Colleges prepare for OBBBA earnings accountability by getting their program data right, modeling which programs are at risk, and keeping their own evidence of where graduates work. The checklist below covers the data to collect for each program, the office that should own it, and when it needs to be done.
How do colleges prepare for OBBBA earnings accountability? They work through a short list of data and ownership tasks before the STATS and Earnings Accountability final rule takes effect on July 1, 2027. Under that rule, a program whose graduates' median earnings fall below the earnings threshold in two of any three consecutive award years loses Direct Loan eligibility. The Department of Education calculates earnings from federal data, so a college cannot submit its own salaries. What it can do is build an accurate program inventory, check CIP codes, clear FVT/GE reporting, model programs against the threshold, map its Title IV exposure, prepare the STATS data feed, assign owners for the 60-day completer list review and the 30-day appeal window, and keep a dated, sourced employment record for every graduate. Prentus helps colleges build that last piece, the career outcomes record, program by program.
This checklist reflects the final rule and Federal Student Aid guidance as of October 20, 2026. For what the earnings benchmark measures and why it exists, start with OBBBA earnings benchmark explained. For how Prentus supports compliance across programs, see OBBBA compliance with Prentus.
The dates to plan around
| Date | What happens |
|---|---|
| July 4, 2025 | The One Big Beautiful Bill Act is signed, creating the Do No Harm earnings standard. |
| July 1, 2026 | Statutory effective date. The STATS and Earnings Accountability final rule (91 FR 40136) is published the same day. |
| October 1, 2026 | The 2026 FVT/GE report, covering the 2025-26 award year, was due. |
| January 15, 2027 | Final deadline for unreported or under-reported FVT/GE data from the 2024, 2025 and 2026 cycles. |
| 2027 | The Department plans to publish draft FVT/GE and STATS data for school review, then final data. |
| July 1, 2027 | The STATS final rule takes effect and replaces the FVT/GE rule. |
| October 1, 2027 | First STATS report due for the two most recent award years, unless the Secretary sets other dates. |
The OBBBA earnings readiness checklist
Eleven items, in the order most colleges can work through them. Each one names the data, the owner and the deadline.
| Item | Data to collect | Owner | When |
|---|---|---|---|
| 1. Build the program inventory | OPEID, six-digit CIP code and credential level for every Title IV program | Institutional research with the registrar | Now |
| 2. Check every CIP code and credential level | Catalog description vs. reported CIP code and credential level | Academic affairs with the registrar | Before the Department publishes 2027 data |
| 3. Clear the FVT/GE reporting backlog | Program and student files for the 2024, 2025 and 2026 cycles | Financial aid with institutional research | By January 15, 2027 |
| 4. Count completers per program | Completers per award year, by program | Institutional research | Now, then every award year |
| 5. Model each program against the earnings threshold | Public earnings by program vs. the high school earnings benchmark for your state | Institutional research | Now |
| 6. Map your Title IV exposure | Title IV recipients and Title IV dollars in each at-risk program | Financial aid with the CFO | After item 5 |
| 7. Prepare the STATS data feed | Tuition and fees, grants and scholarships per completer or withdrawn student, programmatic accreditation, licensure states | Financial aid, bursar and compliance | Before October 1, 2027 |
| 8. Set up the 60-day completer list review | The Department’s completer list vs. your own records | Registrar with institutional research | Each time the list arrives |
| 9. Calendar the 30-day appeal window | Completer list evidence, threshold version applied, the median vs. threshold comparison | Compliance or general counsel | Before the first determination |
| 10. Keep a dated, sourced employment record for every graduate | Employer, title and date for each completer, with a source on every record | Career services | From completion through the fourth tax year after it |
| 11. Name one executive owner and review quarterly | A one-page status for items 1 to 10, by program | A cabinet-level executive | Every quarter |
Build the program inventory
Owner: Institutional research with the registrar. When: Now.
The earnings premium is judged program by program, and a program is identified by OPEID, six-digit CIP code and credential level. Start with one list that every office agrees on. Most later items hang off it.
Check every CIP code and credential level
Owner: Academic affairs with the registrar. When: Before the Department publishes 2027 data.
Programs are measured as reported. A program filed under the wrong code is compared on the wrong record, and fixing it after the data is published is much harder than fixing it now.
Clear the FVT/GE reporting backlog
Owner: Financial aid with institutional research. When: By January 15, 2027.
The FVT/GE rule stays in force through June 30, 2027. The 2026 report was due October 1, 2026, and Federal Student Aid set January 15, 2027 as the final deadline for unreported or under-reported data from the last three cycles (GENERAL-26-49). Our gainful employment guide has the full timeline.
Count completers per program
Owner: Institutional research. When: Now, then every award year.
