AIR Submits Comments on Proposed STATS and Earnings Accountability Framework

AIR recently submitted formal comments to the U.S. Department of Education in response to the Notice of Proposed Rulemaking on Accountability in Higher Education and Access Through Demand-Driven Workforce Pell, including the proposed Student Tuition and Transparency System (STATS) and earnings accountability measures.

The comments reflect the perspectives of Institutional Research, Institutional Effectiveness, and data professionals who will be responsible for implementing these requirements and ensuring the accuracy, integrity, and usability of the resulting data.

AIR expressed support for efforts to improve transparency and provide students and families with clearer, more meaningful information about postsecondary outcomes. At the same time, the comments raised several key considerations related to the validity, interpretation, and implementation of the proposed framework.

Broadening measures of value.
AIR cautioned against relying solely on earnings as the primary measure of program value or accountability. While earnings are an important indicator, they do not fully capture the mission of many programs—particularly those preparing students for careers in public service, education, and community-based professions. The comments encourage a more multidimensional approach to understanding return on investment and student outcomes.

Avoiding unintended consequences.
The comments highlight the potential for an earnings-only framework to create unintended incentives for institutions to discontinue programs that serve critical workforce and community needs but may not meet earnings thresholds. Such outcomes could limit student choice and run counter to broader access and equity goals.

Creating meaningful opportunities for improvement.
AIR raised concerns about the retrospective nature of the proposed accountability model, noting that institutions may have limited ability to respond before sanctions are applied. The comments recommend a structured improvement process, including advance warning, formal improvement planning periods, and time for interventions to take effect before eligibility decisions are finalized.

Ensuring strong implementation and data quality.
AIR emphasized the importance of clear technical guidance, sufficient lead time, and robust opportunities for institutions to review and validate data before it is used in public reporting or accountability determinations. The comments also call for phased implementation, sustained technical assistance, and particular attention to institutional capacity—especially for community colleges and minority-serving institutions.

Supporting trust in federal data systems.
Finally, AIR underscored the importance of maintaining trust in federal postsecondary data systems. Rapid implementation timelines, evolving methodologies, or limited institutional support may undermine data quality and confidence in the resulting measures. The comments encourage approaches that balance accountability with accuracy, transparency, and institutional capacity.

AIR remains committed to supporting members through technical guidance, professional development, and continued policy engagement as federal data and accountability systems evolve.