OBBBA Compliance Watchdog
An early-warning screen on the 2025 budget law’s program-level earnings-premium standard. For every university we flag the programs whose graduate earnings currently fall below the state benchmark a high-school graduate (undergraduate programs) or bachelor’s graduate (graduate programs) earns, then rank institutions by the share of their completions sitting in those at-risk programs. Public data, a directional read for boards and leadership, not the Department’s official calculation.
Most exposed institutions
Ranked by the share of completions in programs currently below the state earnings benchmark, among 2,232 universities with at least four programs reporting earnings.
| # | Institution | Completions exposed | Programs below | Risk band | Example programs below benchmark |
|---|---|---|---|---|---|
| 1 | Los Angeles Film SchoolCA · Private for-profit | 100.0% | 4 / 4 | High exposure | Communications Technologies, Visual & Performing Arts |
| 2 | UEI College-BakersfieldCA · Private for-profit | 100.0% | 4 / 4 | High exposure | Business, Management & Marketing, Health Professions & Clinical Sciences |
| 3 | UEI College-FresnoCA · Private for-profit | 100.0% | 4 / 4 | High exposure | Business, Management & Marketing, Health Professions & Clinical Sciences |
| 4 | New York Film AcademyCA · Private for-profit | 100.0% | 4 / 4 | High exposure | Visual & Performing Arts, Visual & Performing Arts |
| 5 | Community Care CollegeOK · Private | 100.0% | 7 / 10 | High exposure | Personal & Culinary Services, Agriculture & Animal Sciences |
| 6 | Southern Careers Institute-BrownsvilleTX · Private for-profit | 100.0% | 4 / 4 | High exposure | Personal & Culinary Services, Computer & Information Sciences |
| 7 | Musicians InstituteCA · Private for-profit | 100.0% | 4 / 4 | High exposure | Communications Technologies, Mechanic & Repair Technologies |
| 8 | Southwest Institute of Healing ArtsAZ · Private for-profit | 93.8% | 3 / 4 | High exposure | Health Professions & Clinical Sciences, Personal & Culinary Services |
| 9 | Guam Community CollegeGU · Public | 93.1% | 5 / 6 | High exposure | Visual & Performing Arts, Education |
| 10 | American National UniversityVA · Private for-profit | 92.9% | 3 / 4 | High exposure | Business, Management & Marketing, Health Professions & Clinical Sciences |
| 11 | Berklee College of MusicMA · Private | 90.0% | 4 / 5 | High exposure | Visual & Performing Arts, Visual & Performing Arts |
| 12 | Palo Alto CollegeTX · Public | 89.1% | 1 / 4 | High exposure | Liberal Arts & Humanities |
| 13 | Valley College-MartinsburgWV · Private for-profit | 87.9% | 2 / 5 | High exposure | Health Professions & Clinical Sciences, Health Professions & Clinical Sciences |
| 14 | Southern Careers Institute-Corpus ChristiTX · Private for-profit | 87.4% | 3 / 4 | High exposure | Personal & Culinary Services, Business, Management & Marketing |
| 15 | Pima Medical Institute-RentonWA · Private for-profit | 87.0% | 2 / 4 | High exposure | Agriculture & Animal Sciences, Health Professions & Clinical Sciences |
| 16 | UEI College-Huntington ParkCA · Private for-profit | 85.6% | 3 / 5 | High exposure | Health Professions & Clinical Sciences, Homeland Security, Law Enforcement & Firefighting |
| 17 | Gallaudet UniversityDC · Private | 82.8% | 3 / 4 | High exposure | Public Administration & Social Service, Health Professions & Clinical Sciences |
| 18 | Laurel Business InstitutePA · Private for-profit | 81.5% | 3 / 6 | High exposure | Personal & Culinary Services, Health Professions & Clinical Sciences |
| 19 | Spokane Falls Community CollegeWA · Public | 81.1% | 4 / 7 | High exposure | Communications Technologies, Education |
| 20 | Coalinga CollegeCA · Public | 80.6% | 4 / 9 | High exposure | Family & Consumer Sciences, Liberal Arts & Humanities |
