By Mike Bilfinger, Assistant Director, Public Policy, AACRAO
While the higher education sector is facing a flurry of challenges ranging from the impending demographic or enrollment cliff to growing public skepticism about the value of a degree, few education issues are as infamous as the rising cost of a college degree. With reports that some colleges will soon charge six figures for a degree, it’s no wonder that lawmakers and regulators are looking to address the issue.
To this end, the U.S. Department of Education (the Department) published final Financial Value Transparency (FVT) and Gainful Employment (GE) regulations that are meant to address the growing cost of college tuition and the student debt crisis. The regulations call for institutions to report on 26 metrics going as far back as eight years, including on programs that may no longer exist. The Department will then use this data to calculate a program’s debt-to-earnings ratio and earnings premium.
In the FVT/GE context, debt-to-earnings compares a student’s educational debt to the median earnings of a graduate from the same program. In contrast, an earnings premium compares the median earnings of graduates of a particular program to the median earnings of high school graduates in the same state. The hope is that prospective college students will be able to make a more financially informed decision about where to attend school and, in doing so, save themselves money.
A Summary Timeline of FVT/GE Reporting
Some readers may already be familiar with FVT/GE regulations because this isn’t the first time they have been proposed.
The Department previously held three different negotiated rulemaking processes in 2011, 2015, and 2019 that all got close to a finalized regulation, but each time, the rule was halted before being finalized.
Fast forward to October 2023, when the Department published the final FVT/GE rule in the federal register.
Shortly afterward, it became clear that the chaotic FAFSA rollout hindered institutions’ ability to comply with the regulations and submit data by the initial reporting deadline of October 30, 2024.
Then, the Department announced that it would delay the reporting deadline further to January 15, 2025.
Two days after the January 15, 2025, reporting deadline, the Department announced that it was reopening debt reporting for FVT/GE until February 18, 2025. To be clear, this extension ONLY APPLIES to debt reporting. Any data related to the completers lists needs to have been submitted by January 15, 2025, and institutions cannot make changes to their submitted lists at this point in time.
No Further Delay
The Department’s recently updated FAQs page makes it clear that no further delay is coming. This decision is despite multiple letters dated 11/12/24, 12/2/24, 12/13/24, and 1/29/25 from AACRAO and other higher education associations advocating for more time so that institutions can submit accurate data that truly reflects their students.
The deadline for institutions to submit their completers lists was January 15, 2025, and the deadline for debt reporting is February 18, 2025. Any schools that fail to meet these deadlines will be considered non-compliant. The FAQs do not specify what enforcement action might be taken against institutions found to be non-compliant. However, the regulations state that programs that fail either the debt-to-earnings or the earnings premium will be ineligible to receive Title IV federal financial aid funds starting in 2026.
What does this mean for your institution?
Regardless of where your institution is in terms of being able to submit its data, you are not alone. AACRAO members can visit the AACRAO Registrars discussion group in the AACRAO Exchange to connect with peers who are navigating this compliance challenge and share how they are rising to the occasion. AACRAO’s Government Relations team will continue to monitor this regulation and engage with the Department to share our members’ concerns. Please email gr@aacrao.org with any questions.