Why your program has no earnings number: 76.2 percent of PPD:2026 is dark, and what to put in the memo instead

We measured the suppression instead of describing it: the reason ladder, the observed reporting floors, and the second source that nearly doubles coverage

CRT
Clema Research Team
August 25, 2026
16 mins read
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Table of Contents

The base rate is a blank cell

Three out of four programs in the country have no published earnings number. In PPD:2026, 159,461 of 209,321 programs carry a blank `md_earn_wne_p4`, which is 76.2 percent of the file. Only 49,860 programs, 23.8 percent, have a median earnings figure at all.

The same 159,461 rows also carry no federal earnings-test result. `mstr_obbb_fail_cip2_wageb` is the wider of the two OBBBA result flags, the one that runs the comparison at every credential level whether or not the statute reaches it, and it is null on exactly those rows, with zero mismatches in either direction. There is no partial credit and no provisional result. A missing earnings figure and a missing accountability verdict are the same event.

So when the provost asks what graduates of a specific certificate earn and the analyst comes back with nothing, that is the base rate, not a failed search. The work worth doing is figuring out which of five specific things happened to the cell, then reaching for the fallback that fits.

Six files, 209,321 programs, three join keys covers the suppression rules at the level of "here is what the documentation says." This piece measures them: the floors the file actually honors, the band midpoints that get read as counts, and how much of the darkness a second dataset can recover. For the statutory side of the test itself, the OBBB to Earnings Premium walkthrough already does that job, and we will not repeat it here.

How we counted

Two datasets, queried directly, 29 queries logged. The first is PPD:2026, the Program Performance Data release published in January 2026: 209,321 programs across 5,096 institutions, 411 CIP-4 fields and 8 credential levels. The headline earnings variable, `md_earn_wne_p4`, is CPI-adjusted to 2024 dollars and comes from IRS records for pooled 2017-18 and 2018-19 completers, measured four years after exit.

The second is the Census Bureau's Post-Secondary Employment Outcomes file, built from state unemployment-insurance wage records at 1, 5 and 10 years after graduation, in 2023 dollars. PSEO covers 32 states and 950 institutions, so nothing derived from it is a national figure and we never call it one. PPD is national in scope, covering all 59 jurisdictions.

"Dark" throughout means one thing: no published median earnings value in the cell. Not zero earnings, not an error in your join. A blank.

Every credential level is majority dark

There is no credential level where you can expect to find an earnings number. The best-covered category in the entire file is the First Professional Degree, and even there 59.5 percent of programs are blank. The worst is the Post-baccalaureate Certificate, where 85 of 3,469 programs have a figure and the other 97.5 percent do not.

The ordering runs backwards from the usual assumption that graduate credentials are the better covered ones. Graduate certificates (95.8 percent dark) and doctoral degrees (90.9 percent dark) are among the darkest things in the file, worse than undergraduate certificates and associate degrees.

Coverage by credential level, current earnings measure

Credential levelProgramsWith an earnings numberDark
Undergraduate Certificate38,3495,72385.1%
Associate Degree42,9337,64282.2%
Bachelor Degree68,97124,93663.8%
Post-baccalaureate Certificate3,4698597.5%
Master's Degree33,6409,37372.1%
Doctoral Degree11,8591,08290.9%
First Professional Degree1,64866759.5%
Graduate Certificate8,45235295.8%
All programs209,32149,86076.2%

Share of programs with no published earnings figure, by credential level

Percent of programs with no earnings figure
97.5%
Post-bacc cert
95.8%
Grad cert
90.9%
Doctoral
85.1%
Undergrad cert
82.2%
Associate
72.1%
Master's
Credential level

PPD carries three earnings measures, not one, and letting a program qualify on any of the three barely moves the picture. Counting all three vintages, post-baccalaureate certificates are 96.9 percent dark instead of 97.5, graduate certificates 94.3 instead of 95.8, doctoral 89.5 instead of 90.9, undergraduate certificates 82.8 instead of 85.1, associate 78.2 instead of 82.2, master's 69.7 instead of 72.1, bachelor 60.4 instead of 63.8, and first professional 54.4 instead of 59.5. A few points each. Nothing structural.

