Postsecondary Schools Subject to New Gainful Employment Disclosure Obligations as of July 1, 2019 – Duane Morris
On May 9, 2019, the Department of Education published Gainful Employment Electronic Announcement #119, announcing the release of a new 2019 Gainful Employment (GE) Disclosure Template. On May 23, 2019, the Department followed up with Electronic Announcement #120, which provided additional detail regarding the GE disclosure distribution and delivery requirements for that template. On June 7, 2019, the Department published Electronic Announcement #121, providing additional guidance on the 2019 GE Disclosure Template. All postsecondary institutions offering GE programs are required to utilize the new GE template. A GE program is any Title IV educational program offered by a proprietary institution and any nondegree (less than two year) Title IV program offered by other institutions.
Action Item
The GE disclosure delivery and distribution requirements in the GE rule were previously delayed by the Department until July 1, 2019. These recent announcements by the Department make clear that these delivery and disclosure obligations are effective as of July 1, 2019. All institutions offering GE programs should ensure that they are prepared for the July 1, 2019, deadline by closely reviewing the requirements detailed below and in the electronic announcements referenced above, including with regard to all promotional materials.