Year’ 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’ must be changed to ‘W’ (Withdrew) and the ‘Program Attendance Status Date During Award Year’ should be completed with the last date of attendance. Thus, the institution would report the student as a currently enrolled student.

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.

No. An institution must report the total amount of tuition and fees charged to the student for the program before any aid or other credits are applied to the student’s account. There will be a separate field for reporting institutional grants and scholarships meeting the criteria of the definition found in 34 CFR 668.2. Subtracting non-Title IV aid from tuition and fees would result in amounts being subtracted twice and/or in amounts being excluded improperly.

Institutional debt definition

The FVT/GE regulations require the reporting of “institutional debt” in 34 CFR 668.408(a)(3)(iii), which is described as “[t]he total amount of institutional debt… the student owes any party after completing or withdrawing from the program.” As further described in 34 CFR 668.403(d)(i)(iii), institutional debt includes “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 program attended at the institution that the student is obligated to repay after completing the 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 FVT/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 are also not included as Title IV debt in the D/E calculations.

Reporting institutional debt

Graduated Students: For completers, the institution should report the student’s institutional debt as of the student’s completion date.

Withdrawn students: The institution should report the student’s institutional debt as of the deadline for completing the Return of Title IV funds (R2T4) calculation, or the 45th day following the date that the institution determined that the student withdrew, as defined in 34 CFR 668.22(l)(3). This ensures that changes to a withdrawn student’s institutional debt resulting from R2T4 calculations and tuition refunds are appropriately accounted.

When reporting institutional debt, the institution should NOT include write-offs, amounts sent to collection agencies, or payments made to the institution by the student or another individual after the student’s withdrawal date.

Overawards and other Title IV student aid owed to the institution by the student, including as a result of a R2T4 calculation, are not considered institutional debt and therefore should not be reported as part of institutional debt. However, amounts owed to the institution 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 $11,500 (assume the institution bills up front for the entire program). The student’s financial aid package includes a Federal Pell Grant of $7,395 and a Direct Subsidized Loan for $3,500 ($3,445.05 net disbursement amount). They are placed on an institutional financing plan for the remaining $659.95 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 their program of study. As the result of an R2T4 calculation, the institution must return $1,050 in Title IV funds. The student also receives a tuition refund of $500. The student now has a balance due the institution of $913 that is made up of the $363 remaining under the original institutional financing plan and the $550 they now owe following the tuition refund and the amount that was returned by the institution to the Title IV programs.

After the withdrawal, but before the 45th day after the date that the institution determined the student withdrew, the student repays $200 of the amount owed to the institution. That amount should be ignored because it is an amount repaid by the student after the withdrawal date. The institution should report the entire amount of $913 as institutional debt. In this situation, the school would also reduce the amount it reports for total tuition and fees paid for the student by $500, the amount of the tuition refund.

The Department acknowledges this clarification postdates the submission of some institutions’ FVT/GE reporting. However, given this reporting does not impact the calculation of metrics under FVT/GE, institutions do not need to resubmit reporting submitted prior to this FAQ update.

The FVT/GE regulations define “institutional grants and scholarships” in 34 CFR 668.2 as “[a]ssistance that the institution or its affiliate controls or directs to reduce or offset the original amount of a student's institutional costs and that does not have to be repaid. Typically, an institutional grant or scholarship includes a grant, scholarship, fellowship, discount, or fee waiver” that is included in a student’s financial aid package as estimated financial assistance.

Such awards include:

  • Those provided by a corporation or foundation associated with the institution that manages an endowment belonging to the institution if the institution itself has control over the selection of students for awards from that endowment and the amounts of those awards, even if the institution’s selections are constrained by donor requirements.

  • Tuition waivers that are noted on student accounts, although they do not include an amount that a student is not charged in the first place (since such a reduction would be accounted for in the lower tuition and fees reported elsewhere for the student).

Note that amounts reported for a student’s institutional grants and scholarships may not exceed the amounts reported for their tuition and fees plus books, supplies, and equipment, since the debt used in D/E calculations is already capped at that amount before institutional grants or scholarships are subtracted.

Institutional grants and scholarships do not include funds that are provided to students by outside entities such as unaffiliated private organizations or individuals. They also do not include awards or other amounts provided to students that are not included in a student’s financial aid package as estimated financial assistance.

