ED Releases Gainful Employment Disclosure Template

By Karen McCarthy, Policy & Federal Relations Staff 

The gainful employment (GE) disclosure template has been released by the Department of Education (ED), and schools must, no later than January 31, 2014, use the output document produced from the GE Disclosure Template to meet the currently effective GE disclosure regulatory requirements, according to ED’s electronic announcement.

As ED announced in Gainful Employment Electronic Announcement # 39, on June 30, 2012, the U.S. District Court for the District of Columbia, in Association of Private Sector Colleges and Universities (APSCU) v. Duncan, issued a decision that vacated several of the provisions in the GE regulations that ED published on October 29, 2010 and June 13, 2011.  The Court did not vacate the GE disclosure regulations at 34 CFR 668.6(b).  Those requirements are still in place.  

Until the template was made available, schools could use any format to make the required GE disclosures. Now that ED’s template is available, schools must use it to provide all of the required GE disclosures. 

At the FSA conference next week, ED will be offering a session titled “Gainful Employment Disclosures and Template Demonstration.”

Note that the gainful employment negotiated rulemaking that is underway now may make changes to the required GE disclosures, and therefore, ED’s disclosure template. The regulations under negotiation now will not be effective until July 1, 2015, at the earliest. 



Publication Date: 11/26/2013

Jeff A | 11/26/2013 9:34:29 AM

Of what value are these disclosures? Usually a prospect is considering the same (or similar) program at a handful of colleges in their community, but often only one college will be required to use this disclosure. How does that help? It is meaningless when a few colleges don't have the information available. There is no point of comparison. When asked, an admissions counselor can easily say, 'We don't have all of this data available, but our data is certainly better than that.'

Heather B | 11/26/2013 8:34:03 AM

I looked at the template yesterday. If you have fewer than 10 graduates in the program, there is an option to check a box and not disclose median loan debt. There is not, however, such a box for the on-time completion rate, which I believe is also not disclosed with fewer than 10 graduates. I called the template hotline number and am awaiting a response.

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