Financial Value Transparency, Gainful Employment (FVT/GE) Where Do We Go from Here?

By: Bob Covey-Robbins, Senior FAS Consultant

FVT/GE reporting is here to stay – are you ready for what’s next? With deadlines extending into 2025 and regulatory oversight tightening, ensuring compliance isn’t just about checking a box—it’s about protecting your institution’s future. If your school has completed its Completers List review and submitted an error-free Student Report and a Programs Report, you likely feel more comfortable than many others at this point. But the real question remains: Where do we go from here? 

Many schools that submitted data by January 15 could not obtain information on any errors that needed to resolution by the deadline, so the Department of Education (ED) reopened NSLDS to permit schools to complete the debt reporting by February 18, 2025. While this extension offers temporary relief, it reinforces a larger reality—FVT/GE compliance is an ongoing process, not a one-time task.  

Preparing for Future FVT/GE Reporting Cycles 

Unless laws change, the work completed so far isn’t a “once and done” deal. In fact, we have not even completed the entire first reporting cycle of FVT/GE. Institutions need to stay proactive to navigate what’s ahead, including new deadlines, evolving compliance expectations and potential regulatory risks.  

According to a Financial Aid Services (FAS) survey, 51% of institutions report being only somewhat confident in their team’s understanding of today’s financial aid regulations.

To help your institution stay ahead, we’ve outlined key deadlines and information below. 

• February 18, 2025 is the deadline to complete reporting. Institutions unable to meet this deadline will be required to submit an explanation to the ED explaining why it cannot comply. However, the complete process has not yet been announced, and there is still no clear understanding of what consequences a school may encounter if it cannot comply.
  
• For schools that were able to complete the reporting, the current regulations indicate that ED will or has already begun transmitting the Completers Lists to another Federal agent to obtain median earnings data.
• ED hasn’t updated GE 24-01, which included timeframe information in the publication of the metrics that will be determined in the coming weeks or months.  As of the date of this writing, the Electronic Announcement indicated that metrics will be published in early 2025, along with notifications to institutions on which programs fail Gainful Employment (GE) standards. Then, shortly after, ED will notify institutions that voluntarily discontinue failing GE programs that substantially similar programs cannot be approved until 3 years have elapsed.
  
• GE-24-01 also indicated that ED will provide additional information in early 2025 on how the metrics will affect the eligibility of failing programs.
• Since the next Completers List is due October 1, 2025, and schools have 60 days to review it, we should expect to receive the lists that need to be reviewed around August 1, 2025. According to current publications, the second year of Student and Program reports for award year 2024-2025 will also be due October 1, 2025. 
  
• The Electronic Announcement also indicates the ED plans to make its disclosure website system available by July 2026. The website will inform current and prospective students about the institutions’ GE and Eligible Non-GE Programs.
  
• GEN-24-04 also indicates that regulations becoming effective July 1, 2026 will require schools to provide warnings to current and prospective students for GE programs at risk of losing Title IV eligibility.
• Effective July 1, 2026, prospective students must acknowledge that they have reviewed the program warnings on ED’s website before entering an enrollment agreement with the institution for any non-degree or graduate program that failed the Debt to Earnings rates.   

FVT/GE Reporting Lessons Learned and Future Planning 

It may be beneficial for schools to have one or more “lessons learned” sessions with the people involved in the first round of FVT/GE Completers List review, Student Reports, and Program Reports. Documenting what went well and what did not, as well as who needed to provide input into the reports, may help make the next cycle go smoother.   

Here are some key areas to assess as your reflect on the process:  

Cross-Departmental Collaboration 

• Which departments needed to provide data for the reports?  

• Were we caught off guard by assuming that the FVT/GE was solely a financial aid office responsibility? 

Time and Resource Management 

• What time commitment was needed to pull data, compile reports, review results, and resolve errors? 

• Did we have the necessary staffing and technology resources to complete the process efficiently? 

• Do we need consulting support now, or will we need it for the next cycle? 

Data Accuracy and Compliance Readiness 

• Did we learn any valuable lessons about our institution’s enrollment reporting accuracy?  

• Did we learn that we need to improve our reconciliation of enrollment data directly or indirectly reported to NSLDS with the institution’s data? 

Institutional Support and Leadership Engagement 

• Did the team have the support of the upper administration to complete the work required? If not, what additional education/communication needs to occur for the next cycle? 

• Is the institution concerned that one or more of its GE programs may fail the required metrics?  If so, is there a plan for how the institution will improve or discontinue the program? 

• Do we have a timeline and strategy for implementing regulations that take effect on July 1, 2026? 

Knowledge Retention and Institutional Readiness 

• Does the institution have one or more champions who have and continue to diligently review all of the resources regarding FVT/GE from ED, NASFAA, National Student Clearinghouse website, Association for Institutional Research, etc.? 

• If key participants leave or change roles, do we have a plan for training their replacements and keeping institutional knowledge intact?

Staying Ahead of the Curve 

While we may be able to breathe a sigh of relief that most of the first reporting cycle is behind us, we must also recognize that, as of this writing, we are only eight months from the next reporting deadline. It is not too soon to begin the appropriate plans and preparations to stay ahead of the curve. 

Don’t wait until the next reporting deadline to take action. Financial Aid Services (FAS) can help you develop proactive strategies to enhance efficiency, build trust, and support your students throughout the process. Our team can assist with everything from internal reviews and data analysis to staff training and policy development.  

Partner with FAS and ensure your institution is prepared for the future of FVT/GE reporting.