Over the past two months, Thompson Coburn’s Higher Education Practice presented a five-part webinar series examining in great detail the U.S. Department of Education’s gainful employment regulations. In addition to discussing the calculation and management of debt-to-earnings rates, we reviewed the opportunities institutions will have in 2016 to challenge the Department’s calculations, the student warnings required of schools with failing rates, and the “new” disclosure requirements that go into effect in January 2017.
If you missed a session of our “Navigating Gainful Employment” webinar series, would like to view a session a second time, or would like to share the information with other members of your team, the recordings of all five webinars are now available free and on demand at the following location:
Here you’ll find the recordings for each of the five sessions in the series:
- How to Project Reliable Debt-to-Earnings Rates
- Strategies for Improving Debt-to-Earnings Rates
- Completer List Challenges, Debt Challenges, and Alternative Earnings Appeals
- Preparing for and Managing Required “Student Warnings”
- Managing (and Challenging) the New GE Disclosures
In addition, you can download a PDF of the slides from each presentation, which includes active hyperlinks to gainful employment resources. Finally, we also have included the latest version of our desk guide: “How to Project Gainful Employment Rates,” which sets out a step-by-step process for projecting debt-to-earnings rates.
We encourage institutions offering gainful employment programs to take advantage of these and other resources. While we support continuing efforts to seek the improvement of the gainful employment regulations through political and legal channels, it is unclear if and when such efforts may bear fruit. The political landscape is in flux, making it very difficult to predict whether lobbying efforts will be successful in the near term. And earlier this month, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit rejected the only remaining significant court challenge to the current gainful employment framework. With these thoughts in mind, we suggest that institutions should aggressively prepare to comply with the regulations in their current form for the foreseeable future.
As always, if you have any questions about any aspect of the gainful employment regulations, feel free to contact me. In addition, in the coming months I will be speaking on topics related to gainful employment at the following higher education conferences:
- NASASPS Annual Conference (Austin, TX – April 10-13, 2016)
- Regions PCCS Conference (Philadelphia – April 17-19, 2016)
- Missouri and Kansas Association of Private Career Colleges and Schools (St. Louis – May 20, 2016)
- Regions PCCS Conference (Chicago – May 22-24, 2016)
- APSCU Annual Conference (Orlando, FL – June 5-8, 2016)
If you will be in attendance and would like to discuss gainful employment issues, please feel free to reach out in advance, or to swing by for the presentation.
Aaron Lacey is a partner in Thompson Coburn’s Higher Education practice, and editorial director of REGucation. You can find Aaron on Twitter (@HigherEdCounsel) and LinkedIn, and reach him at (314) 552-6405 or firstname.lastname@example.org. Special thanks to summer associate Jesse Doggendorf, who contributed significantly to this post.