STATS: Student Tuition and Transparency System
STATS is the Department of Education's new Title IV accountability framework. It replaces FVT, sunsets debt-to-earnings, and unifies every Title IV program under one Earnings Premium standard. First reporting deadline: October 1, 2026.
Read the full STATS breakdown for the regulatory text, calculation method, and what changes vs Gainful Employment.
Apr 20, 2026
NPRM published in Federal Register
Oct 1, 2026
First institutional reporting deadline
Early 2027
First Earnings Premium metric calculated
2 of 3 yrs
Below threshold = 2-yr loss of Direct Loans
What Changed
STATS consolidates three regulations into one
The carve-outs that let most degree-granting programs avoid Gainful Employment are gone. Every Title IV program is now in scope of the same accountability standard.
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 all Title IV programs.
- ReportingProgram-level cost, enrollment, completion, scholarship data submitted annually each October 1.
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. 30-student minimum cohort with rolling backfill.
- PenaltyBelow threshold 2 of 3 years = 2-year loss of Direct Loan eligibility.
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
The IRS data lags by four years. Your team needs to know now.
The first Earnings Premium for institutions calculates in early 2027 using 2025 earnings data covering 2021 program completers. By the time the Department tells you a program is failing, you have already missed three to four 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 demoStudent 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.
STATS reporting export
Generate the October 1 submission with program tuition, completions, and verified placement in a single package.
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.
How Prentus Helps
See your Earnings Premium before the IRS does
The Department will not calculate STATS metrics until early 2027, using earnings data from 2021 cohorts. Prentus tracks the equivalent signal continuously so your team sees the trend years before the Department finalizes it.
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.
October 1 submission ready
Tuition, fees, scholarships, enrollments, completions. Prentus generates the STATS submission in one export instead of a Q3 fire drill across registrar, financial aid, and career services.
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 metric arrives early 2027, four years after the cohort graduated
- ✗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
- ✗October 1 STATS submission turns into a fire drill every year
- ✗Appeals limited to calculation errors. No way to argue out of a designation
Prentus 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
- ✓October 1 STATS submission generated from live data, not a year-end push
- ✓See your projected Earnings Premium position a year before the IRS does
Common Questions
STATS FAQ
What does STATS stand for?
Student Tuition and Transparency System. The Department of Education proposed the framework in a Notice of Proposed Rulemaking published April 20, 2026 (Federal Register docket 2026-07666).
When does my institution have to report?
October 1, 2026 for the first cycle, covering two most recent award years. Annually each October 1 afterward.
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). Cohort window is a single year from four years prior to the most recent earnings data, expanding backward until reaching at least 30 students.
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 be designated low-earning outcome. That designation strips Direct Loan eligibility for two years.
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.
Don't wait for the IRS calculation
See how Prentus tracks program-level outcomes in real time so your STATS submission lands clean and your Earnings Premium position is visible months before the Department settles the metric.
Book 30-Minute DemoOr read the STATS breakdown, see Workforce Pell requirements, or the full OBBBA compliance guide.