No field of study is safe

Across the 36 CIP-2 families with 500 or more programs, the best-covered field in the country is 62.0 percent dark. That is Personal and Culinary Services, with 2,994 programs. The worst is Philosophy and Religious Studies at 94.1 percent, with 2,470 programs. Every single large field sits inside that band.

The fields where a provost is most likely to ask sit right in the middle of it. Computer and Information Sciences: 83.1 percent dark across 11,046 programs. Education: 74.3 percent across 16,225. Business: 70.3 percent across 24,024. Health Professions, the largest family in the file at 29,246 programs, is among the better-covered ones at 66.2 percent dark, and two thirds of it is still blank.

Share of programs with no published earnings figure, six fields of study

Percent of programs with no earnings figure
94.1%
Philosophy and religion
89.8%
Physical Sciences
87.5%
Engineering tech
83.1%
Computer and info sci
74.3%
Education
66.2%
Health professions
Field of study (CIP2)

No state, no sector, no size of college escapes it

No jurisdiction in PPD:2026 comes in under 66.7 percent dark, and the observed minimum sits above that line rather than on it. The best-covered anywhere is New York at 69.0 percent across 11,541 programs, followed by Wisconsin at 70.8, Rhode Island at 70.9, Florida and Virginia both at 71.3, Minnesota at 72.6, New Jersey at 73.0 and Massachusetts at 73.8. The darkest of the 50 states is Alaska at 87.4 percent across 641 programs, then Montana 85.9, Wyoming 85.5, and New Mexico and California both 83.3. Several territories and freely associated states run darker than any state, up to the 100 percent that is the highest value anywhere. California is the striking case: 23,578 programs, the largest state universe in the file, and five out of six of its programs have no earnings figure.

Sector barely separates anything either, with one exception. Private non-profit institutions are 78.1 percent dark across 68,058 programs, public institutions 76.5 percent across 133,507 programs, and for-profit institutions 53.4 percent across 7,756 programs. For-profits are the best-covered sector in the country by more than twenty points, on the smallest program footprint. The file does not say why. A shorter catalog of larger programs would produce exactly this.

Institution size cuts the opposite way from the intuition, and getting it backwards is how bad memos get written. Per program, small colleges are covered better than large ones: colleges running 1 to 5 programs have 54.1 percent of those programs dark, while colleges running 31 to 60 programs have 80.8 percent dark. A tiny college usually runs one or two big programs, and big programs clear the floor.

The penalty for being small is not at the program level. It is at the institution level, where it is brutal.

Coverage by how many programs the college runs

Programs the college runsCollegesShare of their programs that are darkShare of colleges with zero numbers anywhere
1 to 51,89454.1%31.1%
6 to 1559069.2%20.0%
16 to 3037979.9%12.4%
31 to 6096580.8%5.2%
61 to 12087477.7%2.5%
More than 12039473.2%2.3%

Nearly a third of the smallest colleges, 589 of 1,894, have no published earnings figure for any program they run. Not one. Across the whole file, 835 of 5,096 institutions (16.4 percent) are in that position. If you work at one of them, every program-level earnings question you receive has the same answer, and you should say so once, in writing, rather than re-running the search each time it is asked.

Counting all 5,096 institutions, those 835 included, the median institution has a published earnings figure for exactly 25.0 percent of its own programs. The mean is 35.4 percent, pulled up by the large systems.

"The median institution in PPD:2026 has a published earnings figure for exactly one quarter of its own programs. Planning a program review around published earnings means planning around the quarter you can see."

Five reasons a cell is blank

A blank is not one thing. Five different situations produce the same empty cell, and each one points at a different fallback. Work down this list in order. The first branch that matches is your answer, and each branch has a sentence you can put straight into the memo.

