COE Guidance on Change in Program Length

January 24, 2024

Guidance on Changing Programmatic Length to Remain Compliant with the U.S. Department of Education’s Gainful Employment Revisions to § 668.14(b)(26)(ii)

The Council on Occupational Education (COE) has established a temporary process to support institutions that are reducing a program’s length to remain compliant with recent amendments to Part 668 – Student Assistance General Provisions in the Federal Register involving Gainful Employment § 668.14(b)(26)(ii).

The following steps and considerations are designed to create a seamless approach to reducing program length:

  1. Submit a letter on institutional letterhead to COE’s Compliance Division (contact information below) requesting a change in program length for Gainful Employment compliance reasons. The letter must:
    1. Include a brief rationale for the change;
    2. Identify the “before” and “after” lengths of each program; and
    3. Include state-approval documentation.
  1. No fees will be required with the letter of request.
  2. Institutions within the moratorium on substantive changes may submit a letter of request to change a program’s length solely to remain compliant with Gainful Employment.


Additional Considerations

  • The timeline for approval may vary based on the number of pending letters of request and programmatic applications. For a typical programmatic review, COE requests that institutions plan for a period of 6-8 weeks for initial review. Please plan accordingly based on any deadlines established by state or federal agencies.


  • The above process does not apply to other programmatic changes (e.g., change in delivery mode, new programs, name changes, or increases in program length). Please use existing applications or the MiniForm to request such changes. Approval is not guaranteed.


Contact Information

Non-Public Institutions | Dr. Tangela Purifoy, [email protected]

Public Institutions | Ms. Cherie Jolley, [email protected]