VIEWPOINT: ED Delays Financial-Value Transparency and Gainful-Employment Reporting

The U.S. Department of Education (ED) recently announced a revised deadline for submitting required data under the Financial Value Transparency and Gainful Employment (FVT/GE) rules. The new deadline for institutions to report and review Completers Lists has been extended to Jan. 15, 2025 — moving from the previous deadline of Oct. 1, 2024. This change […]

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The U.S. Department of Education (ED) recently announced a revised deadline for submitting required data under the Financial Value Transparency and Gainful Employment (FVT/GE) rules. The new deadline for institutions to report and review Completers Lists has been extended to Jan. 15, 2025 — moving from the previous deadline of Oct. 1, 2024. This change follows ongoing Title IV challenges faced by colleges and universities, including delays and issues related to the rollout of the new Free Application for Federal Student Aid (FAFSA). Many institutions and groups like the National Association of Student Financial Aid Administrators expressed concerns that meeting the initial deadline would be difficult amidst these ongoing complications. Additionally, a group of 20 senators recently requested a further extension to July 2025, reflecting widespread concern over the ability to comply with the current timeline. ED acknowledged these challenges and noted that the extended deadline will allow colleges and universities to prioritize critical FAFSA-related activities while still ensuring compliance with FVT/GE reporting requirements. ED also said that it is addressing issues identified in the Completers Lists, with updates expected soon. While the Department of Education has granted more time, it is also planning to offer an opt-in opportunity for those (likely few) institutions that wish to submit their data earlier. Colleges and universities are advised to actively follow further guidance from the department to ensure that they meet the new Jan. 15, 2025 deadline. Bond also will continue to offer updates and information to support clients’ effective and compliant implementation of the regulations.                              
Seth F. Gilbertson is a member (partner) in the Buffalo office of Syracuse–based Bond, Schoeneck & King PLLC. He brings direct experience in labor and employment, student affairs, investigations, and regulatory compliance matters to his clients, with an emphasis on educational institutions and nonprofits. Contact him at sgilbertson@bsk.com. This article is drawn and edited from the law firm’s Higher Education Law Report blog on its website.
Seth F. Gilbertson: