Institutions Must Update Gainful Employment Disclosures

Although court action this summer vacated some gainful employment (GE) regulatory provisions, colleges are still required to update gainful employment annual disclosures. The Department of Education's November 23 Announcement #42, made this clear:  “Institutions that have not already updated their GE Program disclosures for the 2011-2012 award year must, no later than January 31, 2013, update their disclosures for each of their GE Programs.”  (For background, see July 23 Washington Update story)

Although these disclosures were required, last July the Department notified colleges that they didn’t have to make them until it provided more information later in that month.  While much later than promised, Announcement # 42 seems to be that clarifying information.  Several points are worth noting.

• The deadline for updating 2011-12 award year disclosures was January 31, 2012.
• The GE disclosure template that colleges are supposed to use, however, is not yet available.
• Instead, colleges must use their institutionally-determined format to provide disclosures.
• Colleges that have already updated their disclosures for the 2011-12 award year, should make sure they are consistent with the guidance in Announcement #42.
• Disclosures include occupations, normal time to completion, tuition and fees and other applicable costs, placement rates, and loan debt.
• Colleges should calculate their own median educational loan debt of GE completers for Title IV and private loans, and institutional debt.  Normally, the Department would calculate and provide institutions with loan numbers, but because colleges didn't have to report the data to the Department, they now must do their own calculations.)

In a related notice, Announcement #41, the Department has clarified that, based on the recent court decision, most new GE programs don't require Secretary of Education approval.  In general, institutions may “self-determine eligibility” for programs leading to degrees for which an institution is approved to offer.  However, at institutions that are only provisionally certified - and in some other specific cases - must be approved before the institution may disburse Title IV funds to, or on behalf, of students.

For more information, please contact:
Maureen Budetti