AAU joined ACE and 51 other higher education associations in sending a letter to Acting Secretary Carter 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 Acting Secretary Carter,
On behalf of the undersigned higher education associations, I write to ask that the Department of Education (Department) delay the reporting requirements for the financial value transparency (FVT) and gainful employment (GE) rule beyond the newly established Feb. 18 deadline.1 Given the change in the administration and the challenges institutions faced in reporting their data by Jan. 15, we ask that the deadline be extended from Feb. 18 to at least July 2025 and include an opportunity to also correct the completers list.
During the initial reporting window, we received feedback from institutions that found it difficult to successfully report the data due to a number of issues, to include lack of clarity in guidance issued from the Department; challenges with institutional student information software, such as Ellucian Banner; inaccuracies in institutional completers lists; challenges with the National Student Clearinghouse data; operational barriers resulting in the inability of institutions to upload their files efficiently to the National Student Loan Data System; and a lack of communication from the Department to institutional questions about the reporting requirements.
While the issues with the reporting burden is one that this new administration is inheriting, you have an opportunity to pursue a new approach that ensures institutions have an adequate amount of time to report the data. It is unacceptable that flawed data has been transmitted to the Internal Revenue Service (IRS) to calculate debt-to-earnings ratios and the earnings premium measures that institutions will be held accountable for. We ask that you terminate this process and only send data to the IRS after institutions have been given time to report with clear guidance. Institutions should not be penalized for data errors when it has been clear that more time was needed for accurate reporting.
The American Council on Education (ACE) sent a letter to former Secretary Miguel Cardona last month asking for a delay in reporting until July 2025 with results from a survey of senior college and university leaders.2 While we are asking for a delay until at least July 2025, we understand that you will need time to staff up, assess what has taken place, and finalize your approach towards FVT and GE. Time beyond July 2025 may well be needed in order to operationally process the data reporting, and we welcome continued conversation with you on this matter.
We thank you for your attention to this letter. It is our hope that you will consider these institutional concerns and delay the reporting requirements until July 2025, at the very least.
Sincerely,
Ted Mitchell President
On behalf of:
AccessLex Institute
Achieving the Dream
ACPA-College Student Educators International
AICU Rhode Island
American Association of Colleges and Universities
American Association of Colleges for Teacher Education
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
American Dental Education Association
American Indian Higher Education Consortium
APPA: Leadership in Educational Facilities
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 of Pennsylvania
Association of Jesuit Colleges and Universities
Association of Jesuit Colleges and Universities
Association of Public and Land-grant Universities
Association of Schools and Colleges of Optometry
Association of Schools and Programs of Public Health
Career Education Colleges and Universities
Council for Christian Colleges & 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 & Universities
National Association of College and University Business Officers
National 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
Southern Association of Colleges and Schools Commission on Colleges
State Higher Education Executive Officers Association
WASC Senior College and University Commission
Wisconsin Association of Independent Colleges and Universities
1 Federal Student Aid. (2025, January 17). Reopening of FVT and GE Debt Reporting Process Until Mid-February. U.S. Department of Education. https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2025-01-17/reopening-fvt-and-ge-debt-reporting-process-until-mid-february
2 American Council on Education. (2024, December 13). Request for Extension on Financial Value Transparency and Gainful Employment Reporting. https://www.acenet.edu/Pages/Advocacy-Documents.aspx