If the student was enrolled in more than one educational program, when reporting for the TA Detail Record, the institution has two options for attributing the private loans, tuition and fees, allowances for books, supplies, and equipment, and institutional grant and scholarship amounts:

1) Attribute the amounts evenly among the programs.

Under this option, the institution may simply divide the total amount(s) by the number of programs and use the result for reporting. For example, if a student took out $10,000 in private loans for enrollment in two programs, $5,000 is attributed to each of the two programs.

2) Use the actual amounts applied to each program.

Under the second option, if the institution can document the actual amounts, it may attribute those amounts 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 one of its programs, only the remaining $8,000 is attributed to the second program. Institutions choosing this option must maintain the documentation so that it is available upon request.

Please note the following:

  • When reporting for the TA Detail Record for students who completed or withdrew from Eligible Non-GE Programs, the institution should report amounts for all programs at the same credential level in which the student enrolled at the institution since the 2017-18 award year. See FAQ R-23 for more information.

  • Institutions do not report Title IV debt. Those amounts will be determined and attributed by the Department from NSLDS data.

Schools should also use one of the two methods described above when reporting award year values in the AA Detail Record for students who are currently enrolled in more than one program at the institution as of June 30.

Annual data should be reported for students who are enrolled as of the end of the most recently completed award year. For students who have graduated or withdrawn as of the end of the prior award year, cumulative data for a student’s entire time in the program should be reported. It is important that institutions report this cumulative data so that complete information is available for scenarios where some years’ data might otherwise be missing from the total, such as for years when a student did not receive Title IV aid to attend the program or for years predating those covered by reporting.

For students who have withdrawn from or completed the program, the institution will report cumulative totals for that student, which would cover the student’s entire enrollment in the program, both before and after any withdrawals.

As an example, in the 2018-2019 award year a student was enrolled in a program until they withdrew in December of 2018. The institution had assessed the student $5,000 in tuition and fees with zero institutional grants or scholarships and had included a total for books, supplies, and equipment of $800 in the student’s COA up to the student’s withdrawal. The student then re-enrolled in the same program in March of 2019 and graduated the following June, all in the same 2018-2019 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. When reporting cumulative totals for this student, the institution will report the aggregate amount of $7,000 for tuition and fees, zero for institutional grants and scholarships, and a total of $1,000 for books, supplies, and equipment.

Only include students in your reporting for programs at your school for which they have received Title IV aid. If a student did not receive Title IV aid for any programs at your school, do not include them in your FVT/GE reporting. If a student received Title IV aid for Program A but, not for Program B, include that student in reporting for Program A, but not in reporting for Program B.

Yes. For the most recently completed award year (2023-2024 for the FVT/GE reporting due October 1, 2024) and subsequent award years, schools must include all Title IV students in FVT/GE reporting beginning with the award year in which they first received Title IV aid to attend the program and for all subsequent award years in which they attend the program, regardless of whether any further Title IV aid was received.

For years predating 2023-2024, schools will report students who have received Title IV aid at any time to attend a program as a completion or withdrawal in the appropriate award year, even if Title IV funds were not received in the award year of the completion or withdrawal. Cumulative amounts reported at graduation or withdrawal must include amounts for all award years when the student was in the program, including periods when they were not Title IV recipients. Because of the record retention requirements under 34 CFR 668.24(e), schools are expected to have records of the tuition and fees assessed to their students for all or most of the initial reporting period. If, for a portion of the initial reporting period, they do not have individual records for a student's allowance for books, supplies, and equipment costs they could use the established allowance they used in packaging aid for the program during the relevant award years.

No. Because Parent PLUS loans benefit the student, but must be repaid by the parent, they are not included in debt calculations for D/E rates or for program information.

Schools should report the total number of program graduates who attempted a licensure exam and the total number of program graduates who passed a licensure exam, as most recently reported to the institution’s accrediting agency. If your institution’s accrediting agency does not require the school to provide count of students who take a licensure exam, you should not provide a value (report a space) in those fields.

An institution is already expected to include financial resources, including private education loans, in a student’s financial aid package if the resources were received because the individual is a student. This is true even when the institution does not certify a private education loan, but otherwise becomes aware that a student has received such a loan, for example through discussions or email exchanges with the student. An institution should be reasonably be aware of such private education loans and should include them in a student’s financial aid package.

The Department applies the same requirement to this reporting: an institution should include in its reporting any private education loan that is included in a student’s financial aid package because the school became aware of it, even if the loan was not certified by the school.

In such a situation, the institution should report on all the disbursements that were made at the time that reporting is completed on or before October 1.

In that situation, the institution should report program length or weeks in Title IV academic year” that is longest.

In that situation, the institution should report all students as having “Out-of-State Tuition (OS)”.

No. Schools should not exclude any students from reporting, whether they use transitional or standard reporting. The Department will apply the appropriate exclusions for students when calculating the D/E and EP measures.

The allowance for books, supplies, and equipment is the total annual allowance for books, supplies, and equipment that an institution includes in a student’s cost of attendance for the award year being reported. This amount should be the actual amount included in a particular student’s cost of attendance for that award year, in accordance with the institution’s process for developing the allowance. It should incorporate any corrections or use of professional judgment by the institution as of the date that the institution completes reporting.

If a student is not enrolled at the institution for the entire year, the institution should prorate their allowance for books, supplies, and equipment to account for the period during which the student was enrolled.

The definition of “Eligible Non-GE Program” under 34 CFR 668.2 specifies that it includes all work associated with the program’s credential level. This accounts for the fact that some of the coursework for a non-GE degree may have been associated with more than one CIP code.

Therefore, for GE Programs, institutions report information for students who complete or withdraw from the program only for the program itself, defined as the combination of the CIP code and credential level. For Eligible Non-GE Programs, institutions report information for the program itself as well as all other programs at the same credential level going back to the 2017-2018 award year. Institutions are not required to report information for earlier award years.

For example, consider a student who enrolled in a traditional undergraduate program at a public institution that is considered an Eligible Non-GE Program. The student began their enrollment in an “undeclared” status, which the institution associates with the CIP Code 24.0102 and a credential level of 03 - Bachelor’s Degree. The student remains in that status for their first two academic years, borrowing $10,000 in private loans during that period. For the student’s junior year they transfer into a business major, which the institution associates with the CIP Code 52.0201 and a credential level of 03. The student borrows an additional $5,000 in private loan funds during their enrollment in that program. Finally, at the beginning of the student’s senior year, they transfer into an English major, which the institution associates with the CIP Code 23.0101 and a credential level of 03. The student remains enrolled in this program for two years and accrues an additional $10,000 in private loan debt before graduating at the end of his fifth year of enrollment at the institution. Because all of the programs described above were the same credential level as the program that the student completed – 03 - Bachelor’s Degree – when reporting Total Amounts (TA) for the student, the institution would sum all of the private loan debt that the student borrowed and report the total amount, or $25,000. The school would also report the total tuition and fees, institutional scholarships, and allowances for books and supplies for the student’s enrollment in all of those programs at the same credential level.

Because institutions report institutional debt owed by a student as of the day the student graduated or withdrew from the program, there is no difference between GE Programs and Eligible Non-GE Programs when reporting Total Amounts of institutional debt for a student.

If at least one of the eligible programs within a GE or Eligible Non-GE Program is not programmatically accredited, you should report “No” for the Programmatically Accredited Indicator for that program.

If your school’s GE or Eligible Non-GE Program operates different tracks/concentrations at the same CIP code and credential level, report the program as meeting the licensure requirements for the State only if at least one track/concentration of the program allows for meeting licensure requirements in the State.

The institution should use the same method that it uses to prorate institutional charges to determine the tuition and fees that it reports for the AA Detail Record.

Two steps are required for an institution to determine the amount of tuition and fees assigned to each payment period using the proration method described in the cash management regulations under 34 CFR 668.164(c)(5).

Step One: The institution determines the amount of tuition and fees associated with each payment period in the program. Using the proration requirements under 34 CFR 668.164(c)(5)—

     

If the program has substantially equal payment periods, the institution divides the total tuition and fees for the program by the number of payment periods in the program.

     

If the program does not have substantially equal payment periods, the institution divides the number of credit or clock hours in the applicable period by the total number of credit or clock hours in the program, and multiplies that result by the total tuition and fees for the program.

