October 2024: This post has been updated from a previous version to incorporate new information from the U.S. Department of Education.

The Biden administration has delayed the rollout of new rules on Financial Value Transparency (FVT) and Gainful Employment (GE) reporting for a second time to give higher education institutions more time to comply. The Department of Education (ED) has set a new deadline for January 15, 2025, replacing an earlier October 1 filing date set in March 2024.

According to ED, the new FVT/GE rules are intended to provide potential students with a complete financial picture of an institution, including whether graduates are prepared to be employable, have manageable amounts of student debt, and whether their potential earnings reflect the investment in their education.  

The October 2024 deadline was the first extension after the agency initially announced the rules would take effect July 31, 2024. However, the agency released the new January 2025 date after pushback from lawmakers and higher education leaders.  

Financial aid offices are already overwhelmed processing 2024-2025 Free Application for Federal Student Aid (FAFSA) applications, which were delayed after a glitchy rollout last year, and anticipate delays for the 2025-2026 forms. The department said it pushed the FVT/GE deadline back in part to relieve that pressure.

What are the Financial Value Transparency and Gainful Employment rules?

According to Federal Student Aid, Financial Value Transparency (FVT) rules are intended to improve transparency and the quality of information for students about costs, financial aid sources and post-graduation experiences for all students enrolled in Title IV-eligible programs. 

The school’s reported debt-to-earnings ratio and earnings premium are used to determine if a student could have negative outcomes (more on that below).

Similarly, the Gainful Employment (GE) regulation uses debt-to-earnings and earnings premium to decide if a non-degree program, such as a certificate or diploma program, is Title-IV eligible.

What Schools Are Impacted

The FVT/GE requirements are separate but connected sets of rules. They impact schools based on financial models and Title IV eligibility. 

The FVT policy applies to all schools that administer Title IV federal financial aid, regardless of school type. Note that the FVT rules do not endanger Title IV eligibility, but the information will be published online.  

The new GE rules primarily impact for-profit institutions, which will have to report data on all programs. Non-profit institutions, including community colleges, only need to report on non-degree programs, such as certificates. If schools do not meet standards for two out of three straight years, it could result in losing Title IV status starting in 2026. 

The data collection process will require significant time and resources from school administrators. Schools that do not use an integrated student information system and instead manage their student information in spreadsheets or across disparate software applications are likely to face challenges with the new reporting requirements. 

This post will cover the latest developments in the new FVT/GE rules, what it means for schools going forward, and how your school can streamline reporting and data management.

The U.S. Department of Education has announced updated deadlines to report information under the Financial Value Transparency and Gainful Employment (FVT/GE) rules.

Diving Into the Financial Value Transparency and Gainful Employment Rule Framework

The Biden administration directives have been under consideration for several years. It marks a return to heightened oversight for for-profit trade schools and non-degree programs, and private and public institutions that administer Title IV federal financial aid. 

The issue has been a political back-and-forth since the Obama administration’s Department of Education issued limited GE rules out of concern that for-profit schools were charging high tuition but not adequately training students to earn a living wage in their chosen field. 

The Trump administration subsequently suspended the policy, and the Biden administration directed the Department of Education to resume work when President Biden took office in 2020.

Financial Value Transparency and Gainful Employment Reporting: Transitional or Standard Options

The federal government is offering two reporting periods to give schools more flexibility in reporting: 

  1. Schools can elect a “Transitional” status and report the last two years of data on undergraduates and graduates
  2. Schools can submit to “Standard” data requirements and provide seven years of undergraduate data and eight years of graduate data 

Schools may consider their ability to collect and report data, past performance, cost increases, and student debt levels to decide whether they opt for transitional or standard submissions.

Anticipating the earlier deadlines, some schools may be ready to report their data so the DOE is offering a limited number of institutions an “early opt-in” window. Schools can apply to submit their reports before the January 15 deadline and DOE will release information about that option soon.

Understanding the New Gainful Employment Rules Policy

The GE rules are intended to give potential students a clear look into their financial future based on the school and program they choose. 

The government asserts that some career training programs saddle graduates with unaffordable loans and may not equip them for potential earnings any better than someone in their state who has not attended a post-secondary program. 

A school must demonstrate its capability to prepare students for gainful employment. As part of this requirement, schools must publish detailed data on their graduates’ loans, income and job placement.

The new GE rules include two requirements: 

  1. Qualifying programs in any professional sector must demonstrate that graduates can afford their annual debt payments 
  2. Schools must show their graduates earn more than adults in their state who didn’t pursue a post-secondary education

The Biden administration’s Department of Education says the oversight will protect 700,000 students annually who might enroll in one of the 1,700 low-performing programs.

The government plans to publish the data collected from schools so students can do their own research to see possible financial outcomes. Additionally, students must sign an acknowledgment that they’ve viewed information about programs whose students have graduated with unaffordable amounts of debt.  

If a school or program fails to meet the benchmark for two straight years, it risks losing its eligibility to administer Title IV financial aid. 

Schools are required to publish detailed data on their graduates’ loans, income and job placement.

Financial Value Transparency (FVT) Framework and Disclosures

For this rule, the Department of Education will collect and publish data on student debt and earnings from all post-secondary programs that receive federal financial aid to assess the value of the programs. 

This rule applies to all Title IV-eligible schools and institutions will be required to report on each student who receives federal aid in nearly every program, including enrollment, completions, withdrawals, costs, debt and institutional aid. 

Schools will have to collect and publish data on the following:

  • Student loan amounts for federal, private and institutional aid to show how program graduates have paid for their education
  • Information related to tuition and ancillary expenses, such as fees, books and supplies 

This rule also requires students to sign a disclosure to acknowledge they have reviewed the information and are aware of the data. The Department of Education estimates the new transparency reporting requirements will impact approximately 400 programs with about 120,000 students.