| 21 | Jones County Junior CollegeMS · Public | 79.5% | 4 / 8 | High exposure | Psychology, Liberal Arts & Humanities |
| 22 | San Joaquin Valley College-HesperiaCA · Private for-profit | 79.5% | 3 / 9 | High exposure | Health Professions & Clinical Sciences, Business, Management & Marketing |
| 23 | Intellitec College-Grand JunctionCO · Private for-profit | 79.1% | 2 / 4 | High exposure | Personal & Culinary Services, Health Professions & Clinical Sciences |
| 24 | Patrick & Henry Community CollegeVA · Public | 77.8% | 3 / 6 | High exposure | Family & Consumer Sciences, Liberal Arts & Humanities |
| 25 | UEI College-GardenaCA · Private for-profit | 77.1% | 3 / 4 | High exposure | Business, Management & Marketing, Health Professions & Clinical Sciences |
| 26 | Wenatchee Valley CollegeWA · Public | 77.1% | 1 / 5 | High exposure | Liberal Arts & Humanities |
| 27 | Lemoore CollegeCA · Public | 76.9% | 6 / 11 | High exposure | Family & Consumer Sciences, Family & Consumer Sciences |
| 28 | UEI College-StocktonCA · Private for-profit | 76.4% | 3 / 4 | High exposure | Health Professions & Clinical Sciences, Homeland Security, Law Enforcement & Firefighting |
| 29 | Southern Careers Institute-PharrTX · Private for-profit | 76.0% | 3 / 4 | High exposure | Computer & Information Sciences, Business, Management & Marketing |
| 30 | UEI College-ResedaCA · Private for-profit | 74.3% | 3 / 4 | High exposure | Health Professions & Clinical Sciences, Homeland Security, Law Enforcement & Firefighting |
| 31 | San Joaquin Valley College-FresnoCA · Private for-profit | 73.8% | 4 / 7 | High exposure | Health Professions & Clinical Sciences, Agriculture & Animal Sciences |
| 32 | Northeast Mississippi Community CollegeMS · Public | 73.0% | 1 / 5 | High exposure | Liberal Arts & Humanities |
| 33 | Coahoma Community CollegeMS · Public | 72.9% | 8 / 11 | High exposure | Precision Production, Personal & Culinary Services |
| 34 | Illinois Eastern Community CollegesIL · Public | 72.8% | 3 / 4 | High exposure | Personal & Culinary Services, Health Professions & Clinical Sciences |
| 35 | Life UniversityGA · Private | 71.9% | 2 / 6 | High exposure | Psychology, Health Professions & Clinical Sciences |
| 36 | UEI College-West CovinaCA · Private for-profit | 71.6% | 3 / 4 | High exposure | Health Professions & Clinical Sciences, Homeland Security, Law Enforcement & Firefighting |
| 37 | Cambridge CollegeMA · Private | 71.4% | 3 / 6 | High exposure | Education, Business, Management & Marketing |
| 38 | UEI College-OntarioCA · Private for-profit | 70.9% | 3 / 4 | High exposure | Health Professions & Clinical Sciences, Homeland Security, Law Enforcement & Firefighting |
| 39 | UEI College-Chula VistaCA · Private for-profit | 70.6% | 3 / 4 | High exposure | Health Professions & Clinical Sciences, Homeland Security, Law Enforcement & Firefighting |
| 40 | Trinidad State CollegeCO · Public | 70.4% | 5 / 8 | High exposure | Personal & Culinary Services, Mechanic & Repair Technologies |
| 41 | Las Vegas CollegeNV · Private for-profit | 70.2% | 1 / 4 | High exposure | Health Professions & Clinical Sciences |
| 42 | Parker UniversityTX · Private | 70.1% | 2 / 5 | High exposure | Health Professions & Clinical Sciences, Health Professions & Clinical Sciences |
| 43 | Carrington College-Phoenix NorthAZ · Private for-profit | 69.1% | 2 / 4 | High exposure | Agriculture & Animal Sciences, Health Professions & Clinical Sciences |
| 44 | Fortis Institute-WayneNJ · Private for-profit | 68.8% | 1 / 4 | High exposure | Health Professions & Clinical Sciences |
| 45 | School of Visual ArtsNY · Private for-profit | 68.7% | 4 / 7 | High exposure | Visual & Performing Arts, Communications Technologies |
