Amidst the flurry of executive orders, rulemaking and litigation combined with the Department of Education trying to put itself out of existence, schools and universities face a host of challenges. There are multiple initiatives in play, including Workforce Pell implementation, earnings-based accountability proposals, accreditation reform efforts and expanded fraud-prevention measures.
Those of us in the compliance space know that we must be the calm in the midst of the political storm, as operationalizing policy is very different than creating it. For our purposes, what is most important is figuring out what we have to do and how long we have to do it. We are the ones who have to answer the question: How does this actually function, consistently, legally, at scale, with real people, systems, funding constraints—and how do we account for unintended consequences?
We are currently in an era where regulators and policymakers are intently focused on the economics of a degree and the return on investment. As the Vice President of Resolution Services and Title IX Coordinator at University of Phoenix, I recently spoke at the 2026 UPCEA Annual Conference, where I touched upon recent federal policy changes, including the how and why behind them, the risks and opportunities this creates for institutions and—perhaps most importantly—what institutions need to know and prioritize in order to avoid pitfalls and navigate the changes ahead.
What’s on the Agenda
We are on the heels of an incredibly busy year from a policy perspective, and this one is showing no signs of slowing down. While certainly not an exhaustive list, the following show just some of the policy issues discussed at UPCEA, as well as some of the items that I expect to continue to impact our profession in the year to come.
Workforce Pell: The Department of Education formally issued proposed regulations implementing Workforce Pell. Short-term programs are moving into the Title IV ecosystem but only under a tightly controlled accountability framework emphasizing earnings, labor-market alignment and state oversight.
Accreditation rulemaking: The Department of Education’s Accreditation, Innovation, and Modernization (AIM) committee is now underway with draft regulations circulating publicly. The Department framed the proposals around increasing competition among accreditors, lowering barriers for new accreditors, improving student outcomes, expanding credit transferability and addressing academic freedom, research integrity and conflicts of interest.
Student aid fraud prevention: Within the last several weeks, the Department of Education launched what it describes as the largest nationwide fraud-prevention effort in the agency’s history. Fraud prevention is turning into a core Title IV compliance function. That is especially relevant to high-volume online programs and open-enrollment continuing-ed offerings, where fraud risk is higher.
Financial value transparency: All institutions are now subject to a new earnings-based accountability framework. The department is moving from the older gainful employment/financial value transparency framework to a single earnings-based accountability system that applies across nearly all Title IV programs.
What This Means for Institutions
The policy environment now requires tighter alignment among compliance operations, funding strategies and academic program development. Institutions that operate in silos in these areas do so at their own peril. For example, Workforce Pell could create growth opportunities for institutions offering online, hybrid, technical and professional continuing education programs. However, eligibility standards focus heavily on program length, completion rates, labor-market outcomes, earnings benchmarks and state approval processes. Institutions need to closely examine how ready and prepared they are to utilize Workforce Pell.
Institutions who have a program triage system, not just oversight, can hopefully stay ahead of the game. Viewing programs through an economic lens requires a close look at program offerings and a determination of what is defensible, fixable or at risk. For any programs at risk (low earnings, high debt, poor completion rates), they must act accordingly, which may mean deciding quickly which programs to keep or eliminate.
The New Mindset
These policy changes mean more than just a need for new action: They reflect shifting priorities that institutions and professionals need to adjust to. Overwhelmingly, these priorities point to the need to become more agile, emphasizing adaptiveness and proactiveness. Many of these policies are not designed to be operationalized at institutions that are slow and bureaucratic. Instead, collaboration with colleagues in multiple areas is essential, as are the hard discussions about what strategies will work best at your institution. All areas must work together to figure out how to be more responsive to workforce shifts, demographic changes, technology adoption and employer demand while staying compliant.
Do not underestimate implementation complexity. Ensure your institution’s systems are connected and you have a solid compliance infrastructure. Older financing and governance structures may not work anymore, so be honest about whether they need to change. Both compliance and strategy need to be addressed in the same conversation.
Most importantly, we must recognize that these changes are not the last ones we will see. Being proactive now means being prepared in the future, and adapting now means setting ourselves up for agile thinking later. In this evolving marketplace and regulatory landscape, the only thing we can count on is change coming—and coming fast.