Earnings threshold calculation
Median earnings of program completers, four tax years after completion, compared to state or national earnings benchmark — modeled with sequential cohort-aggregation rules.
The most rigorous STATS exposure audit a Title IV institution can run.
ProgramGuard assembles a documentation-complete earnings-accountability exposure pack — every program's pass/fail model, the completer-list correction, the student risk disclosure, and the calculation-error appeal — checked against the letter of 34 CFR Part 668 Subpart Q before a compliance analyst releases it.
Every subsection of 34 CFR §668.402Five statutory notice elements, gate-checkedState & national earnings comparators modeledCompliance analyst release on every pack5-business-day SLA
Why audits fail
A single miscalculation can cost a program its federal loan eligibility.
A Title IV institution's ability to keep enrolling federal-loan-funded students in a given program now depends on a math problem almost nobody on campus has run before: does that program's graduates' median earnings, four tax years after completion, beat a specific state-or-national earnings comparator, calculated under a brand-new sequential cohort-aggregation rule, for two of the next three years.
Get the completer list wrong and the Department calculates the wrong answer; miss the 60-day correction window and that wrong answer stands; miss the 30-day appeal window after a 'low-earning' determination and a program that may have been correctly passing loses federal loan eligibility anyway.
ProgramGuard exists to close that gap with a single, exhaustive standard applied identically to every file.
3,302
programs estimated to fail the earnings test on day one
The benchmark
Measured against the letter of the regulation — subsection by subsection.
We do not summarize the law and hope. Every audit is scored against a versioned rule pack tied to the exact text of 34 CFR Part 668 Subpart Q. These are the provisions each pack is held to.
Low-earning program determination
Programs failing the earnings test in two of any three consecutive years are designated 'low-earning outcome programs' and lose Direct Loan eligibility.
Completer-list correction window
Institutions have 60 days to correct the completer-list data the Department uses for the calculation; missed corrections lock in the Department's data.
Appeal on calculation error
A 30-day window to appeal a low-earning determination based solely on calculation errors; no substantive challenges allowed.
Student risk disclosure
Mandatory 30-day disclosure to enrolled students when a program is flagged as low-earning, with specific content requirements.
Provisional certification exposure
If too much of an institution's Title IV volume sits in failing programs, the institution faces provisional certification risk.
How an audit is built
Intake to compliance analyst release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human compliance analyst signs every release. That order is never reversed.
01
Exposure Scan
Upload your program/CIP-code list and completer records. We return a free completeness read: which programs are at risk, which data elements are missing, and what deadlines apply.
02
Earnings modeling
We model each program's pass/fail exposure against the actual STATS earnings-threshold methodology, including state and national comparators, sequential cohort-aggregation, and special rules for graduate programs and tipped occupations.
03
Completer-list validation
We cross-check your completer records against NSC and IPEDS data, flag discrepancies, and prepare the correction filing within the 60-day window.
04
Deterministic completeness gates
Earnings calculations reconcile to the regulation to the penny; the 60-day window is verified; the disclosure checklist is resolved; SCRA is screened. Any failure blocks release.
05
Compliance analyst release
A compliance analyst reviews the exception queue and signs the release. High-value or complex programs route to attorney review first.
06
Delivery
You receive the pack: ranked exposure report, completer-list correction, student risk disclosure drafts, calculation-error appeal template, and a 60/30-day ICS calendar — ready for the institution to file under its own name.
The bar we hold
Rigor you can measure.
100%
Compliance analyst-released
No pack ships without a human signature.
5 days
Standard SLA
From complete intake to released pack.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
4
Data sources reconciled
NSC · IPEDS · state wage records · institution records, every applicable file.
Why ProgramGuard
Built to be the most thorough option an institution has.
Documentation-complete, by design
The deliverable is completeness itself — every regulatory element and data source accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run data validation as your clerical agent. We never contact students, give legal advice, or file appeals on your behalf.
Engagement
Flat fee, per released audit. No contingency, ever.
Simple, predictable, and aligned with a documentation standard — not a cut of any recovery.
- A free Exposure Scan before you commit — see exactly which programs are at risk.
- One flat fee per released STATS Exposure Audit; disclosed pass-through data-source fees.
- Optional fixed-fee attorney review for complex or high-volume institutions.
- Optional Appeal Continuity Add-on for the 30-day calculation-error appeal, pre-drafted to your exposure report.
FAQ
Questions, answered precisely.
Is ProgramGuard a law firm?
No. ProgramGuard, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-stakes matters.
Do you contact students or file appeals on our behalf?
Never. ProgramGuard is not a debt collector and does not contact students or debtors. The institution remains the party responsible for all filings and communications with the Department of Education.
What makes an audit 'complete'?
Completeness is defined by the regulation: the earnings threshold calculation verified, the low-earning determination modeled, the completer-list correction prepared, the student risk disclosure drafted, and the appeal template ready. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a compliance analyst-released pack. The free Exposure Scan is returned much sooner and tells you exactly which programs are at risk.
How are you priced?
A flat fee per released audit, plus disclosed pass-through data-source costs. No contingency and no percentage of any recovered amount or sale proceeds.
See which programs are at risk before the deadline closes.
Start with a free Exposure Scan. Send your program list and completer records and we'll return a completeness read against every subsection of 34 CFR Part 668 Subpart Q.
Documentation-completeness service · not legal advice · the institution files every notice.