Skip to main content
PrentusPrentus
OBBBA: STATS Final Rule

STATS: Student Tuition and Transparency System

STATS is now a final rule. Published in the Federal Register July 1, 2026, it harmonizes FVT, Gainful Employment, and debt-to-earnings into one Earnings Premium standard for nearly every Title IV program. General provisions are effective July 1, 2027. One final legacy GE and FVT reporting cycle is still due October 1, 2026.

Read the full STATS breakdown for the regulatory text, calculation method, and what changes vs Gainful Employment.

Painterly illustration of floating program cards with one highlighted in lime, suggesting Earnings Premium measurement

Jul 1, 2026

STATS final rule published in Federal Register

Oct 1, 2026

Final legacy GE/FVT reporting cycle due

Jul 1, 2027

General STATS accountability provisions effective

2 of 3 yrs

Below threshold = loss of Direct Loan eligibility

Docket ID ED-2026-OPE-0100, RIN 1840-AE06. A small number of technical and conforming instructions are effective August 31, 2026, ahead of the general July 1, 2027 effective date.

What Changed

STATS consolidates three regulations into one

The carve-outs that let most degree-granting programs avoid Gainful Employment are gone. Nearly every Title IV program is now in scope of the same accountability standard, effective July 1, 2027.

What STATS replaces

  • FVTThe Financial Value Transparency framework retires. STATS takes over.
  • DTEThe debt-to-earnings metric is eliminated. One Earnings Premium metric replaces it.
  • GE scopeGainful Employment's narrow scope (non-degree at nonprofits, all at for-profits) expands to nearly all Title IV programs.
  • ReportingProgram-level cost, enrollment, completion, and scholarship data submitted annually, alongside one final legacy GE/FVT cycle due October 1, 2026.

The Earnings Premium test

  • ComparisonMedian graduate earnings vs. earnings threshold for non-graduates in the same state and program type.
  • UndergradThreshold = median earnings of HS-diploma-only workers ages 25 to 34.
  • GraduateThreshold = lowest median earnings of bachelor's-degree holders ages 25 to 34 by state + CIP.
  • Data sourceIRS earnings data + Census Bureau threshold data, first calculated using 2026 tax-year earnings.
  • PenaltyBelow threshold 2 of 3 years = loss of Direct Loan eligibility; 3 straight years risks all Title IV aid.

Important: Appeals are limited to whether the Department erred in calculating the metric, under 34 CFR Part 668, Subpart G. Institutions cannot appeal the threshold itself, the choice of comparison population, or whether the cohort window captured the right students. The only real defense is outperforming the threshold on the original measure.

The Real Problem

IRS earnings data lags for years. Your team needs to know now.

STATS first calculates the Earnings Premium using 2026 tax-year earnings, with general accountability provisions effective July 1, 2027. By the time the Department tells you a program is failing, you may have already missed several cohorts of intervention windows. Schools that wait for the official metric lose the chance to act.

Prentus runs continuous LinkedIn-based employment verification, salary detection, and program-level dashboards so institutional research and career services see the same outcome data at the same time, months before IRS records settle. The same data feeds STATS reporting submissions and gives your team a real early-warning view.

See the outcome tracking demo

Student completes program

Prentus starts tracking employment from day 1 after graduation. No survey campaign required.

LinkedIn verification runs continuously

Detect employer name, title, start date, salary range when available, on a rolling basis.

Program-level dashboard

Institutional research, career services, and compliance all see the same median earnings figure by program, by cohort, by CIP code.

Reporting export, ready either way

Generate the October 1, 2026 legacy GE/FVT submission today, and the same export format carries forward once STATS reporting requirements are effective July 1, 2027.

Who STATS affects (everyone in Title IV)

The expansion is the point. GE-style accountability used to skip most degree programs. STATS does not.

Community Colleges

Certificate, workforce, and associate-degree programs are now graded on the same Earnings Premium metric. Programs with strong placement and modest tuition are fine; programs with weak placement and any meaningful tuition face the same scrutiny historically reserved for for-profits.

High urgency. Most programs now in scope.

Four-year universities

Degree programs that were exempt under Gainful Employment are not exempt under STATS. Bachelor's programs with weak field-of-study outcomes can now lose Direct Loan eligibility. Graduate programs face the bachelor's-degree-holder benchmark.

Major change. Carve-outs gone.

