Posted Date: October 23, 2015
Robin Minor, Chief Compliance Officer, Federal Student Aid
Subject: Gainful Employment Electronic Announcement #66 - Accreditation and Licensure Requirements in Gainful Employment Certifications
As we discussed in Gainful Employment Electronic Announcement #54 – Certification Requirements for Gainful Employment Programs, under 34 CFR 668.414, each institution must certify to the Department that each Title IV-eligible Gainful Employment program (GE program) that it offers:
Is approved by a recognized accrediting agency or is otherwise included in the institution’s accreditation by its recognized accrediting agency or, if the institution is a public postsecondary vocational institution, is approved by a State agency recognized to approve such programs in lieu of accreditation [34 CFR 668.414(d)(1)];
Is programmatically accredited if such accreditation is required by a Federal governmental entity or by a governmental entity in the State in which the institution is located or in which the institution is otherwise required to obtain State approval under 34 CFR 600.9 [34 CFR 668.414(d)(2)]; and
In the State in which the institution is located or in which the institution is otherwise required to obtain State approval under 34 CFR 600.9, satisfies the applicable educational prerequisites for professional licensure or certification requirements in that State so that a student who completes the program and seeks employment in that State qualifies to take any licensure or certification examination that is needed for the student to practice or find employment in an occupation that the program prepares students to enter [34 CFR 668.414(d)(3)].
Institutions have asked for two clarifications on the certification requirements in 34 CFR 668.414(d)(2) and (d)(3) as they relate to programmatic accreditation, as follows:
Question: Can an institution certify that a GE program meets the programmatic accreditation requirements in 34 CFR 668.414(d)(2) if the institution has not yet obtained full programmatic accreditation for the program?
Response: Generally, an institution must obtain full programmatic accreditation for a program that requires programmatic accreditation in the State in which the institution is located before it may certify that the program meets the requirements in 34 CFR 668.414(d)(2). For the purpose of the transitional certification which must be provided to the Secretary on or before December 31, 2015, an institution may certify that a program that has not yet received full programmatic accreditation meets the requirements in 34 CFR 668.414(d)(2) if the State in which the institution is located permits the institution to offer that program to students in that State as of the date that the institution’s certification is provided to the Secretary.
Question: Because some States require that a program be programmatically accredited in order for graduates of that program to be eligible to obtain professional licensure or certification (or sit for a licensure exam) in that State, may an institution certify that a program meets the requirements in 34 CFR 668.414(d)(3) if the program has not yet obtained full programmatic accreditation?
Response: An institution can certify that the requirements in 34 CFR 668.414(d)(3) are met under these circumstances if, on the date the certification is made, the State requiring programmatic accreditation for licensure would permit graduates from the program to apply for the relevant licensure.
As we noted in EA #54, institutions may submit a transitional certification for programs that already meet the certification requirements and submit separate certifications for programs that do not currently meet the certification requirements on or after the date those programs are eligible to certify as long as those subsequent certifications are submitted by December 31, 2015.
If you have questions about the information in this announcement contact the School Eligibility Service Group at (202) 377-3173. You may also email GECertification@ed.gov.