Gainful Employment MSFAA Lansing, MI February 1, 2012.

Gainful EmploymentGainful EmploymentMSFAALansing, MIFebruary 1, 2012

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Gainful EmploymentGainful Employment

The Law - HEAThe Law - HEA An educational program is Title IV

eligible only if the program: If offered by a public or non-profit

institution, leads to a degree; or If offered by any institution, “leads to gainful employment in a recognized occupation”

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What is a GE Program?What is a GE Program? At proprietary institutions all programs

are GE Programs except for - Preparatory coursework necessary for

enrollment in an eligible program Programs leading to a bachelor’s

degree in liberal arts offered since January 2009 that have been regionally accredited since 2007

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What is a GE Program?What is a GE Program?

At public institutions and not-for-profit institutions all programs are GE Programs, except for - Programs that lead to a degree Programs of at least two years in

length that are designed to be fully transferable to a bachelor’s degree program and do not lead to a credential awarded by the institution

Preparatory coursework necessary for enrollment in an eligible program

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What is a GE Program?What is a GE Program?

At all institutions, GE Programs do not include –

Teacher certification coursework that does not lead to a certificate awarded by the institution Collection of classes required by state, but

not leading to an institutional credentialIf the institution awards a

certificate/diploma for teacher certification coursework, it is a GE program.

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GE Program IdentifiersGE Program Identifiers

A Gainful Employment program is identified by the: 6-digit OPEID of the institution

offering the program (8-digits for reporting)

6-digit CIP Code (Classification of Instructional Program) assigned to the program by the institution

2-digit Credential Level

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GE Program ID NumberGE Program ID Number

Undergraduate Certificate in

Ornamental

Horticulture at Faber College

00100201060301 6 Digit OPE ID # CIP Code Credential Level

Credential LevelsCredential Levels

01 = Undergraduate certificate (or

diploma programs)

02 = Associate’s degree

03 = Bachelor’s degree 04 = Post baccalaureate certificate

(includes post-graduate certificate programs)

05 = Master’s degree

06 = Doctoral degree

07 = First-professional degree

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Disclosure InformationDisclosure Information

Disclosure Information on Program’s website home page - Must be simple and meaningful Must contain direct links from any

other webpage with general, academic or admission information about the program

Must be in an open format that can be retrieved, downloaded, indexed, and searched by commonly used web search applications


Disclose for each GE Program: Occupations (by name and SOC code)

that program prepares students to enter Links to occupational profiles on O*NET

Program costs – Tuition and fees Room and board Books and supplies May include other costs


Disclose for each GE Program: On-time completion rate - Denominator - Number of students

who completed program during most recently completed award year for which information is available

Numerator - Number of students who completed within normal time, as published by institution (Not 150% of normal time).


Disclose for each GE Program: Job placement rates for students

completing the program Use formula that the institutional

accreditor, program accreditor, or the state requires

Must be disclosed on a program basis, even if formula is for institutional level placement rates


Disclose for each GE Program: Median loan debt incurred by

students who complete the programTitle IV loan debt (FFEL and Direct Loan only) – Amount borrowed.

Private educational loan debt – Amount borrowed

Institutional finance plansAmount owed

Annual ReportingAnnual Reporting

Multiple reporting methodsBatch using SAIG mailbox

◦Fixed width format◦Comma separated value (CSV)

Online via NSLDS◦Direct online entry

Under Enroll tab, GE List, Gainful Employment Add

◦NSLDS GE Submittal Template Download at fsadownload.ed.gov Allows upload of 50 records at one time


Institution must report information on students who were enrolled in a GE Program for each award year -

Information includes: Student identifying information Program identifying information Amounts from private education loans

and from institutional financing plans Enrollment information Tuition and Fees (Optional)


Student identifiers For each student who enrolled in a

GE Program during the award year Social Security Number First, middle and last name Date of birth

