THE GAINFUL EMPLOYMENT DANCE – or, Understanding the Distinction between Disclosure and Reporting Requirements

Those who dance understand that there are a number of specific aspects in being a great dancer.  One is confidence in knowing what steps are appropriate for the music being played.  This characteristic is also important when considering the gainful employment (GE) regulations.  It cannot be considered a truism that those who have responsibility for GE compliance on their campus must be great dancers, or that great dancers would make exceptional employees to work with the GE regulations.  However, the characteristic noted about dancers is also important for those working to comply with the GE regulations.

When working with GE, it is important to be confident in the appropriate steps or requirements.  In the GE Dance, the proper steps include both disclosure and reporting requirements as put forth by the US Department of Education (ED).  While the regulations have been out for a while now, and a number of efforts have been made to distinguish the difference between the requirements related to disclosure and those related to reporting, there still seems to be a bit of stumbling in the dance. People remain uncertain of what moves constitute the correct steps.  In choreographing the GE Dance, we will address the two components of disclosing and reporting.

Key Factors in Gainful Employment Disclosures

The requirement for GE disclosures is for the purpose of ensuring the public is aware of information that is pertinent to the GE programs at your particular institution.  This is so they may make informed choices related to education options.  The information in the regulations at 34 CFR 668.412 that is deemed to be necessary for disclosure includes:

• The occupations that the program prepares students to enter (by occupation name and SOC code), with links to occupational profiles on the O*NET website;
• The program length (the normal time to complete the program);
• The on-time graduation rate for students completing the program (whether full-time or part-time);
• The tuition and fees the school charges a student for completing the entire program within normal time, the cost of room and board if applicable, and the typical costs for books and supplies (unless those costs are included as part of tuition and fees);
• The job placement rate for students completing the program if placement rate calculations are required by your state or accrediting agency;
• The median loan debt incurred by students who completed the program (separately by Federal Student Aid loans, private educational loans, and institutional financing plans); and
• Other information ED provides to the school about the program (e.g., the mean or median earnings of program completers and those who withdrew, the most recent cohort default rate, loan repayment rate, annual earnings rate, etc.).

In addition to the above list, the GE disclosure information requires the dissemination of the number of clock or credit hours (or the equivalent, as applicable) in the program, the total number of individuals in the program during the most recently completed award year, and the percentage of students in the program who received a Federal or private education loan for the program.  Some of this information may also be published in the school’s catalog or elsewhere.  Further, the school is required to disclose whether the GE program is programmatically accredited, and if so, the name of the accrediting agency.  Also, the school must link its Web site to ED’s College Navigator Web site.

The process of disclosing information to comply with the GE regulations is primarily accomplished through the use of ED’s Gainful Employment Disclosure Template (GEDT).  This template provides the method and format for consolidating the information delineated above.  ED is required to update its template on an annual basis.  Schools must then update their GE information each year through use of the GEDT.  This is typically required to be completed by January 31 of each year utilizing data for the most recently completed award year.  For example, in January 2016, schools will disclose data for the 2014-2015 award year.  To assist schools in understanding the information necessary to complete the GEDT, ED also provides a GEDT Quick Start Guide.  It is available in two different versions, depending upon the Web browser utilized.  Links to the applicable version for your use are available at ED’s GEDT Information Page at https://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html.

Key Concepts in Gainful Employment Reporting

A point of confusion arises for some individuals when they think of the effort expended to comply with the disclosure of GE information, which we just highlighted above.  That effort, and the information submitted, is sometimes referred to as having “reported” information to ED.  But, the reality is that the above process just discussed is not reporting, but the process of “disclosing” information.  Perhaps one way to think of it is that disclosure is providing information to the public (even though it is done with ED’s GEDT).  Reporting is the submission of required data on individual students to ED for statistical purposes, e.g., calculation of Debt-to-Earnings (D/E) rates, and so forth.  Therefore, GE reporting is a separate process altogether.

The basic information that is collected through the GE reporting process is stipulated in 34 CFR 668.411.  Reporting is comprised of providing:

For each Title IV recipient enrolled in a GE program—

• The name, CIP code, credential level, and length of the program;
• The date the student initially enrolled in the program;
• The student’s attendance dates and attendance status (e.g., enrolled, withdrawn, or completed) in the program during the award year; and,
• The student’s enrollment status (e.g., full-time, three-quarter time, half-time, less than half-time) as of the first day of the student’s enrollment in the program;

For students who completed or withdrew from the GE program during the award year—

• The date the student completed or withdrew from the program;
• The total amount the student received from private education loans for enrollment in the program that the institution is, or should reasonably be, aware of;
• The total amount of institutional debt the student owes any party after completing or withdrawing from the program;
• The total amount of tuition and fees assessed the student for the student’s entire program; and
• The total amount of the allowances for books, supplies, and equipment included in the student’s Cost of Attendance (COA) for each award year in which the student was enrolled in the program, or a higher amount if assessed the student by the institution;
• A placement rate for the program (if required to calculate a placement rate for the school and/or program by the school’s accrediting agency or State) and the name of the accrediting agency and/or State that required the calculation.  The rate is to be calculated using the methodology required by the accrediting agency or State, as applicable; and,
• Any other information ED requires an institution to report, as described in a notice published by ED in the Federal Register.

GE reporting is accomplished through either batch reporting to NSLDS by uploading data provided by your school’s software (for example, a third-party software such as FAME’s Freedom), use of ED’s Gainful Employment Spreadsheet Submittal template, or by direct data input into the NSLDS Professional Access Web site (NSLDSFAP). This process of reporting GE data is in contrast to that described earlier where disclosure of GE information is accomplished only through the GEDT.

Key Comparisons in the Components of the GE Dance

Since confusion has continued to surface regarding the understanding of the distinction between disclosure requirements and reporting requirements, we will compare the two in more detail, side by side.  The following table provides—as can be the case in a choreographed group dance—the counterpoint of each GE component.  Both are related, but different, in emphasis and purpose.  The table will assist in a visual display of each requirement’s distinctive aspects.

Distinctive Aspects of Gainful Employment Requirements – Table 1

Comparative Item	Disclosures	Reporting
Students Included in Data	All students enrolled in the GE program	Only students in the GE program who received Title IV aid
Loan Program Information Provided1	Title IV and Private Loan information, as well as institutional financing plans are included	Title IV loans, Private loans, and the student’s institutional debt information are reported
Data Timeframe	January 31	October 12
Data Submission	Through GEDT	Through NSLDS
Method of Data Submission	GE Disclosure Template only	GE Spreadsheet Submittal Template; direct online data input via NSLDS; or, batch file available from 3rd Party software
Data Provided	Resides at School on School’s Computer/Web site	Submitted to ED
Data Usage	Public uses data for informed education decision-making	ED uses to calculate D/E rates, Loan Repayment Rates, etc.