NASFAA Supports NPRM Changing Requirements on New Gainful Employment Programs(2)

NASFAA supports the Department of Education’s (ED) proposed changes to the requirements related to new gainful employment programs and appreciates ED’s efforts to reduce administrative burden wherever possible, NASFAA President Justin Draeger wrote in official comments submitted on Nov. 14.

Final rules published on Oct. 29, 2010 included requirements for institutions to notify ED before offering a new educational program that provides training leading to gainful employment in a recognized occupation (gainful employment program). Through this notification process, ED may advise an institution that it must obtain approval to establish the Title IV eligibility of an additional gainful employment program.

ED established the notification requirement out of concern that some institutions might attempt to circumvent the proposed gainful employment standards by adding new programs before those standards could take effect. The notification process requirements, referred to as "interim requirements," were intended to remain in effect until the final regulations would take effect.

Once the debt measures go into effect on July 1, 2013, ED doesn’t believe that it will be necessary for schools to notify ED of all new gainful employment programs. The proposed rules establish a smaller group of gainful employment programs for which an institution must obtain approval from the Department. ED believes that the proposed regulations will significantly reduce burden on institutions and ED while still ensuring the effectiveness of the established debt measures.