2019-25: Enhance CCCApply to Comply with GE Disclosure Requirements

Problem / Issue

Colleges are looking for a good solution to enforce the new GE requirements prior to starting new Applications.  The Tech Center is discussing options now that could be reviewed by Advisory Committee to determine best practice.  To be continued....

ED Announces Two Previously-Delayed Gainful Employment Disclosure Requirements Will Go Into Effect July 1, 2019

By Jill Desjean, Policy and Federal Relations Team

On Friday, the Department of Education (ED) released its Announcement of Applicable 2019 GE Compliance Dates, reminding institutions of the July 1, 2019 deadline to comply with the gainful employment (GE) regulations in 34 CFR 668.412 (d) and (e). These rules require institutions to include the disclosure template on all promotional materials made available by or on behalf of an institution to prospective students, and to provide a copy of the disclosure template directly to prospective students before they sign an enrollment agreement, complete registration, or make a financial commitment to the institution.

The Trump administration had previously delayed implementing these two sections of the 2016 GE requirements three times. The Obama-era requirements were first set to go into effect in April 2017 when the new administration delayed them until July 2017. Following that delay, Education Secretary DeVos announced plans to postpone the implementation of the disclosure requirements until the following year, July 2018. Then, on June 18, 2018, a third delay was announced, this time until July 1, 2019.

The gainful employment regulations were re-negotiated in 2018. No new final rule has been published as of this date, but, if published by November 1, 2019 the new rule will become effective on July 1, 2020. This led to speculation that ED would issue a fourth delay until the new rule became effective. Friday’s announcement, however, clarifies that there will be no further delay.

Publication Date: 5/28/2019

Proposed Solution

6.25.19 - Per meeting with Jennifer and Tim, the more we explore the significance and complexity of this requirement, which will require each college to align we are shocked at the amount this requirement, the more apparent it is that this belongs in MyPath as a "pre-Application" requirement that can be put into a checklist and tracked (and confirmed) that the student received the information.  Patty to meet with Mike Caruso and discuss options to implement this requirement in MyPath, which should be reviewed by a steering committee as a pre-application and have is enhancement 

6.21.19 - The Tech Center is discussing options now that could be reviewed by Advisory Committee to determine best practice.  To be continued....

Feedback from Betty Glyer-Culver, 8.12.19

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Hi Patty, I am only going to be able to attend today’s meeting for maybe the first half hour if at most. There are items on the agenda I am most interested one of them being Dual Enrollment. So I will look forward to reading the meeting minutes on this item. Note that I would be happy to serve on any workgroups related to Dual Enrollment/Advanced Ed or wherever I might provide support from a research lens.

Also I see that Gainful Employment reporting is on the agenda. I am the lead for all Federal Reporting for our district. (lucky me). The item on the agenda you are referring to is specific to GE Disclosure reporting. However it is important for you to know that the federal government has provided the colleges the option for early rescission of the Gainful Employment regulations which includes GE Disclosure reporting. Here is the back ground information on the early rescission rule. I would be more than happy to speak to this but as I indicated I can only attend the meeting for the first half hour, maybe. Los Rios has opted in to the early rescission option and I would imagine most colleges would. 

Here is the key piece of information related to the early rescission of Gainful Employment reporting (emphasis is mine):

Institutions that early implement the rescission of the GE rule will not be required to report GE data for the 2018-2019 award year to NSLDS, which will be due October 1, 2019.  Additionally, those institutions that early implement will not be required to comply with the current requirements in 34 CFR 668.412 (d) and (e) that require institutions to include the disclosure template, or a link thereto, in their GE program promotional materials and directly distribute the disclosure template to prospective students, which will be required starting on July 1, 2019.  Institutions that early implement will no longer be required to post the GE Disclosure Template and may remove the template and any other GE disclosures that are required under 34 CFR 668.412 from their web pages.  Finally, an institution that early implements will not be required to comply with the certification requirements for GE programs under 34 CFR 668.414.

Here is the link to the GE Electronic Announcement 122-Early Implementation of the Rescission of the Gainful Employment Rule for your review:

https://ifap.ed.gov/eannouncements/062819GEAnnounce122EarlyImplofRescissionGERule.html

hope this is helpful to your discussion.  betty

Betty Glyer-Culver 
Director of Institutional Research 
Los Rios Community College District 
1919 Spanos Court 
Sacramento, CA 95825 
(916) 568-3068

Email:  glyercb@losrios.edu

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Supporting Documentation

Dependencies, Risks and/or Reporting Requirements?