Posted Date: December 11, 2015
Jeff Baker, Director, Policy Liaison and Implementation, Federal Student Aid
Subject: Gainful Employment Electronic Announcement #71 - Reviewing and Correcting GE Completers Lists
As is provided under the Gainful Employment (GE) regulations at 34 CFR 668.405(b), later this winter NSLDS will send Draft Gainful Employment (GE) Completers Lists to each institution that has one or more GE Programs. Sending institutions their GE Completers List is the second step, following GE reporting by institutions to NSLDS, in the multi-step process of calculating a GE program’s Debt-to Earnings rates (see Dear Colleague Letter GEN-15-12 for a full discussion of the regulatory GE requirements and processes).
The purpose of this Electronic Announcement is to provide institutions with information about the actions they should take upon receipt of their Completers List to ensure accuracy. NSLDS will send the Draft GE Completers List to the SAIG mailbox designated by the institution for this purpose. To designate an SAIG mailbox for this and other GE purposes, an institution must do so at fsawebenroll.ed.gov. For information on the layout of the SAIG GE Completers List see Chapter 5 and Appendix C of the NSLDS GE User Guide.
If an institution has not designated a GE SAIG mailbox by the time NSLDS sends the Completers Lists to institutions, the only way the institution can receive its GE Completers List is by requesting it through the NSLDSFAP website under the Reports tab. For information on the layout of the GE Completers Report see Appendix B of the NSLDS GE User Guide. This functionality will not be available until NSLDS sends all institutions their GE Completers Lists.
Institutions will have 45 days from the date NSLDS sends out Draft Completer Lists to provide evidence of incorrect information on the list. If an institution believes that there are errors on the Draft Completers List, it must use our Data Challenges and Appeals Solution system (DCAS) to request a correction or to submit a challenge. Upon confirmation that we have agreed with the request for correction the institution should also correct their data in NSLDS GE reporting so that the correct information will be used in subsequent GE calculations and for GE disclosures. Detailed information about the DCAS system will be posted to our IFAP website within the next few weeks as will an online self-paced training module. Refer to GE Electronic Announcement #67 for instructions on how to enroll for access to DCAS.
Request for Data Corrections – An institution may, using the DCAS system, request a correction to any of the data it had reported to NSLDS as part of the GE NSLDS Reporting. These data include program identifiers (e.g., CIP code, Credential Level), students’ program attendance information (e.g., dates of enrollment, enrollment status), and students’ financial information (e.g., tuition and fees, books and supplies, private loan debt, institutional debt).
Challenges - The regulations at 34 CFR 668.404(e) provide that certain students are excluded from Completers Lists and thus, from the GE program’s Debt-to-Earnings rates. For information on these exclusions see the Exclusions paragraph of Dear Colleague GEN-15-12. The GE Completers List will include an indicator of whether the student is to be included or excluded, and if excluded the reason why. Institutions may, using the DCAS system, challenge the determination that the student is to be included or excluded by providing evidence supporting the challenge.
The list of a GE program’s completers generally includes all of the program’s former students who completed the program during a two-year cohort period. However, in some instances, as discussed below, that period will be expanded to include students who completed during a four-year cohort period. For more information see the Cohort Periods paragraph of Dear Colleague GEN-15-12.
A GE program’s debt-to-earnings rates are calculated if there are at least 30 completers in the cohort. However, to allow for possible exclusions, we have chosen a 90 completer threshold for creation of the Completer Lists. Thus, if the GE program had more than 90 completers during the two-year cohort period, only those students will be included on the program’s Completers List. Completer Lists for programs with 90 or fewer students in the two-year cohort period will have students who completed the program in both the two-year cohort period and in the four-year cohort period.
For programs with more than 30 and less than 90 completers in the two-year cohort period, institutions may wish to focus their Completer List review on the students designated as being in the two-year cohort unless their challenges might result in the two-year cohort begin reduced to less than 30 completers. For programs with fewer than 30 students in the two-year cohort or with the possibility of having fewer than 30 students in the 2-year cohort if challenges are accepted, institutions should review all completers on their list. While, as noted, programs with fewer than 30 students in the 4-year cohort period after challenges are accepted will not have a debt-to-earnings rates calculated, their earnings data and other information will be used for disclosure purposes.
In November we presented two webinars that provided important information on the GE Completer List process. The November 18, 2015 webinar focused on how institutions receive, access, and review their Completers Lists. The November 19, 2015 webinar focused on how institutions will use the DCAS system to request corrections or to submit challenges. Both webinars were recorded and are available on the GE Information page on IFAP in the section for Webinars and Presentations.