Working out why the cell is empty

1

The cohort was below the reporting floor

By far the most common branch

The file simply never publishes small cells, and it is consistent about where the line sits. On the IRS-derived earnings measure, the smallest cohort count anywhere in PPD:2026 is 16, for both count_wne_p4 and count_wne_p4_1516. Not one row in 209,321 carries a value of 1 to 15. On the debt side the smallest cohort count that appears anywhere is 10, and the debt median itself needs 19 borrowers.

  • The cohort count and the median travel together on the current earnings measure: count_wne_p4 is non-null on exactly the same 49,860 rows as md_earn_wne_p4, and zero rows have one without the other.
  • So if the count is blank too, you are almost certainly here, and no amount of re-joining will produce a number.

Memo sentence: the completer cohort was too small for federal reporting, so no earnings figure exists for this program in this release.

2

A cohort count exists, but it is a band midpoint and the median is withheld

The branch that produces wrong internal averages

On the gainful-employment three-year measure, count_ne_p3_1516 takes the value 15 on 2,509 programs and the value 25 on 8,388 programs, and never takes any value from 16 to 24 or from 26 to 29. Those are not counts. 15 stands for a cohort of 10 to 19 and 25 stands for a cohort of 20 to 29. All 10,897 of those programs have a null median, which is 29.5 percent of the 36,995 programs carrying any p3 cohort count.

  • Never average or sum these values as if they were real cohort sizes. A departmental rollup that treats 15 as a headcount is wrong by construction, and nothing in the file will flag it.
  • A band midpoint is still information: it tells you the program is small, which is often the actual answer the provost needs.

Memo sentence: the file reports an approximate cohort size in the 10 to 19 range and withholds the median, so we can report scale but not earnings.

3

The cohort cleared the size threshold and the median is missing anyway

Rare, and narrower than people think

Disclosure avoidance is the branch everyone reaches for first, and on the gainful-employment three-year measure it almost never applies: 156 programs have a p3 cohort of 30 or more and still no published median. That is 0.6 percent of the 26,098 cells that clear the size threshold. Of those 156, 121 have 100 or more completers. Check the scope before you lean on this one. It is a statement about the p3 median, not about the headline four-year figure, and the file gives no reason for any individual withholding.

Memo sentence: this program clears the size threshold and the three-year median is withheld anyway, so cohort size is not the explanation and the file does not offer another one.

4

The credential sits outside the scope of the test

Not suppression at all

Some programs are blank on the test columns because the test does not reach them. 41,818 programs, 20.0 percent of the file, carry which_test_cip2_wageb = "Not Listed in Section 84001". That group is exactly all 38,349 undergraduate certificates plus all 3,469 post-baccalaureate certificates, and no other credential level. There is also a small graduate-only flag, missing_test_cip2_wageb, true on 2,995 rows (1.4 percent): 1,747 master's, 569 doctoral, 216 first professional and 463 graduate certificate. It is never true for an undergraduate program.

For the rest of the file the applicable benchmark is named, and the split is lopsided: the Same-State HS Median alone covers 97,660 programs, 46.7 percent of the file, and six other benchmark types share the remaining 69,843. The two-regime comparison carries the full distribution with a median bar against each type.

Memo sentence: this credential is not listed under the relevant section of statute, so no benchmark is assigned and no result is expected.

5

There is no number, so there is no determination

The consequence branch

This is the one that matters at the cabinet table. mstr_obbb_fail_cip2_wageb is null on exactly the same 159,461 rows where md_earn_wne_p4 is null, with zero mismatches. A dark program is not a passing program and it is not a failing program. It has not been evaluated. Anyone building a risk register off the published flags is building it on 23.8 percent of the portfolio, and the statutory result is narrower still: 1,220 official failures against a tested denominator of 44,052, which is 21.0 percent of the file.

