Posted Date: June 24, 2011

Author:  David Bergeron, Deputy Assistant Secretary for Policy, Planning and Innovation, Office of Postsecondary Education

Subject: Gainful Employment Electronic Announcement #11 - Determining Whether an Educational Program is a Gainful Employment Program

Dear Colleague Letter GEN-11-10 (GEN-11-10) posted to IFAP on April 20, 2011, included information about which educational programs at an institution are Gainful Employment Programs (GE Programs) under the Higher Education Act. If an educational program is a GE Program it is subject to the requirements for GE Programs as provided in the final regulations that were published on October 29, 2010, which are generally effective July 1, 2011, and the final regulations related to the metrics that were published on June 13, 2011.

Note that in Gainful Employment Electronic Announcement #3 published on May 20, 2011, we provided a correction to information in GEN-11-10 related to teacher preparation programs.

GEN-11-10 identified both proprietary institutions and postsecondary vocational institutions together in the description of what educational programs are and are not GE Programs. However, as noted below, any educational program that leads to a certificate or other non-degree credential awarded by a public or private non-profit institution, regardless of the length of the program, is a GE Program.

Since publication of GEN-11-10 we have been asked by several institutions to make a determination as to whether one or more of their educational programs is a GE Program. To assist institutions in making such determinations themselves, we are providing below a brief summary of the information included in GEN-11-10 and a series of Questions that an institution can answer to determine if a particular educational program is a GE Program.

Summary:

  • Virtually all educational programs offered by for-profit institutions are GE Programs.

  • All educational programs that lead to a degree awarded by a public or private non-profit institution are not GE Programs.

  • Virtually all non-degree educational programs awarded by a public or private non-profit institution are GE Programs.

Questions:

To determine if a particular educational program is a GE Program, the institution should answer the following questions about the educational program:

Question 1 -

Does the institution wish to have the educational program be, or remain, eligible for Title IV aid?

NO - If the answer is no, the program is NOT eligible for Title IV aid and, therefore is not a GE Program.

YES - If the answer is yes, continue to the next question.


Question 2 -

Does the coursework lead to a degree, certificate, or other credential awarded by the institution?

NO - If the answer is no, the program is NOT eligible for Title IV aid and therefore is not a GE Program [See Note A below for three exceptions where the program is Title IV eligible but not a GE Program].

YES - If the answer is yes, continue to the next question.


Question 3 -

Is the institution a for-profit (proprietary) institution?

YES - If the answer is yes, the program is a GE Program [See Note B below for two exceptions where the program is not a GE Program].

NO - If the answer is no, continue to the next question.


Question 4 -

Is the credential that is awarded by the public or private non-profit institution a degree - associates, bachelor's, graduate, or professional (e.g., MD, DDS, DVM, JD)?

YES - If the answer is YES, the program is not a GE Program.

NO - If the answer is no, the program is a GE Program.


Note A –

There are three exceptions to the general rule that to be eligible for Title IV aid, a student must be a regular student - enrolled in a program that leads to a degree, certificate, or other credential awarded by the institution. While these three exceptions allow students to receive all or some types of Title IV aid, they do not create GE Programs. The three exceptions, with regulatory citations, are -

  1. A program of at least two years that is acceptable for full credit toward a bachelor’s degree and qualifies the student for admission into the third year of a bachelor’s degree program. Otherwise eligible students may receive funding from any of the Title IV student aid programs. [34 CFR 668.8(b)(1)(ii)]

  2. Coursework necessary for the student to receive a State professional teaching credential or certification where the institution itself does not provide a certificate or other credential. Students must be enrolled at least half time and are eligible only for the FWS and Title IV loan programs. Note that similar courses of study that do result in a certificate or other non-degree credential being awarded by the institution are GE Programs. [34 CFR 668.32(a)(1)(iii)]

  3. Preparatory courses of study that do not lead to a degree, certificate, or other credential awarded by the institution and that provide course work necessary for enrollment in an eligible program. Students are eligible for no longer than one-twelve-month period and only for the Direct Loan Program. [34 CFR 668.32(a)(1)(ii)]

Note B –

The two exceptions to the general rule that all programs offered by for-profit institutions are GE Programs are -

  1. Programs that lead to a baccalaureate degree in liberal arts if the institution has been accredited by a regional accrediting agency since October 1, 2007 and the institution has offered the program since January 1, 2009. Otherwise eligible students may receive funding from any of the Title IV student aid programs. [34 CFR 600.5(a)(5)(i)(B)]

  2. Preparatory courses of study that provide course work necessary for enrollment in an eligible program. Students are eligible for no longer than one-twelve-month period and only for the Direct Loan Program. [34 CFR 668.32(a)(1)(ii)]

Information and updates related to Gainful Employment will be posted on the Gainful Employment Information Page. This page can be accessed either by going directly to http://ifap.ed.gov/GainfulEmploymentInfo/index.html or by clicking on the words ”Information Page” in the Gainful Employment box on the right hand side of the IFAP home page.

We hope that the information provided in this Electronic Announcement is helpful to institutions as they evaluate each of their educational programs to determine whether the program is Title IV eligible, and if so, whether it is a GE Program.

Should you have further questions, please send an e-mail to GE-Questions@ed.gov.

   

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