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cp-j0gw.18: plain-language standalone explainer pages (M04, M07, M14) #6

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27 changes: 23 additions & 4 deletions tests/ui/explainers.test.ts
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Original file line number Diff line number Diff line change
@@ -1,7 +1,8 @@
// cp-j0gw.15 — plain-language standalone explainer pages structural test.
// Each explainer page must surface the same shared patterns: public-data
// badge, top-disclaimer, breadcrumb, verify-against-primary-sources callout,
// and a topic-specific anchor heading.
// cp-j0gw.15 + cp-j0gw.18 — plain-language standalone explainer pages
// structural test. Each explainer page must surface the same shared
// patterns: public-data badge, top-disclaimer, breadcrumb,
// verify-against-primary-sources callout, and a topic-specific anchor
// heading.

import { describe, expect, it } from 'vitest';
import { readFileSync } from 'node:fs';
Expand All @@ -26,6 +27,24 @@ const PAGES = [
topicAnchor: /lowest of three/i,
sourcesAnchor: /84001\(c\)\(3\)\(B\)|668\.402\(c\)\(3\)/,
},
{
file: 'M04.html',
title: /M04\s*—\s*When a program crosses from passing to failing/,
topicAnchor: /two failures in three years|two-failures-in-three-years/i,
sourcesAnchor: /84001\(c\)\(1\)|668\.402|668\.603/,
},
{
file: 'M07.html',
title: /M07\s*—\s*First-failure disclosures/,
topicAnchor: /Department-prescribed warning|first-failure release date/i,
sourcesAnchor: /668\.43\(d\)\(1\)|668\.43\(d\)\(2\)/,
},
{
file: 'M14.html',
title: /M14\s*—\s*Named populations/,
topicAnchor: /named CIP families|elevation factor/i,
sourcesAnchor: /regulatory-impact analysis|most at risk/i,
},
{
file: 'M18.html',
title: /M18\s*—\s*When program failure could spread/,
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214 changes: 214 additions & 0 deletions web/explainers/M04.html
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<!doctype html>
<html lang="en">
<head>
<meta charset="utf-8" />
<meta name="viewport" content="width=device-width, initial-scale=1" />
<title>M04 — Pass / fail trigger and the four-year lag — CSU Deans EP Tool</title>
<link rel="stylesheet" href="../css/main.css" />
<link rel="stylesheet" href="../css/explainers.css" />
</head>
<body>
<header class="site-header">
<p class="breadcrumb">
<a href="../index.html">← Back to home</a>
·
<a href="../learn.html">Mechanism Library</a>
</p>
<h1>M04 — When a program crosses from passing to failing</h1>
<p class="tagline">
How the rule reads single-year results, what 'two failures in three
years' actually means, and why every measurement looks back four
tax years.
</p>
<p class="public-data-badge" aria-label="Public data only">
<span class="badge-dot" aria-hidden="true">●</span>
Public data only · No private or institutional data leaves your browser
</p>
</header>

<aside class="top-disclaimer" role="note" aria-label="Important context">
<p>
<strong>Read first.</strong>
Built by educators — <strong>not attorneys, not legislative analysts</strong>.
Every walk on this page is a working explanation of a published
proposed rule, not legal advice. Independently verify all citations
against the
<a href="../sources.html">primary sources</a>
before any external submission, public comment, or institutional decision.
</p>
</aside>

<main class="explainer-page">
<section>
<h2>The short version</h2>
<p class="lede">
The earnings-premium test produces a single-year pass-or-fail
arithmetic for each measured program. One single-year failure
attaches a disclosure obligation but no Title IV consequence. Two
single-year failures within any three consecutive measurement
years take the program out of Direct Loan eligibility for new
students.
</p>
<p>
Each measurement year reads earnings four tax years after the
measured graduating cohort. That four-year lag is built into the
statute itself. The first measurement year a graduating class
ever appears in is therefore four years after that class
graduates — and a program does not feel any pass-or-fail signal
until that lag has already passed.
</p>
</section>

<section>
<h2>The single-year pass/fail arithmetic</h2>
<p>
For each award year a program is measured in, the rule computes
two numbers — the program's median earnings (graduates who are
working and not still in school) and a benchmark figure drawn
from federal Census data — and asks whether the median is
greater than or equal to the benchmark.
</p>
<div class="field-step">
<strong>Pass</strong>
The program's median earnings are greater than or equal to the
benchmark figure. The program is reported PASS for that
measurement year. No federal consequence attaches; the program
remains fully Title IV eligible.
</div>
<div class="field-step">
<strong>Fail</strong>
The program's median earnings are less than the benchmark
figure. The program is reported FAIL for that measurement year.
Disclosure obligations attach (M07). Title IV eligibility is not
yet affected by the single failure.
</div>
<div class="field-step">
<strong>Not measured</strong>
The program does not have enough graduates, or enough IRS
earnings records, to produce a published median. The program is
reported NOT MEASURED for that year. NOT MEASURED is not a pass
and not a fail; no consequence attaches.
</div>
<p>
The single-year arithmetic is straightforward. The state machine
on top of it — the rule that decides what consequence attaches
and when — is what makes the test stateful across years.
</p>
</section>

