Law Prof: Law Schools Still 'Inaccurate' On Employment Numbers
On March 29, 2024, the Department of Education (ED or the Department) issued both Dear Colleague Letter GEN-24-04 and Electronic Announcement GE-24-01, providing guidance on certain regulatory requirements of the Financial...more
As most employers with employees working in California or assigned to a California location know, and as we reported in “Big Brother Just Got Bigger: Expanded Pay Data Reporting Expected to Hit the Golden State,” 2022...more
On March 29, 2024, the U.S. Department of Education published an electronic announcement delaying the reporting deadline for institutional data related to the Gainful Employment (GE) and Financial Value Transparency (FVT)...more
On October 10, 2023, the U.S. Department of Education (ED) published a Final Rule in the Federal Register (88 FR 70004) adopting new “Financial Value Transparency” (FVT) reporting and disclosure requirements for nearly all...more
With a potential government shutdown bringing into question the ability to meet the master calendar requirement, the Department of Education (ED) released the final and official Gainful Employment (GE) rule on October 10,...more
On May 19, 2023, the U.S. Department of Education (ED) published a Notice of Proposed Rulemaking (the Proposed Rule) in the Federal Register that would substantially amend and expand the regulatory requirements to which all...more
More than a year after the Department of Education (ED) completed its negotiated rulemaking covering an array of regulations related to institutional and programmatic eligibility for federal financial aid, ED published a...more
Formal Package Addresses Gainful Employment and Financial Value Transparency, Financial Responsibility, Administrative Capability, Certification and Ability to Benefit...more
After returning from recess on August 12, the California Senate Appropriations Committee took up the package of six remaining higher education bills intended to address concerns about private postsecondary education providers...more
The California Legislature began its summer recess on July 12 with a package of bills with broad implications for all institutions operating under BPPE authority still awaiting further Senate action. All seven of the original...more
On July 1, the US Department of Education released a final rule that rescinds the entirety of the Obama-era Gainful Employment (GE) Rule. While the technical effective date of the rescission of the GE rule is July 1, 2020,...more
After earlier delays in implementation, the U.S. Department of Education (the Department) has instructed postsecondary education institutions that more extensive distribution requirements for Gainful Employment (GE) program...more
Despite hopes that the US Department of Education might delay the expanded Gainful Employment disclosure requirements as it has done for the two past years, ED announced recently that covered institutions must meet these new...more
As outlined in our previous posts on proposed regulations in California, we are also tracking newly proposed laws introduced in Washington State, Oregon and New York, all part of a growing trend in which state (or in one...more
Events of the last week have reflected the Department of Education’s give-a-little, take-a-little approach to the Gainful Employment Rule. The department continues to take steps to implement certain aspects of the current GE...more
Keeping up with the Gainful Employment Rule has been a full time job in recent months. Between new Department of Education actions to prepare a second set of GE rates, negotiated rulemaking to write a new rule, a lawsuit...more
The Department of Education announces changes to the Gainful Employment Disclosure Template. Disclosure Template Deadline and Updates - In its Electronic Announcement, ED set April 6, 2018 as the new deadline for...more
The Department of Education issued a notice on August 18 that extends the deadline for all institutions to file alternate earnings appeals that challenge the debt-to-earnings rates issued for their GE programs in January...more
As described in our previous posts about ED’s new Audit Guide for annual Title IV compliance audits, the new auditing requirements include expanded testing in many compliance areas, such as gainful employment, incentive...more
As noted in our previous blog post on ED’s new Audit Guide, for the first time ED is requiring that independent audit firms conduct extensive testing relating to Gainful Employment (GE) data reporting and mandated disclosures...more
With minutes to spare before the close of business today, the Department of Education (ED) issued a Notice in advance of official publication in the Federal Register, announcing a delay in a number of requirements relating to...more
The Department of Education’s (ED) announcement that it plans to engage in a new negotiated rulemaking to revise the Gainful Employment (GE) Rule leaves unanswered critical questions regarding the implementation of certain GE...more
With continued questions about the Trump Administration’s commitment to Obama-era regulations, including the Gainful Employment (GE) Rule, one state is ready to jump into the fray and offer its own state-based alternative to...more
A smooth transition from the outgoing to incoming administration is a hallmark of democracy and something both parties strive to achieve. Among the myriad issues that must be addressed, one of the more important ones for both...more
The Third Circuit recently affirmed the denial of class certification in a suit alleging that a law school made misrepresentations about the employment status of its graduates, thereby inducing students to pay inflated...more