Are you on track for successful FVT reporting?

So much bad news hit the nation’s financial aid offices in the last admissions cycle that you’d be forgiven for missing some important details. Just to recap, we saw a catastrophically delayed FAFSA, a last-minute about-face by the feds on allowing batch corrections to FAFSA forms, a greatly increased compliance burden associated with new privacy standards for FAFSA income data and, last but not least, a development that is the focus of this post—an entirely new and burdensome workstream associated with the Department of Education’s Financial Value Transparency and Gainful Employment (FVT/GE) initiative.

Two main things to know about FVT

Let’s begin by covering some basics for you, focusing on the FVT piece of the program. (Its GE provisions have limited applicability for most academic programs at most four-year colleges and universities.)

There are two key things to be aware of.

First, starting in July 2026 the initiative will make available to the public unblinded financial outcomes information for every academic program at every college and university in the country. More specifically, it will report two financial outcomes measures for students graduating from each program: their average debt-to-earnings ratio and their average earnings premium.

Metrics that FVT will report on every academic program at every college and university

While the Department of Education is not planning on sanctioning underperforming undergraduate programs, students enrolling in graduate programs that fail the debt-to-earnings test will be required to formally acknowledge their awareness of that underperformance before federal financial aid can be released to them.

There’s plenty more to say about the potential impact of the outcomes metrics, but we’ll leave that for another day. FVT poses a more immediate challenge to enrollment leaders—namely, the reporting burden associated with it, which is the second of the two main things mentioned above.

A big reporting burden and a looming deadline

Colleges are on the hook for providing the Department of Education with an extensive set of data points that it will use to calculate the metrics described above (work that will fall to financial aid teams at some schools and institutional research teams at others).

An outcry from financial aid professionals and pressure from a group of 20 senators led the feds to push back the reporting deadline from October 1 of this year—timing many considered impossible, even for capable and well-resourced financial aid teams—to July 2025. That will certainly help, as will FVT-reporting tools and support services from organizations such as the National Student Clearinghouse and the College Board (via its PowerFAIDS system).

Even so, the task facing financial aid offices is daunting.

One reason is that some of the information the Department of Education is asking for requires combining data points that often reside in different parts of a school’s digital information landscape—e.g., in their student information system versus their accounting system. Doing that in an automated and scalable way can be a heavy lift, involving coding and other similarly expensive work.

Another challenge concerns data integrity. For example: As mentioned above, FVT reporting occurs at the level of academic programs. Academic departments occasionally change the CIP codes that are used to define their programs, and if they did so in one of the years you’re gathering data for, that could interfere with your data-collection efforts or result in you reporting faulty numbers.

Multiply the examples cited above by 10 and you’ll get some sense of the FVT reporting challenge facing financial aid teams.