Graduate Earnings Outcomes and How Schools Prove Them

Graduate earnings proof is evidence of what a program's completers earn after they leave. For FVT, GE and Workforce Pell, the Department of Education calculates median earnings from federal agency data, never from school surveys. The school controls three things. Its completer list, the program and cost data it reports, and its own dated employment records.

This guide summarizes the regulations and data documentation as they stood on October 14, 2026. Each formula below links to its primary source. Check the current text before you rely on it for a filing.

Who calculates graduate earnings

Six sources produce most of the earnings numbers a school will be judged by or compared against. None of them takes a salary from the school. Several start from the completer data the school reports, which is why that list matters.

The exact formulas and thresholds

FVT and GE earnings premium (current rule)

The earnings premium measure applies to GE programs and eligible non-GE programs under 34 CFR 668 Subpart Q. The Department compiles the completer list from the school's reported data, removes excluded students, and sends the list to a federal agency with earnings data. That agency returns the median in aggregate, plus a count of students it could not match. It never returns individual earnings.

• The earnings threshold. Census Bureau median earnings for adults aged 25 to 34 with only a high school diploma or equivalent who worked or were looking for work, in the school's state. The national figure applies when fewer than half of the program's students are from that state.
• The cohort. Completers from a two-year cohort period, widened to four years when the two-year count is under 30. With fewer than 30 completers after exclusions, no measure is issued.
• The consequence. A GE program that fails the same measure in two out of any three consecutive award years loses Title IV eligibility under 34 CFR 668.603.

GE debt-to-earnings rates (current rule)

The earnings test from July 1, 2027

The STATS and Earnings Accountability final rule, published in the Federal Register on July 1, 2026 at 91 FR 40136, takes effect July 1, 2027. It removes the debt-to-earnings rates and keeps one earnings test for GE programs and eligible non-GE programs. Three details change how earnings are read.

• Timing. Earnings are measured in the fourth tax year after program completion, for completers who are working.
• Pass line. A program passes when median earnings equal or exceed the threshold. For undergraduate programs the threshold is still adults aged 25 to 34 with only a high school diploma, now counting those who worked and were not enrolled.
• Consequence. Failing in two out of any three consecutive award years makes a low-earning outcome program, which loses Direct Loan eligibility.

For what changes in reporting and appeals, see our gainful employment and FVT guide.

Workforce Pell value-added earnings

• The earnings year. The first full tax year after the award year in which the student completed.
• Small programs. The Department needs at least 30 completers, adding up to three earlier award years to reach that count, and at least 16 matched earnings records. Below either line, no value-added earnings figure is calculated for that year.
• The result. The Department publishes the figure at least three months before the award year. Zero or negative value-added earnings make the program ineligible for Pell.

Workforce Pell also has a placement test. Through the 2028-29 award year, at least 70% of students must be employed during the second quarter after exit, calculated from administrative data including wage records and certified by the Governor (34 CFR 690.94(a)(2)). The full program rules are on our Workforce Pell page.

Public earnings sources

• College Scorecard. Earnings are W-2 wages and deferred compensation plus positive Schedule SE self-employment earnings, for students who received federal aid. Students still enrolled or not working in the measurement year are left out, and small cells are suppressed for privacy. Completer medians are published one and five years after completion (field of study and institution documentation, September 2025).
• Census PSEO. Earnings at the 25th, 50th and 75th percentiles one, five and ten years after graduation, in 2023 dollars, for institutions whose transcript data reach the Census Bureau through a data-sharing agreement. Graduates who earn less than full-time work at the federal minimum wage, or who have two or more quarters with no earnings in the year, are dropped (PSEO documentation).
• State UI wage records. The same records drive WIOA's median earnings indicator, measured in the second quarter after exit (20 CFR 677.155(a)(1)(iii)). Census notes that unemployment insurance coverage excludes independent contractors and the unincorporated self-employed, and that federal workers are not covered by state UI.

What the school controls and what the government calculates

The split is clean once you see it. The government owns the earnings. The school owns the inputs and the evidence around them.

