CHEA’s policy briefing highlighted the U.S. Department of Education’s implementation timeline for a new earnings-based accountability framework for Title IV programs. The final regulations establish a “Do No Harm” standard tied to earnings outcomes and repayment performance, with rules that generally remove eligibility only when programs consistently underperform comparable benchmarks. The briefing also reports procedural next steps for institutions: submission requirements for either earnings/job outcome reporting under the GE/FVT approach or reporting via the Student Transparency System (STATS) framework. CHEA notes that early implementation election and delayed accountability consequences may apply for certain fields, including occupations where tipped income is substantial. For campus leaders, the immediate action items are compliance calendar decisions—how to report under the new framework, when to submit, and how to plan for program-level eligibility consequences beginning with early rates in 2027.