02 Jan Gainful Employment Update

By Steve McDowell, Assistant Director of Financial Aid Services, Connecticut State Colleges & Universities

On March 25, 2014, the Department of Education had issued a Notice of Proposed Rulemaking (NPRM) regarding Gainful Employment.  With over 95,000 comments received by the financial aid community, the Department published their final regulations to the Federal Register on October 31, 2014; they are scheduled to become effective on July 1, 2015.

The intent of these regulatory changes is to hold institutions accountable for whether their students find jobs and earn a living wage upon graduation through reporting on various measures related to eligible GE programs.  Of note, these final rules have eliminated the program-level cohort default rate metric, which was largely the rationale for the court order that vacated the original rules from 2011.

Generally speaking, all non-degree programs, and most programs at proprietary institutions, must lead to gainful employment in a recognized occupation.  Data to be reported out to NSLDS may be categorized into four groups: Institution Data, GE Program Information, Student Data, and Financial Data for Students.  Within these categories exists various subsets of data, some of which include program CIP Codes and Credential Levels, Length of Program with start and end dates, Enrollment Status at the first day of enrollment in the GE program, and student debt levels.  The Final Rules also require various metrics, eligibility thresholds, and certification requirements for programs that fall within GE purview.

While annual disclosures to institution websites for GE programs are required annually by January 31 for the preceding award year, the reporting schedule to NSLDS for Title IV Recipients enrolled in GE programs that exist only as of July 1, 2015 is as follows:

July 31, 2015:                     2008-2009 through 2013-2014

October 1, 2015:               2014-2015

Please note: an updated Gainful Employment Submittal Template for NSLDS reporting will be available from the Department of Education in early 2015.  The Disclosure Template, released in September 2014, may be located here.

Additional resources pertaining to Gainful Employment:


2014 Federal Student Aid Training Conference – Presentations

  • Session 30: Gainful Employment Disclosures
  • Session 58: Gainful Employment Reporting to NSLDS


Gainful Employment Assistance from Federal Student Aid: