This Guideline outlines the requirements for recording and maintaining information pertaining to the collection of information necessary for OEDS reporting, specifically a student’s first pursuits post-graduation from any program offered by a licensed private career school. 8 NYCRR § SECTION 126.19. SCHOOL ACCOUNTABILITY
Upon a student’s enrollment, a licensed director, agent, or teacher shall create the First Destination Record. The school then shall maintain this form and student information for seven years after a student’s date of graduation or withdrawal from the program.
Section 126.11(a)(12) of the Commissioner’s Regulations states, in part, that all records and files of a school shall be maintained for seven years, and shall include records of employment or educational status of each student graduating during a reporting period established by the commissioner, which include the name, address and telephone number of hiring employer, the job title and the starting date of employment, or the name and address of the educational institution and the date when the student started instruction at that institution.
As captured on First Destination Record, the information required to be maintained within the student file includes:
- Name of the graduate’s new employer/ educational institution/ military service branch
- Address of the graduate’s new employer/ educational institution/ military service branch
- Phone number of the graduate’s new employer/ educational institution/ military service branch
- Student Outcome Status:
- Withdrawn/Dropped
- Graduated
- Continuing with Education
- The graduate’s new role/position title
- The graduate’s start date at their reported first destination. Schools may update this information if it is within one hundred eighty days post-graduation.
It is required that schools maintain a First Destination Record in the students’ file for all students enrolled as of September 1, 2025. The data collected with this form will be used for the 2027 OEDS Reporting Period of July 1, 2025 - June 30, 2026. Any student data preceding September 1, 2025, will still need to be included in the respective OEDS reporting period collection, but schools will not be expected to produce the First Destination Record for these individual students enrolled prior to September 1, 2025.
First Destination Record Data Usage
- Annual OEDS Reporting
School Directors shall use the First Destination Record to tabulate information needed for OEDS reporting such as the relatability of the graduate’s first destination experience to their field of study, and overall job placement rates.
- School Catalog
Section 126.9(a)(14) of the Commissioner’s Regulations states, in part, that each licensed private career school shall publish a catalog or bulletin, which shall be furnished to each prospective or enrolled student, which shall include data regarding student completion and job placement as set forth in subdivision (f) of section 126.10 of this Part for the two most recent reporting periods. Such reporting periods shall be defined by the Commissioner.
- Advertising
Schools shall use these records to tabulate information needed to produce accurate and informative advertising and promotional materials with the prior approval of their Field Associate.
Section 5005(b) of Education Law states, in part, that if the school advertises job placement rates as means of attracting students to enroll in the school, the school shall disseminate to all prospective and enrolled students, the most recent available data on employment and graduation statistics for students who have attended that school.
Section 126.2(c)(3) of the Commissioner Regulation states, in part, that enrollments of students shall not be sought by advertising or promotional material representations of job placement rates, unless such representations can be documented with the data required under section 126.10 of this Part.
Any questions or concerns regarding this policy should be directed to the school’s field associate.