NASFAA Provides Helpful Reminders For Gainful Employment Reporting
By Joan Berkes, Policy & Federal Relations Staff
Gainful employment (GE) reporting continues to raise questions as schools work their way through new GE functionalities in NSLDS. Here are a few reminders based on inquiries NASFAA has received in response to a previous article.
Reporting Enrollment for Summer Cross-over Sessions
Remember that schools must report a student’s presence on an award year basis, as the award year runs on the calendar (i.e., July 1 through June 30). If a student was enrolled in a summer session that crossed over July 1, you must report the appropriate enrollment dates in both award years. The year to which you assigned summer for Title IV payment purposes does not play a role in GE reporting. The student must appear in the GE reporting records on NSLDS as enrolled in his or her program of study in both award years.
For example, a student attended a session that ran from June 20, 2013, through August 2, 2013. You must report the student’s attendance in the June 20 through June 30 portion of the summer session under the 2012-13 award year, and the July 1 through August 2 portion under the 2013-14 award year. It does not matter whether you treated the summer cross-over period as a trailer assigned to the 2012-13 award year or as a header assigned to the 2013-14 award year.
GE Program Had No Enrolled Title IV Recipients
A GE program listed on a school’s PPA that had no Title IV students in attendance during an award year does not have to appear in the NSLDS GE program list for that year. If the program does show up on the list, you need to go to program tracking and indicate that you had no Title IV students in that award year by changing the program status to I2, “No students enrolled in GE program.” (“Student” for this purpose means someone who received Title IV funds.)
Active GE Program for Which Data Was Reported Does Not Appear on the Program List
First, check that when you ran the program list, you had the filters for “Reported by COD” and “Reported by GE” set to “All” to avoid excluding programs from the listing inadvertently. Also, you can search on one of the students in that program to see if his or her data is there.
If you used the batch method to submit data, you should have gotten an error/acknowledgment file. If you did not, something went awry with your submission. If you submitted data online using the spreadsheet, no error/acknowledgment file is generated because errors would have to be fixed before submission is allowed. In that case, you can contact [email protected].
Note that if you submit the missing records again and they duplicate what NSLDS did in fact receive, NSLDS would deactivate the original submitted records and no other action is required.
Reporting for the 2007-08 Award Year
Schools should report data for the 2007-08 award year only for GE programs that have a required medical or dental internship or residency. ED will not use the 2007-08 award year to generate missing data letters, because very few schools are required to report data for that year. Programs that do fall under this category (i.e., have medical/dental internships or residencies and are subject to gainful employment rules) will indicate “yes” in field code 13 in the GE Submittal File Detail Record, and must show a credential level of 06, 07, or 08 (Doctoral degree, first professional degree, or Graduate/Professional certificate). This issue mainly affects foreign medical schools.
Publication Date: 9/4/2015
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