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Focus on Regulation

U.S. Department of Education releases Gainful Employment Disclosure Template – Use required by January 31

On November 22, 2013 the U.S. Department of Education (“ED”) released a Gainful Employment Disclosure Template (“GEDT”).  ED regulations require institutions to use the GEDT to provide all required gainful employment disclosures.  No later than January 31, 2014 institutions must use the output document that the GEDT generates to meet gainful employment disclosure requirements.

The GEDT is an online application that creates a standardized output document with the gainful employment disclosure information.  ED has provided guidance about its use:

  • Data entered into the GEDT are not saved or communicated to ED; rather, the GEDT creates an HTML file for institutions to upload to their own websites. The output HTML file includes all required gainful employment disclosures for a program. 
  • The institution must generate a separate output file for each gainful employment program.
  • According to the Quick Start Guide released by ED, the output file must also be included on any printed invitations, advertisements, promotional materials, or solicitations that mention or otherwise refer to the specific gainful employment program, when feasible.
  • An institution may not use its own template.  ED has said: “To ensure that the required data are disclosed to prospective students in a consistent and consumer-friendly format, institutions MUST use [the HTML output file] developed by the Department of Education to disclose the required information about their GE Programs.”
  • According to ED, an institution may not modify the output files in any way: “If the HTML code within the output files is modified in any way, please be aware that the institution will no longer be in compliance with the GE Program regulatory requirements.” The GEDT provides optional context boxes if the institution wants to provide additional explanations and clarifications related to the program and the disclosure information.

ED had previously informed institutions that the required disclosures must be posted on the gainful employment program’s home page and could not be provided through a hyperlinked site or document.  Recent Electronic Announcement #46 explains that institutions must “prominently provide a direct link from the home page of the GE Program website to the program’s disclosure page that was generated by the disclosure template application.”  In addition, any other web page that contains general, academic, or admissions information about the gainful employment program must also contain a “prominent and direct link to the program’s web home page or to the GE Program disclosure page generated by the application.”