Gainful Employment & Financial Value Transparency FAQs


Last Updated:
June 3, 2024

Legislation

What is the Gainful Employment (GE) and Financial Value Transparency (FVT) Act?

It is new legislation enacted to create a transparency and accountability framework by which the Department of Education (ED) can assess “whether career programs meet the statutory requirement of preparing students for gainful employment in a recognized occupation.” Per ED’s fact sheet:

“Under the GE program accountability framework, the Department [of Education] 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 and a new earnings premium test.”

The Financial Value Transparency (FVT) scope expands reporting requirements well beyond those programs identified as Gainful Employment (GE) programs. Under the July 1, 2024, regulation, institutions will be required to report all programs that share the same four-digit CIP code and have had 30 or more completers in total over the four most recent award years for both GE and non-GE programs. This includes the total number of recipients and non-recipients of Title IV and HEA funds enrolled in the program as well as student-level data for all recipients of Title IV and HEA funds. These reporting requirements are a significant expansion over the 2014 GE regulations that were rescinded July 1, 2019.

What is the difference between the GE and FVT regulations?

Per Federal Student Aid (FSA) in its FSA Dear Colleague Letter (GEN-24-04):

“The FVT regulations are designed to improve the quality and availability of information provided directly to students about the costs, sources of financial aid, and outcomes of students enrolled in all title IV, HEA (Title IV) eligible programs. These regulations establish two measures: the debt-to-earnings measure and the earnings premium measure. The regulations also establish performance benchmarks for each measure to determine whether the program may have adverse financial consequences to students. These requirements apply to both Gainful Employment Programs (GE Programs) and Eligible Non-GE Programs, but do not affect program eligibility for Non-GE programs.

The GE regulations establish an accountability framework for GE Programs that uses the same earnings premium and debt-to-earnings measures to determine whether a GE program remains eligible for Title IV funds. These requirements can affect program eligibility and apply only to GE Programs. The GE regulations do not apply to Eligible Non-GE Programs.”

Where are the federal regulations for GE and FVT?

How does GE/FVT impact my institution?

Even if your institution does not offer ANY programs classified as GE-eligible under the new regulations, you must report any non-GE programs and the students attending those programs, including all recipients of Title IV and HEA funds. Essentially, this means that nearly EVERY participating Clearinghouse institution will be impacted by the GE/FVT legislation reporting requirements and should anticipate having to meet the reporting requirements by the October 1, 2024, deadline.

The GE/FVT act requires institutions to report extensive financial aid and institutional cost data elements during a time when they have no resources to spare to build and support complex new compliance processes. As your partner, the Clearinghouse is committed to alleviating your administrative burden for complying with the GE/FVT reporting requirements through a new and free solution that will enable low-effort data submission/extraction, data access, benchmarking, evaluation, and outcomes reporting.

The Clearinghouse’s Free Solution

What will the Clearinghouse’s free GE/FVT reporting solution include?

  • Data Identification and Augmentation: Using enrollment and degree data from your institution and NSLDS, we will expertly identify your institution’s student groups. Then deploying a validated process that examines 20 years of enrollment and financial aid history, with unparalleled accuracy, the Clearinghouse will add students to your institution’s standard or transitional cohort file (see “What information do I need to report for GE/FVT?”) and, starting with the first reporting due by October 2025, your annual cohort file (see “How do the standard, transitional, and annual cohort reporting options differ?”).
  • Data Streamlining, Integrity, and Accuracy: With the assistance of your institution’s GE/FVT contact, we will complete the validation and data augmentation process. In addition, we will ensure your data passes a robust series of validations to prevent records from being rejected downstream by NSLDS.
  • Data Streamlining, Augmenting, and Access Provisioning: Your institution will be able to easily access and update your Completers List, including adding students who graduated from your institution during the cohort period but were not captured in the original NSLDS dataset. Through a user-friendly and dynamic interface on our secure site, your institution officials can confidently review and update your Completers List until they are satisfied that it is accurate and complete BEFORE the final list is provided to the NSLDS, so it can calculate the debt-to-earnings and earnings premium measures. This feature ensures your institution’s reporting is as up-to-date and accurate as possible before the debt-to-earnings calculations are determined.

When will the Clearinghouse’s free GE/FVT reporting solution be available?

Our new free GE/FVT reporting solution will be available July 2024. As we get closer, we will share information on how you can sign up for our solution.

How can my institution get involved in the Clearinghouse’s free GE/FVT reporting solution?

If you would like to support the Clearinghouse’s free GE/FVT reporting solution by providing insight, user acceptance testing assistance, or other feedback, please email us at auditresource@studentclearinghouse.org. (Thank you in advance for your help!)

GE/FVT Programs

What is an eligible program?

An eligible program is one that qualifies for federal aid (Title IV, HEA, including considerations for federal grants) and leads to an associate, bachelor’s, professional, or graduate degree. 34 CFR 668.8 provides specific details about program eligibility qualifiers, including the minimum length of instruction to qualify.

What is an ineligible program?

A program that does not qualify for federal aid.

What is a GE program?

Per Federal Student Aid (FSA) in its FSA Dear Colleague Letter (GEN-24-04):

“All nondegree programs (e.g., certificate programs, diploma programs) that lead to recognized credentials at public and private nonprofit institutions are GE Programs except for CTP programs and prison education programs.

All educational programs offered by for-profit (proprietary) institutions are GE Programs except for CTP programs and a limited number of bachelor’s degree programs in liberal arts if the institution has been regionally accredited since October 2007 and the program has been offered by the institution since January 2009 under 34 CFR 600.5(a)(5)(i)(B). These bachelor’s degree programs in the liberal arts offered by proprietary institutions are Eligible Non-GE Programs, but are not GE Programs.

Some institutions offer degree programs where students may also be awarded a non-degree credential (e.g., certificate, diploma) after completing a portion of the degree program. Such programs are generally not considered GE Programs at non-profit and public institutions. However, a program where a significant number of the students enrolled in the program do not actually earn the degree and withdraw after obtaining the certificate may be, upon review, determined to be a non-degree program. In that case, the certificate program would then be considered a separate GE Program.”

What is a non-GE program?

Per Federal Student Aid (FSA) in its FSA Dear Colleague Letter (GEN-24-04):

“Eligible Non-GE Programs include all Title IV eligible programs, including degree programs, at public, private non-profit, and proprietary institutions, with the exceptions described above.”

Which programs must be included in FVT reporting?

Eligible GE programs and non-GE programs.

How do I determine if any of my school’s graduate-level programs qualify as graduate programs for GE reporting?

According to page 5 of the NSLDS Financial Value Transparency and Gainful Employment (FVT/GE) User Guide:

“A qualifying graduate program is a program whose students must complete required postgraduation training programs to obtain licensure to practice in the field. Such programs must be accredited by an agency that meets State requirements if a State has such requirements for licensure. In order to be considered a qualifying graduate program, at least half of a program’s graduates must obtain licensure in a State where the postgraduation training requirements apply. Refer to the GEN-24-04 Regulatory Requirements for Financial Value Transparency and Gainful Employment for more information.”

What is a completer?

A student who graduated from the program. Completers are not withdrawn students.

Reporting GE/FVT Data

What information do I need to report for GE/FVT?

  1. You will be required to report a program-level data file containing general information on the programs your institution offers, including the number of students in the program and whether or not it is a qualifying graduate or undergraduate program.
  2. You will also need to report student-level information containing detailed information on the students who attended your programs, such as enrollment status(s) for each award year, tuition cost, cost of books and supplies, grants and scholarships, private education loans, residency status, etc.

You can report student-level information using one of these two options:

    1. Standard cohort file: Seven years of undergraduate data and eight years of graduate data
    2. Transitional file: The last two years of data for both undergraduates and graduates.

How do the standard, transitional, and annual cohort reporting options differ?

  • Standard Cohort: The initial standard cohort file includes seven years of undergraduate and eight years of graduate student information. This data is used by NSLDS to calculate the debt-to-earnings rates and earnings premium measures for your institution and determine the median debt for the reported period.
  • Transitional Cohort: If your institution elects to submit the transitional cohort, the data used to calculate the debt-to-earnings rates and earnings premium measures will be determined by 1) the median debt for the most recently completed two-year award period and 2) earnings across the standard cohort period of data. As a result, your students’ median earnings data will be based on students who graduated from 2017-2018 and 2018-2019 (for programs with 30 or more completers in a 2-year period), or 2015-2016, 2016-2017, 2017-2018, and 2018-2019 (for programs with 30 or more completers when the 4 years must be leveraged), while their debt will be based on the most recent two-year period of data provided by your institution.

Although the transitional cohort requires less data and therefore places less overall burden on your institution, you should be aware that if your institutional cost and/or the cost of books/supplies increased in the past six years, both the calculation and how it affects your institution may be impacted given its comparison to earnings over the six-year cohort.

  • Annual Cohort: Starting October 2025, your institution will be responsible for reporting the most recent award year of data for your programs and students, including all fields that were reported in the initial standard or transitional cohort file.

Will we report GE/FVT data as part of our existing Enrollment Reporting transmission or will it be separate?

The Clearinghouse will offer an augmented supplemental process for institutions to use to provide us with their standard and transitional reporting in compliance with the October 1st deadline. This approach will 1) mitigate the burden on institutional IT teams to implement the needed student informational system (SIS) changes and 2) provide institutions with additional reporting flexibility so they can provide the new data elements and discrepancy resolutions to the Clearinghouse. Going forward, the Clearinghouse will collaborate with all major SIS vendors to determine how institutions can best integrate the additional data elements into their reporting processes.

How to Stay Informed

How can I stay updated on GE/FVT and the Clearinghouse’s free GE/FVT reporting solution?

Bookmark our Gainful Employment and Financial Value Transparency resource center page! It will be regularly updated with the latest information on our solution and how institutions should prepare to report GE/FVT data as well as the regulatory landscape. We will also share information on how you can sign up for our exciting new reporting solution and how we plan to continue to modernize our Enrollment Reporting platform to best support your institution through GE/FVT and beyond. We’ll also update this FAQs page as we obtain additional clarity from Federal Student Aid (FSA) on GE/FVT technical requirements and specifications, including the file layout and data element definitions.

In addition, the Clearinghouse is holding free GE/FVT webinars and providing updates on Compliance Central. You can check our Enrollment Reporting & Compliance events calendar to sign up for our live webinars and visit the Clearinghouse Academy to watch our on-demand webinars. Don’t forget to subscribe to Compliance Central to receive our latest compliance and Enrollment Reporting updates.

Was this article helpful?