AAU joined ACE and 48 other higher education associations in sending a letter to Secretary Cardona at the U.S. Department of Education requesting a delay to the deadline for reporting requirements in financial value transparency (FVT) and gainful employment (GE).
Dear Secretary Cardona,
On behalf of the undersigned higher education associations, I write to share the results of a survey of colleges and universities that clearly identifies the challenges they face in meeting the Jan. 15, 2025, deadline for reporting requirements in financial value transparency (FVT) and gainful employment (GE). Given the responses received, and the implications of a change in administration, we ask that the deadline be extended from Jan. 15 to July 2025.
To better understand the concerns of our member institutions, the American Council on Education (ACE) conducted a survey of college and university presidents that was distributed by ACE and other higher education organizations. The survey yielded a total of 355 respondents, with a representative sample coming from public and private, nonprofit institutions and having a broad impact on a diverse array of institutional types.
The survey found that colleges and universities were unclear as to their requirements under the FVT and GE regulations. To be exact, 54 percent of respondents found the sub-regulatory guidance to be just somewhat clear, or remained neutral in their thoughts around this, while 40 percent of respondents felt that the guidance was not clear at all. In addition, 82 percent of respondents believed that their completers lists would not truly be finalized within a five-day period largely due to the fact that the Department allows for institutions to make corrections to their draft completers lists until Jan. 15,1 and a new administration begins just five days later.
Among other findings:
- 79 percent of respondents expected it to take more than 30 days to receive their official notice of determination;
- 73 percent of respondents expressed the need for additional resources to comply with the regulations (with 37 percent articulating significant need); and
- An overwhelming 87 percent of respondents shared their support for a delay in the reporting deadline to July 2025.
The attached document summarizes the survey responses and provides more information on how participants responded. We thank you for your attention to this letter. It is our hope that you will take institutional concerns seriously and delay the reporting requirements until July 2025.
Sincerely,
Ted Mitchell President
On behalf of:
ACPA-College Student Educators International
American Association of Colleges of Nursing
American Association of Colleges of Osteopathic Medicine
American Association of Collegiate Registrars and Admissions Officers
American Association of Community Colleges
American Association of State Colleges and Universities
American Association of Veterinary Medical Colleges
American Council on Education
Association for Institutional Research
Association of American Medical Colleges
Association of American Universities
Association of Catholic Colleges and Universities
Association of Community College Trustees
Association of Governing Boards of Universities and Colleges
Association of Independent California Colleges and Universities
Association of Independent Colleges and Universities in Massachusetts
Association of Independent Colleges and Universities in Pennsylvania
Association of Independent Colleges and Universities of Ohio
Association of Independent Colleges and Universities of Rhode Island
Association of Jesuit Colleges and Universities
Association of Public and Land-grant Universities
Association of Schools and Programs of Public Health
Career Education Colleges and Universities
Commission on Independent Colleges and Universities in New York
Connecticut Conference of Independent Colleges and Universities
Consortium of Universities of the Washington Metropolitan Area
Council for Christian Colleges and Universities
Council for Higher Education Accreditation
Council of Graduate Schools
EDUCAUSE
Great Lakes Colleges Association
Hispanic Association of Colleges and Universities
Higher Education Loan Coalition
Higher Learning Commission
Independent Colleges and Universities of Texas
Independent Colleges of Indiana
Independent Colleges of Washington
Maryland Independent College and University Association
Michigan Independent Colleges and Universities
NASPA-Student Affairs Administrators in Higher Education
National Association of College and University Business OfficersNational Association of Colleges and Employers
National Association of Independent Colleges and Universities
National Association of Student Financial Aid Administrators
New England Commission of Higher Education
North Carolina Independent Colleges and Universities
State Higher Education Executive Officers Association
UPCEA, The Online and Professional Education Association
WASC Senior College and University Commission
Wisconsin Association of Independent Colleges and Universities
1 Federal Student Aid. (2024, September 13). Updated Timeline for Financial Value Transparency and Gainful Employment Reporting and Completers Lists. U.S. Department of Education. https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2024-09-13/updated-timeline-financial-value-transparency-and-gainful-employment-reporting-and-completers-lists