This Electronic Announcement (EA) reminds institutions of two important requirements related to the Financial Value Transparency/Gainful Employment (FVT/GE) regulations. The requirements are:
As announced in EA GE-24-08, the Department has updated the deadlines for both of these activities in recognition of the additional time schools need to prioritize their work on the FAFSA. Both of these activities must now be completed by January 15, 2025.
The evaluation of Completers Lists and submission of required data are performed separately. Schools do not need to finish their Completers List review before completing their required reporting, or vice versa.
The table below provides a high-level summary of the years and students covered by the review of completers lists and the submission of required reporting that is due by January 15, 2025.
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Completers List
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FVT/GE reporting
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Students included
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Graduates who received Title IV aid for the program
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Enrolled, graduated AND withdrawn students who received Title IV aid for the program
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Award years covered
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Two-year cohort
Four-year cohort*
*Used when 30 completers cannot be identified in the two-year cohort
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Graduated and Withdrawn Students – Two options: Transitional reporting
Standard reporting
Enrolled Students:
*Qualifying graduate programs only
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Programs included
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Any GE or Eligible Non-GE Program that:
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All GE or Eligible Non-GE Programs unless the program is part of a group of substantially-similar programs (programs within a 4-digit CIP code level at any credential level) which do not have at least 30 completers over the four most recently completed award years.
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FVT/GE Regulations
The FVT/GE regulations are a transparency and accountability framework established under the Final Rules published October 10, 2023 in the Federal Register (88 FR 70004). The regulations establish debt-to-earnings and earnings premium measures to determine whether Gainful Employment (GE) and Eligible Non-GE programs provide students with sufficient financial value. The new regulations also establish an accountability framework for GE Programs that uses the two measures to determine whether a GE program remains eligible for Title IV funds.
Completers Lists
The Department uses administrative data from the National Student Loan Data System (NSLDS) to compile draft lists of completers. These lists establish the cohorts for obtaining earnings data, and identify completers who fall under one of the exclusions in 34 CFR 668.403(e) and 668.404(c). For example, a program with at least 30 completers in the two-year cohort will include students who completed the program in 2017-2018 and 2018-2019 on the lists distributed this year.
Completers Lists are provided annually to institutions, who have at least 60 days to make any corrections to their data in NSLDS following receipt of the list, after which the Department will submit the information to the Internal Revenue Service (IRS). The final list is also provided to institutions, but there is not a second opportunity for review. Once the Department has received median annual earnings data for programs from the IRS, those amounts will be used in calculating the debt-to-earnings and earnings premium measures. For this year, as mentioned above, schools have additional time to evaluate their Completers Lists and must complete that process by January 15, 2025.
As shown in the table above, not all of an institution’s programs may appear on the Completers List. Programs need to have both a sufficient number of recent completers (defined as 30 or more at the 4-digit CIP Code level from the 2020-21 through 2023-24 award years) as well as at least 30 completers at the 6-digit CIP level from 2015-16 through 2018-19. Additionally, not all completers may show up on a list. Students are excluded for various reasons specified in the regulations, including not having received Title IV aid or being enrolled full-time in an institution in the year evaluated for earnings.
The Department established the process for Completers Lists in the final regulations to acknowledge the possibility that minor NSLDS enrollment inconsistencies could have impacts on an institution’s debt-to-earnings or earnings premium measures.
As fiduciaries, participating institutions are always expected to exercise care and diligence in administering the federal student aid programs and to correct errors when they are identified, including through the Completer’s List process. The Department does not consider corrections to NSLDS enrollment reporting, alone, to be an indication of previous non-compliance or a lack of administrative capability.
If your school did not automatically receive its draft FVT/GE Completers List in your school’s SAIG TG mailbox because at least one location is not yet enrolled for NSLDS FVT/GE reporting, you must refer to the “FVT/GE Completers List Ad Hoc Report (GEFVC1)” section in the EA GE-24-09 for more information about the ad hoc report option.
Please refer to Volume 3 – FVT/GE Completers List of the NSLDS FVT/GE User Guide for guidance on understanding the content of the Completers List, reviewing student data, identifying exclusions, and other relevant topics.
Note: If you would like to automatically receive the final Completers List in your school’s SAIG TG mailbox when it is sent, refer to the detailed SAIG enrollment information in the June 13, 2024 Electronic Announcement.
Reporting Requirements
The regulations establish requirements for institutions to report information about students who received Title IV aid and enrolled in each of the institutions’ Eligible Non-GE programs and GE programs to enable the Department to calculate the program’s debt-to-earnings (D/E) rates, earnings premium (EP) measure, and other information that institutions or the Department will later disclose to the public.
The reporting is separate from the requirement to evaluate Completers Lists. Institutions do not need the final version of the Completers Lists to complete this reporting.
This year, FVT/GE reporting is due by January 15, 2025. Data for subsequent award years will be due the October 1 following the close of an award year (reporting for award year 2024-2025 is due October 1, 2025, etc.).
FVT/GE reporting requirements apply to both Gainful Employment (GE) programs and to Eligible Non-GE programs. For institutions electing to use transitional reporting, it covers award years 2022-2023 and 2023-2024. For institutions using standard reporting, reporting covers data for award years 2017-2018 through 2023-2024, with the addition of 2016-2017 data for Qualifying Graduate Programs. The Department considers reporting to be complete only when both program-level and student-level reporting are complete for all programs that are required to report.
