NASFAA Submits Comments on Gainful Employment NPRM

In comments submitted to ED yesterday, NASFAA supported fair, reasonable, and well-targeted regulations that ensure Title IV funding for programs that lead to gainful employment.

Among other issues, NASFAA commented that the proposed rules:

  • Provide insufficient regulatory accommodation for those GE programs that are considered low-risk, i.e, programs where the total number of borrowers or amount of debt is relatively low.
  • Include an extensive, complicated, and overwhelming list of 16 possible disclosure items, representing in total 36 possible data items due to possible disaggregations.
  • Lack a meaningful front-end approval process that would serve to protect students from risky programs before they assume unmanageable debt, rather than after.


Publication Date: 5/28/2014

John T | 5/28/2014 1:27:43 PM

I have enjoyed being a member of NASFAA but am disappointed int he comments on GE. For profit schools are no different than not for profit schools. We both recruit for students, we both educate and we both desire to have our revenues exceed our expenses. The drafter of the GE regulations stated that a for profit school has a different incentive - for the owner to make more money and be paid a high salary. First that is a general statement and does not apply to all and second I do not know of a for profit school owner that makes $5,000,000 like the coaches in not for profit institutions. It is discriminatory in appliance and in fact.

Cynthia B | 5/28/2014 10:41:42 AM

Thank you for your representation of institutions affected by the proposed rules on GE. I manage a large community college district financial aid department that will suffer greatly from the affects of these proposed rules, should they take place. Hopefully, ED will take your comments under serious consideration, otherwise my district will assume burdensome regulations that could take time away from serving our student population.

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