October Compliance Reporting

Campus Security Act of 1990

20 U.S.C. § 1092(a)(1) (O ) and § 1092 (f) (5) and 34 C.F.R. § 668.46 and § 668.41

The Campus Security Act requires colleges to report campus crime statistics and security measures to all students and employees by October 1 of each year. Crime statistics must be submitted to the Department of Education by October 15th of each year.

Equity in Athletics Disclosure Act of 1994

20 U.S.C. § 1092g; 34 C.F.R. §§ 668.41 and 47

Each coed institution of higher education that participates in Title IV programs and has an intercollegiate athletic program must make available on request by October 15 of each year to enrolled students, prospective students, and the public a report regarding gender equity in its athletic programs. Students must receive an annual notice of the availability f this report. No deadline is specifically enumerated, but typically occurs before the end of September. Within 15 days of making the report available to students, prospective students, and the public and no later than October 30th of each year, the institution must submit the report to the Secretary of Education.

Higher Education Act Financial Value Transperancy and Gainful Employment

20 U.S.C. §§ 1001, 1002; 34 C.F.R. Part 600 and § 668 Subpart Q

Effective July 1, 2024, U.S. Department of Education regulations went into effect with the stated goal of addressing concerns related to student loan debt in virtually all academic programs that offer Title IV Federal Student Aid to students—both GE and “non-GE” programs—the latter being degree programs at public or nonprofit institutions. Under these regulations, “[b]eginning on July 1, 2026,” the Department will publish on a website “debt-to-earnings” and “earnings premium” metrics for these programs. To facilitate the Department’s metrics calculations, the regulations require institutions to report to the Department on multiple data points for most Title IV programs, with the first report due February 18, 2025, and extended to September 30, 2025. The Department will not calculate metrics for small programs (fewer than 30 students completing in a four-year cohort) and programs that do not participate in Title IV. Institutions must link to the Department’s website in various program materials.

For programs that fail the Department’s metrics, the regulations require institutions to provide certain disclosures to students as of July 1, 2026. These programs are:

Graduate non-GE programs at public and nonprofit institutions (i.e., not undergraduate degree programs at public and nonprofit institutions), which must secure pre-enrollment acknowledgements that students have reviewed the Department’s website; and GE programs, which must secure the same acknowledgements and also provide students with pre-enrollment warnings about the program’s potential loss of Title IV eligibility.

If a gainful employment program fails the same metric (debt-to-earnings or earnings premium) for two out of any three consecutive award years where the metrics are calculated, the program (and “substantially similar” programs) becomes ineligible for Title IV for three years.