Institutions can use the following reports to support their FVT/GE reporting, including to identify the programs and students for which the Department expects reporting to be completed.
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The FVT/GE Program Enrollment Detail Report (SHDPE1) provides school users with a list of all students and their certified program enrollment data as reported to NSLDS via the Enrollment Reporting process. This report allows schools to request data by several parameters, and should be used by schools to review program level enrollment to determine if the student should be included in their FVT/GE reporting.
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The FVT/GE Program Enrollment Summary Report (SHSPE1) provides school users with a list of programs that have students with certified attendance as reported to NSLDS via the Enrollment Reporting process.
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The FVT/GE Students with No Program Enrollment Report (SHNPE1) provides school users with a list of students where the student was certified with campus-level enrollment data and no program-level enrollment data on NSLDS via the Enrollment Reporting process.
The SHSPE1 and SHNPE1 reports are still undergoing updates and an announcement will be posted when they are ready for use. More information on these reports can be found in EA GE-24-04, published April 12, 2024.
FVT/GE reporting options for schools include batch file submittals via the Student Aid Internet Gateway (SAIG), online reporting, or the spreadsheet submittal process via the NSLDS Professional Access website. Schools that want to report FVT/GE data using the batch process need to enroll a SAIG TG Mailbox for NSLDS FVT/GE reporting. Step-by-step instructions are included in EA GE-24-05, published June 13, 2024. For users who want to use the web to report FVT/GE data, information about online access is also provided in the announcement.
Reporting Current Disbursements with Correct CIP Code and Credential Level
In addition to evaluating Completers Lists and providing FVT/GE reporting on past periods, institutions must also ensure accurate reporting of CIP Codes and credential levels for current disbursements. Schools must ensure that COD System payment data reflects a student’s program CIP Code and Credential Level at the time the disbursement was made. As noted in Dear Colleague Letter GEN-24-07 and EA GENERAL-24-74, the Department amended the Administrative Capability regulations in 34 CFR 668.16(t) and the Financial Responsibility regulations in 34 CFR 668.171(c) related to GE programs effective July 1, 2024. The Department will implement these new requirements using the CIP Code and Credential Level reported in COD System payment data to determine whether a school complies with the new GE program funding regulations for financial responsibility and administrative capability. If a student subsequently changes their program of study during the payment period for which the disbursement was made, the institution should report the student’s new CIP Code and Credential Level with the next disbursement record. Again, as fiduciaries, participating institutions are always expected to exercise care and diligence in accounting to the Department for the funds received under federal student aid programs.
Please note that if a disbursement is associated with multiple programs that use different credential levels, the institution should report the credential level associated with the program in which the student is primarily enrolled and report the CIP Code associated with that credential level in the first CIP Code position when submitting the record to COD.
Resources and Training Materials
The Department has provided various informational resources on the FVT/GE requirements, and we encourage institutions to review those materials as they prepare to complete the Completers List and reporting processes. These materials are available on the Financial Value Transparency and Gainful Employment Information page on the FSA Partner Connect Knowledge Center, and include:
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Dear Colleague Letter GEN-24-04, which summarizes the regulatory requirements (updated September 16, 2024);
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NSLDS FVT/GE Supplemental Training Resource, published November 6, 2024;
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Electronic Announcement GE-24-04, which describes the NSLDS reports schools will use to identify the programs and students for which the Department expects reporting to be completed (updated November 1, 2024);
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Electronic Announcement GE-24-09, which describes the process for evaluating Completers Lists (published October 25, 2024);
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Electronic Announcement GE-24-06, which describes the reporting process (updated September 16, 2024);
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the NSLDS Financial Value Transparency and Gainful Employment (FVT/GE) User Guide, which provides comprehensive information about the process for evaluating Completers Lists, and reporting data (updated October 30, 2024);
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Frequently Asked Questions (updated October 29, 2024); and
There is a recorded training webinar entitled How to Report FVT/GE Data to NSLDS that may be viewed on the FSA Training website. You will need to log in to view this webinar.
There will also be a session on the FVT/GE reporting and Completers List requirements at the 2024 Federal Student Aid Training Conference on December 3 – 6, 2024. The session is entitled BO20: Get the Information You Need on Financial Value Transparency and Gainful Employment (FVT/GE) Reporting.
Note: On September 13, the Department had announced we would create an opt-in opportunity for a limited number of schools to provide their reporting this fall and obtain results sooner. As the Department has continued to implement the FVT/GE regulations, we have determined that in lieu of this previously mentioned opportunity we will instead reach out to institutions as they report their data to obtain feedback and troubleshoot any issues with the reporting process. When the Department announces results, all institutions will receive data on their metrics at the same time.
Contact Information
For operational questions about FVT/GE, please contact GEOperations@ed.gov.
For technical questions about using the NSLDS system to complete FVT/GE reporting, please contact the NSLDS Customer Support Center at 1-800-999-8219 or nslds@ed.gov.
For policy questions about the FVT/GE regulations, please email GE24@ed.gov.
