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Yesterday I gave a presentation at Collegis’ DisruptED 2026 for an invited group of institutional leaders, focusing on the observation that most federal regulatory actions are in the bag and that institutional leaders need to recognize the shift from policy debate to implementation. The core regulations I described were the new institutional accountability rules and the graduate loan limits, noting that there will be a much more important emphasis on program portfolio reviews for institutional leaders, not delegating these reviews just to colleges or departments.

There was a lot of interest in two points I made about accountability that I’d like to share here (either I need more On EdTech+ readers in these meetings, or this is a sign that key points are not well understood yet).

tl;dr—Accountability is going to be based on programs and earnings that have already happened, and combining data through cohort aggregation will mean many more programs will be subject to scrutiny and might fail.

The first issue is the timeline of the initial rule determinations. The regulations become effective, for the most part, on July 1, 2027 as part of the 2027-28 award year. The first determination of programs failing the metrics will occur somewhere between July 1, 2027 and late 2027. The second year of determination starts July 1, 2028, and that is the first time that programs may lose access to Title IV Direct Loans and even Pell Grants in some cases.