400 Maryland Avenue, S.W., Washington, DC 20202

www.ed.gov

The Department of Education’s mission is to promote student achievement and preparation for global Competitiveness

by fostering educational excellence and ensuring equal access.

UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF POSTSECONDARY EDUCATION

 Overview of the Gainful Employment Information Rates

Session 3: March 14-18, 2022

This memo presents an overview of the information rates published by the Department of Education (ED) 

to provide the field with data to better understand the impact of the proposed rule. The data analyzed 

here include informational Gainful Employment (GE) metrics for GE programs offered by all domestic 

institutions currently in operation based on PEPS information as of February 22, 2022. These are draft 

data that are both subject to, and expected to, change from year to year. Moreover, due to limitations in 

data available to the Department, the methodology used to produce these data differs from the 

Department’s proposed methodology in the 2022 Negotiated Rulemaking sessions, which relies on data 

elements that institutions would need to but do not currently report. ED believes these information rates 

give the best possible depiction of the rule’s impact given the data currently available to the Department, 

but the debt-to-earnings rates published here will differ from those produced under the proposed 

methodology for some programs. Institutions may be able to use their own data to assess how their debt 

measures created using ED’s proposed methodology may differ from the measures presented here.

For programs with a two-year cohort (excepting those with medical/dental residencies due to data 

limitations), if the GE rule were in place the data released in Fall or Winter 2021-2022 would be based on 

the set of Title IV students completing their credential in the 2014-2015 and 2015-2016 award years. 

Students in such programs would have their earnings captured in the third calendar year following the 

end of the award year in which they completed—calendar years 2018 and 2019, respectively, for the two 

cohorts. The earnings data used in the information rates are assembled following this structure. 

To better contextualize the impact of the Gainful Employment rule, we include in the associated data file 

information on other programs that are not defined as GE programs under the statute and the number of 

credentials awarded in those programs using data from IPEDS. The data on credentials awarded from 

IPEDS include both Title IV and non-Title IV students, whereas the GE information rates data are based 

only on Title IV award recipients. These data can be used to roughly estimate the number of all students 

enrolled in programs that pass and fail the GE metrics relative to the total number of students enrolled in 

different institutions, fields of study, and sectors.1

Notes About the Data Used for 2022 Informational Rates

In interpreting the rates presented in this memo, several key properties of the data used to produce these 

data should be noted:

1 The data are imperfect for this purpose, since the IPEDS data measure completions and not total enrollment by 

program. Moreover, IPEDS data do not distinguish between Title IV and non-Title IV students by program.
Page 2 – Gainful Employment Information Rates Analysis | REVISED

• ED has proposed capping individual borrowing amounts at the amount paid for tuition, fees, 

books, and supplies for each student before calculating median debt levels. ED does not currently 

have reported data to implement the cap, so estimated median program debt levels may be 

higher in the information rates as a result. See data presented at Session 2 for more information 

on the effects of capping total loan debt.

• ED has proposed including institutional and private loan debt in calculating median debt levels. 

ED does not currently have the reported data, so estimated median program debt levels reflect 

only Federal student loan debt and may be lower in the information rates as a result. 

• To calculate median debt levels by program, ED used the debt levels for the two-year cohort of 

completers between 2015-2016 and 2016-2017—a cohort differing from that used to measure 

earnings. We measure their debt levels in 2016 dollars (adjusting by the CPI), and use this as an 

estimate for the debt levels of the AY2015 and AY2016 2-year cohort assuming debt levels 

remained unchanged in real terms between these cohorts. 

• To provide the public with these informational rates, ED relied on program-level median earnings 

data through the College Scorecard. ED notes that the methodology for calculating these earnings 

data differs from that used in the 2014 rule in several important ways: 

o The lag from when students complete a program to when their earnings are measured is 

longer, and median program earnings are likely to be significantly higher as a result. The 

methodology proposed in the 2022 Negotiated Rulemaking utilizes this longer timeframe. 

o Earnings data are computed at the 4-digit, rather than 6-digit level. The methodology 

proposed in the 2022 Negotiated Rulemaking utilizes this same 4-digit CIP code level.

• Programs that require students to complete a medical or dental internship or residency would 

receive a longer timeframe for measuring earnings than other programs under the methodology 

proposed in the 2022 Negotiated Rulemaking and under the 2014 GE regulations. Those programs 

are not identified in our data, so those programs are instead included here with the same 

timeframe for earnings (three years) as other GE programs in the information rates. Earnings for 

those programs are likely lower as a result.

