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ARTICLE · 13 JULY 2026

Department Of Education Finalizes Earnings Accountability Framework For Title IV Programs – Key Takeaways For Institutions

Duane Morris LLP
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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...

United StatesConsumer Protection
Anthony J. Guida Jr.
Anthony J. Guida Jr.
Edward Cramp
Edward Cramp
Katherine Brodie
Katherine Brodie
Kristina Gill
Kristina Gill
John M. Simpson
John M. Simpson
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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.

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 (also known as the “One Big Beautiful Bill Act”). The final rule, titled “Accountability in Higher Education and Access Through Demand-Driven Workforce Pell: Student Tuition and Transparency System (STATS) and Earnings Accountability,” stays close to the consensus language agreed upon in the Department’s Accountability in Higher Education and Access through Demand-Driven Workforce Pell (AHEAD) negotiated rulemaking, with some important changes noted below after public comment following publication of the notice of proposed rulemaking (NPRM).

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