The Department of Education’s new program-level earnings accountability rules are approaching, and institutions now have a narrow window to understand which programs carry Title IV risk. A planning guide from Noodle’s Chief Partnerships Officer Stephen Green lays out how the earnings test will work, when leadership teams need to act, and what internal data institutions may already have that can be used to prioritize remediation. The framework takes legal effect around September 2026, while program-level determinations for most programs are expected to begin July 1, 2027. Green’s guide emphasizes that key program exposure data will not be available until early 2028, compressing the timeline for institutions to identify where risk is concentrated and to redesign programs before the first determinations. According to the guide, leadership should focus on the rule’s measurement approach, where exposure tends to concentrate by program type, and the likely compliance redesign needs—rather than waiting for final outcome datasets. It also signals that institutions must build an internal workflow for tracking earnings-related indicators alongside Title IV eligibility responsibilities. With the first decisions landing soon after the data cutoff, the biggest operational challenge is moving from compliance planning to program-level decision-making in a short planning cycle.