Memo sentence: no earnings figure means no federal determination for this program, so it belongs in an "unevaluated" column, not in the passing column.

One branch people expect that does not exist

A sixth reason gets offered constantly in meetings: the program is blank because it is not gainful-employment eligible. The data says the opposite. Programs ever classified as GE are worse covered than programs never classified as GE, not better: 14.1 percent of GE programs have a current earnings figure (7,633 of 54,063) versus 27.2 percent of never-GE programs (42,227 of 155,258). On the gainful-employment three-year measure it is 6.9 percent against 14.3 percent.

GE status marks the kind of program that tends to get suppressed (short and small), so it travels with the blank rather than causing it. Drop it from the decision tree.

The reporting floors, as the file actually behaves

The five floors below are what we could observe by scanning the loaded data for the smallest value that ever appears. They are a description of what the file does, not a citation of regulatory text. They are also unusually clean as minima: nothing below any of these floors appears anywhere, zero exceptions, which is how you know you are looking at a rule rather than a coincidence. A floor is not a publication guarantee, though. Clearing one is necessary, not sufficient, as the 156 programs in branch three show.

Reporting floors observed in the loaded data

What you are looking forFloor observed in the file
IRS median earnings, four years out16 completers with earnings. No cohort of 15 or fewer appears anywhere
Gainful-employment three-year median30 completers. Cohorts of 10 to 19 print as 15 and 20 to 29 print as 25, with the median always withheld
Median student debt19 borrowers. Published at 19, withheld at 18, no exceptions across 51,301 rows
Any variable at all10 students. No count below 10 appears in the file
PSEO median earnings30 graduates with earnings. Smallest published cell is exactly 30, matching the catalog rule

The exclusive reason ladder

Put every program in the file into exactly one bucket, working from most informative to least, and the shape of the problem is blunt. More than two thirds of the national program universe, 145,221 programs or 69.4 percent, is fully dark: no earnings figure on any of the three measures, no debt median, not even a cohort headcount. There is nothing in the row to fall back to.

Why a PPD:2026 cell is blank, one bucket per program

Reason the cell is blankProgramsShare of all 209,321
Nothing is blank: current earnings published49,86023.8%
Only an older completer cohort is published6,0182.9%
Only the gainful-employment three-year measure is published1640.1%
A cohort headcount exists but every median is withheld3950.2%
No earnings at all, but a median debt figure is published8810.4%
No earnings, no debt median, only a debt cohort count6,7823.2%
Fully dark: no earnings, no debt, no cohort count145,22169.4%

Exclusive reason ladder, percent of all 209,321 programs

Percent of all 209,321 programs
69.4%
Fully dark
23.8%
Current earnings published
3.2%
Debt cohort count only
2.9%
Only an older cohort published
0.4%
Debt median but no earnings
0.2%
Headcount only, medians withheld
Reason the cell is blank

The middle rows are the interesting ones for practice, because they are the recoveries. Falling back to an older completer cohort inside PPD is legitimate and it works, a little: `md_earn_wne_p4_1516` is published on 42,005 programs and `md_earn_ne_p3_1516` on 25,942, and using all three measures together lifts coverage from 49,860 programs to 56,042, from 23.8 percent to 26.8 percent. That recovers 6,182 programs for the cost of one extra column, and it still leaves you dark on 73 percent of the file.

No number means no determination

The 159,461 match is exact, and the exactness is the point. Programs are not being scored on partial evidence or given a provisional result pending more data. Where the earnings figure is missing, the master pass/fail flag is missing, and the two sets are identical to the row.

For anyone assembling an institutional exposure picture, this changes the arithmetic of the denominator. A dashboard that shows "programs failing" over "programs in the file" understates risk, because three quarters of the denominator was never tested. The honest presentation has three columns: passing, failing, and not evaluated. If you are building that view for the first time, the exposure-map playbook walks through the triage order.

