Nonprofit Resources
Comments Due May 20 on Proposed STATS and Earnings Accountability Regulations
As we previously reported, the U.S. Department of Education (ED) has proposed new federal regulations that would establish the Student Tuition and Transparency System (STATS) and implement an earnings accountability framework that would apply a single earnings-based test to all academic programs.
These proposals have significant implications for Title IV eligibility, program‑level accountability, transparency, and institutional risk across higher education.
The public comment period closes May 20, 2026, and ED has emphasized that it will consider substantive public input when developing the final regulations.
Why This Matters
The final regulations, which could become effective as early as 2027, will reshape federal student aid eligibility and compliance expectations.
The key impacts include:
- Expansion of earnings‑based accountability beyond existing financial value transparency and gainful employment requirements to all programs participating in Federal Direct Loans.
- Implementation of STATS as the new framework for program‑level transparency and reporting.
You can review the proposed rule in the Federal Register.
How to Submit Comments
The public comment period gives institutions an opportunity to influence how these requirements are finalized and implemented.
To submit your comments:
- Navigate to the proposed rule page on the Regulations.gov website.
- Follow the instructions to provide your feedback, then select “Submit Comment.”
We recommend providing clear, specific comments that are supported by data, operational considerations, or student impact analysis wherever possible. Please note that all comments are public and attributed.
We encourage you to share this reminder with colleagues in academic leadership, financial aid, compliance, institutional research, and government relations. Thoughtful feedback from institutions will help ensure the final regulations reflect the operational realities of higher education and minimize unintended consequences.
Please contact us if you have questions or would like assistance evaluating the potential impacts.