OBBBA Compliance for Higher Education
The Do No Harm earnings standard takes effect July 1, 2026. Programs that can't prove graduates out-earn high school diploma holders lose federal loan eligibility.
5 questions · 3 minutes · Know where you stand
What Is the OBBBA Do No Harm Standard?
The One Big Beautiful Bill Act (H.R. 1, 119th Congress), signed July 4, 2025, introduced the Do No Harm earnings accountability standard for all Title IV institutions. Under this standard, degree programs must demonstrate that graduates' median earnings exceed the state median for 25–34-year-olds with only a high school diploma — measured four years post-completion.
Programs that fail in two of three consecutive years lose federal student loan eligibility. This affects over 5,500 Title IV institutions and applies to public, nonprofit, and for-profit schools alike. Undergraduate certificate programs are exempt from Do No Harm but remain subject to the separate Gainful Employment rule.
What Changed
What the OBBBA Changed
Signed into law July 4, 2025, three accountability requirements your institution needs to understand now
"Do No Harm" Earnings Test
All degree programs must prove graduates earn more than someone with only a high school diploma. Fail two of three consecutive years and your program loses federal loan eligibility.
Workforce Pell: 70% Placement Required
Short-term programs (8–15 weeks) are now Pell-eligible starting July 2026, but only with a verified 70% job placement rate at 180 days post-completion.
Learn more →
Gainful Employment Still Active
The Biden-era GE rule remains in effect for certificate programs and all for-profit degree programs. For-profits face both GE and Do No Harm simultaneously.
Learn more →
The Accreditation Angle
More Than Compliance: An Accreditation Risk
Your accreditor
Will review outcome data at renewal. "We're working on it" isn't an answer when the earnings test is already measuring your programs.
Your board
Will ask how graduate earnings compare to the state benchmark. OBBBA makes program-level outcome data part of every board conversation.
Your prospective students
Will compare programs by outcome data before they enroll. OBBBA makes these comparisons visible and public.
Your at-risk programs
Get one year of mandatory student warnings. Then two consecutive failures in three years means no federal loans for that program.
Know Where You Stand Before July 1
5 questions. 3 minutes. Find out if your institution tracks outcomes the way OBBBA requires.
Take the Free Readiness AssessmentThe Prentus Approach
Automated Outcome Tracking, Always Audit-Ready
Career services teams can't run annual survey campaigns for 20,000 students and also do their jobs. Prentus automates the tracking so data is always current.
LinkedIn Auto-Detection
Prentus automatically scans LinkedIn to verify employment status and employer name. No survey needed. Your outcome data updates continuously.
Program-Level Reporting
Export outcome data by program, credential level, and cohort. Exactly the format DoE's earnings test requires. Board-ready in minutes.
180-Day Placement Tracking
For Workforce Pell programs, Prentus tracks the 180-day post-completion window automatically, meeting the 70% placement rate requirement.
Multi-Program Dashboard
See outcome rates across every program at a glance. Flag programs approaching the Do No Harm threshold before your DoE report does.
The Old Way vs the Prentus Way
✗ Without Prentus
- ✗Annual survey campaigns to 20,000 students with 20% response rates
- ✗Staff manually compiling data from 6 different systems before every review
- ✗Outcome reports that take 3 months to produce
- ✗No visibility into at-risk programs until DoE tells you
- ✗Board meetings with estimates instead of verified data
- ✗No process for students who don't respond
With Prentus
- ✓LinkedIn auto-detection runs continuously — no survey campaigns needed
- ✓Outcome data compiles automatically by program and cohort
- ✓Board-ready reports in minutes, not months
- ✓Dashboard flags programs approaching the Do No Harm threshold
- ✓Verified earnings data, not estimates
- ✓Non-responder tracking with documented follow-up attempts
Free Resource
OBBBA Compliance Checklist
10 requirements your institution must be able to answer with data, not estimates.
Graduate Outcome Definitions
You have a written, program-level definition of a successful outcome — not just any job, but one that clears the earnings threshold relevant to your credential level.
Earnings Tracking by Program
You track graduate earnings at the program level, not just institution-wide. A student working in a different field than their program shouldn't inflate your numbers.
Four-Year Post-Completion Measurement
OBBBA measures earnings four years after program completion. Your tracking system captures students well past the six-month survey window.
State-Level Earnings Comparison Data
You can compare your graduates' median earnings to the state median for 25–34-year-olds with a high school diploma (or bachelor's for grad programs). If over 50% of students are out-of-state, national thresholds apply.
Automated Reporting Infrastructure
Your outcome data compiles automatically — not through staff manually exporting from five different systems before an accreditor visit.
Multiple Verification Methods
You don't rely solely on student self-reporting. LinkedIn verification, employer records, or third-party wage data back up your employment numbers.
Non-Responder Documentation
You have a documented process for students who don't respond to employment follow-ups, with final status codes and attempt records.
Cohort Tracking
You track the same cohort of students over time — not a moving population. This is how DoE calculates the earnings test.
Year-One Failure Warning Process
OBBBA requires institutions to warn enrolled students if a program fails the earnings test in year one. You have a process ready.
Board-Ready Outcome Reports
You can produce a program-level outcome report within 30 days of request — not a scramble to pull data three months before a board meeting.
Get the Full Checklist + Documentation Guide
Printable PDF with all 10 items, checkboxes, documentation space, and notes on what DoE actually looks for.
No spam. We'll send the PDF and add you to our OBBBA update list.
“Prentus uniquely understands that career services is an enrollment and retention lever, not just a graduation requirement.”— Ana Aristizabal, Director of Investments, Potencia Ventures
Common Questions
OBBBA Compliance FAQ
Does OBBBA apply to my institution if we're a nonprofit?
Yes. The Do No Harm earnings standard applies to all Title IV institutions — public, nonprofit, and for-profit — for all degree programs. Undergraduate certificate programs are exempt from Do No Harm but remain under the Gainful Employment rule.
Do we have to report earnings data ourselves?
No. The Department of Education calculates earnings thresholds using Census Bureau data and provides results to institutions annually. What you need is a reliable record of which graduates are employed and in what roles — so you can verify and appeal DoE's data if needed.
What happens if one of our programs fails the earnings test?
Year one failure: mandatory disclosure to enrolled students. Two failures in three consecutive years: the program loses access to federal student loans for at least two years. Institutions can appeal. Programs can reapply after the ineligibility period.
How is Gainful Employment different from OBBBA's Do No Harm?
They cover different programs. GE applies to certificate programs at all institutions and all degree programs at for-profits. It includes both an earnings test and a debt-to-earnings ratio. Do No Harm applies to degree programs at all institutions but only uses an earnings test. For-profits face both.
Verified Outcomes Are Your Best OBBBA Defense
See how leading institutions use Prentus to track graduate outcomes automatically — and walk into every review with data, not estimates.
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