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Earlier this month, Tom Netting and Sally Samuels summarized the anticipated financial regulations on Gainful Employment (GE) and Financial Transparency. They broke down what changed, what will remain the same, as well as reviewed critical timeframes and the potential impacts to your institution. Be sure to check out the recording of the webinar below.


Gainful Employment

Under the GE program accountability framework, the Department assesses whether career programs meet the statutory requirement of preparing students for gainful employment in a recognized occupation using two separate and independent metrics:


A debt-to-earnings rate that compares the median annual payments on loan debt borrowed for the program to the median earnings of its Federally aided graduates. For a program to pass, its graduates’ debt payments must be no more than 8% of annual earnings or 20% of discretionary earnings, which is defined as annual earnings minus 150% of the Federal poverty guideline for a single individual (about $21,870 in 2023).


A new earnings premium test that measures whether the typical graduate from a program who received Federal aid is earning at least as much as a typical high school graduate in the labor force (i.e., either working or unemployed) in their State between the ages of 25 and 34. This is equal to roughly $25,000 nationally but varies across States.


Check out the full list of GE Definitions.


In a single year, if a program fails in either metric, they will be required to provide warnings to both current and prospective students that the program could be at risk at losing Title IV in coming years. If programs fail the same metric in two of three consecutive years, they will not be eligible to participate in Federal Student Aid.


For a more detailed dive into the topic check out the Final Rule FACT SHEET – Gainful Employment blog post.


Financial Value Transparency


The Higher Education Act acknowledges there are differences across programs and colleges, and this means we have different tools available to promote these goals in different contexts. The final rule therefore creates a Financial Value Transparency (FVT) Framework that will provide information to all students in all programs on the typical earnings outcomes, borrowing amounts, cost of attendance, and sources of financial aid to help students make more informed choices.


The Department will help students be better informed by hosting a new program information website that provides standardized information about program costs (including tuition and fees, books, and supplies), non-Federal grant aid, loan burden (including both private and Federal loans), earnings of completers, and applicable occupational and licensing requirements. This website will give students and families a personalized estimate of what they’ll pay out-of-pocket to earn credentials in specific postsecondary programs, along with key information on the debt and earnings outcomes of program graduates.


For a comprehensive exploration of this subject, we invite you to check out the in-depth Final Rule FACT SHEET – Financial Value Transparency blog post.


In the ever-changing world of higher education, staying informed is critical. Be sure to check out the webinar below where Tom and Sally provide insights into the final regulations. You may also sign up for the Fame newsletter to ensure you are up to date on the world of higher education. As changes occur, we are here to provide the guidance you need.

Download Slides: Gainful Employment and Financial Transparency

About the Authors:

Materials and content originate from the Department of Education posting, with insights and summaries provided by Tom Netting and Sally Samuels.

Sally Samuels, Director of Compliance, Fame

Sally is one of the country’s leading authorities on Federal financial aid administration with more than 43 years of “in the trenches” experience. As a respected Industry leader, she is frequently called upon to speak at School, Accrediting, Regional and State conferences as well as to act as school liaison during program reviews and compliance audits.


Having processed, reviewed and taught financial aid for over 40 years Sally brings real life experiences, observations and illustrations to her audience adding a touch of humor to regulatory compliance. Her style makes the sometime complex topics easy to understand and audiences always come away with practical knowledge that they can apply to their everyday situations. Sally has been published many times in various Higher Education periodicals providing her expertise and insight on administering Federal funding based on compliance with the Federal statutes.



Tom Netting, President/CEO, TEN Government Strategies, Co-Executive Director, CSPEN

Having spent all of his professional career devoted to higher education policy oversight and implementation, Tom Netting has an extensive knowledge of the laws and regulations governing all aspects of higher education. His considerable background and experience have afforded him the opportunity to view the development and implementation of federal higher education and workforce development policy in their entirety – including issues related to higher education and workforce development, health care, veteran affairs policies and the procurement of federal appropriations.