NAST Advisory on Gainful Employment
July 1, 2011 (updated August 15, 2011)
The following advisory on gainful employment contains corrected dates of implementation. Date changes from the original advisory email message are indicated in bold.
On June 13, the U.S. Department of Education issued final regulations on Gainful Employment -- Debt Measures for institutions that participate in federal Title IV loan and grant programs. These regulations are effective July 1, 2012
Regulations on Gainful Employment -- New Programs were issued on October 29, 2011. These regulations were effective July 1, 2011.
This message focuses on the October 29, 2010 program integrity regulations that will require reports about individual students and graduates from many institutions by October 1, 2011. These reports include information that may not be collected or compiled at present.
The most important thing you can do is check with the office or person in your institution that is responsible for Title IV compliance issues to determine whether any programs you offer fall under the federal definition of gainful employment (GE) programs. If they do, you or your institution will be responsible for the requisite reports and meeting other extensive regulatory requirements. The definition of a GE program includes:
- All Title IV-eligible stand-alone non-degree (NDG)--certificate, or equivalently titled or reported--programs at any level (undergraduate, post-baccalaureate, graduate, or post-graduate) in public or private non-profit institutions.
Please note: Certificates required or awarded as part of degree programs in these institutions are not considered GE programs. Other exceptions are: a) NDG programs at least two academic years long that are fully transferrable to a baccalaureate degree program; and b) preparatory courses of study required to enter a Title IV-eligible program.
- All Title IV-eligible degree and non-degree programs at for-profit institutions.
- All degree-based teacher preparation programs that result in direct teacher certification by the institution itself. Degree-based teacher preparation programs that prepare students for certification by a state entity other than the institution are not considered GE programs.
The GE definitions and rules are much more complicated than the brief summary we have provided above, and federal interpretations are subject to change. This is why coordination with the Title IV officers at your institution is critically important. They have the most current information from USDE.
The following links provide more information:
Important for all that have programs meeting the federal GE definition
Important for those intending to establish a program that meets the federal GE definition
American Council on Education Questions and Answers on the GE Regulations
- IFAP Gainful Employment Frequently Asked Questions
To repeat, the GE requirements are federal regulations and not NAST accreditation standards. NAST is providing this information to keep you apprised of developments that could affect your institution or your program.
As you may know, there is great concern in the higher education and accreditation communities about several aspects of these regulations, and these concerns have been expressed throughout the regulation development period. As a result, the final regulations are less draconian than earlier proposals. Even so, troubling policy issues remain: the concept of indexing the price of higher education to the earnings of graduates, the potential for eventual extension of this concept to all programs in all types of institutions, and the high and perpetual implementation costs that reduce funds allocated to educational programs, for example. Members of congress disagree about the appropriateness and efficacy of the GE regulations, but as of today no legislative action can be forecast prior to the implementation dates.
We will continue to keep you informed of developments on these and other regulatory issues and policy debates potentially affecting the work of theatre programs in higher education. We are willing to respond to inquiries about GE regulations, but definitive information comes only from USDE and is normally sent to the Title IV officer at your institution.