The U.S. Department of Education recently announced that more than 1,900 institutions have not reported or have underreported data required under the Financial Value Transparency and Gainful Employment (FVT/GE) regulations for the 2024 and 2025 reporting cycles. Institutions with outstanding reporting have until January 15, 2027, to come into compliance.

That is a big number and, not surprisingly, it has raised questions about why so many institutions are not fully current on their reporting.

I had the same question.

Over the past few weeks, I have asked Institutional Research (IR) and data professionals, including members of AIR’s Data Policy Advisory Group, what they are seeing at their institutions. I also checked in with the National Student Clearinghouse, which is working directly with institutions to help them complete FVT/GE submissions.

This is not a formal study, and the perspectives shared by advisory group members and other practitioners are not representative of all institutions with missing data. There is not one simple explanation.

But there are some consistent themes in what I am hearing, and I think they help put the numbers in better context.

First, not every institution on the list is in the same situation.

The headline number—more than 1,900 institutions—makes the problem sound fairly uniform. It is not.

About 58% of institutions appear to have submitted all seven required files. About 14% are missing only one or two, while roughly 12% are missing all seven. Inside Higher Ed similarly found that 578 institutions had not properly submitted any of the seven required files, compared with more than 1,900 missing or underreporting at least some data.

That distinction matters.

An institution that has successfully submitted five or six of seven files may be facing a very different problem from one that has not submitted anything. One member of AIR’s Data Policy Advisory Group wondered whether institutions missing just one or two files may be dealing with unresolved technical issues, support needs, or follow-up problems rather than an inability or unwillingness to do the reporting at all.

We do not have enough information to know for sure. But it is worth being careful about treating all 1,900 institutions as though they are in the same situation.

Capacity keeps coming up.

When I first looked through the Department’s lists, one thing jumped out at me. Many appeared to be smaller institutions, including less-than-two-year institutions and community colleges.

That made me wonder whether capacity might be part of the explanation, particularly at institutions with smaller IR/IE, data, financial aid, or administrative staffs.

The perspectives I received reinforced that observation.

One person at a small institution told me that completing the FVT/GE reporting essentially required taking one staff member off everything else he was doing for a period of time. They got it done, but not without consequences for other work —and, frankly, for staff morale.

One advisory group member from a two-year institution said they meet weekly, participate in the available training, and still barely make the deadline.

Another practitioner, whose institution is on the Department’s list, said the reporting does not fall under IR at their institution but described the broader reporting burden as overwhelming for an under-resourced institution.

What I find especially important is that some of these comments came from institutions that did complete the reporting. They are not explaining why they failed to report. They are telling us what it took to succeed.

To me, that indicates that capacity is not just part of the explanation for incomplete reporting. It is something we need to pay attention to as we think about compliance more broadly.

The work crosses institutional boundaries.

Another theme that came through clearly is that FVT/GE reporting does not necessarily sit squarely within one office.

The data, systems, and decisions needed to complete the work may cross financial aid, Institutional Research, student information systems, registrar or admissions functions, IT, and sometimes involve legal counsel.

One institution that successfully completed the reporting held weekly meetings among IR, financial aid, and admissions to stay on the same page, resolve errors, and work through questions.

At another institution, IR felt responsible for getting the reporting completed but did not have direct access to the National Student Loan Data System (NSLDS), where required reports had to be retrieved. That institution also had difficulty obtaining a needed Completers File.

That is a pretty good example of why “just get the reporting done” can be easier said than done.

The person responsible for completing a federal submission may understand exactly what needs to happen and still not control the data, systems, access, or decisions needed to make it happen.

There is a learning curve—and some of the barriers are surprisingly practical.

Practitioners also described a steep learning curve with a new and complicated reporting process.

Some of the challenges are what you would expect: understanding the regulations and reporting instructions and determining what data are needed.

Others are much more practical: obtaining the right files, resolving errors, determining who has access to which system, working through previous reporting cycles, and figuring out where to go when something does not work.