Gainful employment and Financial Value Transparency rules require warning students that certain programs are at risk of losing eligibility for Title IV aid and that a student's program of choice has potential risks.

New Information for Schools to Track

Because the new FVT/GE rules will require schools to report on financial aid and career placement data, it means schools need to stay on top of gathering information from students, graduates and employers. 

Under the new GE rules, the DOE will use student data to determine a school’s Title IV eligibility:

  • Programs that pass the DOE’s standards can continue administering Title IV aid to their students
  • Programs that come close or fail the standards test risk suspension from federal aid
  • A GE program could become ineligible if it fails to meet standards for two of three consecutive years
  • A GE program could become ineligible if it fails for four straight years
  • If a school is at risk or failing, it triggers a notification to enrolled students and prospects

Under the new FVT rules, the DOE will require schools to track two sets of information: debt-to-earnings ratios and earnings premiums. They also need to report information on Title IV-funded students in most programs, including enrollment, completions, withdrawals, costs, debt and institutional aid. 

Debt-to-Earnings Ratios

The debt-to-earnings ratio determines whether a program prepares its students for gainful employment in their chosen field. It uses typical loan debt and earnings data for graduates to determine the ratios, then publishes the rates for discretionary income and annual earnings. 

Put together, the two rates measure a GE program’s annual loan payments as a percentage of their annual earnings. Under the ratio, the amount a program graduate needs to set aside for their student loan payments must equal 8% or less of their yearly earnings.  

A GE program becomes ineligible if it fails to meet both debt-to-earnings metrics for two out of three years.

Earnings Premium Test

Schools must show that at least half of their graduates earn more than a typical high school graduate in their state who does not have a post-secondary degree. Programs that fail to meet this standard for two out of three consecutive years become ineligible for Title IV aid.

Student Information System Solutions for New Financial Value Transparency and Gainful Employment Rules

These additional reporting requirements will undoubtedly create more work for school administrators. If your team isn’t confident in the accuracy of its data – or spends too much time trying to find it – your school could be at risk of losing Title IV funding.

A student information system supports the entire student lifecycle, from admissions to graduation and beyond. Campus Cafe’s system includes modules for financial aid management and career placement data, which many providers charge extra for. 

Most importantly, every module in our system is connected and pulls student data from one centralized location. Our staff will train your administrators to extract information quickly and easily using a suite of tools and reports.

A Customizable CRM to Collect and Manage Student Data

Campus Cafe’s integrated Customer Relationship Management (CRM) module lets users track and manage student interactions. It helps keep real-time information organized and accessible to multiple users.

For the new GE rules, the CRM can track career placement data in several ways: 

  • Administrators can configure the database to include job placement data in a student’s profile, which staff can update as needed  
  • Graduates’ job placements can be assigned to a specific company, individual, field or certifying body, making the information accessible to sort and search

To enhance reporting and searches, users – including students and graduates – can add granular details to the CRM database through self-service portals. Below is an example of the fields you can track.

Pre-Built Reports That Streamline Information Gathering

Schools that want to stay ahead of the new GE/FVT rules will need to keep their data organized and accessible for all stakeholders. For this task, Campus Cafe’s library of pre-built reports is a valuable and time-saving resource. The user-friendly system is easy to navigate no matter the users’ technical capabilities. 

Tools that can help with GE/FVT reporting include:

  • Dashboards: See key metrics on career placement information and gainful employment data on a visual dashboard
  • Customized reports: See GE and career placement reporting based on your school’s programs and student population
  • Filters: Sort and drill down into specific data fields
Pre-built reports that can be used for accreditation and state and federal reporting help teams work faster and more efficiently.

Intuitive Student and Alumni Portals

Students and graduates can easily update their work history, wage information and contact details in Campus Cafe’s student and alumni portals. The cloud-based system lets users log in from any device and location. 

Encouraging students and graduates to update their information reduces the workload on your staff and improves the validity of your program’s data.

Responsive Customer Service and Technical Support

As schools approach the new FVT/GE realities, they will likely have questions and need technical assistance. Campus Cafe’s U.S.-based technical support team is on hand to assist your staff with answering questions, including specific information related to reports and using the CRM.  

Additionally, our extensive online knowledge base contains detailed and regularly updated information, videos and use cases.

Tips to Manage Financial Value Transparency and Gainful Employment Reporting Requirements and Data Collection

Even with the latest extension, complying with new FVT/GE rules can put a strain your staff. An integrated student information system can help with organizing data and building accurate reports, but schools need to be proactive in coordination and planning.   

Consider these tips to help your team: 

  • Ensure all impacted staff are aware of the new rules, reporting requirements and their roles in maintaining compliance
  • Collect student and program data from all impacted departments
  • Review the data for accuracy
  • Stay up to date with information from trusted industry organizations, including  Association for Institutional Research, the National Student Clearinghouse and National Student Loan Data System (NSLDS) 
  • Utilize reporting tools and technical support from your student information system partner

The Bottom Line: An Integrated SIS Makes It Easier to Comply With the New Financial Value Transparency and Gainful Employment Requirements

Many schools are likely to face a learning curve and a strain on resources to comply with the new GE and FVT rules. Now is the time to determine how your school will manage the data collection process. 

Campus Cafe can help your school make the switch from spreadsheets, manual data entry or antiquated student management software to our modern, all-in-one cloud-based SIS. You’ll save time collecting student data, consolidate resources and stay on the right side of the DOE’s new compliance requirements. 

See more ways Campus Cafe’s integrated student information system can help your team stay ahead of important changes to financial aid reporting.

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