A program needs 30 completers in its expanded cohort and earnings matched for at least 16 students to receive a measure. Know which programs sit near that line, because a small program can move in or out of measurement from one year to the next.
Model each program against the earnings threshold
Owner: Institutional research. When: Now.
For undergraduate programs the threshold is the median earnings of adults aged 25 to 34 with only a high school diploma who worked and were not enrolled. Public sources such as College Scorecard and, where your state takes part, Census PSEO give a directional read. They use different populations and years than the federal test, so treat the result as an early warning, not a forecast.
Map your Title IV exposure
Owner: Financial aid with the CFO. When: After item 5.
A failing program loses Direct Loans. The institution is also exposed: under 34 CFR 668.16(t), at least half of Title IV recipients and half of Title IV funds must not come from low-earning outcome programs. Know your share before the Department calculates it.
Prepare the STATS data feed
Owner: Financial aid, bursar and compliance. When: Before October 1, 2027.
STATS adds the total of federal, state, private and other grants and scholarships each completer or withdrawn student received. Make sure your aid and billing systems agree, and that accreditation and licensure fields are complete. Inaccurate submissions can raise administrative capability concerns.
Set up the 60-day completer list review
Owner: Registrar with institutional research. When: Each time the list arrives.
The Department builds the completer list from data you already report, sends it to you, and gives you 60 days to correct it. It is the only direct say a school has in the list behind the federal median. Decide now who reconciles it and how fast.
Calendar the 30-day appeal window
Owner: Compliance or general counsel. When: Before the first determination.
Appeals must be filed within 30 days of the notice, and only on listed grounds: the list of completers, the version of the earnings threshold applied, the comparison of the median with that threshold, and other bases the Secretary sets (34 CFR 668.603). Name the reviewer in advance.
Keep a dated, sourced employment record for every graduate
Owner: Career services. When: From completion through the fourth tax year after it.
The federal test reads earnings in the fourth tax year after completion. Your own record is how you see a program trending low while there is still time to change career support, employer partnerships or the program itself. Collect a personal email and mobile number before students leave, since school email often expires.
Name one executive owner and review quarterly
Owner: A cabinet-level executive. When: Every quarter.
This work crosses institutional research, the registrar, financial aid, academic affairs and career services. Without one owner it stalls between offices. A quarterly review keeps at-risk programs in front of the people who can act on them.
For college leadership teams
See which programs need attention before the federal number lands
Prentus keeps a verified, sourced employment record for every program, so item 10 runs on its own. Book a demo and we will walk through your programs with you.
What the government calculates and what the college controls
The Department of Education calculates
- Median earnings for each program, from federal data, measured in the fourth tax year after completion for completers who are working and not enrolled.
- The earnings threshold for each program.
- Whether a program passes, which it does when its median equals or exceeds the threshold.
- Which programs become low-earning outcome programs after two failures in any three consecutive award years.
The college controls
- The accuracy of the program and student data it reports, including CIP code, credential level and completion dates.
- Corrections to the completer list within 60 days of receiving it.
- Tuition, fees and the aid data it reports under STATS.
- Its own record of where each graduate works, with a date and a source.
- The career support that gets graduates into better-paid work before the fourth tax year arrives.
For the formulas behind each federal earnings test and how they differ from College Scorecard and Census PSEO, read graduate earnings outcomes and how schools prove them.
Common readiness mistakes
- Waiting for the federal number. Earnings are read years after completion. By the time a failure shows up, the cohorts that caused it have already graduated.
- Treating survey salaries as the federal median. A first-destination salary is useful context. It is not what the Department will use.
- Leaving the completer list to whoever opens the email. Sixty days goes fast. Without a named owner the only direct correction window closes.
- Assuming a small program is safe. The cohort widens when completers are few. A program near 30 completers can enter measurement in a later year.
- Running it from one office. Institutional research cannot fix a CIP code, and financial aid cannot track where graduates work. Split the list by owner.
Quick self-check
How Prentus helps
Prentus is the career outcomes platform. It does not calculate the earnings premium. That comes from federal data. Prentus gives your team a verified employment record for every program, with a source on every record, so item 10 is handled and items 5 and 6 rest on real evidence.
- 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 institutional research or whoever prepares a filing.
Students use Prentus from day one until they are hired, so the career support and the evidence live in one place. See the full picture on our OBBBA compliance page.
Primary sources
All sources checked October 20, 2026.
- STATS and Earnings Accountability final rule, 91 FR 40136, published July 1, 2026, effective July 1, 2027
- Federal Student Aid electronic announcement GENERAL-26-49 (FVT/GE reporting, STATS early implementation and publication)
- 34 CFR 668.16 (standards of administrative capability)
- 34 CFR 668.603 (ineligible programs and appeals)
This checklist is general information, not legal advice. Check the current regulations before you rely on them.
