Schools that do not have any academic programs subject to gainful employment regulations must report that fact to the U.S. Department of Education (ED) by Oct. 1, 2011. NASFAA staff have confirmed this guidance with ED.
Some schools mistakenly believe that gainful employment regulations do not apply to any of their programs. Gainful employment rules apply to all non-degree programs at both the undergraduate and graduate level, including certificate programs, offered by public and non-profit institutions and virtually all academic programs offered by proprietary institutions. ED estimates that 5,000 out of the 6,000 Title IV-participating schools have at least one program subject to gainful employment rules (GE program). For assistance in determining if a program is a GE program, see Gainful Employment electronic announcement #11.
By requiring schools to report that they do not have any GE programs, ED is prompting schools to make a thorough assessment of their programs. If a school reports that it has no GE programs, and ED records indicate otherwise, ED staff will be contacting that school to help it comply with the reporting regulations by Nov. 15, 2011. If a school does not report that it has no GE programs, and does not report GE program information by Nov. 15, ED staff will contact that school to determine if GE reporting is required. By that time, the school will be out of compliance if it was required to report on GE programs by Nov. 15.
Publication Date: 9/30/2011