A third and final negotiated rule-making session will be held on March 12 to define this rule for schools that receive Title IV aid - federally funded financial aid such as the Pell Grant and Stafford loans, for example. In these sessions, representatives from the U.S. Department of Education and affected constituencies work together to reach consensus on proposed rules.
The Obama administration had strengthened the gainful employment rule. Under the Trump administration, however, the Department of Education is considering the removal of the bulk of penalties for-profit colleges and universities would face. When the Department published its most recent proposal in February, many higher education experts weren't surprised by the call to defang the controversial Obama-era regulation.
Before analyzing how the potential loosening of the gainful employment rule would affect student loan borrowers, it's important to understand the current rule.
What Gainful Employment Is
For higher education programs to award federal student aid to students, a program must lead to a degree at a nonprofit or public institution or, for nondegree programs at such institutions or all programs at for-profits, prepare students for gainful employment in a recognized occupation.
To measure whether a program prepares students for gainful employment, the debt-to-earnings ratio is calculated. This ratio measures the ability of individuals to reasonably repay their student loans borrowed for these programs, based on the typical loan debt and earnings of a cohort of borrowers who completed their program.
If the debt-to-earnings ratio is too high for a program or institution, it could lose the eligibility to award federal student aid to students. This type of penalty provides an incentive to institutions to ensure their programs are robust enough for individuals to gain practical knowledge to enhance their employment prospects.
Prior to the second negotiated rule-making session in February, the Education Department released its recommendations and updated language for gainful employment, which would significantly change the regulation's reach and strength.
Extending the Reach but Removing Sanctions
The Education Department's new proposal would extend the gainful employment rule to all higher education programs eligible for federal student aid. The Department explained: We propose to change the focus of these regulations from programs that prepare students for gainful employment in a recognized occupation to all 'educational programs.'
At first glance, it seems the Education Department is bolstering efforts to ensure all students are well informed about the effectiveness of program offerings. But the Department also proposes eliminating the sanction that designates a program as passing or failing based on its gainful employment debt-to-earnings ratio.
With the proposed standards, programs would be considered "acceptable" or "low-performing. This change in terminology lessens the implications for students when considering programs that may not be performing as well as others.
Most significantly, low-performing programs wouldn't lose eligibility for Title IV student aid. The only penalty a school would face is a requirement to notify students about the ability of their graduates to repay their student loans.
But with only an information disclosure, students could easily overlook this notice – among the many other disclosures they receive – and the implications of a low-performing program could be lost on them. If the Department isn't providing incentives for institutions to offer and maintain high-performing programs for employability, it may be more difficult for prospective students to evaluate program options effectively.
Other Ways to Determine if a Program Is Worth Completing
Even without gainful employment sanctions, students can compare programs at various institutions to determine a good fit. Your first and best indicator of a successful institution, in the Student Loan Ranger's opinion, is to look at the cohort default rate, known as CDR.
The CDR measures the percentage of borrowers who defaulted on their federal student loans within three years of leaving the institution. The higher the CDR, the more students who are defaulting on their loans. Schools that have rates higher than 30 percent face losing Title IV aid eligibility.
A low CDR indicates that students who attended an institution are able to repay their loans effectively, making it safe to assume they are able to find gainful employment. The Student Loan Ranger advises students to never attend an institution with a high CDR without researching what caused former students to default at such a high rate.
Another useful tool for researching your college and university options is the Department of Education's College Scorecard, which shows average cost, debt, graduation rates, default rates and salaries.
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