Although these regulations do not directly affect the continued Title IV eligibility of non-GE programs, at its core the FVT framework does involve the unprecedented calculation and disclosure of D/E and EP metrics for non-GE programs. The Department will not calculate rates for a program if it does not have data for a sufficient number of completers for the cohort period. This would include situations in which an institution does not use the transitional reporting process and did not report completers for a particular program during all or part of the cohort period because it was not required to report enrollment at the program level during that period.

G-Q13 How do I know if a program at my school is a Qualifying Graduate Program? (Added July 19,

• A program fails the D/E rates if it fails both the annual D/E rate and the discretionary D/E rate.
• You can use the “Graduated Status Reconciliation” list to update a student’s program status to Graduated, whenever a Graduated enrollment status isn’t reflected for the completed program.
• Our reports provide an extensive repository of verified payroll, credit, and affluence data.
• By simulating standard and transitional reporting metrics, we help institutions expect potential shortcomings and address them preemptively.
• However, prior to disbursing Title IV funds to students in a non-GE graduate program with failing D/E rates, students in the program must execute a required acknowledgment of the program’s “high debt burden” designation through an ED-hosted website.
• This model can adapt more readily to evolving regulations and the way they affect your institution’s compliance and reporting needs.

A First-Professional Degree is the first degree that signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor’s degree. As part of our upcoming webinar, we will discuss several factors to consider when deciding whether to pursue the standard or transitional report option. The Department provided an outline of Final Rule D/E rate and EP measure calculations and thresholds at its 2023 Federal Student Aid conference—Session BO6 Gainful Employment; slides are available here.

What is the Financial Value Transparency/Gainful Employment (FVT/GE) Completers List?

For example, if the IRS is unable to match three students out of 100 students, the Secretary orders by amount the debts of the 100 listed students and excludes from the D/E rates calculation the three largest loan debts. Below we list the major provisions of the Financial Value Transparency and Gainful Employment regulations and then provide more detailed summaries. Detailed information is provided in the final regulations, and the Department plans to publish additional policy and operational guidance to support institutions in their implementation efforts. Electronic Know Your Customer (eKYC) offers financial transparency a way to ease compliance burdens while maintaining regulatory effectiveness. KYC is a regulated process used to verify a customer’s identity and assess risk, traditionally requiring physical document submission and in-person verification.

How does FVT/GE impact my institution?

Schools should also use one of the two methods described above when reporting award year values in the AA Detail Record for students who are currently enrolled in more than one program at the institution as of June 30. A two-year program that leads to a certificate or other recognized nondegree credential (not a degree) of its own does not fall under the transfer program exception described above. As such, because the program does not lead to a degree, it is Title IV eligible only because it must lead to gainful employment in a recognized cash flow occupation (a GE Program). The program is a GE Program even if the credits earned in the program are transferable to a four-year bachelor’s program. The Clearinghouse can identify students who would otherwise be missing from your cohort and completers record, and we will prefill some of your FVT/GE report data, which saves you time and effort. This webpage includes information to assist institutions with the FVT/GE reporting requirements.

• This ensures the updated enrollment reporting is available for both the NSLDS SSCR Roster Distribution process and your FVT/GE Draft Completers List.
• This would include situations in which an institution does not use the transitional reporting process and did not report completers for a particular program during all or part of the cohort period because it was not required to report enrollment at the program level during that period.
• The Department understands institutions may desire additional flexibility beyond the already twice-moved deadline for reporting the required FVT/GE data.
• Institutions will now have until January 15, 2025, to provide all required FVT/GE reporting and review the Completers Lists.
• If a non-GE program has a passing D/E rate but fails the EP measure, no student acknowledgement would be required prior to Title IV disbursements, though the disclosure requirements remain.
• Since then, countries have adopted anti-money laundering/countering financing of terrorism (AML/CFT) measures, with Customer Due Diligence (CDD) at their core.

How do I navigate to “Graduated Status Reconciliation” on the Clearinghouse secure site?

Note that Car Dealership Accounting a program “passes” the D/E rate metric if it passes the annual rate analysis but not the discretionary rate analysis, or vice versa; a program must fail both the annual and discretionary D/E rate analysis to “fail” the D/E rate test overall. Furthermore, even for non-GE programs whose Title IV eligibility is not conditioned on passing D/E rates, institutions must nonetheless report the pertinent program and student-level data to allow ED to calculate D/E rates for all programs. In their final form, these regulations require that in order to maintain participation in federal student financial aid programs under Title IV of the Higher Education Act (Title IV), any GE program must meet both a debt-to-earnings (D/E) rate measure and also an earnings premium (EP) benchmark.

Because most institutions of higher education participate in Title IV, the burdensome requirements of the Final Rule will apply in some manner to nearly all public, non-profit, and proprietary colleges and universities. To assist you in understanding how your institution may be impacted—and what you need to do now to prepare for compliance–we provide a high-level overview of the Final Rule below, as well as specific steps your institution should consider down the long and winding road to prepare for these new requirements. (The AACS complaint is available online.) If the FVT/GE regulations are not enjoined, rescinded or otherwise delayed, the Final Rule will take effect on July 1, 2024, and institutions must report their initial tranches of pertinent data to ED by July 31, 2024. Only students who received Title IV aid at any time from your institution for the completed program should be included in your Draft Completers List.

We’re the compliance experts

The recently finalized Gainful Employment (GE) and Financial Value Transparency (FVT) regulations, to be in effect as of July 1, 2024, are proving to be quite confusing. Part of the problem is the Gainful Employment language, which leads people to think of the late Obama Administration version that was successfully challenged in lawsuits and ultimately abandoned during the Trump Administration. Please continue to monitor Federal Student Aid’s Knowledge Center and FVT/GE Topics Page for new information as it becomes available. The U.S. Department of Education (the Department) has added additional Frequently Asked Questions (FAQs) that are available on the FVT/GE Topics Page. Please do not hesitate to contact Jonathan Tarnow, John Przypyszny, Cindy Irani or Sarah Pheasant if you have any questions regarding the Final Rule, this alert or other education regulatory matters.

Financial Value Transparency and Gainful Employment Regulations: What We Know Now

Initially, institutions will be required to provide a Transitional Certification demonstrating this for existing GE programs. After receiving your required financial aid data, the Clearinghouse will make sure all data fields adhere to NSLDS definitions and standards. We’ll also ensure that your data passes a robust series of validations to reduce the risk of NSLDS’ rejecting records, which would require more work by your institution. Once you have corrected the errors for each award year’s file, the data is processed into our database and, if you choose, you can download a CSV file to review the data. At that point, the Clearinghouse submits the data, with all applicable award years, to NSLDS. If NSLDS detects additional errors, NSLDS will send an error report to the Clearinghouse that will be presented on our secure site UI (user interface) for your review.

Data validation

B-READY assesses these challenges within its Financial Services topic, particularly in the Commercial Lending category, which evaluates regulatory frameworks and explores ways to enhance access to finance through stronger yet more efficient CDD measures. The fight against financial crime took a major leap forward in 1989 with the creation of the Financial Action Task Force (FATF). Since then, countries have adopted anti-money laundering/countering financing of terrorism (AML/CFT) measures, with Customer Due Diligence (CDD) at their core. CDD helps financial institutions verify customer identities, assess risks, and monitor transactions—enhancing transparency and protecting financial systems. For programs that are offered exclusively through distance education or correspondence courses, schools should leave the fields for State # in MSA of Main Campus blank, and report “X” for “Not Applicable” in the fields for Program Prepares Licensure in MSA State #.

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