Gainful Employment - Overview

Rhonda Mohr, Student Financial Assistance Programs

Myrna Huffman, Management Information Systems

Agenda

• How did we get here?• Gainful Employment Defined• Disclosure Requirements• New GE Programs • Reporting Requirements• Questions

Federal Title IV Regulatory Process

• Negotiated Rulemaking -November 2009 through January 2010

• Notice of Proposed Rulemaking (NPRM) -June 18, 2010• Notice of Proposed Rulemaking (NPRM) -July 26, 2010• Two sets of Final Rules published on October 29, 2010,

with effective dates of July 1, 2011– Program Integrity –Including Gainful Employment

Reporting and Disclosures– Gainful Employment –New Programs

• Final Rules on metrics – unofficial draft published June 2, 2011

Federal Government Communications• CCCSFAAA Conference – December 2010• Regional Training Events – Winter 2011• DCL Gen 11-10 issued April 20, 2011• May 25/26 webinars announced May 5, 2011• GE Webpage announced May 12, 2011• DCL Gen 11-10 correction issued May 20, 2011• GE Reporting Draft User Guide issued May 23, 2011• Webinar training May 25-26, 2011• New GE Programs guidance June 1, 2011• Updated GE Reporting User Guide issued June 3, 2011

CCCCO Communications

• August 2, 2010 – NPRM Comments• September 9, 2010 – NPRM Comments• February 7, 2011 – FA Regional Representatives Meeting• March 15-16, 2011 – All FA Directors Meeting• April 27, 2011 – CFAO list serve memo• May 16, 2011 – FA Regional Representatives Meeting• June 2, 2011 – Letter from Linda Michalowski and Patrick

Perry• June 7, 2011 – CFAO/CSSO list serve memo

Gainful Employment Statute• An educational program is Title IV eligible only if

the program:– Is offered by a public or non-profit institution

and leads to a degree or transfer; or– Is offered at any institution and “leads to

gainful employment in a recognized occupation”.• Referred to as a Gainful Employment

Program or a GE Program.

Recognized Occupation

• One identified by a Standard Occupational Classification (SOC) code established by OMB; or

• One identified by an Occupational Network O*NET-SOC code established by the U.S. Department of Labor; or

• One determined by the Secretary of Education in consultation with the Secretary of Labor.

Gainful Employment Programs • Public institutions and not-for-profit

institutions –– All programs, except for –

• Programs that lead to a degree;• Programs of at least two years in length that

are fully transferable to a bachelor’s degree program; and

• Preparatory course work necessary for enrollment in an eligible program.

Gainful Employment Programs

• A Gainful Employment Program is identified by its:– 6 digit OPEID– 6 digit CIP Code (Classification of Instructional

Program)– 2 digit Credential Level

• New Programs = new CIP Code or new 01 credential level

Credential Levels

• 01 = Undergraduate certificate• 02 = Associate’s degree• 03 = Bachelor’s degree• 04 = Post baccalaureate certificate• 05 = Master’s degree• 06 = Doctoral degree• 07 = First-professional degree

Disclosures

Gainful Employment Disclosures-General

• For each GE Program, institution must provide prospective students with specific information.

• Effective July 1, 2011• Institution must use disclosure form provided by the

Department, when available.– Will not be available by July 1, 2011– Draft form is available and may be used now

• Institutions must comply with these disclosure requirements independently until form is available

Annual Disclosure Requirement

• July 1, 2011 – may use 2009-10 data to calculate metrics

• Update with 2010-11 data within a “reasonable amount of time”

• Annual updates to be completed within a “reasonable amount of time” after each subsequent award year

Disclosures

• Disclose for each GE Program:– Occupations (by name and SOC code) that program

prepares students to enter– Links to occupational profiles on O*NET– Program costs – for entire program in normal

completion time• Tuition and fees • On-campus room and board• Books and supplies• May include other costs

• Disclose for each GE Program:– On-time completion rate

• Number of students who completed program during most recently completed award year for which information is available

• Number of students who completed within “normal time”

– Not the same as 150% used for other purposes– As published by institution

Disclosures

Normal Time Frame Defined• Time necessary to complete all requirements

according to college catalog• “Typically two years for an AA degree and

various for certificate programs”• Must be time based• Transfer students get full “normal time”• Program changes do not adjust “normal time”

– To be counted as completing on time, a student who changes programs at the institution and begins attending a new program must complete within the timeframe beginning from the date the student began attending the prior program

Disclosures

• Disclose for each GE Program:– Median loan debt incurred by students who

complete the program• Title IV loan debt –Amount borrowed • Private educational loan debt –Amount

borrowed • Institutional finance plans – Amount owed

Disclosures

• Disclose for each GE Program:– Job placement rates for students completing the

program using the NCES methodology• NCES methodology not ready at this time• Until then use formula that the institutional

accreditor, program accreditor, or the state requires

• Not required for CCCs at this time

Web Disclosures• Disclosure Information on Program’s website

home page– Each GE Program must have a dedicated page

• Must be simple and meaningful• Must contain direct links to any other webpage

with general, academic or admission information about the program

• Must be in an open format that can be retrieved, downloaded, indexed, and searched by commonly used web search applications

Print Media Disclosures• Catalogs and Schedules – complete disclosures “whenever

feasible” • If not feasible because of size or structure must include URL

or live link to website– Postcards, flyers, brochures, etc– Example: “For more information about our graduation

rates, the median debt of students who completed the program, and other important information, please visit our website at www.ABCcollege.program”

• Print materials must be revised within a reasonable amount of time–

New GE Programs

New Programs-Timelines

• If the first day of class will begin on or after July 1, 2011 and before October 1, 2011, notification must be provided no later than July 1, 2011. – If the institution does not provide the required notification by July

1, 2011, it must wait for Departmental approval before disbursing funds to students enrolled in the new GE Program. The institution must also inform students that the program has not been approved by the Department to be eligible for federal student aid.

• For new GE Programs where the first day of class will begin on or after October 1, 2011, institutions must provide notification to the Department at least 90 days prior to the first day of class.

• An institution that provided notice of a new GE Program at least 90 days before the first day of class (or July 1, 2011 if applicable) of that new program may begin offering the additional program without receiving Departmental approval unless the Department requests, at least 30 days prior to the date the program is scheduled to begin, additional information or otherwise informs the institution to delay the start of the additional program.

New Programs - Notifications• Must include sufficient narrative information to

demonstrate that the program meets the requirements of an eligible GE Program and to support the need for the program– How need of program was determined– How college became aware of need of program– How the program was designed to meet market needs– Wage analysis and wage data related to the new program– Consultation processes with external entities

• Can cover multiple programs if same or similar process used

Reporting

Gainful Employment Reporting Requirements• Institution must annually report information on

students who were enrolled in a GE program for each award year –– Student identifying information– Program identifying information– Amounts from private education loans – Amount owed on institutional financing plans– Enrollment information

• The GE data User Guide is available and being reviewed by CCCCO

Reporting Requirements

• By October 1, 2011 all colleges must report:– 2006-2007, 2007-2008, 2008-2009, 2009-2010, and

2010-11 award year information• If unable to report any of the required information,

institution must provide an explanation. Explanation sent to GE-Missing-Data@ed.gov.

• Annual data submissions are due on each October 1st for subsequent years

Resources• GE webpage on IFAPhttp://ifap.ed.gov/GainfulEmploymentInfo/index.html

• For GE QuestionsGE-Questions@ed.gov • CCCCO• rmohr@cccco.edu• mhuffman@cccco.edu