IHEP Submits Technical Comments to Strengthen Higher Education Transparency and Accountability Regulations

Washington, DC (May 20, 2026) – IHEP submitted technical comments to the U.S. Department of Education on its proposed higher education transparency and accountability regulations. Drawing from IHEP’s expertise in postsecondary data and higher education policy, the letter supports the proposed earnings-based accountability framework and recommends several improvements to strengthen transparency, accountability, and student access to high-quality information about college programs. IHEP’s recommendations include maintaining the Student Tuition and Transparency System (STATS), integrating program-level metrics into the College Scorecard, strengthening student warnings for programs that fail the earnings premium measure, reinstating reporting on cumulative institutional loan debt, and ensuring the timely release of program-level data institutions have already reported. The letter also recommends maintaining the consistent application of the earnings premium test to all programs, reinstating the loss of all Title IV aid as a consequence for gainful employment programs failing the earnings metric, modifying the process used to evaluate small programs, and maintaining a limited appeals process. Together, these recommendations would help ensure students, families, policymakers, and researchers have access to clear, comprehensive, and comparable information on program costs and outcomes, enabling more informed decision-making and stronger accountability across higher education. 

Read the full comment letter.