FVT-GE Reporting: Where Do We Stand?

Posted on February 14, 2025 by Oozle Media

The uncertainty surrounding the Financial Value Transparency and Gainful Employment (FVT-GE) reporting requirement continues. The original reporting deadline of January 15, 2025, has passed, yet institutions remain in limbo as the Department of Education (ED) has not issued further guidance on extensions or changes. Whether due to an oversight or deliberate delay, this silence leaves institutions in a challenging position.

Despite numerous appeals to Congressional leaders and ED for an extension—especially given the likelihood that these regulations will be rescinded following the presidential inauguration on January 20, 2025—the deadline stood firm. A similar scenario unfolded in 2017 when the second iteration of Gainful Employment (GE-2) was rescinded shortly after the Trump administration took office. However, until a formal delay or repeal is announced, institutions must proceed as if compliance is still required.

How to Approach FVT-GE Reporting

To streamline the process, institutions can opt for transitional reporting, which requires submitting data for only the 2022-2023 and 2023-2024 award years. Under this approach, two cohorts of students must be reported:

• FSA Recipients Who Graduated or Withdrew During 2022-2023 or 2023-2024
  • Each graduate or withdrawal requires a single line of data in the GE submission spreadsheet.
  • This will be a “TA” record, requiring the total amount for their period of enrollment.
• FSA Recipients Still Enrolled as of June 30, 2024
  • Each student enrolled as of this date requires a single line of data in the GE submission spreadsheet.
  • This will be an “AA” record, requiring annual amounts for the 2023-2024 award year only.

For most institutions, reporting private education (non-federal) loan amounts will likely result in many $0.00 entries. Fortunately, spreadsheets allow for efficient data entry through copy-and-paste functions. While accuracy is important, spending excessive time on self-auditing is unnecessary—the priority was submitting the GE report on time.

Additionally, institutions were required to complete a program-based report, which included one line of data for each gainful employment program offered. This portion was largely informational and required minimal effort. Submittal spreadsheets were accessed through the NSLDS Professional Access website, where completed reports were also uploaded.

For more details, institutions can refer to the Gainful Employment User’s Guide.

How Did We Get Here? The History of Gainful Employment

The concept of Gainful Employment (GE) regulations dates back to the Obama administration, which sought to ensure that students in career-focused programs received an education that led to meaningful employment and manageable debt. The initial rules were introduced in 2010, targeting for-profit institutions and non-degree programs at public and nonprofit institutions. Programs that failed to meet debt-to-earnings thresholds risked losing federal student aid eligibility.

In 2017, under the Trump administration, these regulations were rescinded, citing concerns over fairness and administrative burden. This led to a period of regulatory uncertainty, where institutions operated without formal GE requirements.

The Biden administration reinstated and expanded gainful employment regulations under the Financial Value Transparency framework, reinforcing accountability measures for programs receiving federal aid. However, with another presidential transition, there is widespread speculation that the current regulations may again be repealed, mirroring the events of 2017.

Moving Forward

While the future of FVT-GE remains uncertain, institutions must remain vigilant and prepared for any regulatory shifts. Whether further guidance is issued or a repeal occurs, schools must continue to monitor updates from the Department of Education and industry groups advocating for additional clarity.