The debt side is worse, and in different dollars

Debt coverage is thinner than earnings coverage: 39,639 programs of 209,321, or 18.9 percent, have a published median debt figure. The threshold is the sharpest in the whole file. Median debt is published whenever `debt_all_stgp_eval_n` is 19 or more and withheld whenever it is 18 or fewer, with zero exceptions across the 51,301 rows that carry a debt count. That means 14,690 programs tell you how many borrowers they had and refuse to tell you what those borrowers owed.

Combine the two sides and the most requested ratio in program review mostly cannot be computed. Only 38,027 programs, 18.2 percent of the file, have both a debt median and an earnings median. 11,833 have earnings but no debt, 1,612 have debt but no earnings, and 157,849 have neither. Fewer than one program in five supports a debt-to-earnings calculation.

One more trap when you do have both. PPD debt is CPI-adjusted to 2019 dollars while PPD earnings are adjusted to 2024 dollars. They are in the same table, next to each other, in different money. Do not put them in the same sentence without saying so, and do not build a ratio that quietly treats them as comparable.

A second source nearly doubles your coverage

When you hit a blank, the next thing to try is a different publisher. Our overlap universe is 90,238 program cells: the institutions PSEO reports on inside its 32 states, not every program in those states. PPD alone lights 19,192 of them, 21.3 percent. Add PSEO's 1-year median and 37,256 are lit, 41.3 percent. That is a 94 percent relative increase in the number of programs you can say anything about, and 18,064 cells have a PSEO figure where PPD is blank.

Two warnings before you use that. First, PPD and PSEO are not the same measurement. PPD earnings come from IRS records four years after exit for pooled 2017-18 and 2018-19 completers in 2024 dollars. PSEO earnings come from state unemployment-insurance wage records at 1, 5 and 10 years after graduation in 2023 dollars. A program lit in one file and dark in the other has been measured once, differently. It has not been confirmed twice.

Second, most published figures cannot be cross-checked at all. Only 14,608 of the 90,238 cells (16.2 percent) carry a number from both sources. 4,584 are PPD-only, and 52,982 (58.7 percent) are dark in both. Even with two large publishers pointed at the same question, and even inside the institutions both of them report on, more than half of that universe stays blank.

The payoff is also lopsided, and it is concentrated exactly where undergraduate program review lives.

Percent of program cells with an earnings number, PPD alone against PPD plus PSEO

Percent of program cells with an earnings number
7.8%
Undergraduate Certificate, PPD alone
36%
Undergraduate Certificate, plus PSEO
15.4%
Associate Degree, PPD alone
45.3%
Associate Degree, plus PSEO
40.4%
Bachelor Degree, PPD alone
65.6%
Bachelor Degree, plus PSEO
Source combination

Undergraduate certificates go from 7.8 percent lit to 36.0 percent across 18,550 cells. Associate degrees go from 15.4 to 45.3 across 20,837. Bachelor degrees go from 40.4 to 65.6 across 25,408. First professional degrees go from 31.3 to 58.8 across 723.

Above the bachelor's line, the second source buys you nothing. Master's degrees stay at 24.3 percent across 14,473 cells. Doctoral degrees stay at 6.8 across 5,430. Graduate certificates stay at 3.8 across 3,378. Post-baccalaureate certificates move from 2.2 to 2.6 across 1,439, which is noise.

The reason is structural rather than statistical. PSEO does not publish master's or doctoral-research earnings at the CIP-4 grain at all: 48,849 master's and 18,442 doctoral-research institution-level CIP-4 rows are flagged privacy-suppressed and null across every cohort, and adding the state-level rows makes 96,340 rows with zero published values. Those rows are empty by construction, not by cell size. None of the 67,291 institution-level rows carries an IPEDS graduate count either. Waiting for a bigger cohort will not fill them.

