By Maria Carrasco, NASFAA Staff Reporter
The Department of Education’s (ED) extensive rulemaking agenda has created a flurry of new regulations that took effect earlier this month, and while a significant portion of the One Big Beautiful Bill Act (OBBBA) is having an immediate impact on campuses, the administration’s new accountability framework will also lead to new responsibilities for financial aid offices.
During the NASFAA 2026 Virtual Summit, members of the policy team hosted a timely session to dive into the new Student Tuition and Transparency System and Earnings Accountability (STATS) framework, which was officially published on July 1.
While Under Secretary of Education Nicholas Kent noted at NASFAA’s 2026 National Conference that there is no immediate urgency for schools to address these new regulations, he reminded attendees that the first data reporting period is due October 1, 2026, and that the department will begin calculating new earnings tests in 2027.
In order to prepare financial aid offices for this change, Megan Walter, NASFAA’s senior policy analyst, began Wednesday’s session by providing an overview of the Gainful Employment and Financial Value Transparency (GE/FVT) timeline and how previous efforts dating back to 2011 were ultimately stalled.
Most changes to the STATS framework are effective July 1, 2027, with an option to implement early, beginning July 1, 2026. Walter explained to attendees how the new “low-earning outcome test” will work for undergraduate and graduate programs, and how the new STATS framework differs from GE/FVT regulations.
NASFAA recently developed a flowchart outlining the process that the Department of Education will use to determine which student completers and their earnings are included when calculating a program's First-Year Earnings Premium under the new STATS/Earnings Accountability regulations.
Walter noted some of the exemptions and carve-outs in the new STATS framework. The final rule has an exemption for institutions that enroll only students with a documented specific learning disability or autism. These institutions still have to comply with STATS reporting, and ED will still calculate an earnings premium for their programs. What they're exempt from is the consequence: even a failing earnings premium will not trigger loss of Direct Loan or Title IV eligibility for those programs.
Some institutions are also shielded from losing all Title IV eligibility, even if they have a failing program. Institutions that don't participate in the Direct Loan program, and haven't for the five most recent award years, are exempt from that consequence. The same protection applies to institutions that agree not to permit Direct Loan borrowing for a failing program for five consecutive award years, provided ED determines that doing so serves students' best interest.
During the presentation, Jill Desjean, NASFAA’s director of policy analysis, walked attendees through the warning process if their institution fails the new STATS framework, as well as the institutional appeals process.
From there, Desjean outlined the timeframe for this new STATS reporting framework, with GE/FVT reporting due on October 1, 2026, and STATS reporting due on October 1, 2027. Desjean pointed to an electronic announcement from ED that provided limited guidance on how institutions can implement the STATS reporting framework early.
Clare McCann, managing director of policy and operations at American University’s Postsecondary Education & Economics Research (PEER) Center, presented data outlining earnings thresholds for undergraduate programs by state, and graduate programs by broad field of study.
From there, McCann walked through data on low-earning programs. Overall, she said, the data indicate that fewer than 4% of students are enrolled in failing programs, with the largest share in undergraduate certificate programs. Notably, McCann pointed out that undergraduate certificates account for only 8% of enrollment but 52% of students in low-earning programs.
She added that her organization found that most institutions, except for for-profit institutions, have very few of their students in failing programs. Notably, McCann pointed out that HBCUs and MSIs have lower enrollment in failing programs than other institutions.
The session ended with the panel answering questions from attendees. One attendee asked what a school should consider when weighing whether to opt for early STATS implementation.
Desjean said she didn’t have an answer, but she imagined that the department would likely address this question in its upcoming STATS and earnings accountability webinar on July 29.
Another attendee asked whether institutions would have access to American Community Survey (ACS) data, which is used as a threshold in the STATS framework, and whether they could use this data to run their own model and see the potential impact in advance.
McCann said ACS data is public, but it is not the most straightforward, and gave some caveats to using the data. She added that her organization is currently conducting its own analysis of what the STATS framework will entail for all programs and institutions.
Publication Date: 7/17/2026
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