Sleepwalking Through Gainful Employment's Growing Impact
GE is growing in scope despite data limitations; plus two data corrections
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We have a few topics in the queue (weekly interesting reads, Educause conference notes, commentary on OPM market chaos, etc), but I think it is important to offer a quick update on what we’re learning about Gainful Employment (GE). Namely, the scope is growing, and I need to make two corrections.
Too much of the higher ed community in the US tends to think of Gainful Employment still in terms of protecting students from poor-performing career training programs, and oh yeah, some broader disclosures. There is growing awareness that non-GE programs will have new reporting requirements through the new Financial Value Transparency (FVT) portion of the rules, but by and large I see too many people missing the significance of the expansion in scope.
I have described in some detail many of the data limitations and poor assumptions behind the GE & FVT rules, including that a large majority of programs do not have valid debt or earnings data and pass by not-failing (rather than pass by metrics). To its credit, the US Department of Education (ED) acknowledges the problem in the Regulatory Impact Analysis section of the final GE & FVT rules.
What is important to note, however, is that the myriad data limitations are not causing ED to be more cautious in the usage of GE metrics. Instead, ED is expanding the scope of GE’s usage despite the problems. The first example is of course the FVT disclosures and student acknowledgement forms.
But there are signs that there is more to come. Consider the implied or suggested usage of GE metrics to determine student loan discharge as discussed in this week’s negotiated rulemaking. As described in an update from Career Education Colleges and Universities:
A summary from the National Association of Student Financial Aid Administrators also described how negotiators not only picked up on this topic be discussed an expansion of usage (remember that GE and FVT rules are only based on program completers):
No one in neg reg or at ED seems concerned that they are relying on very limited data.
There are quite a few regulations and executive actions by ED that fall into the protect students from poor-performing programs, and hold these programs accountable theme. Increasingly, GE metrics are being used or being considered as a method to define which programs are performing poorly. Despite the numerous data limitations.
It would be a mistake for higher ed administrators to use complacency to not understand the impact of this scope expansion in the usage of GE metrics. Understand the data being used, understand the risks to schools, understand student loan cancellation implications, understand potential impacts on prospective students.
My two recent posts on the final GE & FVT rules included two descriptions that need correction.
The first is that I minimized the scope of FVT on Wednesday by describing the exemption of undergraduate degree programs. Alert reader (some might say my secret QA resource) Erika Swain from the University of Colorado pointed out that while ED’s fact sheet was vague on the subject, the rules show that all undergraduate programs will need to disclose their GE metrics and have them available on the public government website. The exemption is that undergraduate degree programs will not need to obtain student acknowledgement for programs that fail GE metrics. In other words, the exemption is only for notification and acknowledgement, not for disclosure.
Erika is correct, and I have updated Wednesday’s post.
The second correction is that I have not shown the difference between the College Scorecard data and the Program Performance Data (PPD 2022) in how median debt is calculated. The GE & FVT rules (and regulatory impact analysis) is based on PPD 2022, and that data includes non-borrowers in the median debt determination. The College Scorecard has better data overall, but its median debt fields do not include non-borrowers. I discovered this oversight based on a comment in the final GE & FVT rules.
I had made the mistake of not calling out this difference based on the confusing CS data dictionary that includes conflicting statements.
There is no access to the underlying data, meaning that institutions (and analysts) have to rely on ED for both the data and data descriptions, both of which need improvement. Moving forward, I will either directly use PPD 2022 data when available or at least note this discrepancy in data methodology in descriptions of charts.
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