The past several weeks have brought significant developments for institutions participating in federal student aid programs. From delayed implementation of portions of the new Student Success, Transparency, and Accountability by Taxpayer Support (STATS) framework to new guidance on 2026 reporting requirements, schools are facing important decisions that will shape this year’s accountability reporting.
At DJA, we’ve been closely monitoring each development and helping our clients understand not just what has changed—but what actions need to be taken next.
A Major Win for Career Education Programs
At the end of June, the U.S. Department of Education finalized the STATS regulations while also announcing an important modification that many institutions had advocated for.
The Department delayed the program eligibility consequences for programs preparing students for occupations where a majority of workers receive tipped income. This effectively provides at least a one-year delay before eligibility consequences apply to many cosmetology, barbering, massage therapy, and esthetics programs while earnings data is recalculated using tax years that include the new “No Tax on Tips” policy.
This announcement represents an important victory for the career education community and reflects the tremendous advocacy efforts made by institutions, associations, coalition partners, and schools that submitted public comments throughout the negotiated rulemaking process.
At the same time, the Department also responded to a federal court order affecting the definition of certain professional degree programs under the RISE regulations. While the core definition of a professional student remains unchanged, portions of the expanded professional degree definition have been stayed pending further legal proceedings, requiring institutions with affected graduate programs to carefully review the Department’s updated guidance.
New Guidance for 2026 GE/FVT and STATS Reporting
Just weeks later, the Department released another important Electronic Announcement updating NSLDS Professional Access in preparation for the 2026 reporting cycle.
Perhaps the biggest operational change is that institutions choosing to early implement the new STATS framework will no longer be required to report seven previously required data elements. These fields have now been made optional within NSLDS Professional Access, reducing the amount of information schools must collect and submit under STATS. Institutions remaining under the current Financial Value Transparency (FVT) and Gainful Employment (GE) framework must continue reporting these data elements in full.
An Important Decision Before October 1
Although reporting has been streamlined for early STATS adopters, one thing has not changed:
All institutions must still complete an accountability reporting submission by October 1, 2026.
Each institution must now determine whether to:
- Continue reporting under the existing GE/FVT framework, or
- Elect early implementation of STATS for the 2026 reporting cycle.
That decision will determine which reporting requirements apply and how data must be prepared.
How DJA Is Helping Clients Prepare
As in prior years, DJA is finalizing our annual GE/FVT and STATS Reporting Assistance Agreement to guide institutions through the reporting process. This year’s agreement will ask each client to identify which reporting framework they intend to use so we can tailor our data collection and reporting support accordingly.
With regulatory requirements continuing to evolve, our team remains committed to monitoring Department guidance, updating New Leaf where necessary, and providing practical implementation support every step of the way.
Looking Ahead
This year’s reporting cycle illustrates just how quickly the federal financial aid landscape continues to change. While recent updates have reduced some reporting burden and provided welcomed relief for certain career education programs, institutions still face important compliance decisions in the months ahead.
DJA will continue providing timely guidance as additional announcements are released, helping institutions remain compliant while navigating the transition from the existing GE/FVT framework to the new STATS reporting environment.
If you have questions about your institution’s reporting strategy or would like assistance determining whether early STATS implementation is appropriate for your school, our team is here to help.
Thank you,
Renee Ford, Vice President