Use student’s Social Security Administration information


Program Information For each student enrolled in a GE

Program Institutions OPEID (8 digit) where

student attended Name of program as established by

institution Classification of Instructional

Program (CIP) code of educational program

Credential Level


Private education loan information Defined in 12 CFR 226.46(b)(5) by the

Federal Reserve Board Total amount of non-Title IV loan

received to pay costs associated with attendance in the GE Program Examples – loans from financial

institutions, credit unions, states and other localities, guaranty agencies, and postsecondary educational institutions

Annual Reporting Annual Reporting

Institutional Financing Plan information Includes – Loans Extensions of credit Payment plans or Other financing mechanisms

That would otherwise not be considered a private education loan but that results in a debt obligation that a student must pay to an institution after leaving the program

GE MetricsGE Metrics

Two metrics established via regulation Repayment Rate

A percentage of the loan amounts that a GE Program’s former students are repaying

Debt-to-Earnings Ratios Annual Income RatioDiscretionary Income RatioFor the GE Program’s completers, the

average educational loan annual repayment amount as a proportion of the average borrowers’ annual income.

Repayment RateRepayment Rate Repayment Rate is a percentage of

the Title IV loan amounts that a GE Program’s former students are repaying (weighted for loan balance)

ED calculates a GE Program’s Repayment Rate using the program’s former students whose Title IV loans entered repayment during the applicable cohort period (e.g., 2YP)

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Performance RequirementsPerformance Requirements

GE Program considered to lead to gainful

Employment if it has-• Repayment Rate of at least 35%

OR • Annual loan payment under the

debt-to-earnings ratios of 12% or less of annual earnings OR

• Annual loan payment of 30% or less of discretionary income

Cohort Period UsedCohort Period Used“2YP”

◦ two year period consisting of the third and fourth federal fiscal years preceding the federal fiscal year for which the Repayment Rate calculation is performed.

Informational rates to be issued in April 2012 ◦ For the most recently completed federal fiscal year

of 2011, included the program’s former students who entered repayment on FFEL or Direct Loan Program loans during fiscal years 2007 and 2008. That is between October 1, 2006 and September 30, 2008. It tracks repayment activity on these loans during the fiscal year 2011, between October 1, 2010 and September 30, 2011.

Repayment RateRepayment Rate

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Loan repayment rate for a program calculated annually using the following ratio:

OOPB = Original Outstanding Principal Balance

LPF = Loans Paid in Full PML = Payments-Made Loans

OOPB of LPF plus OOPB of PML

OOPB


A loan is successfully being repaid if: Its balance is reduced by at least $1.00 over

the course of the year or paid in full; It is on track to being forgiven due to public

service employment; Borrower is making payments under an

interest‐only or income‐based repayment plan, but limited to no more than 3% of the OOPB; or

For post-baccalaureate programs, is a consolidation loan and all interest accrued over the course of the year has been paid.

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ExampleFormer Students OOPBStudent A $ 2,000Student B 3,000Student C 5,000Student D 10,000

Total OOPB $20,000 for 2YP

Only Student D successfully paying on loan

Repayment Rate = $10,000 / $20,000 = 50%

Debt-to-Earnings RatioDebt-to-Earnings RatioAnnual IncomeAnnual Income

Calculated annual loan payment based on median loan debt

Higher of the mean or median annual earnings

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Debt-to-Earnings RatioDebt-to-Earnings RatioDiscretionary IncomeDiscretionary Income

Calculated annual loan payment based on median loan debt

Higher of the mean or median annual earnings less 150% of HHS Poverty

Guidelines for single person

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Debt to Earnings RatiosDebt to Earnings Ratios

Median Loan Debt is the lesser of total tuition and fees assessed the student

for enrollment in all programs ORsum of -

◦ total FFEL and Direct Loan Program loans owed for attendance in the gainful employment program, as reflected in NSLDS

◦private education loans, as reported by the institution

◦debt obligations arising from institutional financing plans, as reported by the institution

