Rapidly Approaching Deadlines for Schools

By David Futrell, Training & Regulatory Assistance Staff

At last week’s Federal Student Aid Conference in Las Vegas, U.S. Department of Education (ED) officials reminded schools of several upcoming deadlines related to the Federal Perkins Loan Program and gainful employment programs, most of which are December 31, 2015.

Federal Perkins Loan Program

All institutions participating in the Federal Perkins Loan Program are reminded that they must return the federal portion of any Excess Liquid Capital in their Perkins Loan Revolving Fund to ED by December 31, 2015. Dear Colleague Letter GEN-15-19 includes guidance and attached interactive worksheets for institutions to use to determine the amount of Excess Liquid Capital that must be returned. If the school performs the worksheet calculations and determines there is no Excess Liquid Capital to return, they do not have to do anything further; they just need to keep the completed worksheets for audit/program review purposes.

Gainful Employment (GE) Programs

GE Program Transitional Certifications: With limited exceptions, an institution’s most senior executive officer must sign a certification that each of the institution’s currently eligible GE programs listed on its Eligibility and Certification Approval Report (ECAR) meets the requirements of 34 CFR 668.414(d). All required transitional certifications must be completed and submitted to ED by December 31, 2015.

For additional guidance and exceptions, refer to the November 20, 2015, Gainful Employment Electronic Announcement #70—Reminder of Upcoming Deadline for Gainful Employment Program Transitional Certification, and the June 11, 2015, Gainful Employment Electronic Announcement #54—Certification Requirements for Gainful Employment Programs. See also the NASFAA Today’s News article, GE Reporting Was Only the First Step: More Deadlines Loom.

GE Completers Data Challenges and Appeals Solution (DCAS) System: All schools with GE programs must sign up for the DCAS system via the Student Aid Internet Gateway (SAIG) website as soon as possible but no later than December 31, 2015. The DCAS system will allow schools to challenge their self-reported data and ED-calculated metrics related to their gainful employment program Draft Completers List. Schools will have only 45 calendar days after ED publishes the Draft Completers Lists to submit challenges to the data. The 45-day clock starts on the day ED sends the completers list to the school’s SAIG mailbox, even if the school delays in signing up. ED has not indicated when it will be sending the completers lists to schools. If the completers list is sent on a weekend, the clock starts on the following Monday. If the timing is such that the 45-day period encompasses a holiday or vacation period, schools will need to plan accordingly, since the 45 days will run through that period and will not likely be extended.

For more information, refer to the October 26, 2015, Gainful Employment Electronic Announcement #67—S SAIG Enrollment Now Available for DCAS Online Service, and the NASFAA Today’s News article, GE Reporting Was Only the First Step: More Deadlines Loom.

Gainful Employment Program Disclosure Templates: Schools with GE programs have until January 31, 2016 to update their disclosures for each of their GE programs to reflect information from the 2014-2015 award year. Schools must use the updated Disclosure Template according to guidance published with the October 23, 2015, Gainful Employment Electronic Announcement #65—Release of the 2014-2015 Disclosure Template for Gainful Employment (GE) Programs. Any questions should be submitted to ED’s GE Questions mailbox at [email protected].


Audio recordings of select sessions held at the 2015 Federal Student Aid Training Conference can be found at


Publication Date: 12/8/2015

Linda W | 12/8/2015 11:51:35 AM

Seems to me that ED can control when they send out the Draft Completers List and not send it out when the majority of the schools are closed during the holidays. To hint that we need to monitor this over the holidays is insensitive and feels like a bit of hardball posturing .

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