What the PSEO status codes actually mean

PSEO is more honest than PPD about why a cell is empty: it tells you, with a status flag. Getting the vocabulary right matters, because there are two published versions of it and only one is correct for this data. The `status_flag` domain in the PSEO data dictionary claims 1 means suppressed. In the loaded database it is the reverse: every one of the 34,275 code-1 cells carries a median, and every code-5 cell is null. Use the table below and ignore the dictionary domain. The readings for codes 5, -1, 3 and 4 come from how those codes behave in the loaded data, not from the published domain.

PSEO status codes and what is in the cell

PSEO status codeWhat the code meansIs there a number in the cell
1Valid dataYes. All 34,275 code-1 cells in the working slice carry a median
5Privacy-suppressed (cell size under 30)No. Confirmed: the smallest published cell is exactly 30 graduates
-1Not yet available (cohort too recent)No. Appears only at 5 and 10 years, never at 1 year
3IPEDS count not availableNo. Appears only on the graduate-count flags
4IPEDS count partially missingNot an earnings flag. Appears only on the graduate-count flags
0Value OK, no suppression (published dictionary)Does not occur in this database
9Complementary suppression (published dictionary)Does not occur in this database

The working slice here is 75,772 program cells: institution level, CIP-4, all cohorts pooled, the PSEO grain closest to a PPD program. At 1 year after graduation, 34,275 cells are published, 45.2 percent. At 5 years, 31,160, or 41.1 percent. At 10 years, 22,809, or 30.1 percent.

Coverage falling with the horizon looks like heavier suppression and partly is not. At 10 years, 35,424 cells (46.8 percent) are privacy-suppressed and another 17,539 (23.1 percent) carry code -1, meaning the cohort simply has not been observed ten years out yet. At 5 years the code -1 count is 6,587 (8.7 percent), and at 1 year it never appears. A code -1 cell is a "come back later." A code-5 cell is not.

Separating those two failure modes changes how good PSEO looks. 16,872 of the 75,772 pooled cells (22.3 percent) are dark because the publisher does not release that degree level at that CIP grain, full stop. Of the 58,900 cells PSEO actually attempts, 34,275 are published, 58.2 percent, and 24,625 are suppressed on cell size. PSEO publishes most of what it tries to publish. It just tries on less than you would like.

Participation is uneven in a way that will bite anyone comparing states. PSEO holds 621,941 rows across 32 states and 950 institutions, but Texas contributes 110 institutions while Michigan and Idaho contribute one each, and Alabama and Arizona three each. The 1-year published share ranges from 27.6 percent (Michigan, one institution, 330 cells) to 67.7 percent (Idaho, one institution, 93 cells), and no state publishes 70 percent of its CIP-4 program cells. Among states with real institutional coverage: South Carolina 56.4 percent across 54 institutions, New York 52.2 across 79, Virginia 49.2 across 67, Minnesota 48.2 across 61, Texas 47.0 across 110, Illinois 45.1 across 79, Ohio 43.4 across 38, Indiana 42.5 across 62, Georgia 41.1 across 35, Massachusetts 38.4 across 28, and Pennsylvania 29.2 across 24. Read the institution count before you read the percentage.

What to put in the memo instead

You cannot manufacture a suppressed median. You can write a memo that answers the underlying question, which is almost never "what is the median" and almost always "is this program worth continuing." Five things go in it, in this order.

The five fallbacks, in order of yield

1

Roll up one CIP level

The single highest-yield move

Nothing else in this analysis comes close. PSEO 1-year published share at the CIP-4 grain, then the CIP-2 family, then all fields combined: Baccalaureate 74.8, 85.2, 95.7 percent. Associates 54.4, 65.6, 95.2. Certificates under one year 43.1, 55.0, 85.4. Certificates of one to two years 40.0, 51.4, 88.1. For master's and doctoral-research programs the jump is from nothing to almost everything: 0.0 to 82.8 to 95.1 percent for master's, and 0.0 to 75.5 to 83.6 for doctoral research.

Memo sentence: we cannot report earnings for this program, but graduates of this field at this institution have a published median, and here it is.