Debt-to-Earnings Ratios Debt-to-Earnings Ratios

SSA will provide the median and mean earnings of the GE Program’s completers

ED will use the higher of the two averages

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Debt-to-Earnings RatiosDebt-to-Earnings Ratios

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Exclude students -- With one or more loans in a

military-related deferment status With loans discharged, or

pending discharge, for death or total and permanent disability

Enrolled in Title IV eligible program

Debt-to-EarningsDebt-to-Earnings

Annual Loan Payment— The program's completers’ median loan debt

–Amortized at 6.8% over –

10 years for a certificate, associate degree, and post-baccalaureate program

15 years for a baccalaureate or master’s program

20 years for a doctoral and first professional degree program

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Upon one year’s failure, institution must provide warnings to students and prospective students that provide – Notice of the program’s failure and the

amount by which the program failed Any plans the institution has for

improving the program Must establish a three‐day waiting

period after the warnings are provided before students can enroll

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Upon failing two years out of three, institution must, in addition to the one-year warnings, also tell students and prospective students that — Their debts may be unaffordable The program may lose Title IV

eligibility What transfer options exist

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Upon being a failing program for three out of four years, the educational program loses eligibility for Federal student aid

Initial targeting of the worst programs by capping loss of Title IV eligibility for FY 2014 rates only at 5 percent each of public, nonprofit, and for-profit programs

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To Add GE ProgramTo Add GE ProgramInstitutions must notify ED at least 90 days

before the first day of class when adding a new educational program that leads to gainful employment in a recognized occupation (GE Program) If the first day of class is on or after July

1, 2011 and before October 1, 2011, notification was due by July 1, 2011

If the first day of class is on or after October 1, 2011, institutions must provide notification to the Department at least 90 days prior to the first day of class

To Add GE ProgramTo Add GE ProgramInstitution’s notification must include -

An electronic E-App with GE Program details

Accrediting agency approval State approval Notice of Intent to Offer an Educational

Program;and Section L of the E-App containing

original signature of the appropriate official

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Notice Of Intent To Offer GE Notice Of Intent To Offer GE ProgramProgramTo ensure Notice of Intent is complete please:

◦Describe the process used for Determining the need for the program, and Developing the program content

◦Describe the process used to evaluate if the resulting content is appropriate to meet the need

◦Clearly identify the external parties involved in the development, review, or approval of the program, what their review disclosed, and actions taken in response

Notice Of Intent To Offer GE Notice Of Intent To Offer GE ProgramProgram If program is currently taught at the

institution it is ok to mention actual placement rates

Focus on benefit to students/employers – make a clear connection between the program, the job it prepares the student for, and the local, regional, or national market need for employees in that job

Notice Of Intent To Offer GE Notice Of Intent To Offer GE ProgramProgram Institution’s notice of intent must include:

How institution determined need for the program How the program was designed to meet local market

needs If an online program, how designed to meet regional

or national market needs Contain any wage analysis performed How program was reviewed/approved/developed

with business advisory committees, program integrity boards, public/private oversight agencies, and any businesses likely to employ graduates

Demonstrate approved by, or included in, school accreditation

Provide the date of the first day of class

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Approval RequiredApproval Required

If the institution did not provide the required notification timely, it must wait for Departmental approval before disbursing funds to students enrolled in the new GE Program Example - for programs beginning

between July 1, 2011 and October 1, 2011 must have provided new GE notifications by July 1, 2011

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Approval RequiredApproval RequiredApproval is also required if - The institution is provisionally certified The institution is adding a Direct

Assessment Program The institution is adding a

Comprehensive Transition and Postsecondary (CTP) Program

or The Department advises the institution

that it must wait for approval

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Jamie A. MaloneTraining OfficerU.S. Department of [email protected]

My supervisor is:Jo Ann BorelTitle IV Training [email protected]

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Gainful Employment MSFAA Lansing, MI February 1, 2012.

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