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 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: 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 There is a crosswalk between CIP and SOC codes that can be found at:

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:

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.

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.

The FVT/GE regulations define “institutional debt” in 34 CFR 668.403(d)(1)(iii) 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 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.

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 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). Her 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). She is 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 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.

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, the institution has two options for attributing the private loan, institutional debt, or institutional grant and scholarship amounts – attribute the amounts evenly among the programs or use the actual amounts applied to each program.

Under the first option, the institution may simply divide the total amount received (or owed for institutional debt) 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.

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 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.

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

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.

Published: 04/05/2024