By Joan Berkes, Policy & Federal Relations Staff

The deadline for reporting gainful employment (GE) data from 2008-09 through 2013-14 was July 31, 2015. Now that the initial flurry of reporting GE data under the new regulations is past, what are schools finding in the resultant records? And how can that help them for the next reporting deadline which is already looming: October 1, 2015 for award year 2014-15 data.

Note: If you missed the 7/31/15 deadline altogether, you need to complete your reporting as soon as possible. The Department of Education (ED) will be contacting presidents of non-respondent institutions, but in the meantime the National Student Loan Data System (NSLDS) is still accepting initial data reports as well as processing data corrections. Need help? See the NSLDS Gainful Employment User Guide. For help on reporting, contact the NSLDS Customer Support Center at 800-999-8219 or by email at [email protected].You may also email questions about gainful employment rules to [email protected]. Q&As related to the reporting requirement are posted on ED’s Gainful Employment FAQs webpage.

The reporting protocols inevitably give rise to opportunities for error, duplicate records, and conflicting information:

• A student who was enrolled in a GE program in more than one award year must be included in the reporting for each of those award years.
• A student in more than one GE program must be reported separately for each of those programs.
• A student who ‘stopped out’ and reentered the same program during the same award year must be reported separately for each separate instance of enrollment in the program.

In resolving questions about submitted data, it is also important to understand that:

• Records reported to NSLDS may be deactivated (individually or in groups) if loaded in error or if identifiers (which cannot be updated) are incorrect. Either the school or NSLDS can deactivate a record.
• An institution’s gainful employment programs may be listed in NSLDS as a result of the Common Origination and Disbursement (COD) system or Federal Student Aid (FSA) records, or institutional reporting of GE data.

We are aware of a couple of GE reporting issues, described below. You may want to check your own records to see if you have the same issues.

Have you encountered other problems or anomalies that your colleagues could benefit from hearing about? Please describe them in comments section below this article.

Deactivated records

One school discovered that some submitted records were deactivated by NSLDS. NSLDS told the school that this action was taken because the records appeared to be duplicates, and advised the school to review the deactivated records to be sure that the data should not have been different from the record which it duplicated.

Once deactivated, a record cannot be re-activated, even though it remains in the system in the deactivated status. Thus, if it was truly a different record for that student, the school must add it again with the correct data. This issue is likely to occur at other schools as well.

Conflicting Credential Level

Some schools reported a credential level that is different from NSLDS records obtained from COD (for example, undergraduate rather than graduate, or credential rather than associate degree). This conflict may be a result of error or miscommunication between offices on your campus when you gathered data, or it may indicate that the NSLDS record needs to be corrected.

Checking NSLDS Information

You can go into NSLDS to check your data, to see whether NSLDS made changes to that data, or to find out whether NSLDS expected to receive data for a program but did not. Detailed instructions are in the latest version of the NSLDS Gainful Employment User Guide.

Checking GE Program Status

You can see which of your programs ED believes are GE programs, and whether you have reported any data for them, by using the GE Program Tracking List. The tracking list will show which source reported a program as GE (COD, FSA, or your school). If the program was supplied to NSLDS by COD or FSA but not by the institution’s reporting of data, the school may need to either:

• Report GE student records for the program; or
• Update the status of the program as it appears in NSLDS records if it is designated as a GE program in error. The program status indicates whether the program is active, had no Title IV recipients enrolled, was ineligible for the year being reviewed, or is something “other” than those designations.

If the status reason is “other,” institutions are expected to supply additional information. Responses should be sent to [email protected] with “Not a GE Program – Other” in the subject line.

Checking Record Status

You can also obtain lists of students by their status, to see which records are active (i.e., the student was reported) and which were deactivated. You might want to check the deactivated status to find possible errors in reporting. NSLDS also allows you to pull the data you submitted back out of its records through the Gainful Employment Data Extract File Report – GENEX1. See Appendix B of the User Guide. 

Resolving Student Identifiers

The User Guide notes that data providers are not allowed to load information into NSLDS on two different students with the same SSN. ED conducts a matching process at the time data is initially processed for loading to NSLDS. If a student record is found to be already in NSLDS, and the identifiers provided by the entity attempting to load the record do not match what is currently in the database, the system will generate a SSN conflict error notifying the data providers that the SSN is in use by another student. In such cases, the institution must research the accuracy of the student identifiers provided in the GE data submission. This research may need to be conducted in conjunction with the data provider that supplied the initial set of information to NSLDS; the SSN Conflict page allows users to display a list of the data providers that previously reported on the SSN. 

Checking Data Submission Status

ED advises in its GE Q&As that when an institution sends a GE Submittal File using the batch process, NSLDS will return to the institution a GE Response Error / Acknowledgement file within 36 hours. Within 10 days, the institution must correct and resubmit records that have errors detected by NSLDS. If the institution does not receive a GE Response Error / Acknowledgement file after reporting data using the batch process, the information was either never received by NSLDS or it could not be processed. If that happens, the institution must determine the error and resubmit the file.

If the institution sends GE data using either the “GE Submittal Spreadsheet” or “Online” method instead of the batch process, errors will be noted and displayed. The institution must correct the errors before it can submit the file/record.

What’s Next? 

Under the regulations (sec. 668.405) that became effective July 1, 2015, ED will use the data reported to create a list of the students who completed the program during the cohort period and provide the list to the institution. The institution may correct the information about the students on the list no later than 45 days after the date ED provides it. (The institution bears the burden of proof that the list is incorrect.) The institution may either (1) provide evidence showing that a student should be included on or removed from the list [reasons for exclusion are given in sec. 668.404(e) of the regulations], or (2) correct/update a student’s identity information and the student’s program attendance information.

The corrected list contains the students for whom ED will obtain annual earnings averages from the Social Security Administration. ED will then calculate draft debt-to-earnings (D/E) rates for each GE program. At that stage, corrections to the list of students are no longer permitted, but the institution could correct information about the federal loan amounts attributable to a student. 

ED then publishes final rates. Currently there is no date certain for that event… stay tuned to NASFAA’s Todays News for the latest information on gainful employment reporting and D/E rates.

Publication Date: 8/26/2015

Comments Disclaimer: NASFAA welcomes and encourages readers to comment and engage in respectful conversation about the content posted here. We value thoughtful, polite, and concise comments that reflect a variety of views. Comments are not moderated by NASFAA but are reviewed periodically by staff. Users should not expect real-time responses from NASFAA. To learn more, please view NASFAA’s complete Comments Policy.