By Michael T. Wherry, CPA
The Department of Education (ED) simplified parts of the 2019 Gainful Employment Disclosure Template, with ED outlining the changes in a May announcement (Gainful Employment Electronic Announcement #119). In the weeks leading up to the July 1 deadline to comply with the changes, ED also gave institutions some important clarity and leeway on the new template.
Perhaps most importantly, ED eliminated the staggered completion cohorts based upon program length and student start year. This year, an institution can base the median loan debt calculation on Title IV students who completed the program within 100% of normal time during the most recently completed award year (2017/2018).
However, ED indicated in a guidance document (Gainful Employment Electronic Announcement #121) released on June 7, 2019, that an institution could use the same cohort methodology as in previous disclosures with the start year advanced forward by one year. While ED believes the elimination of the staggered completion cohort is a simplification, it acknowledged that the reprogramming of data systems at this point in time might be overly burdensome and thus the option to utilize the prior year methodology with the start year advanced forward by one year was allowed.
Streamlining was the theme for the 2019 template, with ED aiming to reduce administrative burden while still providing relevant program information for prospective or enrolled Title IV students. For instance, the new template is not a web-based application but a text-based document that can be updated for each program before being posted to their respective websites in the format that works best for them.
Completing the GEDT
Read on for a brief guide to the new template before the deadline to comply arrives (You can find the new template here).
- Length of the program: Provide the normal length of time to complete the program in whole numbers, indicating if it is in weeks, months or years, as published in your institutional catalog or other publications.
- Total program costs: This is the current or future projected costs for the normal time to complete the program, including tuition and fees, books, supplies and equipment. Exclude room and board or other expenses from the calculation.
- Median cumulative debt: This is the median debt for all students who received Title IV aid at any point during attendance in the program, including private, institutional and federal student debt. As we discussed earlier, this calculation was simplified for 2019, but schools have the option to use the 2018 method. An institution should use the methodology which is easiest for their student information system to compute. This is how they differ:
2018: Institutions must use the start year, not the completion year, of Title IV students who began the program during the given award year and completed it within 100% of normal time. It becomes more complicated to calculate because on-time completers may have different completion years, depending on what time of the award year they started and the pace at which they completed.
2019: Staggered completion cohorts based on program length and student start year are eliminated. Institutions can base calculations on Title IV students who completed the program within 100% of normal time during the most recently completed award year (2017-2018).
Small/new programs: Gainful employment (GE) disclosures are required for all programs, but according to the guidance, if a program is too new to have any completers or has fewer than 10 Title IV aid completers, they should not list a median debt amount. An institution should use similar language as the 2018 template: “Fewer than 10 students completed this program within normal time. This number has been withheld to preserve the confidentiality of the students.”
- Licensure information: Using five prepared statements in the template, provide information on whether a program does or does not meet licensure requirements for states in the metropolitan statistical area of the institution, as well as states for which the institution is aware of whether the program satisfies education prerequisites to qualify a student for licensure. Not all of the statements may apply to the given program.
- College Scorecard URL: It is mandatory to include the introductory language and link to the College Scorecard, which are already provided in the template. Even if a program is not currently listed in the scorecard, the ED guidance said the list has been recently expanded and is expected to expand further in the future.
- Warning language: If a program’s final Debt-to-Earnings Rate failed ED standards, include the prepared language provided in the template that describes the repercussions, specifically that students may not be able to use financial aid for the program. This is only if the program fails the standards.
Providing the GEDT
A 2018 notice in the Federal Register required institutions to comply with two Gainful Employment disclosure regulations related to promoting and distributing the GEDT. As noted in Gainful Employment Electronic Announcement #120, these disclosures were delayed until July 1, 2019 and no further delay has been granted by ED. Thus, Institutions must also comply with these disclosure requirements by July 1,2019.
- Promotional materials: All promotional materials that mention a GE program by name or otherwise promote it must display the disclosure in a prominent manner or, lacking airtime or space, identify a link the URL or link to the information. Promotional materials include catalogs, invitations, flyers, billboards and advertisements.
- Direct distribution: Before prospective students sign an enrollment agreement, complete registration or make a financial commitment to an institution, the disclosure must be provided to them as a separate document. This can be hand-delivered to the student or third-party individually or as part of a group presentation, or it can be emailed to a primary email address. In either situation, the institution must receive written or electronic confirmation that the message was received.
These disclosures are vital for institutions and students, and the professionals at McClintock & Associates understand that completing and distributing them properly can be a challenge when regulations change. We’re here to help, so please reach out if you have any questions.