What it takes for colleges to comply with recent ROI demands

Each institution must build a new and collaborative data set spanning as much as eight years, often requiring data from an older Student Information System or data that may be flawed.
Sean McTighe
Sean McTighe
Sean McTighe is the executive director of Title IV compliance and data intake operations at the National Student Clearinghouse.

University administrators across the nation breathed a collective sigh of relief when a set of higher ed reporting requirements—probably the most complicated colleges have seen in a decade—were recently delayed to January 2025.

The reprieve in these Financial Value Transparency (FVT) and Gainful Employment (GE) regulations is temporary, however, and the most prescient higher education administrators recognize that the compliance landscape is shifting permanently: Colleges and universities need to be ready to answer questions about return on investment. Whether or not the FVT and GE regulations keep to the current timeline, the reality is that taxpayers, parents, students and policymakers today all want to know the value of an education.

The origins of the FVT and GE regulations date back to President Obama’s administration, which proposed GE as a method for holding for-profit colleges accountable for the outcomes of their graduates. President Trump rescinded the regulations during his term. President Biden then brought them back—along with the FVT requirements, to answer questions on return on investment for all higher education institutions participating in Title IV.

What it takes for colleges to comply

Each institution must build a new and collaborative data set spanning as much as eight years, often requiring data from an older Student Information System or data that may be flawed. The sooner an institution recognizes the uniqueness of this requirement and assembles a task force, identifying where the data elements are located and determining who will address discrepancies—the better off it’s going to be.



These are stressful times for college administrators. Even before they begin to address these new reporting requirements, they have faced unprecedented challenges with the new FAFSA form and on-campus issues and are often operating with constrained resources.

Many institutions have turned for help to the National Student Clearinghouse, where we have built a new platform designed to address the FVT and GE reporting requirements and alleviate as much of the burden on institutions as possible. Our nonprofit organization already helps about 3,600 colleges and universities fulfill their regulatory compliance, providing us with a clear path to helping institutions with these new regulations.

Long term, ROI is here to stay

As much as they appreciate the Education Department’s temporary reporting reprieve, the institutions we are working with can see the long-term trend—a growing chorus of families and policymakers who want to know the value of a degree.

Even with an election coming up, the trend won’t change. Whether you’re looking at Republican legislative proposals or Democratic regulations, state-level requirements or accreditation requirements—even questions from parents and students—there is a nonpartisan focus today on assessing return on investment.

The ongoing conversation about return on investment (ROI) has created increased pressure for schools to demonstrate the value of a postsecondary degree or completion. By taking the right steps today, colleges and universities can set themselves up to successfully answer ROI questions and demonstrate the value.

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