This article discusses the required disclosure information and calculations that schools must provide under the Gainful Employment regulations. It covers the current disclosure requirements and provides tips for compliance. Potential new disclosure requirements under final rules will take effect in 2017. The article stresses ensuring compliance with both current and upcoming disclosure rules, as noncompliance can result in audit or program review findings.

1. For Publication
Inceptia.org
Gainful Employment – The Disclosures
By Dennis Christich, Inceptia Strategic Business Director
This article will cover required disclosure information and the disclosure calculations.
Current Disclosure Information
Schools are required to disclose certain information to prospective students on school websites
and also on promotional materials. These requirements are outlined in the Department of
Education’s (ED) Program Integrity Regulations published on October 29, 2010, and went into
effect on July 1, 2011. Please examine the table below to learn more about the required
disclosures and view applicable calculations that may be needed to determine specifics for each
disclosure.
Required
Disclosure
Details Calculation(s)
Occupations
• Must list occupations by name and SOC
codes that the GE program prepares the
students to enter
• Must link to the O*Net site to the
occupational profile
(http://www.onetonline.org)
• Must use a representative sample if more
than 10 possible occupations
N/A
Normal time to
complete
program
• Must specify how long it takes to the
complete the program
• 100% of time it takes to complete, not the
150% of the time that is contained in the
“Student Right-to-Know” metrics
Program length in weeks,
months or years
On-time
graduation rate
for completers
• Must specify the percent of students who
completed in the most recently completed
award year within normal time
• Includes leaves of absences
• Time if a student withdrew and then
returned
• Enrollment in other programs if the
student did not complete the other
program
Step 1: Determine how many
students completed in the
most recently completed
award year.
Step 2: Determine the number
of students in Step 1 who
completed within the normal
time.
Step 3: Divide the number in
Step 2 by the number in Step
1. Then divide by 100.
Educational
costs
• Provide tuition & fees charged for
completing the program within normal time
• Provide typical costs for books & supplies
(unless included in tuition and fees)
• Provide room & board (if applicable)
• Other expenses are optional, but you must
Calculate total fixed and
typical variable costs by
category

2. provide a link or information to program
cost information under “Student Right-to-
Know”
Placement rate
for completers
• Must disclose accrediting agency and/or
State, placement rates and methodologies
• If not required by an accrediting agency or
the State, then you are not currently
required to disclose a placement rate
Use Accrediting Agency
and/or State methodologies
Median loan
debt
• Must specify the median (not the mean)
loan debt incurred by student who
completed the program
• There are three categories of median
debts:
1. Title IV, HEA program loans (FFEL, Direct
Loans but exclude Perkins Loans, PLUS
Loans and TEACH Grants that converted
to Unsubsidized Direct Loans and all
loans taken out over the course of the
program, NOT just one year of the
program)
2. Private education loans (defined as “non-
Title IV” loans provided by private
educational lenders for post-secondary
educational expenses) and all loans taken
out over the course of the program
3. Institutional financing plans (include any
loan, extension of credit, payment plan, or
other financing mechanism provided by
the institution or a related party for
attendance that is not otherwise reported
as a private education loan and any debt
the student owes the school as of the day
they completed the GE program
The median is the middle
value in a distribution of
values, above and below
which lie an equal number of
values.
Step 1: Determine which
students completed the GE
Program in the most recently
completed award year.
Step 2: Arrange each
student’s debt in ascending
order, including students with
zero debt.
Step 3: Identify the middle
value since the median is the
middle value in the distribution
of all values. If there is an
even number of values in the
distribution and thus there is
no middle value, calculate the
mean (average) of the two
values at the halfway point.
Other program
information
provided by
the Secretary
This category is the catch-all and currently there is
nothing to disclose under this provision.
N/A for now
A disclosure template was released in September of 2014, and institutions were to publish their
2013-14 information by January 31, 2015. The goal of this initiative is to create transparent, and
easy to locate, standardized web page that contains detailed information for gainful employment
programs, so students are better prepared to make informed decisions about selecting a
program.

3. Gainful Employment Program Sample Disclosure Template
Source: Department of Education, FSA 2014 Conference Session #30
Best Practices
In my experience, there are a couple of main areas where institutions routinely struggle to comply
with Gainful Employment. Here are some tips to help avoid some of the pitfalls:
• Your institution’s website may have a main page that contains all your consumer
information, including Gainful Employment metrics. That’s great, but you must still
provide the completed program specific disclosure template on each individual academic
page.
• Communicate with your Admissions, Marketing, Communications Offices, etc. to ensure
they are aware that anytime an individual GE program is written out in any format (T.V.
commercial, course catalog, radio, advertisement, social media, etc.) you must also
include the exact URL of the Gainful Employment disclosure template for that program. In
some cases it may not be feasible to include the live link or URL; however, you should
clearly explain where the information can be found on your website.
• Always keep in mind that your institutional website is viewable 24/7. Therefore anyone,
including Department of Education staff, can access your information without ever leaving
their regional office. Make sure your website is current and precise – at all times!
• When in doubt, always go back to the actual regulatory language to ensure you are
meeting the requirements. Do not rely solely on guidance from ED, or even a trusted
colleague.
• Meet all published deadlines by planning for them in advance. It may sound obvious, but
it’s surprising how people procrastinate when they don’t agree or understand rules and
stipulations. Be as proactive as possible, and perhaps assign a detail-oriented staff
member the responsibility of administering the Gainful Employment requirements.

4. Disclosures Under New Final Rules
The new disclosure requirements that were published in the Final Rule dated October 31, 2014
will not go into effect until January 1, 2017, allowing ED sufficient time to transition from the
current disclosure requirements to those included in the final regulations. This will allow ample
time for them to seek comments on the new disclosure template, conduct focus groups and
consumer testing, or pursue guidance and technical assistance.
Institutions will be required to use the new disclosure template provided by ED for each of their
GE programs. So at this time, many new items are under consideration and are not yet finalized.
Once determined, they will be published in the Federal Register. For a list of potential disclosure
categories that may be included, you can refer to FSA 2014 Conference Session #30, slides 47-
49, referenced below.
Potential Audit and/or Program Review Findings
I would be remiss if I did not stress the potential risk for audit and/or federal program review
findings. In fact, in 2014, §668.6 Reporting and disclosure requirements for programs that
prepare students for gainful employment in a recognized occupation finding is included in both
the Top 10 Audit and Top 10 Program Review Findings provided by ED. This particular finding
was new this past year to the Program Review list as finding #7 and it came in as #10 on the
Audit findings list. Consequently, this is an area to ensure your institutional compliance with
constant vigil. Please note: the findings are found in both the GE disclosure and reporting areas.
Summary
If your institution does have any Gainful Employment programs, please double check to make
sure you are complying with the current disclosure regulatory requirements. And don’t forget to
prepare your institution for the new requirements effective January 1, 2017. For more information
about Gainful Employment and Financial Literacy visit the Inceptia Institute.
Resources and References
Gainful Employment Information page on IFAP
Gainful Employment Disclosure Template
FSA Assessment – Activity #11 – GE Disclosures
FSA 2014 Conference Session #30
Federal Regulations
###