Step Two: The institution then adds together the tuition and fees associated with all payment periods that are assigned to the most recently completed award year to determine the total amount of tuition and fees to include in the AA Detail Record.

For example, consider a situation where an institution charges $12,000 in tuition for a 1200 clock-hour program that has three payment periods, PP1, PP2, and PP3. PP1 includes 450 hours, PP2 includes 450 hours, and PP3 includes 300 hours. For this program, performing the proration as described under 34 CFR 668.164(c)(5)(ii) would result in the following amounts of tuition and fees being assigned to each payment period: PP1 would include $4,500 (450 divided by 1,200 multiplied by $12,000), PP2 would include $4,500 (450 divided by 1,200 multiplied by $12,000), and PP3 would include $3,000 (300 divided by 1,200 multiplied by $12,000). For one particular student the school assigns PP2 and PP3 to the most recently completed award year, so for this student the institution would report $7,500 in tuition and fees (the total of tuition and fees associated with PP2 and PP3) in the AA Detail Record.

Schools should report all non-Title IV education loans, including state loans and federal loans such as Nursing Student Loans, under “Private Loans Amount” for the AA Detail Record or “Total Private Education Loans for Student's Entire Enrollment in the Program” for the TA Detail Record.

For the 2024 Reporting Year only, schools should not report information regarding federal education non-loan grant assistance or benefits. This includes, but is not limited to—

  • Emergency Financial Aid grants made to students from the Department’s Higher Education Emergency Relief Fund (HEERF) program,

  • GI Bill benefits from the VA, and

  • Educational assistance benefits from the DoD.

For this value, the institution should include the total number of students that were enrolled in the program at any time during the most recently completed award year. (An award year is the period from July 1 to June 30.) The value should include both Title IV recipients and students who did not receive Title IV aid.

For programs that are offered exclusively through distance education or correspondence courses, schools should leave the fields for State [#] in MSA of Main Campus blank, and report “X” for “Not Applicable” in the fields for Program Prepares Licensure in MSA State [#].

If another school has merged into your institution, you are responsible for reporting that school’s students under the OPEID in which they were enrolled as of June 30, 2024, or where they completed or withdrew. In scenarios where data from the other school is unavailable, your school should be prepared to provide an explanation for why reporting was not completed.

No. The treatment of programs at least two years in length acceptable for full credit towards a bachelor’s degree as programs that are neither GE programs nor Eligible non-GE programs in Dear Colleague Letter GEN-24-04 applies to specially designed transfer programs for which the institution does not award a credential (which fall under Credential Level 99). An associate’s degree program is designed to culminate in a credential, in this case an associate’s degree (Credential Level 02), and does not fall under that category.

FVT/GE operates based on award years, which cover the period from July 1 through June 30. For enrollment counts, a student will be included in a program’s enrollment count for any award year in which they were enrolled in the program. For annual (AA) reporting, values for a payment period are included in the award year to which the period is assigned. For total (TA) reporting, values are cumulative and therefore how the award years are assigned will not impact the total amounts; you will report these amounts for the award year in which the student graduated or withdrew.

If an out-of-state student is being billed specifically at in-state rates for a particular circumstance, report the student as being in-state. If the out-of-state student is given a discount but not being billed at in-state rates, continue to report the student as out-of-state.

If neither your institutional accrediting agency nor a programmatic accrediting agency requires data for students who take and/or pass a licensure exam, you should leave a space in the relevant fields. If one accrediting agency or the other (but not both) requires this information, report the values as calculated for whichever agency requires them. If both your institutional accreditor and a programmatic accreditor require you to report data on students taking and passing a licensure exam, you should report the values as calculated for the programmatic accrediting agency.

The Department understands institutions may desire additional flexibility beyond the already twice-moved deadline for reporting the required FVT/GE data. However, the Department is unable to offer additional flexibility at this time. Institutions that fail to complete reporting by the revised deadline will be considered non-compliant with the regulatory requirements, and the Department will determine appropriate action based on the circumstances.

Data must be submitted no later than 11:59 p.m. Eastern Standard Time on January 15, 2025. The NSLDS system will then cease accepting data while the Department calculates the metrics.

Last Modified: 02/06/2025 • Published: 10/11/2024