Every Program, One Test: The STATS Earnings Accountability Final Rule
On July 1, 2026, the Department of Education published the final rule implementing the WFTCA 'Do No Harm' earnings test. For the first time, every program at every Title IV institution must show that its graduates out-earn a benchmark. We mapped all 49,860 programs to see who is exposed.
On July 1, 2026, the Department of Education published the final rule implementing the WFTCA “Do No Harm” earnings test, the accountability framework created by the Student Transparency and Accountability in Tuition Spending (STATS) Act provisions of the One Big Beautiful Bill Act. The rule does something no prior accountability regime has done: it applies a single earnings-based standard to every program, at every credential level, at every Title IV institution.
The core idea is simple to state and consequential to apply. A program must demonstrate that its graduates earn more than they likely would have without the credential. Programs that fall short can, in time, lose access to federal Direct Loans. The dashboard below shows where all 49,860 programs with reported earnings currently stand against that benchmark. Find your institution below, or search by state, to see which programs are failing or sit close to the threshold.
Open the full dashboard in a new tab →
What Changed
The most important shift is one of scope. Under the final rule, all programs at all Title IV institutions are now subject to earnings-based accountability, not just Gainful Employment programs. Every credential level at every institution type, public, private nonprofit, and for-profit alike, must demonstrate adequate graduate earnings.
The debt-to-earnings metric that anchored earlier Gainful Employment rules is gone. The earnings premium is now the sole test. A program passes by showing that its median graduate earnings meet or exceed a benchmark. For undergraduate programs, that benchmark is the state-level high school median wage for adults ages 25 to 34. For graduate programs, it is the lowest of three bachelor’s-degree medians: same-state same-field, same-state all-field, and national same-field. I walked through exactly how these benchmarks are built, and what triggers sanctions, in an earlier post on how the earnings test works.
The methodology measures earnings in the fourth year after completion, looking only at completers who are working and no longer enrolled. That fourth-year window matters, because it gives graduates time to move past the entry-level wages that would make almost any program look weak in year one.
The final rule also softens several edges from the proposed version. Tipped-occupation programs, including cosmetology, barbering, massage, and culinary programs, receive a delayed implementation timeline. Non-Direct Loan institutions have an exemption pathway. The rule adds disability-related accommodations and includes voluntary provisions for institutions that choose to opt out of Direct Loan participation.
What’s Coming
The rule takes effect immediately, but the consequences arrive on a staggered schedule that stretches years into the future.
The practical takeaway for institutions is that the clock started today, even though the first real determination is two years out. The catch is that the earnings driving those determinations belong to students who completed years ago, so a program that is failing now cannot simply improve its way out before the first results land. What institutions can still control is how they respond: whether to manage their exposure through the voluntary Direct Loan opt-out or an orderly teach-out, and how they price and recruit for the programs they keep.
Reading the Dashboard
The dashboard covers all 49,860 programs with reported median earnings across 4,212 institutions. It flags each program as passing, at risk, or failing against its applicable benchmark. “At risk” is defined narrowly and deliberately: a program that currently passes but sits within $2,000 of its benchmark. Those are the programs where a modest shift in graduate earnings, or in the state wage floor they are measured against, could flip the result. Use the search and filters to look up a specific institution, field, or credential level.
Tuition Revenue at Risk
The dashboard also estimates the tuition revenue tied up in failing programs, both by state and by institution. Nationally, roughly $1.38 billion in annual net tuition currently flows through programs that fail the earnings test, across 987 public and nonprofit institutions. It is important to read this as exposure, not loss. The figure captures the revenue attached to failing programs today, not a forecast of what schools will actually forgo, since programs have time to respond, many fail by narrow margins, and students may keep enrolling even after results are published. The estimate is deliberately conservative: it takes the lower of two independent calculation methods for every institution and leaves out programs too small to report earnings, so the real number is more likely understated than overstated.
A Note on the Data
This analysis reflects CIP4-level data, the four-digit program grouping available today. The operational test will use the more granular CIP6 level once that dataset is published in early 2028, so individual program results will shift as broad categories split into their component programs. Tipped-occupation programs are flagged per Section 668.402(c)(3) of the final rule. Revenue-at-risk figures allocate each institution’s IPEDS 2022-23 net tuition revenue across its failing programs by enrollment, taking the lower of a bottom-up per-student estimate and a top-down portfolio-share estimate for each institution. Earnings are expressed in 2024 CPI-U dollars.
For a step-by-step walkthrough of how the test itself works, how the benchmarks are built, and the full consequence ladder, see How the New Federal Earnings Test for Colleges Works.
Source: AHEAD Program Performance Data (PPD:2026).