A new planning guide is telling colleges they must prepare now for the Department of Education’s forthcoming earnings accountability rules under Title IV. The program-level earnings test will be central to determining whether programs remain eligible for federal student aid, with legal effectiveness expected around September 2026 and the first determinations arriving July 1, 2027 for most programs. The guide emphasizes that institutions will not receive the program-level data needed to measure exposure until early 2028, compressing the window for colleges to understand where risk is concentrated and what changes are worth making before the first determinations. For leadership teams, the guide frames earnings accountability as an operational planning exercise: institutions will need to map exposure by program type, align existing data sources to Title IV reporting requirements, and consider design and advising interventions early. The policy shift raises the compliance stakes for colleges already under pressure to improve outcomes transparency—especially those serving nontraditional and lower-income students whose results may vary across cohorts.