Forum Spotlight: The next phase of OB3 is already in motion

Many campuses are focused on the significant federal loan changes in the One Big Beautiful Bill Act (OB3) that took effect July 1, 2026. At College Board Forum, The Next Phase of OB3: Earnings Accountability and Campus Readiness looked ahead. Campus professionals from the University of Rochester, Bunker Hill Community College, Johns Hopkins University, and The University of Texas at Rio Grande Valley discussed the Student Tuition and Transparency System (STATS), a new federal accountability and transparency framework, which includes a new earnings test for federal loan eligibility. Key takeaways for campuses: 

• It’s broad. STATS replaces the current gainful employment framework and covers federal aid-eligible programs, from certificates through doctoral degrees, at any type of institution. 
• Your benchmark matters. Undergraduate programs are measured against typical earnings of high school graduates, and graduate programs against typical earnings of bachelor’s degree holders, using state or national figures depending on where students come from. A higher state benchmark can put mission-critical fields close to the line. 
• Campuses are making different reporting choices. This cycle, institutions could choose to adopt the new STATS reporting format early or report under existing rules. Regardless of the approach they choose, the new earnings requirements apply to every federal aid-eligible program. Preparing will take collaboration across campus offices. 

The timeline: first determinations are expected in spring 2027, and the first programs could lose Direct Loan eligibility on July 1, 2028. Rules and guidance continue to evolve. 

The question to ask now: Do you know which of your programs could be affected? What strategies is your institution considering for at-risk programs? View more details at Student Tuition and Transparency System Information.