The government calculates

• Median earnings for each program, from federal agency data, returned in aggregate.
• The earnings threshold, from Census data, published each year.
• Debt-to-earnings rates until the STATS rule replaces them.
• Value-added earnings for each Workforce Pell program.
• The Workforce Pell placement rate, which the Governor certifies from wage records.

The school controls

• The accuracy of program and student data it reports under 34 CFR 668.408, including CIP code, credential level and completion dates. That report has no earnings field.
• Corrections to the completer list within 60 days of receiving it, for FVT, GE and Workforce Pell.
• Tuition and fees, which sit inside both the debt measure and the Workforce Pell test.
• Its own record of where each graduate works, with a date and a source.
• The career support that gets graduates into better-paid jobs before the earnings year arrives.

What to collect, and when

The federal earnings year arrives years after a student leaves. Your own evidence has to start much earlier, so you know which programs are trending low while there is time to act.

1. 1At enrollment. Collect a personal email and mobile number, since school email often expires after completion. Confirm the program's CIP code and credential level match what it teaches.
2. 2At completion. Record the exact completion date and exit status. Ask about job offers, employer, title and pay in the same message, and log the reply with its date.
3. 3Second quarter after exit. Check employment for every completer. This is the Workforce Pell placement window and the WIOA earnings quarter.
4. 4First full tax year after completion. This is the Workforce Pell earnings year. Refresh employer and title for each Pell completer.
5. 5When the completer list arrives. Reconcile it against your records and correct errors inside the 60-day window.
6. 6Fourth tax year after completion. Under the STATS rule this is the year that counts. Keep employment records current through it, program by program.

Common mistakes

• Treating survey salaries as the federal number. A first-destination salary is useful context. It is not the median the Department will use.
• Missing the completer list window. The 60-day correction period is the only direct say a school has in the list behind the federal median.
• Wrong CIP code or credential level. Programs are measured as reported. A program filed under the wrong code is compared on the wrong record.
• Assuming a small program is safe. Under 30 completers in two years, the cohort widens to four years. Value-added earnings can reach back three earlier award years.
• Trusting wage records to be complete. Self-employed graduates, contractors and some federal workers do not appear in state UI data. Keep your own record for them.
• Comparing numbers that measure different things. Scorecard, PSEO and the federal tests use different populations, years and dollar bases. Line them up before you compare.
• Publishing an individual’s pay. Show medians and counts by program. Never show a single graduate.

How Prentus helps

Prentus is the career outcomes platform. It does not calculate the earnings premium, debt-to-earnings rates or value-added earnings. Those come from federal data. Prentus gives your team a verified employment record for every program, with a source on every record.

• A monthly LinkedIn scan plus third-party sources find where graduates work.
• AI reviews the evidence and your staff confirm each outcome.
• Email and SMS surveys reach graduates the scan cannot.
• CSV export hands the record to whoever prepares a filing.

The same record shows which programs are pulling earnings down while there is still time to act. Students use Prentus from day one until they are hired, so the career work and the evidence live in one place. See how verified outcomes look in public on Where Grads Work, read how schools compare first-destination surveys with automated outcomes scanning, and read our guide to what schools file for gainful employment compliance.

Primary sources

All sources checked October 14, 2026.

• 34 CFR 668 Subpart Q, sections 668.402 to 668.405 and 668.408 (FVT framework, earnings premium, D/E rates, data process, reporting)
• 34 CFR 668.603 (ineligible GE programs, Subpart S)
• STATS and Earnings Accountability final rule, 91 FR 40136, published July 1, 2026, effective July 1, 2027
• 34 CFR 690.95 (Workforce Pell value-added earnings) and 690.94 (completion and placement)
• 20 CFR 677.155 (WIOA primary indicators of performance)
• College Scorecard data documentation (September 2025 versions)
• Census Bureau LEHD, Post-Secondary Employment Outcomes data and documentation

This guide is general information, not legal advice. Check the current regulations before you rely on them.