<section>
<h2>The two-failures-in-three-years rule</h2>
<p>
OBBBA § 84001(c)(1) sets the program-level Title IV consequence
on a two-failure trigger inside a rolling three-year window. The
window slides forward each year. A program that fails in year
one and again in year three loses Direct Loan eligibility on the
year-three release; a program that fails in year one and again
in year four does not lose eligibility on the year-four release,
because year one has rolled out of the three-year window by then.
</p>
<p>
The trigger reads only across <em>measurement years</em>. A NOT
MEASURED year does not count as a pass and does not count as a
fail. It is a year without a result. A program with measurement
gaps can take longer to accumulate two failures inside any
three consecutive measurement years, but the gap does not erase
earlier failures — they remain on the running tally until they
age out of the three-year window.
</p>
<p>
The federal data product the Department published in advance of
the rulemaking carries pre-computed pass/fail flags for each
measurement year. The tool reads the published flag as
authoritative and surfaces local re-computation alongside it as
a cross-check (M01).
</p>
</section>

<section>
<h2>The four-year earnings lag</h2>
<p>
The statute defines program earnings as median earnings four tax
years after the measured graduating cohort completed. That lag
is structural: the federal data the Department uses is built
from IRS records (W-2 and Schedule SE filings), and four tax
years is the lag that produces stable post-completion earnings
for graduates who entered the workforce after their degree.
</p>
<p>
The lag has two practical consequences. First, the first
measurement year a graduating class ever appears in is the
fourth tax year after that class graduates. A class that
completed in academic year 2023-24 first appears in measurement
year 2027-28 (the federal data release that reports tax-year
2027 earnings).
</p>
<p>
Second, any institutional response to a failure — a curriculum
change, a program closure, a new program, a CIP-code shift —
takes at least four years from the entering cohort onward to
register on the test. A program that admits a new entering
cohort under a redesigned curriculum will not see that cohort's
earnings appear in the federal data for at least six years
after admission (two-to-three years to graduate plus four tax
years post-completion).
</p>
</section>

<section>
<h2>What this means in practice</h2>
<p>
One failure attaches a disclosure obligation that the program
must publish on admissions and recruitment materials before the
next entering cohort accepts admission (M07). The disclosure
obligation is independent of any appeal. Filing an appeal under
proposed § 668.603 does not pause the disclosure requirement;
the failing program must surface the federal-warning language
while the appeal is pending.
</p>
<p>
Two failures inside any three consecutive measurement years take
the program out of Direct Loan eligibility for new students.
Existing borrowers are unaffected for prior disbursements (M05).
A program restored to compliance after eligibility loss must
clear the published procedure under proposed § 668.604; the
institution may not restart enrollment without an affirmative
determination from the Department.
</p>
<p>
The proposed appeal scope under § 668.603 is limited to
calculation-error claims — arithmetic disputes about the
single-year pass/fail computation. Methodological disagreement,
IRS-match-quality concerns, and disputes about the cohort-side
expansion outcome are outside the appeal scope.
</p>
</section>

<aside class="verify-callout" role="note" aria-label="Verify against primary sources">
<h2>Verify against primary sources</h2>
<p>
Every claim above traces to a publicly available statute,
proposed rule, or federal data file. See the
<a href="../sources.html">Public data sources</a>
page for the OBBBA statute (§ 84001(c)(1) — two-failure
trigger; § 84001(c)(2) — single-year pass/fail definition), the
proposed rule (§ 668.402 — measurement window; § 668.603 —
appeal scope; § 668.604 — re-entry procedure), and the federal
data file's pre-computed pass/fail field. Re-derive against
those sources before any external submission.
</p>
</aside>

<nav class="explainer-nav" aria-label="Other explainers">
<a href="./M03.html">← Previous: M03 — Lowest-of-three benchmark routing</a>
<a href="./M07.html">Next: M07 — First-failure disclosures →</a>
</nav>
</main>

<footer class="site-footer">
<p class="primary-source-reminder">
Re-derive against primary sources before any external submission.
</p>
</footer>
</body>
</html>
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