2

Check the second publisher before you declare the number missing

Inside the overlap universe, 18,064 program cells have a PSEO 1-year figure where PPD is blank, lifting coverage from 21.3 percent to 41.3 percent. The lift is real below the master's line and zero above it, so check first for certificates, associate and bachelor programs, and do not bother for graduate credentials at the CIP-4 grain.

Memo sentence: the federal program file is blank here, but the state wage-record file publishes a figure for the same program, measured differently, and we are reporting that instead.

3

Report the cohort size, since it often survives when the median does not

PSEO usually still hands you a headcount when it suppresses earnings: 19,836 of the 41,497 cells with suppressed 1-year earnings, 47.8 percent, still carry an IPEDS graduate count. It runs the other way too, on 1,609 cells that have published earnings and no graduate count. In PPD, the p3 band midpoints do the same job more crudely: a value of 15 tells you the cohort is between 10 and 19.

Memo sentence: earnings are withheld, but the program graduates roughly this many students a year, which is the number the viability question actually turns on.

4

Take the older cohort inside the same file

Using all three PPD earnings measures instead of just the current one lifts coverage from 49,860 programs to 56,042, 23.8 percent to 26.8 percent, recovering 6,182 programs. Small, but it costs one extra column and the vintage is disclosed in the file. Label the cohort year in the memo, because a 2015-16 completer cohort answers a different question than a 2018-19 one.

Memo sentence: no current figure exists, so we are reporting the earlier completer cohort and flagging the vintage.

5

Say what the blank itself means

The finding that reframes the whole conversation

Dark programs are small programs, and the asymmetry is extreme. Among PSEO cells where a graduate count exists, suppressed cells are 37.8 percent of the cells but only 2.1 percent of the graduates. The average suppressed cell has 23.3 graduates; the average published cell has 647.2. Suppression is hiding a large number of very small programs, not a large number of students.

  • That cuts both ways. Your dark programs are, on the whole, tiny, and being tiny is itself a viability finding.
  • It also means a portfolio-level earnings average built only on published cells describes almost all of your graduates, even though it describes only a quarter of your programs.

Memo sentence: this program is dark because it is small, and its size is the relevant fact for the decision in front of us.

The version of this memo that gets a decision made says four things in four sentences. Here is why the cell is blank, named from the five branches. Here is the nearest defensible number and what it actually measures. Here is the cohort size, because size is what the question was about. And here is the one thing we can say with certainty: this program has no federal determination, so it cannot be counted as passing.

That memo takes fifteen minutes if you already know the suppression structure. It takes most of a week if you have to rediscover it, program by program, every time the question is asked in a slightly different shape.

Method, vintages, and what these numbers do not say

Everything above comes from direct queries against two loaded datasets, logged so they can be re-run. The full query set, including the analyses we discarded and why, is in the evidence files listed under Sources.

PPD:2026 is release year 2026, published January 2026. Earnings are from pooled 2017-18 and 2018-19 completer cohorts, four years after exit, from IRS records, CPI-adjusted to 2024 dollars. Debt is CPI-adjusted to 2019 dollars. The unit of analysis is the program, defined as the combination of institution, credential level and CIP-4 code, 209,321 of them.

PSEO is the pooled all-cohort view (grad cohort 0000, latest cohort 2019), earnings in 2023 dollars, from state unemployment-insurance wage records. It covers 32 states and 950 institutions. No PSEO figure in this piece is a national figure and none should be described as one.

