To align with changes enacted in the One Big Beautiful Bill Act (OBBB), the Department of Education has proposed a new accountability framework for all college and university programs that qualify for Title IV financial aid. The Student Tuition and Transparency System (STATS) will replace the current Financial Value Transparency and Gainful Employment (FVT/GE) framework, setting earnings thresholds for graduates of any higher education program that receives federal financial aid. STATS is set to take effect in in July 2026, with the first earnings premium calculations to be released in 2027.
While the FVT/GE framework applied only to gainful employment (GE) programs (programs at for-profit institutions of higher education and non-degree programs), STATS will apply to any college or university program that qualifies for Title IV financial aid. STATS will replace the debt-to-earnings (D/E) metric with a revised earnings premium metric. As currently proposed, the earnings threshold for undergraduate programs is the median earnings of a working high school graduate (aged 25 to 34) not enrolled in postsecondary education in the state in which the target institution is located. (If the institution enrolls more than 50% of its students from out of state, the national median is used). For graduate programs, the earnings threshold is the median earnings of a bachelor's degree recipient (aged 25 to 34), using the lesser of median earnings in the state, median earnings in the same field of study in the state, or median earnings in the same field of study nationally. (If the institution enrolls more than 50% of its students from out of state, the lesser of the national median or the national median in the same field of study is used).
Both GE and non-GE programs will now have to meet this threshold in two of three consecutive years. Those programs that do not meet this accountability standard would lose Direct Loan eligibility. Due to the two of three consecutive years earnings test, the earliest a program could lose Direct Loan eligibility is July 2028.
In January 2026, the Department of Education's Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) committee distributed a dataset for all Title IV-eligible programs that includes an indicator of whether a program would pass or fail the earnings accountability measure, using data on program graduates from 2015-16 to 2024-25 (codebook, fact sheet, appendix; note that the column in the dataset indicating whether a program would pass or fail is "fail_obbb-cip2_wageb", with 1 indicating fail).
Data-Forward Leadership: Key questions
How does the earnings premium improve our understanding of how well we are serving students? What is still missing?
What do we lose by replacing the debt-to-earnings ratio with the earnings threshold?
Should the accountability metric(s) used be the same for not-for-profit and for-profit institutions? for undergraduate and graduate programs?
What data would you also include in telling the story of how your program or institution serves its students in terms of post-graduation outcomes?
Key Resources:
Full text of proposed Student Tuition and Transparency System (STATS): https://www.federalregister.gov/documents/2026/04/20/2026-07666/accountability-in-higher-education-and-access-through-demand-driven-workforce-pell-student-tuition (Public comments, and Inside Higher Ed's summary of the public comments)
Department of Education Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee meeting transcripts, recordings, and materials: https://www.ed.gov/laws-and-policy/higher-education-laws-and-policy/higher-education-policy/negotiated-rulemaking-for-higher-education-2025-2026#ahead-committee
AHEAD dataset: https://www.ed.gov/media/document/ahead-session-2-program-performance-data-debt-earnings-and-earnings-test-metrics-112908.xlsx
Also: codebook, fact sheet, appendix.
National Association of Student Financial Aid Administrators (NASFAA) Deep Dive Analysis of New Accountability Framework: https://www.nasfaa.org/news-item/38137/Deep_Dive_Understanding_Analyses_of_New_Accountability_Frameworks_Under_the_One_Big_Beautiful_Bill_Act
NAFSAA comparison of Financial Value Transparency/Gainful Employment (FVT/GE) vs. STATS: https://www.nasfaa.org/uploads/documents/OB3_GE_FVT_Comparison_Regulations.pdf