Completers Lists for FVT/GE Reporting Requirements Distributed
Last Friday, the Department of Education distributed corrected Financial Value Transparency (FVT) and Gainful Employment (GE) completers lists to institutions. These lists are one component of the FVT/GE reporting requirements that are due early next year.
January 15, 2025 Reporting Deadline for all FVT/GE Requirements
Institutions have until January 15, 2025, to review and correct their updated completers lists. It is important to note, however, that January 15, 2025, is the deadline to submit all required FVT/GE reporting to the Department.
Completers lists are one part of those requirements, with the much larger FVT/GE reports, otherwise known as “debt reports,” making up the rest. These requirements operate independently of one another and given the scale and complexity of data that must be reported, institutions should not wait until their completers lists are finalized to begin compiling and submitting the required FVT/GE data.
The chart below, adapted by NAICU from Department of Education materials, explains the difference between completers lists and debt reports, which include entirely different groups of students:
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Completers Lists |
FVT/GE (Debt) Reports |
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Students included |
Graduates who received title IV |
Graduates and non-graduates who received title IV |
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Years covered for this cycle |
For 2-year cohorts of 30 or more completers: · 2017-18 · 2018-19 For 4-year cohorts of 30 or more completers: · 2015-16 · 2016-17 · 2017-18 · 2018-19 |
If using transitional reporting: · 2022-23 · 2023-24
· 2017-18 · 2018-19 · 2019-20 · 2020-21 · 2021-22 · 2022-23 · 2023-24 Note: Qualifying graduate programs also report 2016-17
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Programs included |
First: Programs need 30 or more completers between 2020-21 and 2023-24 (at the 4-digit CIP) Second: the 6-digit CIP needs 30 or more completers in a 2- or 4-year period. |
Programs with at least 30 completers in award years 2021-21 through 2023-24 at the 4-digit CIP. (Note: Small programs may be excluded from reporting in a given year but may need to be reported on in future years if the 30-completer threshold is crossed. Programs are assessed on a rolling basis.)
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How used |
· The Department uses this to request median earnings data from the IRS/Census Bureau · Serves as the denominator in the debt-to-earnings ratio
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· Provides the bulk of relevant data under the FVT/GE framework · Serves as numerator in debt-to-earnings ratio |
The completers lists and debt reports are used in different ways and include data from entirely different groups of students, though there may be some overlap.
Completers Lists: These lists are used by the Department to determine the cohort of students for whom the Internal Revenue Service and the Census Bureau are asked to provide earnings data. The median earnings data serves as the denominator in the debt-to-earnings ratio and is used in the earnings premium calculation. Institutions must confirm that the correct students are included on the list, but do not otherwise provide data to the Department on this cohort.
Debt Reports: Debt reports provide the bulk of the relevant information on students and programs under the FVT/GE framework and require substantial data collection of up to eight years in arrears, including data on non-graduates of qualifying programs.
Further information regarding completers lists, debt reports, and the reporting mechanisms for FVT/GE can be found in the Department’s User Guide, which was updated last month.
Lastly, the separate debt reporting forms that the Department created to help institutions comply with the new reporting requirements are still being reviewed and the agency will provide more information at a later date.