You can use the “Graduated Status Reconciliation” list to update a student’s program status to Graduated, whenever a Graduated enrollment status isn’t reflected for the completed program. The enrollment status change to Graduated (G) will be sent from the Clearinghouse to NSLDS on your behalf. Essentially, this means that nearly EVERY participating Clearinghouse institution will be impacted by the FVT/GE legislation reporting requirements and should anticipate having to meet the reporting requirements by the deadline. Another impact to your Completers List will be the students who have completed programs but for some reason those programs were never reported to NSLDS. The FVT/GE Students with no Program Enrollment Report (SHNPE1) will allow you to identify the students with what is financial transparency a certified Campus Enrollment Status of ‘G’ and no certified programs. Schools can utilize the NSLDS Enrollment Reporting process to report the program data to ensure that your Completers List includes all eligible program graduates (completers).

• You should start reviewing your Completers List to ensure your graduated students are included.
• In April 2024, AIR surveyed members to better understand the resources and training needed to accomplish FVT/GE reporting.
• This amount should be the actual amount included in a particular student’s cost of attendance for that award year, in accordance with the institution’s process for developing the allowance.
• If fewer than 30 students completed the program during the four-year cohort period, D/E rates and the EP measure will not be calculated for the program.
• An institution will be provided 60 days to correct the information from the date that the Department provides the list to the institution.
• Because the Department has extended the deadline for institutions to evaluate their Completers Lists until September 30, 2025, those lists will be reverted to draft status in NSLDS by Monday, February 17, 2025.

FVT/GE Reporting

For students who have graduated or withdrawn as of the end of the prior award year, cumulative data for a student’s entire time in the program should be reported. For programs using standard reporting, 30 completers would be required for the 2-year cohort or the 4-year cohort for metrics to be calculated and debt and earnings data to be published. For programs using transitional rates, this would mean that there must be at least 30 completers in the 4-year cohort for earnings and at least 30 completers in the two most recently completed award years for debt. Both debt and earnings cohorts must meet the minimum size of 30 completers for transitional D/E rates to be calculated and released. For qualifying graduate programs, the two-year cohort consists of the students who completed the program during the sixth and seventh award years prior to the calendar year we use for earnings data in calculating the D/E and EP measures.

Student Level Reporting and Program Level Reporting +

The third report will assist schools in identifying students where enrollment was certified in NSLDS without program-level information. Completers Lists are provided annually to institutions, who have at least 60 days to make any corrections to their data in NSLDS following receipt of the list, after which the Department will submit the information to the Internal Revenue Service (IRS). The final list is also provided to institutions, but there is not a second opportunity for review. Once the Department has received median annual earnings data for programs from the IRS, those amounts will be used in calculating the debt-to-earnings and earnings premium measures. For this year, as mentioned above, schools have additional time to evaluate their Completers Lists and must complete that process by January 15, 2025.

What if my institution does not address the “Graduated Status Reconciliation” section?

The FVT/GE Students with No Program Enrollment Report (SHNPE1) provides school users with a list of students where the student was certified with campus-level enrollment data and no program-level enrollment data on NSLDS via the Enrollment Reporting process. The table below provides a high-level summary of the years and students covered by the review of completers lists and the submission of required reporting that is due by January 15, 2025. First, the Final Rule advances a new Financial Value Transparency policy intended to provide prospective students with consumer-minded data about important financial outcomes for individuals who complete Title IV programs. For example, a student enrolls in a 900 clock-hour program, incurring direct charges of $11,500 (assume the institution bills up front for the entire program). The student’s financial aid package includes a Federal Pell Grant of $7,395 and a Direct Subsidized Loan for $3,500 ($3,445.05 net disbursement amount). They are placed on an institutional financing plan for the remaining $659.95 of institutional charges.

Today, the Accounts Payable Management United States Department of Education (the Department) is pleased to announce the availability of an FVT/GE Topics page on Federal Student Aid’s Knowledge Center. This page provides institutions with a repository for regulations, policy guidance, publications, and operational information. When characterizing the regulatory efforts of the Department under the first Trump administration, a common refrain is that the agency simply rescinded or revoked all of the rules put into place by its predecessor, the Obama-era Department. For example, while the first Trump administration meaningfully revised the financial responsibility framework and the borrower defense rule, both regulations very much remained in the law. Professional licensure disclosures, introduced by the Obama administration, not only remained, but were moved to the general consumer protection section of the regulations and expanded to all programs, not just those offered via distance education. And while the first Trump administration would rescind much of the Obama-era Title IX guidance, it would replace that guidance with its own complex and lengthy regulation focused on the management of sexual misconduct on campus.

The same regulations, under 34 CFR 668.16(t), also treat an institution as not administratively capable if at least half of its total Title IV funds in the most recently completed award year were from GE programs that failed either the D/E or EP measures. This determination could impact the institution’s certification status and result in additional Departmental oversight. On July 1, 2024, final regulations for Financial Value Transparency and Gainful Employment (FVT/GE) requirements became effective. These requirements apply to most educational programs that are eligible to participate in the student financial assistance programs authorized under Title IV of the Higher Education Act of 1965, as amended (HEA). As a matter of ongoing compliance, institutions must then continue to certify these requirements in their PPAs on an ongoing basis and maintain currency as to the list of eligible programs.

Impact of New FVT/GE Requirements

Institutions will now have until January 15, 2025, to provide all required FVT/GE reporting and review the Completers Lists. We’ve been providing higher education institutions with tools for complying with federal reporting requirements since the 1990s, giving us deep and unprecedented experience in crafting solutions that meet the needs of both institutions and income summary regulators. If neither your institutional accrediting agency nor a programmatic accrediting agency requires data for students who take and/or pass a licensure exam, you should leave a space in the relevant fields. If one accrediting agency or the other (but not both) requires this information, report the values as calculated for whichever agency requires them. If both your institutional accreditor and a programmatic accreditor require you to report data on students taking and passing a licensure exam, you should report the values as calculated for the programmatic accrediting agency.