Is the “Gainful Employment” Requirement For Education Realistic?

by Dr. Dave Just, formally Dean of Corporate and Continuing Education at Community Colleges in MA, OH, PA, SC. Currently President of K&D Consulting

In May of 2019, the U.S. Education Department sent out reminders to universities of the July 1, 2019 deadline to update their websites to include specific information to comply with U.S. Obama-era “gainful employment” regulations. On July 1, 2019 it was revealed that the U.S. Department of Education published its final regulation to eliminate the so-called gainful employment rule. However, it may not go away entirely. Proponents of the rule say Congress might later choose to alter the regulation in the reauthorization of the Higher Education Act (HEA), which would require the department to again address the issue.nly focuses on the “supply-side” of the equation. No matter how much tinkering goes on with the rule, if employers and government policy fail to provide the quality jobs with quality compensation levels for which the focused college learning is directed, gainful employment may remain an unachievable goal.

In the 1990’s, computers and microprocessors began to appear in more and more aspects of a broader range of occupations. The alarms went off that this was going to dramatically and significantly alter the nature of work and the skills required in the future. Education at all levels began to reexamine its learning models and content in an, often, futile attempt to “keep up with change,” never mind get ahead of it.

“Futile” since, concurrent with this transformation, government was compounding this disruption with trade agreements and incentives to a smaller and smaller concentration of corporations that encouraged the exportation of the jobs that education programs were targeting. Additionally, employers imported workers to fill these positions (through visa programs) who would perform the same work at a fraction of the established compensation levels – many of whom attended the same U.S. education institutions.

We unfortunately know now that what followed was a rapid churning of jobs that used to provide income security and fulfilling careers to all levels of the workforce and made it nearly impossible for anyone to enroll in a 2 or 4-year education program confident there will be jobs waiting for them upon graduation.

There is another side to this contradiction. Wall Street players have invested billions of dollars in robotics and artificial intelligence, relentlessly pushing the narrative that these innovations will replace most jobs of the future. If that is the case, what role will education play? No doubt some jobs will be replaced, but I highly doubt that it will be any where near the claims once the true costs of benefits of this technology is revealed. After all, this movement has to contend with the disruption and exportation of work as well.

So how is education supposed to provide its service to emerging workers and moving target employers in the meantime as all of this plays out? Education needs to focus on the demand side with more than just words. In my experience, defining the target job classifications of employers in specific terms and managing the implementation of structured on-the-job training for employers, through whatever change occurs, provides two important functions.

First, it ensures that a graduating student has a structured training program in their field to transition to. Most employers today have relinquished this obligation to provide quality training, opting instead for informal, unstructured and one-to-one work exposure. Then they are disappointed when employees don’t seem to build the capacity the organization needs, take too long to demonstrate capacity and fail to provide the return on worker investment investors expect.

Second, the information gained through the job/task analysis conducted using the employer’s subject matter experts (meant to quickly replicate existing “star” performers) to ensure content validation and job relevancy can be used by the education partner to select highly relevant related technical instruction content, develop it if necessary, and continually improve it for change.

This model is simple, measurable, improvable, and repeatable. It requires little investment and is easily adaptable to a changing landscape. Furthermore, the employer will always see outcomes they can relate to their bottom line. It may not guarantee “gainful employment” as defined by education requirements, but it surely can go a long way to assuring more graduates find it.

When the institutions I served as Corporate and Continuing Education Director partnered with Proactive Technologies, it was not hard to sell the concept to employers. Once the benefits of the program were clear to a participating employer, they often expanded the program to include other critical job classifications, including salary positions. My institution stayed very busy and engaged with the employer providing candidates for employment and customized related technical instruction. We included contemporary programs, when relevant, such as robotics and Mechatronics. Often the programs were registered as apprenticeships at the employer’s request. Moreover, when employers saw the measurable and increasing value of workers in their programs, they were more inclined to adjust compensation in line with the value they could measure; they could see employees more valuable than expendable and had an easier time explaining it to their accountants.

And these programs are a far more efficient use of state workforce development grant funds. We used it as a no-risk way for employers to try this approach on one critical job classification to prove the concept internally. As the employer gained support (based on the results) to expand the program to other job classifications, the grant funding was phased out since upper management at these companies now perceived continuing to support the implementation and expansion of it as more as an investment.

Until government leaders understand the workforce development dilemma in holistic terms and enact legislation more in line with long-term stability and economic growth for all sectors, this approach works very well and provides graduates a better chance at gainful, continued and sustainable employment.

To learn more about this hybrid model of workforce development, contact K & D Consulting or a Proactive Technologies representative . Sign up to attend one of Proactive Technologies’ scheduled GoToMeeting presentations (to your computer) or setup one that fits your schedule. This can be followed up with an onsite presentation for you and your colleagues. A 13-minute promo briefing is available at the Proactive Technologies website and provides an overview to get you started and to help you explain it to your staff.

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    (Mountain Time) The philosophy behind, and development/implementation of, structured on-the-job training; how any employer can benefit from the PROTECH© system of managed human resource development in more that just the training area; building related technical instruction/structured on-the-job training partnerships for employers across all industries one-by-one. How this can become a cost-effective, cost-efficient and highly credible workforce development strategy – easy scale up by just plugging each new employer into the system. When partnering with economic development agencies, and public and private career and technical colleges and universities for the related technical instruction, this provides the most productive use of available grant funds and gives employers-employees/trainees and the project partners the biggest win for all. This model provides the support sorely needed by employers who want to partner in the development of the workforce but too often feel the efforts will not improve the workforce they need. Approx. 45 minutes

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    (Mountain Time) The philosophy behind, and development/implementation of, structured on-the-job training; how any employer can benefit from the PROTECH© system of managed human resource development in more than just the training area; building related technical instruction/structured on-the-job training partnerships for employers across all industries and how it can become an cost-effective, cost-efficient and highly credible apprenticeship. Program supports ISO/AS/IATF compliance requirements for “knowledge(expertise)” capture, and process-based training and record keeping. When partnering with economic development agencies, public and private career and technical colleges and universities, this provides the most productive use of available grant funds and gives employers-employees/trainees and the project partners the biggest win for all. This model provides the lacking support needed to employers who want to easily and cost-effectively host an apprenticeship.  Approx. 45 minutes

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