Cover Story: Goodbye, Gainful Employment and Financial Value and Transparency. Hello, STATS/Earnings Accountability.

Beginning July 1, 2026, the federal government will merge Gainful Employment (GE) and Financial Value and Transparency (FVT) reporting into one reporting scheme. This new reporting scheme, STATS/Earnings Accountability, will comprise elements of both GE and FVT. What makes this new reporting structure so different from the other two? And are there any similarities between the former and latter reporting schemes?

First, it’s essential to understand that the federal government is consolidating the GE and FVT into a single report that will focus exclusively on all GE and non-GE programs, except for smaller programs with fewer than 30 Title IV completers after aggregation. Previously, GE reporting was limited to schools that offered federal financial aid for non-degree programs that led to credentialing (i.e., short-term certificates). FVT expanded elements of GE reporting to all types of programs at an institution (i.e., degree and non-degree programs). To simplify reporting, the One Big Beautiful Bill Act (OB3) created a new reporting structure that combines data reporting elements from GE and FVT. A notable fact is that the federal government will continue to offer an exclusive carveout for institutions that offer degree programs producing fewer than 30 Title IV completers.

On the metric and testing side, the former reports relied on two metrics and tests to determine whether a school’s program led to a positive return on investment: the Earnings Premium (EP) and the Debt-to-Earnings Test (DTE). OB3 simplified the metric/test down to simply EP for the new STATS/Earnings Accountability report. To calculate a program’s earning measure, the federal government will use the median earnings of Title IV aid recipients approximately four years after completion of their program.

Earnings benchmark is where things really diverge from the old reporting schemes. For example, OB3 made a clear distinction between undergraduate and graduate programs. Undergraduate programs will use the median earnings of in-state individuals aged 25-34 with a high school diploma, or, if most students attending the institution are not from the institution’s domiciled region, national data metrics from a broader demographic.

The earnings benchmark for graduate programs is a tad funkier. For instance, graduate programs will use the median earnings of individuals aged 25-34 with a bachelor’s degree, calculated as the lowest of the state median, the state median in the same two- or four-digit Classification of Instructional Programs (CIP) code, or the national median in the same two- or four-digit CIP code. Akin to the earnings benchmark reporting for undergraduate students, graduate programs with a high number of students who do not reside in the institution’s state will use national media data rather than state-level data to calculate a program’s earnings benchmark.

To prevent erroneous calculations, schools will need to exclude the following types of students from their reporting:

• Students with loans that are in a Total and Permanent Disability discharge status code in the National Student Loan Data System (NSLDS).
• Students in multiple degree programs where the other degree program already calculates earnings metrics.
• Students who completed a higher-credentialed undergraduate program at the same institution after completing the program, as of the most recently completed award year before the calculation of the earnings premium.
• Students who completed a higher-credentialed graduate program at the same institution after completing the program, as of the end of the most recently completed award year before the calculation of the earnings premium.
• Students enrolled in Prison Education Programs.
• Students enrolled in Comprehensive Transition and Postsecondary (CTP) programs.
• Deceased students

Schools that offer academic programs that fail the revamped metrics and tests in this new reporting framework will face devastating consequences. Educational programs that fail two of three consecutive years will lose direct loan eligibility. There’s a potential for a loss of all Title IV aid eligibility if failing programs at an institution represent 50% or greater of Title IV aid recipients at that school or 50% of all Title IV aid dollars at the school for two out of three consecutive years.

Schools that face these dire consequences will not be eligible for certain Title IV aid for two years. Separately, the Department of Education will require a warning for all academic programs that fail the earnings premium test. A separate acknowledgement is necessary for all Pell Grant recipients, including information on remaining Pell Grant lifetime eligibility.

Like the GE and FVT reporting structures, the STATS/Earnings Accountability reporting will have an annual reporting deadline of October 1. Institutions that run afoul of this yearly reporting deadline could face separate repercussions from the Department of Education. Unlike FVT reporting, the lookback period for this new reporting is only five years. Previously, FVT and GE had a five-year lookback period, unless a school used the transitional reporting method, which submitted only two years of data.

While GE and FVT never materialized long enough to sanction institutions, STATS/Earnings Accountability is likely to remain in effect long enough to result in a program loss at certain institutions where some or all their academic program offerings fail the earnings premium benchmark tests. The first year of this outcome occurring is in the 2028-29 award year, which begins on July 1, 2028.

Students should know that their financial aid office will likely take the lead role in completing this critical federal reporting. Nonetheless, it may hinder the efficiency of financial aid operations, especially during peak processing periods near the start of the fall semester, as financial aid administrators frantically race to complete this mandated report. All colleges and universities will keep abreast of the reporting results to determine the viability of future academic programs.

While offering an extensive palette of academic degree programs is beneficial for curating a wide range of students on a college campus, it may not make fiscally sense if some of those educational programs carry earnings premium risk that hampers a student’s future earnings post-graduation and risks an institution’s access to federal student aid.