Gainful Employment Electronic Announcement #122 – Early Implementation of the Rescission of the Gainful Employment Rule
Pursuant to a June 28, 2019 Electronic Announcement, and the July 1, 2019 Final Rule rescinding the GE Rule, schools are permitted to immediately elect early implementation of the GE Rule rescission so long as the institution documents its early implementation decision internally. Institutions should document their decision, ensure that their staff is aware of the decision and its impact on GE Rule obligations, and maintains documentation evidencing such decision to be able to provide to ED (or an auditor) upon request. 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 otherwise be due October 1, 2019. Additionally, 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.
If you have any additional questions about this requirement, please contact your legal counsel or Ed Cramp at Duane Morris LLP (emcramp@duanemorris.com).
Webinar for Experimental Sites Initiative’s Federal Work Study (FWS)
July 11, 2019 – Webinar by BED Experimental Federal Work Study Initiative. ED has extended through September 23, 2019 the deadline by which institutions may submit a letter of interest to participate in the experimental initiative.
Invitation for Title IV Postsecondary Schools to Participate in the Payment Vehicle Account Program Pilot
July 12, 2019 – Deadline for schools to submit comments regarding the Department of Education’s (ED) Notice of Proposed Rulemaking (NPRM) proposing changes to federal accrediting agency criteria and distance education requirements.
July 24, 2019 – Deadline for schools to submit an expression of interest to ED to participate in a new Payment Vehicle Account (PVA) Program pilot as a no-cost alternative for delivering credit balance refunds.
July 31, 2019 – Deadline for schools to submit closeout data for 2017-18 Direct Loan Program.
August 2, 2019 – Deadline for schools to comment on draft updated 2020-21 FAFSA form.
Other – The Department of Education (ED) has circulated a report by the Financial Literacy and Education Commission (FLEC), Best Practices for Financial Literacy and Education at Institutions of Higher Education, which provides recommendations for schools to teach financial literacy skills and provide useful information to assist students making decisions related to student borrowing.
The report provides general best practices for financial education programs. Specifically, the report makes recommendations in the following areas:
Looking Ahead – The Federal Student Aid Office has opened registration for the 2019 FSA Training Conference scheduled for December 3 to 6 in Reno, Nevada. The FSA Training Conference is training provided for financial aid professionals by the government for those institutions receiving Title IV funds and is the largest training program in the United States serving the financial aid community. In 2018 more than 2,000 unique schools registered for the conference. Registration is free.