The questions raised during AIR’s August 5 webinar on FVT/GE and STATS give us another window into that experience. Participants asked about reporting requirements, Completers Lists, NSLDS access, unresolved errors, previous reporting cycles, file specifications, system permissions, and how existing FVT/GE obligations interact with early implementation of STATS.

Those questions do not tell us how widespread any one problem is. But taken together, they are a useful reminder that assembling the data is only one part of the job.

The timing and policy environment matter too.

There is another part of the story that is harder to see from the Department’s lists.

The original FVT/GE requirements arrived during an extraordinarily difficult period for financial aid offices as institutions worked through FAFSA implementation problems. Reporting deadlines changed multiple times. Since then, federal policy has changed again, and institutions are now preparing for the transition from FVT/GE to the new Student Tuition and Transparency System (STATS).

The National Student Clearinghouse, which is providing a free service to help institutions with FVT/GE submissions, sees resource constraints as an important part of the picture. But because the Clearinghouse is working directly with institutions on submissions, it also has a somewhat different perspective.

Its experience suggests that prioritization and uncertainty may have played a role as well.

Some institutions may have prioritized urgent FAFSA work over a new reporting requirement. Others may have assumed that the change in administration and the subsequent replacement of FVT/GE with STATS meant outstanding FVT/GE reporting would no longer be required.

The Department has now made clear that is not the case. Institutions remain responsible for completing the required reporting from the prior cycles.

None of this removes an institution’s responsibility to comply. But it does help explain how some institutions may have gotten to where they are today.

What does this mean for STATS?

The immediate issue is getting outstanding FVT/GE reporting completed. But I also think there is a lesson here as institutions prepare for STATS.

The themes we are hearing—capacity, cross-functional coordination, access to systems and data, technical barriers, and uncertainty about changing requirements—are not unique to FVT/GE.

As institutions prepare for STATS, it is worth asking some practical questions. Do the people responsible for the reporting have enough lead time? Do they have access to the systems and data they need? Are roles clear across offices? Are technical specifications and support available early enough for institutions to test their processes and fix problems before a deadline is looming?

The same questions matter for policymakers and organizations providing implementation support. Clear requirements, workable processes, useful training and technical assistance, and realistic attention to institutional capacity all affect the quality and timeliness of the data that ultimately get reported.

What can institutions do now?

For IR/IE and other professionals involved in this work, the immediate priority is knowing exactly where your institution stands—and making sure any outstanding problems are visible to the people who can help resolve them.

If reporting is incomplete, it may be worth getting beyond a general sense that “someone is working on it” and identifying exactly what is still outstanding.

Is a file missing? Is there an unresolved error? Does someone lack access to a system or data source? Is another office needed to move the work forward? Is staff capacity itself the problem?

A few questions may help focus the conversation:

• Are we fully current on our 2024 and 2025 FVT/GE reporting?
• If not, exactly what remains incomplete, and why?
• Is it clear who is responsible for getting the work finished?
• Do the people responsible have the staff time, data, files, and system access they need?
• Are there dependencies on financial aid, IT, student systems, or other offices that need to be resolved?
• Are there technical or prior-cycle problems that should be escalated or taken to one of the available technical assistance providers?

And this is one of those situations where communication with senior leaders matters.

IR/IE professionals are often in a good position to see when what looks like a reporting problem is really a capacity, coordination, or access problem. Senior leaders do not need to know the details of an FVT/GE file layout, but they do need to know when staff cannot solve a problem with the authority or resources they currently have.

AIR is also working to help institutions through this transition. Our Program Accountability Reporting Resource Center brings together current Department guidance, key reporting dates, AIR’s FVT/GE and STATS Reporting Readiness Checklist, webinar materials and Q&A, and other resources for institutions working through both outstanding FVT/GE reporting and the transition to STATS.

The goals are fairly simple: Know exactly where the institution stands. Understand what is getting in the way. And make sure the people doing the work have what they need to finish it.

Christine M. Keller, Ph.D., is the Executive Director and CEO of the Association for Institutional Research (AIR), a non-profit higher education association that empowers professionals and institutions to use data, information, and analytics to inform better decision making.