Takeaways For Institutions: DOE Finalizes Earnings Accountability Framework For Title IV Programs

On July 1, 2026, the U.S. Department of Education published a final rule implementing a new Title IV-program earnings premium measure established by Congress one year ago in the Working Families Tax Cut Act. The final rule stays close to the consensus language agreed upon in the Department’s Accountability in Higher Education and Access through Demand-driven Workforce Pell negotiated rulemaking, with some important changes noted below after public comment following publication of the notice of proposed rulemaking. The final rule represents a fundamental shift for higher education by implementing for the first time a congressionally mandated earnings-based metric that applies to all Title IV institutions and all of their Title IV eligible programs.

Read the full Alert on the Duane Morris LLP website.