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Gainful Employment – The Deadline Approaches…and Consequences

They said it would happen.  And, it is almost here!  The deadline for the first round of Gainful Employment (GE) reporting is July 31, 2015, based upon the requirements of the October 31, 2014, final regulations.  This is a date you do not want to miss!


FAME staff attended a recent conference at which U.S. Department of Education (ED) staff spoke on the topic of GE reporting.  It was clearly stated that schools must have completed their GE reporting by July 31, 2015.  Failure to do so will have consequences.  Two things will happen if a school misses the July 31, 2015, reporting deadline.

  1. ED will send a letter by e-mail to the president of each institution that has GE programs.  The letter will list each of the GE programs for which the institution did not report in a timely manner.  These letters will be sent the first week of August, 2015.
  2. Schools who do not report on time will be placed on Heightened Cash Monitoring (HCM), level 2.  This is more commonly called HCM2.  This requires more ED oversight and involvement in the approval of Title IV program cash disbursements to the school.


There are a number of other key points that schools should keep in mind with regard to GE reporting.

  1. For GE reporting, schools should not report data on students who are not Title IV recipients, nor should data be reported for students who only received Federal Supplemental Education Opportunity Grants (FSEOG) and/or Federal Work-Study (FWS).
  2. If the school determines that it has found errors in the data reported for the submission to meet the July 31, 2015, GE reporting deadline, the school must upload corrected data immediately so that correct information is available for the calculations ED will perform with the data.
  3. Schools are reminded that the data due by July 31, 2015, is to include all applicable data for the 2008-2009 award year through the 2013-2014 award year.  (Any school that has medical or dental residencies, e.g., for a medical doctor or doctor of dentistry, must also include data for the 2007-2008 award year.)
  4. After the GE reporting is completed, schools will receive a “Completers List” from ED that provides the median earnings used for the Debt-to-Earnings (D/E) rate.  Schools may challenge that data.  Subsequently, schools will receive a draft D/E rate.  The draft D/E may be challenged by the school.  After the opportunity for a challenge of the draft D/E rate, schools will receive their final official D/E rates for the applicable years.  Once the final D/E rates are received, schools may notify ED if they intend to submit Alternate Earnings Appeals within 14 days.  If they do so, they must then submit the appeal and documentation within 60 days of receipt of the official D/E rates.
  5. GE reporting is due not later than October 1, 2015, for data applicable to students in the 2014-2015 award year.

For an illustrated depiction of the GE reporting and D/E rate calculation process, see the flow chart below that is excerpted from ED’s GE Reporting Webinar conducted on January 13 and 15, 2015.  The full Webinar slide presentation is available at


More information about GE reporting requirements has been discussed in the January 2015 issue of the FAME Inside Report’s feature article, “Gainful Employment Redux.”  Also, the Inside Report released earlier in July 2015, contains the feature article, “THE GAINFUL EMPLOYMENT DANCE—or, Understanding the Distinction between Disclosure and Reporting Requirements.”

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