For-profit + career training

Familiar territory but a simplified standard. The debt-to-earnings calculation goes away. Only the Earnings Premium remains, applied uniformly. Programs already tracking placement carefully are positioned to weather it.

Medium urgency. Standard simplified.

Get a Free Outcomes Diagnosis

Bring your program-level placement and earnings numbers. Leave with a maturity assessment against the incoming STATS Earnings Premium test and a gap plan. 30 minutes, no sales pitch.

Get a Free Outcomes Diagnosis

How Prentus Helps

See your Earnings Premium before the IRS does

STATS general provisions are effective July 1, 2027, and the Department calculates Earnings Premium metrics from IRS data that lags real time by design. Prentus tracks the equivalent signal continuously so your team sees the trend well before the Department finalizes it.

Program-level outcomes dashboard

Program-level dashboards

STATS measures the Earnings Premium by program and six-digit CIP code. Prentus rolls outcome data up the same way, so institutional research and career services see one number in one place.

Advisor efficiency metrics in Prentus

Reporting cycle ready

Tuition, fees, scholarships, enrollments, completions. Prentus generates the October 1, 2026 legacy GE/FVT submission, and the STATS reporting cycle after it, in one export instead of a fire drill across registrar, financial aid, and career services.

Advisor action dashboard surfacing at-risk students

Intervene before failure

A program designated low-earning outcome loses Direct Loans for two years. Prentus flags programs trending below the Earnings Threshold so career services can act on the right cohort, not after the fact.

Wait for the IRS, or know now

Wait for the IRS calculation

  • First Earnings Premium calculation lags years behind the graduating cohort
  • No early warning if a program is trending below threshold
  • Manual outcome surveys at 6 to 9 months produce 20 to 30 percent response rates
  • Career services and compliance operate from different data sets
  • Each October 1 reporting cycle turns into a fire drill
  • Appeals limited to calculation errors. No way to argue out of a designation

PrentusPrentus continuous tracking

  • LinkedIn-verified employment detected continuously after graduation
  • Salary range and title detected automatically when public
  • Program-level dashboards by cohort and CIP code for early-warning
  • Institutional research, career services, and compliance see one number
  • Every October 1 reporting cycle generated from live data, not a year-end push
  • See your projected Earnings Premium position well before the IRS does

Common Questions

STATS FAQ

What does STATS stand for, and is it law yet?

Student Tuition and Transparency System. STATS is a final rule, not a proposal. The Department of Education published it in the Federal Register on July 1, 2026 (Docket ID ED-2026-OPE-0100, RIN 1840-AE06) after a Notice of Proposed Rulemaking and public comment period earlier in 2026.

When does my institution have to report, and when does STATS take effect?

One final legacy Gainful Employment and Financial Value Transparency reporting cycle opens July 1, 2026 and is due October 1, 2026. The general STATS accountability provisions, including the Earnings Premium test, are effective July 1, 2027. A small number of technical instructions are effective August 31, 2026.

How is the Earnings Premium calculated?

The Department compares median annual earnings of program graduates against an earnings threshold for the comparable non-graduate population (HS diploma holders for undergrad, bachelor's holders for graduate). The first calculation uses 2026 tax-year IRS earnings data.

What if our program falls below the threshold one year?

One year below does not trigger the penalty. A program must fall below in two of three consecutive years to lose Direct Loan eligibility. Three consecutive years of failure puts the program at risk of losing all Title IV aid, including Pell Grants.

Can institutions appeal a STATS designation?

Appeals are narrow. Institutions can only appeal whether the Department erred in calculating the Earnings Premium measure, under existing termination procedures at 34 CFR Part 668, Subpart G. The methodology itself and the choice of threshold are not appealable.

Does STATS use self-reported survey data?

No. The Department uses IRS earnings data and Census Bureau threshold data. Institutions report the cost and completion side (tuition, fees, enrollments, completions, scholarships). Schools cannot influence the earnings number directly, only by improving placement quality over time.

Get a Free Outcomes Diagnosis

Bring your program-level placement and earnings numbers to a 30-minute working session. Leave with a maturity assessment against the STATS Earnings Premium test and a gap plan. No sales pitch.

Get a Free Outcomes Diagnosis

Or read the STATS breakdown, see Workforce Pell requirements, or Gainful Employment requirements. For compliance updates in your inbox weekly, subscribe to the Weekly Workforce Wire.