Lead: On Jan. 9, 2026 the U.S. Department of Education announced negotiators on the AHEAD committee reached consensus on a regulatory package that ties Title IV eligibility to a new earnings test across all postsecondary programs. The package would require programs to show graduates earn more than peers with a high-school diploma (and, for graduate programs, more than bachelor’s holders) or risk losing federal student-loan access. The proposal—framed as part of the One Big Beautiful Bill Act implementation—consolidates gainful-employment rules into a single earnings-based accountability framework and extends outcomes testing to programs and sectors that previously were exempt. The Administration’s change shifts the burden onto institutions and governing boards to track, validate and defend program-level earnings data when reporting to ED. What happened: negotiators set the earnings benchmark and an enforcement mechanism that can cut a program’s Title IV eligibility. Who’s involved: U.S. Department of Education, the AHEAD negotiating committee, Title IV institutions, and institutional governing boards. Why it matters: boards and presidents must now prepare for a data-driven compliance regime that can remove federal aid from programs that fail to meet the benchmark, forcing rapid curricular, credentialing and financial responses.