| 46 | UEI College-Garden GroveCA · Private for-profit | 68.3% | 3 / 4 | High exposure | Health Professions & Clinical Sciences, Homeland Security, Law Enforcement & Firefighting |
| 47 | Converse UniversitySC · Private | 67.8% | 2 / 4 | High exposure | Health Professions & Clinical Sciences, Education |
| 48 | Pima Medical Institute-SeattleWA · Private for-profit | 66.0% | 2 / 4 | High exposure | Agriculture & Animal Sciences, Health Professions & Clinical Sciences |
| 49 | Charter CollegeAK · Private for-profit | 65.5% | 2 / 11 | High exposure | Agriculture & Animal Sciences, Health Professions & Clinical Sciences |
| 50 | Sinclair Community CollegeOH · Public | 65.1% | 4 / 18 | High exposure | Public Administration & Social Service, Personal & Culinary Services |
| 51 | United Education Institute-Las VegasNV · Private for-profit | 64.4% | 3 / 4 | High exposure | Business, Management & Marketing, Health Professions & Clinical Sciences |
| 52 | Norfolk State UniversityVA · Public | 64.3% | 2 / 4 | High exposure | Education, Public Administration & Social Service |
| 53 | Georgetown CollegeKY · Private | 64.1% | 1 / 5 | High exposure | Education |
| 54 | South Suburban CollegeIL · Public | 63.5% | 1 / 4 | High exposure | Liberal Arts & Humanities |
| 55 | UEI College-OceansideCA · Private for-profit | 62.9% | 3 / 4 | High exposure | Health Professions & Clinical Sciences, Homeland Security, Law Enforcement & Firefighting |
| 56 | Northwest CollegeWY · Public | 62.6% | 3 / 5 | High exposure | Liberal Arts & Humanities, Visual & Performing Arts |
| 57 | Southwest Texas CollegeTX · Public | 62.4% | 3 / 8 | High exposure | Family & Consumer Sciences, Precision Production |
| 58 | Hope International UniversityCA · Private | 60.3% | 5 / 10 | High exposure | Theology & Religious Vocations, Psychology |
| 59 | Southwest Mississippi Community CollegeMS · Public | 60.2% | 3 / 5 | High exposure | Personal & Culinary Services, Family & Consumer Sciences |
| 60 | Hollins UniversityVA · Private | 59.4% | 4 / 6 | High exposure | Education, Visual & Performing Arts |
“Completions exposed” is the share of an institution’s graduates in programs whose median earnings four years after completion fall below the state benchmark. A directional risk screen on public College Scorecard and Census data, not the U.S. Department of Education’s official earnings-premium calculation, an accreditation action, or legal advice. The Department uses its own cohorts, measurement windows, suppression thresholds, and an appeals process, and the implementing regulations are still being written. Institutions with fewer than four programs reporting earnings are excluded.
What is the earnings-premium test?
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 can lose federal student-aid eligibility if the median earnings of its graduates fall below the median earnings of a working adult in the same state who holds only a high-school diploma (for undergraduate programs) or only a bachelor's degree (for graduate programs), measured over multiple years.
How does Ibex estimate exposure?
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. It is an early-warning screen on public data, not the Department's official calculation, which uses its own cohorts, windows, and appeals process.
Does a high exposure score mean a program will lose aid?
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.
Want your institution’s program-level report?
Ibex can model your exact cohorts against the benchmark and flag programs that need attention before the first federal calculation.
Source: U.S. Department of Education, College Scorecard Field of Study (2024-25); state earnings benchmarks from the U.S. Census Bureau, ACS 5-year (2022 ACS 5-year). Compiled by Ibex Insights. For informational benchmarking only, not legal, accreditation, or financial advice. See the methodology.