The US Department of Education (ED) recently announced a revised timeline for the implementation of the new Financial Value Transparency and Gainful Employment regulations (FVT/GE Rule). Despite two prior extensions, the significant reporting requirements created challenges for schools’ already burdened financial aid departments due to problems with the Free Application for Federal Student Aid (FAFSA). After recently notifying schools that ED was dealing with internal data problems that impacted the ability of colleges to report required information, on September 13, 2024, ED announced that the deadline to report required information under the FVT/GE Rule is now January 15, 2025.
Over the last year, ED has provided periodic guidance on the FVT/GE Rule that went into effect on July 1, 2024. As a reminder, pursuant to this rule, all institutions that participate in Title IV programs are required to report a significant amount of student and programmatic information to ED. Originally, this information was due on July 1, 2024, but pursuant to a March 29 Dear Colleague Letter (DCL), the deadline was extended to October 1, 2024.
From the beginning, this timeline has been a source of significant concerns from the regulated community (evident by the continued delays), as many institutions now find themselves subject to extensive reporting requirements during a busy fall semester while still recovering from the delayed FAFSA rollout. Most of these updates have been technical in nature – including an extensive Frequently Asked Questions webpage with rolling updates and a handbook outlining the procedure for reporting required information. However, an August 2024 update revealed an acknowledgement by ED of agency challenges with its own data that could impact the process and timing of certain subsets of student data used to assess program performance under the FVT/GE Rule.
On August 30, 2024, ED published a warning regarding certain lists that it generated (commonly referred to as “Completers Lists”) and tools created by the agency to help identify the cohorts of students subject to FVT/GE Rule reporting requirements. ED suggested that “institutions pause reviews of the Completers Lists and use of the FVT/GE Reports as [ED] work[s] to resolve these issues.” In theory, the Completers Lists reflect ED’s records regarding the cohorts of students whose earnings will be included in the FVT/GE metrics. Upon receiving the lists, institutions are required to review them and make any necessary corrections within 60 days. Institutions must return the lists to ED, which will use them to seek earnings information, publish the FVT/GE metrics and, for certain programs, notify institutions of failing results. Without the timely production and review of the Completers Lists and other reports prepared by ED to assist institutions with the reporting obligations, the overall reporting timeline became compressed.
In response to these issues, on September 10, 2024, a bipartisan group of senators sent a letter to ED asking to further delay the FVT/GE reporting requirements until July 2025. The senators stated that “the rollout has continued to experience significant challenges that have greatly impacted students and postsecondary institutions” since its initial extension to October 1. Following this letter, and with no further updates addressing the system’s technical issues, ED announced on September 13 that the deadline for all required FVT/GE reporting is now January 15, 2025. This change, ED notes, will “allow [institutions] to prioritize their work on the FAFSA.” This includes finalizing work for the 2024 – 2025 FAFSA, as well as preparing for the release of the 2025 – 2026 FAFSA. ED’s stated goal is to produce “the first complete set of results under FVT/GE in time to help inform students’ college decisions next award year.” While ED will accept schools opting in to report certain information early, the announcement indicates that the issues with the Completers Lists have yet to be resolved.
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