AIR has heard from institutions with questions about how prior-year Financial Value Transparency/Gainful Employment (FVT/GE) reporting affects their ability to complete the current reporting cycle through the National Student Clearinghouse. In particular, some institutions have been unsure whether they must resolve outstanding 2024 and 2025 reporting before they can proceed with 2026 reporting.

The National Student Clearinghouse has clarified that institutions using its reporting services for federal program accountability compliance —FVT/GE and Student Tuition and Transparency System (STATS) — do not need to complete outstanding 2024 and 2025 work within the Clearinghouse platform before beginning 2026 reporting. Institutions may choose to complete the 2026 reporting cycle first and return to prior-year corrections later. This guidance addresses the sequencing of work through the Clearinghouse; it does not change institutions’ federal reporting obligations or deadlines.

Two federal deadlines are relevant: October 1, 2026, for the current reporting cycle, and January 15, 2027, for unreported or under-reported 2024 and 2025 data. The Clearinghouse strongly recommends completing reporting chronologically when possible because the reporting years are connected. Changes to prior-year data may affect subsequent reporting, including the identification of programs that need to be added through Newly Added Programs files.

Chronological reporting is strongly recommended, but it is not required for those institutions using the Clearinghouse services. The appropriate approach will depend on what corrections are needed, the amount of work involved, and the institution’s capacity.

Start by confirming what actually needs to be corrected

Before reopening a prior reporting cycle or beginning substantial rework, institutions should first determine whether corrections are actually necessary.

The Clearinghouse reports that, in some cases, institutions identified as having incomplete reporting had already submitted the required data but may have problems with specific fields or formatting. Examples include missing leading zeros or records incorrectly indicating whether a student received Title IV aid.

In other cases, institutions may find that the data previously submitted were accurate and simply need to be verified.

That means institutions should not assume that being identified as having incomplete or potentially incomplete reporting necessarily requires rebuilding an entire prior-year submission.

Consider direct NSLDS corrections when only a small number of records are affected

If only a limited number of Student-Level Records or Program-Level Records need to be corrected, the Clearinghouse recommends considering whether the updates can be made directly in the National Student Loan Data System (NSLDS), rather than reopening and reworking an entire reporting cycle through the Clearinghouse platform.

The Clearinghouse identified several available options:

• Student-Level Records can be added, edited, or deleted directly in NSLDS.
• Program-Level Records can also be added, edited, or deleted directly in NSLDS.
• Institutions may use NSLDS submission spreadsheets when appropriate, provided the files meet NSLDS formatting requirements.

Institutions should confirm with the Clearinghouse and/or U.S. Department of Education/Federal Student Aid (FSA) which approach is appropriate for their specific circumstances before making corrections.

Institutions can choose how to sequence the work

The Clearinghouse has indicated that institutions generally have two options:

• Complete 2026 reporting first and return to prior-year reporting and corrections afterward; or
• Address outstanding  2024 and 2025 reporting and corrections before completing the 2026 cycle.

The Clearinghouse will support institutions using either approach.

Institutions choosing to complete 2026 reporting first should understand that reporting out of chronological sequence may create additional reconciliation work later because prior-year changes may affect subsequent reporting.

Institutions choosing to correct prior-year reporting first should consider the amount of work involved and whether that approach is feasible given the October 1, 2026, deadline for the current reporting cycle.

A practical approach

For institutions determining how to proceed, the Clearinghouse’s guidance can be summarized in three steps:

1. Validate whether prior-year corrections are actually needed.
2. If only a small number of records need correction, determine whether direct NSLDS updates are appropriate.
3. Consider the level of effort and data implications of each sequencing option before deciding whether to address prior-year corrections first or complete 2026 reporting first.

Verify federal reporting status with FSA and NSLDS

The Clearinghouse can help institutions work through the reporting process, but institutions should use FSA and NSLDS information to verify their federal reporting status and compliance requirements.

For the 2024 and 2025 reporting cycles, FSA has published a spreadsheet showing which Program and Student files have been received from each institution. Importantly, appearing on the spreadsheet indicates that a file was submitted; it does not confirm that the submission was complete or accurate. Institutions remain responsible for ensuring that all required data have been successfully submitted and that any errors have been resolved.

FSA has said it will continue updating the status spreadsheet through the January 15, 2027, deadline for unreported or under-reported 2024 and 2025 data. During its September 10 FVT/GE and STATS office hours, FSA indicated that it plans to update the spreadsheet monthly.

Institutions should also consult FSA’s new Student Tuition and Transparency System (STATS) topic page, which serves as a repository for federal guidance, announcements, and training related to STATS and earnings accountability.

For questions:

• General questions about FVT/GE or STATS regulations and processes: ReportingSTATS@ed.gov
• Technical questions about NSLDS tools or functionality: NSLDS Customer Support Center, 1-800-999-8219 or nslds@ed.gov

AIR will continue updating its FVT/GE/STATS resources as additional guidance becomes available and as institutions work toward the October 1, 2026, and January 15, 2027, reporting deadlines.