OBBBA Compliance Watchdog

The 2025 budget reconciliation law (effective July 1, 2026, with the Department of Education's first calculations expected in 2027) introduces a 'do-no-harm' earnings-premium standard: a program loses federal Direct Loan eligibility if the median earnings of its graduates fall below the benchmark in two of three years. For undergraduate programs the benchmark is the median earnings of working adults aged 25 to 34 in the same state with only a high-school diploma. For graduate programs it is the lowest of three medians: bachelor's holders in the state, the same field in the state, and the same field nationally.

For every institution we compare each program's most recent median earnings four years after completion (U.S. Department of Education College Scorecard, Field of Study) against the state earnings benchmark (U.S. Census Bureau ACS): the high-school-graduate median for undergraduate credentials and the bachelor's median for graduate credentials. Exposure is the share of the institution's completions that sit in programs currently below that benchmark. The Census medians cover all earners aged 25 and over, and the graduate benchmark uses the state bachelor's median alone rather than the lowest of three, so the screen's bar usually sits above the statutory one and it tends to flag more programs than the official test would. It is an early-warning screen on public data, not the Department's official calculation, which uses its own cohorts, windows, and appeals process.

No. This is a directional risk screen, not a determination. The official test uses specific multi-year cohorts, confidence thresholds, suppression rules, and an institutional appeals process, and the regulations are still being written. Programs near the line should model their own cohorts. This view helps leadership and boards see where to look first.