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Introduction to this special edition: A message from Carol Lindsey, TG vice president for policy and compliance
The past two years have been a period of momentous change in the regulatory environment surrounding the federal student financial assistance programs. Among the many profound changes introduced in the Program Integrity final rules, none has engaged the level of public attention and extensive development effort that the definition of "gainful employment in a recognized occupation" has experienced in the national arena. Due to the very high level of interest among schools, students, the federal government, taxpayers, and the public at large in this issue, we present this special edition on gainful employment. We hope it will serve to inform financial aid professionals and other interested parties about the new rules and help them anticipate and successfully prepare for implementation of the new requirements on July 1, 2012.
Upcoming TG webinar focuses on gainful employment requirements
Federal student aid requirements for educational programs that prepare students for gainful employment in a recognized occupation at a public, nonprofit, or for-profit school are at the forefront of discussion in the financial aid community and beyond. An upcoming TG webinar will review the requirements for reporting, disclosures, and adding new educational programs of this nature that become effective July 1, 2011. The webinar will also address the new regulations on program metrics for student debt levels and repayment success that become effective on July 1, 2012.
Overview — Key concepts and objectives of the final rules on gainful employment debt measures
ED, in developing these final rules, has adopted a definition of "gainful employment in a recognized occupation" that evaluates the degree of success of students enrolling in a program of this nature to effectively manage repayment of educational debt, and for graduates of such programs to secure relevant employment and earn sufficient wages to justify the financial investment required to complete the program. ED's rules are focused on targeting the lowest performing programs of this nature for improvement or discontinuation by the schools that offer them.
The hitchhiker's guide to gainful employment debt measures
For those anxious to begin studying the final rules on gainful employment (GE) program debt measures while awaiting the published version in the Federal Register, TG offers a quick guide to what you'll find and where you'll find it in the prepublication final rule document released by ED on June 2, 2011.
Gainful employment implementation time frames — debt measures
To illustrate the time frame in which the new GE debt measures operate at the program level, TG has developed a chart that visually depicts this information based on a chart provided by ED (Table G, p. 163 in the prepublication version of the final rules).
Significant changes from proposed rules
On July 26, 2010, ED's proposed rules on debt measures to be used for GE program evaluations were published in a Federal Register notice devoted specifically to that topic. Significant changes to the proposed rules were made by ED in response to a record-setting number of public comments submitted in response to the notice of proposed rules as well as in response to extensive additional analysis, research, and consultation by ED with other parties to refine the measures to effectively achieve ED's policy objectives in evaluating performance of GE programs in a balanced and informed manner.
Draft disclosure template for gainful employment programs
As schools develop disclosures to comply with Program Integrity final rules published on October 29, 2010, they are encouraged to review and provide comment on the draft "ED Gainful Employment Program Disclosure Template" published in a Federal Register notice on April 13, 2011. The disclosure template was developed by ED to standardize and automate the process for schools to submit summary information to ED on gainful employment (GE) programs.
Timely guidance available on ED's Gainful Employment Information Page
Are you wondering when the final rules on gainful employment (GE) program debt measures will be published in the Federal Register? Are you looking for answers to questions about the GE reporting, disclosure, and new program requirements taking effect on July 1, 2011? This information and much more is provided on a valuable, one-stop resource that ED has created for schools: the Gainful Employment Information Page.
A closer look at the new loan repayment rate
In order to determine if a program adequately prepares students for gainful employment (GE) in a recognized occupation, the GE final rules released by ED on June 2, 2011, require the program to satisfy minimum thresholds on student debt measures. These measures include the loan repayment rate and two types of debt-to-earnings ratios. This article focuses on the loan repayment rate measure, describing its purpose, outlining significant changes from the proposed rules, providing a basic overview of key terminology, and detailing the calculation of the measure.
Understanding debt-to-earnings ratios
New rules that become effective July 1, 2012, evaluate the effectiveness of a gainful employment (GE) program offered by a school based on its level of success in meeting minimum thresholds on two types of student debt measures: the loan repayment rate and two types of debt-to-earnings ratios. This article describes the purpose of the two debt-to-earnings ratios, highlights significant changes from the proposed rules, explains key terminology, and provides the calculations used to derive the ratios.
Data review and challenge process
A loan repayment rate and two debt-to-earnings ratios are calculated annually for each gainful employment (GE) program. This article focuses on the two-step data review and challenge process a school can use to correct data included in its draft debt measures.
Two-tiered approach to debt warnings
The final rules, released by ED on June 2, 2011, establish minimum standards on program-level measures for student debt levels and repayment success that must be met for gainful employment programs to qualify students to receive Title IV funds. A school that offers a program that does not meet the minimum standards in either of the measures in a single fiscal year (FY) must provide certain information to currently enrolled and prospective students by providing a "debt warning."
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