• The earnings threshold measure in the information rates and in this analysis use a state-specific 

threshold for all programs (measured as the median earnings of a working adult aged 25-34 with 

only a high school diploma or equivalent in the state in which the institution is located). In the 

proposed methodology for the 2022 Negotiated Rulemaking, programs where a majority of 

students enroll from a state other than the state where the institution is located would use the 

national median earnings of workers aged 25-34 with a high school diploma as the threshold). 

This may mean that some programs, particularly fully online programs, would be subject to a 

higher or lower earnings threshold under the proposed rule, depending on the state in which the 

institution is located.

Based on the outcomes of negotiations, comments received following publication of a proposed rule, and 

further analyses of the best data available to ED, the methodology to produce program median earnings, 

debt levels, D/E rates, and earnings thresholds may change. Moreover, some year-to-year variability in 

the metrics is to be expected. The data presented are the best available currently to illustrate the impact 

of the Gainful Employment rule, but the outcomes depicted in the information rates for particular 

programs may differ from those generated by a future gainful employment rule.
Page 3 – Gainful Employment Information Rates Analysis | REVISED

Coverage of the GE Rule

Counting programs at the 4-digit CIP code level, IPEDS completion survey data show that approximately 

164,000 programs had at least one credential awarded by domestic institutions of higher education that 

are still currently operating and participating in the title IV, HEA programs as of February 2022. Of these 

programs, 40,377 are gainful employment programs based on the statutory definition—accounting for 

about 25 percent of all programs, and about 25 percent of all completions reported in IPEDS data. The 

table below shows these numbers by institution control. In total, the information rates include 6,818 

programs at private for-profit institutions; all such programs are GE programs under the statute. The rates 

include 53,082 programs offered by private nonprofit institutions; 4,908 of those (9 percent) are GE 

programs. The rates also include 104,062 programs at public institutions, of which 28,651 (28 percent) 

are GE programs. 

The information rates data were produced only for programs with at least 30 completers in the 2-year 

cohort. Most GE programs graduate few students each year, and so only 3,989 GE programs have debtto-earnings measures in the information rates and 4,184 programs have earnings data available to 

construct the earnings threshold measure. Slightly less than half of the completions reported in GE 

programs in IPEDS data are in programs for which GE metrics are available. At for-profit institutions, about 

two in five programs have reported data, though those programs cover 88 percent of credentials awarded 

in that sector. At private nonprofit institutions, fewer than 250 of the nearly 5,000 programs have 

published data (about 5 percent of programs), and those programs cover about 40 percent of credentials 

awarded in GE programs in that sector. At public institutions, 968 programs (3 percent) have DTE rates 

published and 1,032 (4 percent) have earnings threshold measures published, covering 17-18 percent of 

GE credentials awarded. 

Total 

Programs

Total GE 

Programs

% of Total 

Completions in 

GE Programs

GE Programs with 

Published DTE / 

Earnings 

Threshold Metrics

% of GE Credentials 

Awarded in 

Programs with 

Published DTE / 

Earnings Threshold 

Metrics

Private ForProfit6,818 6,818 100% 2,799 / 2,912 87.9 / 88.4

Private 

Nonprofit

53,082 4,908 5.7% 222 / 240 40.5 / 40.9

Public 104,062 28,651 19.7% 968 / 1,032 17.5 / 17.8
Page 4 – Gainful Employment Information Rates Analysis | REVISED

GE Programs Debt-to-Earnings Performance

The table below shows the debt-to-earnings performance of GE programs by institution control and 

credential level using a measure of median debt that includes Parent PLUS loans. Among certificate 

programs (both undergraduate and graduate certificates), 3,535 are offered by for-profit institutions, 

4,908 by nonprofit institutions, and 960 by public institutions. Of those, 210 programs at for-profit 

institutions fail the measure, covering 9.9 percent of all credentials awarded in the sector; 18 programs 

at nonprofit institutions fail, covering 2.2 percent of credentials awarded; and 12 programs at public 

institutions fail, covering 0.1 percent of credentials awarded. Among Historically Black Colleges and 

Universities (HBCUs),2 just 3 of 332 GE programs fail the DTE rates, representing 0.08 percent of all 3,654 

programs offered by HBCUs; and no Tribally Controlled Colleges and Universities (TCCUs) have published 

GE information rates data.

Within other credential levels, only degree programs offered at proprietary institutions are GE programs. 

