# Will Your Programs Pass? The New Federal Earnings Test and Academic Portfolio Review > Higher Education · ibl.ai > Source: https://ibl.ai/courses/higher-education/program-earnings-accountability > Last updated: 2026-11-14 *Read the 2025 law's earnings test, flag programs at risk and run a portfolio review that weighs mission, cost and demand* **A higher education course from ibl.ai (self-paced, 8 to 10 hours, free).** A self-paced course for provosts, deans, institutional research directors and CFOs on the program-level earnings test in Public Law 119-21: which programs it covers, how to find your programs' public earnings data and flag those at risk, what losing Direct Loans would mean, and how to run a defensible academic portfolio review. - **Price:** Free - **Format:** Self-paced, online - **Time:** 8 to 10 hours - **Pace:** 2.5 hours per week - **Level:** Intermediate - **Language:** English - **Subject:** Academic Affairs [Enroll](https://lms.ibl.ai/platform/highereducation/courses/course-v1:highereducation+program-earnings-accountability+self-paced) ## Course description Will Your Programs Pass? teaches the federal earnings test that Public Law 119-21 added to section 454(c) of the Higher Education Act and the final rule of July 1, 2026 that implements it, effective July 1, 2027. You will learn which degree and certificate programs are covered, how each program's comparison group of working adults is chosen, what is fixed and what is still pending, and how Federal Student Aid is implementing the rule. Hands-on labs use College Scorecard field-of-study data to build a risk table for your own programs. You then model what losing Direct Loans would do to enrollment and revenue, including the new graduate loan limits and the institution-wide 50 percent check, and run a portfolio review that weighs mission, cost, demand and outcomes under shared governance. The capstone is a portfolio review memo for one college or school. Every rule is cited to the statute, 91 FR 40136 or fsapartners.ed.gov, last verified 2026-11-03. ### About this course The 2025 reconciliation law, Public Law 119-21 (the One Big Beautiful Bill Act, which the Department of Education now calls the Working Families Tax Cuts Act), added a program-level earnings test to federal student aid. A degree or graduate certificate program whose federally aided graduates earn less than a comparison group of working adults in two of three years loses access to federal Direct Loans. The Department published the final rule that implements the test on July 1, 2026, and it takes effect on July 1, 2027. This course teaches the test from the primary sources: the statute at [20 U.S.C. § 1087d(c)](https://www.law.cornell.edu/uscode/text/20/1087d), the [final rule at 91 FR 40136](https://www.federalregister.gov/documents/2026/07/01/2026-13286/accountability-in-higher-education-and-access-through-demand--driven-workforce-pell-student-tuition) and Federal Student Aid guidance on [fsapartners.ed.gov](https://fsapartners.ed.gov/knowledge-center/topics/student-tuition-and-transparency-system-information). Labs use the [College Scorecard](https://collegescorecard.ed.gov/data/) and IPEDS to build a risk table for your own programs, and the second half of the course turns that table into a portfolio review that weighs mission, cost, demand and outcomes. ### What you will be able to do - Explain the program-level earnings test that Public Law 119-21 added to section 454(c) of the Higher Education Act, which programs it covers, and how the 2026 final rule puts it into operation. - Identify the comparison group and geography that apply to each of your programs, and separate what the statute and final rule fix from what is still pending or only estimated. - Download your institution's College Scorecard field-of-study data and build a program risk table that labels screening proxies, margins and confidence honestly. - Describe what happens when a program fails: student warnings, appeals, loss and reinstatement of Direct Loan eligibility, orderly closure, the Direct Loan opt-out and the institution-wide 50 percent check. - Model the enrollment and net tuition effect of losing Direct Loans for a program, including the new graduate and parent loan limits. - Run a defensible academic portfolio review that weighs mission, cost, demand and outcomes, follows shared governance and communicates accurately with students. ### Who this course is for **Roles:** provosts and vice provosts, deans and associate deans, institutional research directors, chief financial officers and budget directors, financial aid directors, and presidents' cabinets. **Institutions:** public and private nonprofit colleges and universities that participate in the federal Direct Loan program. **Before you start:** no legal or statistical background is needed. For the labs you need a spreadsheet program that can handle a large file, or Python with the pandas library, and your institution's six-digit OPE ID. ### Format **Time:** 8 to 10 hours, self-paced. **Level:** intermediate. **Hands-on:** labs in which you download your institution's Scorecard field-of-study file, build a risk table, and run the institution-wide check, with an illustrative sample table for comparison. **Structure:** a Start here section, four content sections of readings, worked examples, templates and labs, each ending in an AI assessment, and a capstone in which you write a portfolio review memo for one college or school, followed by a reading list. **Grading:** the four section AI assessments count for 60 percent of the grade and the capstone assessment for 40 percent. The pass mark is 70 percent. ### Currency **Last verified 2026-11-03** against Public Law 119-21, the final rule published July 1, 2026, Federal Student Aid electronic announcements through October 8, 2026, and the College Scorecard data released November 2, 2026. These rules are still changing. The final rule takes effect July 1, 2027, and the Department will publish the yearly earnings thresholds, the wording of student warnings and the appeal process in later notices; Federal Student Aid has said it intends to publish draft data in 2027. Check the current sources before acting, and take institution-specific questions to your financial aid office, institutional research office and counsel. This course is training, not legal or financial advice. ## Outline ### Section 0 · Start here - 0.1 Welcome and orientation ### Section 1 · Understand the federal earnings test - 1.1 What the law says - 1.2 How the final rule puts it into operation - 1.3 Section 1 assessment ### Section 2 · Find your programs' data and flag the ones at risk - 2.1 The public data - 2.2 Building and reading a risk table - 2.3 Section 2 assessment ### Section 3 · Model what losing Direct Loans would mean - 3.1 Consequences and options in the rule - 3.2 Modelling enrollment and revenue - 3.3 Section 3 assessment ### Section 4 · Run a defensible academic portfolio review - 4.1 The four lenses - 4.2 Decisions, governance and communication - 4.3 Section 4 assessment ### Section 5 · Capstone and wrap-up - 5.1 Capstone: A portfolio review memo for one college or school - 5.2 Capstone assessment - 5.3 Reading list and next steps ## Instructors - ibl.ai Higher Education, Course team (ibl.ai) ## More higher education courses - [IPEDS, ACTS and Federal Reporting for Institutional Research with AI](https://ibl.ai/courses/higher-education/ipeds-federal-reporting-with-ai) - [ADA Title II Digital Accessibility for Course Content: The 2027 Deadline](https://ibl.ai/courses/higher-education/ada-title-ii-course-accessibility) - [AI Academic Advising at Scale: Caseload Triage, Proactive Outreach and Human Handoffs](https://ibl.ai/courses/higher-education/ai-academic-advising-caseload-management) - [AI Agents Inside the Trusted Research Environment: Sandboxed Code Execution on NIH, CUI and DUA-Governed Data](https://ibl.ai/courses/higher-education/ai-agents-trusted-research-environment)