Gainful Employment, the new priority for U.S. Higher Education

Campus executives are likely unaware of what needs to be accomplished and when to comply.
By Jim Farmer 02/11/14

On Dec. 11, 2013, the United States Department of Education posted a 68-page draft of regulations for “Gainful Employment (GE).” Largely ignored by the press, this document — soon to be regulation — is becoming the template for change of federal financial aid eligibility for college and university students. Gainful Employment currently only applies to certificate and other programs that do not lead to a degree, but may be extended to all post secondary programs.

For the first time, these regulations introduce starting salaries as a condition for students to receive federal financial aid. The regulations also impose financial penalties for institutions whose students in these programs fail to repay their federal student loans. Required disclosures to students have been expanded, as has reporting to the U.S. Department of Education.

Each of these factors add new requirements for administrative IT (Information Technology). In the next six months, colleges and universities will need to review their current admission, curricula, financial aid, career center and student services for effectiveness, costs and risks in this new environment. Because of the number of GE instructional programs found in for-profit and public community colleges, the proposed regulations will be most burdensome for them.

As written, the regulations would now apply to 11,735 instructional programs. Data analysis shows federal financial aid would be terminated for 1,496 of these — likely with financial penalties. 880 programs must be upgraded in order for students to continue to receive federal financial aid. As ED reported, “Fewer than 1,000 out of the approximately 6,000 institutions that are currently participating in the Title IV programs have no GE Programs.”

Although no new IT student administrative systems are required before the regulations become effective July 1, 2015, the required Web site disclosure and written acknowledgement must be completed before any students are enrolled in these programs. This makes Jan. 1, 2015 a likely date for initial implementation.To keep up with the new regulations, curriculum management modules now become a key enterprise IT component. The Department of Education has stringent documentation requirements for seeking approval of new programs in addition to institutional or state approval processes. The required data needs to remain available for at least seven years.