Of 1,686 for-profit associate degree programs, 199 (11.8 percent) fail the DTE rates, covering 32.9 percent 

of all credentials awarded at that level. Of 948 for-profit bachelor’s degree programs, 117 fail the DTE 

rates (12.3 percent), covering 23.3 percent of all credentials awarded. Among 484 master’s degree 

programs at for-profit institutions, 47 (9.7 percent) fail the DTE rates, covering 14.0 percent of credentials 

awarded. Of 123 doctoral-level GE programs, 12 (9.8 percent) fail the DTE rates, covering 24.7 percent of 

GE credentials awarded. And among 42 first professional degrees covered by GE, 4 (9.5 percent) fail the 

DTE rate, covering 25.9 percent of credentials awarded.

Overall, 619 programs fail the DTE rates. If Parent PLUS loans were excluded in calculating median debt 

levels, ED estimates that 91 fewer programs would have failing rates, though we note that inclusion of 

PLUS may change the status of fewer programs if loans were capped at tuition, fees, books and supplies 

as ED has proposed. Of the 91 programs where including Parent PLUS loans changes their DTE metric from 

passing to failing, 90 are in the for-profit sector. Of those, 50 are certificate programs, 24 are associate 

degree programs, and 16 are bachelor’s degree programs.

Number of 

GE 

Programs

Programs 

Passing DTE 

Without 

Published DTE 

Metrics 

Programs with DTE 

Metrics

% of All GE 

Credentials 

Awarded in 

Programs with 

Failing DTE Rates

Passing 

DTE 

Failing DTE

Private For-Profit 

Certificates

3,535 1,917

1,408 210 9.9

Private Nonprofit 

Certificates

4,908 4,686

204 18 2.2

2 In this analysis, HBCU status is defined based on an institution’s 6-digit OPEID. 
Page 5 – Gainful Employment Information Rates Analysis | REVISED

Public Certificates 28,651 27,683 956 12 0.1

Associate 1,686 1,114 373 199 32.9

Bachelor’s 948 586 245 117 23.3

Master’s 484 288 149 47 14.0

Doctoral 123 81 30 12 24.7

First Professional 42 33 5 4 25.9

GE Programs Earnings Threshold Performance

The table below shows the earnings threshold performance of GE programs by institution control and 

credential level. Among certificate programs (both undergraduate and graduate certificates), 3,535 are 

offered by for-profit institutions, 4,908 by nonprofit institutions, and 960 by public institutions. Of those, 

1,089 programs at for-profit institutions fail the measure, covering 51.1 percent of GE credentials 

awarded; 78 programs at nonprofit institutions fail, covering 23.5 percent of all GE credentials awarded; 

and 190 programs at public institutions fail, covering 2.9 percent of all GE credentials awarded. Among 

Historically Black Colleges and Universities (HBCUs), just 5 of 332 GE programs fail the earnings threshold 

measure, representing only 0.14 percent of all 3,654 programs offered by HBCUs; and no Tribally 

Controlled Colleges and Universities (TCCUs) have published GE information rates data.

Within other credential levels, only programs at proprietary institutions are GE programs. Of 1,686 forprofit associate degree programs, 155 (9.2 percent) fail the earnings threshold measure, covering 21.1 

percent of all credentials awarded at that level. Of 948 for-profit bachelor’s degree programs, 24 fail the 

earnings threshold measure (2.5 percent), covering 2.9 percent of all credentials awarded. Among 484 

master’s degree programs at for-profit institutions, 9 (1.9 percent) fail the earnings threshold measure, 

covering 1.3 percent of credentials awarded. Of 123 doctoral-level GE programs and 42 first professional

degree GE programs, none fail the earnings threshold measure.

Number of 

GE 

Programs

Programs Passing 

Earnings Threshold 

Without Published 

Earnings Threshold 

Metric

Programs with Earnings 

Threshold Metrics

% of All GE 

Credentials 

Awarded in 

Programs with 

Failing Earnings 

Threshold

Passing 

Earnings 

Threshold

Failing 

Earnings 

Threshold

Private For-Profit 

Certificates

3,535 1,866 580 1,089 51.1
Page 6 – Gainful Employment Information Rates Analysis | REVISED

Private Nonprofit 

Certificates

4,908 4,668 162 78 23.5

Public Certificates 28,651 27,619 842 190 2.9

Associate 1,686 1,077 454 155 21.1

Bachelor’s 948 574 350 24 2.9

Master’s 484 278 197 9 1.3

Doctoral 123 79 44 0 0

First Professional 42 32 10 0 0