Four things these numbers do not say:

  • The 90,238-cell overlap universe is a constructed crosswalk, not an official one. We mapped PSEO degree levels to PPD credential levels and stripped PSEO dotted CIP codes to PPD undotted CIP. 19,921 cells appear only in the PPD file and 18,221 only in PSEO, so the two publishers do not agree on what counts as a program. Read the coverage lift as a coverage lift, not as proof that a specific program exists in both files.
  • The reporting floors (16 completers for IRS earnings, 19 borrowers for debt, 10 students for any variable, 30 graduates for PSEO and for the gainful-employment three-year median) are what the loaded data does. The PSEO floor of 30 matches the catalog's stated rule. Treat the rest as observed behavior, not as a citation of regulation text.
  • The p3 cohort values of 15 and 25 are band midpoints for 10 to 19 and 20 to 29. They are not counts and must never be averaged or summed as if they were.
  • The graduate weights behind the 2.1 percent figure are PSEO's pooled all-cohort IPEDS completion counts across 32 states. That pool counts a graduate once per cohort year, so it is not an annual graduate count and should not be quoted as one.

Ask why the cell is blank, not just what is in it

Clema reads PPD:2026 and PSEO together, applies the suppression logic, and answers program-level earnings questions in plain English, including the ones where the honest answer is why no number exists.

Book a demo

Sources

Datasets: U.S. Department of Education, Program Performance Data (PPD:2026) and U.S. Census Bureau, Post-Secondary Employment Outcomes. PSEO status-code definitions and the cell-size rule are from the PSEO data documentation.

Reproducible query log: `docs/data-evidence/why-your-program-has-no-earnings-number/queries.md` (29 numbered queries plus the discarded analyses and why they were dropped) and `docs/data-evidence/why-your-program-has-no-earnings-number/schema.md` (table and column definitions, vintages, and the status-code contradiction).

Related reading on this site: Six files, 209,321 programs, three join keys, From OBBB to Earnings Premium, and the program-level exposure map.

Frequently asked questions

How many programs actually have a published earnings number?

In PPD:2026, 49,860 of 209,321 programs, or 23.8 percent. The other 159,461 programs, 76.2 percent, have a blank median earnings figure. Coverage is thin at every credential level: the best-covered is the First Professional Degree at 59.5 percent dark, and the worst is the Post-baccalaureate Certificate, where only 85 of 3,469 programs carry a number.

If a program has no earnings number, did it pass or fail the federal test?

Neither. It was not evaluated. The master pass/fail flag, mstr_obbb_fail_cip2_wageb, is null on exactly the same 159,461 rows where the earnings figure is null, with zero mismatches. A dark program belongs in an "unevaluated" column. Counting it as passing understates institutional exposure, because three quarters of the denominator was never tested.

What are the actual cell-size floors below which nothing is published?

Observed in the loaded file: IRS median earnings require 16 completers with earnings, and no cohort of 15 or fewer appears anywhere. Median debt requires 19 borrowers, published at 19 and withheld at 18 with no exceptions. No count below 10 appears for any variable. PSEO requires 30 graduates with earnings, and its smallest published cell is exactly 30.

Do cohort counts of 15 or 25 mean the program had 15 or 25 completers?

No. Those are band midpoints. On the gainful-employment three-year measure, 15 stands for a cohort of 10 to 19 and 25 for a cohort of 20 to 29, and values from 16 to 24 or 26 to 29 never appear. All 10,897 programs carrying a 15 or a 25 have a withheld median. Never average or sum these values as if they were counts.

Does checking a second dataset help, and by how much?

Substantially, below the graduate level. Across the 90,238 cells in our constructed overlap universe, meaning the institutions PSEO reports on inside its 32 states, PPD alone lights 21.3 percent and PPD plus PSEO's 1-year median lights 41.3 percent, a 94 percent relative increase. Undergraduate certificates go from 7.8 to 36.0 percent lit. Above the bachelor's line the gain is zero, because PSEO does not publish master's or doctoral-research earnings at the CIP-4 grain.

Are small colleges hit hardest by earnings suppression?

Not at the program level, where the intuition is backwards: colleges running 1 to 5 programs have 54.1 percent of them dark, against 80.8 percent for colleges running 31 to 60. The penalty lands at the institution level. 31.1 percent of the smallest colleges have zero published earnings figures anywhere, against 2.3 percent of the largest.

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