Federal accountability: articles for IR teams
The federal earnings-accountability regime for IR teams: STATS, FVT/GE, PPD, OBBBA, the tests programs have to pass, and how to map your exposure.
Why your program has no earnings number: 76.2 percent of PPD:2026 is dark, and what to put in the memo instead
In PPD:2026, 159,461 of 209,321 programs have no published median earnings figure, and the same 159,461 rows carry no federal earnings-test determination. Here is the decision tree for why a cell is blank, the floors we could observe in the file, and how much a second source recovers.
Clema Research Team · 16 mins readSame 3,361 programs, old GE test vs new OBBBA test: 569 walk free and 19 get caught
On the 3,361 GE programs in PPD:2026 where both regimes can be scored, 1,002 fail both, 569 fail only the old GE test and 19 fail only the new OBBBA test. The two casualty lists overlap on 63.0 percent of their combined 1,590 programs.
Clema Research Team · 13 mins read1,220 programs fail the OBBBA earnings test in PPD:2026. Here is the field and credential breakdown.
We ran the official OBBBA earnings test across all 209,321 rows of PPD:2026. 1,220 programs fail, out of 44,052 actually tested, a 2.77 percent rate. Visual and Performing Arts carries 27.7 percent of the failures, associate degrees fail at 6.60 percent, and 455 programs miss by less than $2,000.
Clema Research Team · 13 mins readInside 8,796 comments on the STATS rule: what higher ed actually told the Department
A deep-dive atlas of every public comment on the Department of Education's "Do No Harm" / STATS earnings-accountability proposal. Counts, themes, campaigns, pull-quotes, emotional register, and the implementation changes the sector is asking for before the first February 2027 results.
Wilson Bright · 16 mins readFVT/GE is ending: what the final 2026 reporting year means for your STATS transition
October 1, 2026 is the last FVT/GE submission under the old regime. Here is exactly what carries over to STATS, what does not, and the four things IR teams should do between now and the first Earnings Premium results.
Wilson Bright · 10 mins readFrom OBBB to Earnings Premium: how the new Workforce Pell accountability math actually works
The One Big Beautiful Bill created a new earnings-accountability regime for higher ed. Here is the line from OBBB to STATS to the Earnings Premium formula, and the 2-of-3 eligibility math, in plain English, with a worked example.
Wilson Bright · 10 mins readYour STATS exposure map: triage your programs before February 2027
ED publishes the first official Earnings Premium results in February 2027. Here's how to map your program-level exposure now, score, stress-test the two-of-three-years window, and plan substitution paths, before the results land in public.
Wilson Bright · 10 mins readThe 50% rule: how a handful of weak certificates can put your whole institution on provisional status
STATS introduced an institutional-level consequence that didn't exist under FVT/GE: if more than 50% of an institution's Title IV funds or recipients sit in failing programs, the entire institution goes on provisional status. Here's how to model your exposure before the cabinet asks.
Wilson Bright · 9 mins readSix files, 209,321 programs, three join keys: turning PPD:2026 into answers your provost actually asks
PPD:2026 looks like a single dataset. On disk it's six Excel files joined on opeid6 + credlev + cip4, with mixed-vintage dollars, statistical-noise privacy suppression, and a CIP-4 key that doesn't match the CIP-6 the STATS test will use. Here's where the analyst hours actually go, and how to skip them.
Clema Research Team · 10 mins readSTATS vs FVT/GE vs PPD: What's the Difference?
STATS, FVT/GE, and PPD all describe pieces of the same federal accountability regime under OBBBA. Here's a plain-English explainer of what each term means and how they fit together.
Wilson Bright · 8 mins read