School Performance Fact Sheet (SPFS): What BPPE Requires

Last updated June 11, 2026

The School Performance Fact Sheet (SPFS) is the disclosure document that every institution approved by California’s Bureau for Private Postsecondary Education must give prospective students before they enroll: “prior to enrollment, an institution shall provide a prospective student with a current School Performance Fact Sheet” (CEC 94910). One is required for each educational program, and the prospective student must sign and initial it before the enrollment agreement is executed (5 CCR 74112(a); CEC 94912).

The fact sheet is where your completion, placement, exam passage, and salary numbers become a signed legal document. It is also one of the few compliance areas where data problems escalate to fines instead of ending as a notice to comply. This guide covers what goes on the fact sheet, how each rate is calculated, the two signature rules schools mix up, and the documentation the Bureau expects behind every figure.

What the fact sheet is and when it must be provided

The obligation is per prospective student, per program, and before enrollment: the fact sheet handed over must be current (CEC 94910). It is not a marketing document the school designs freely - the regulation requires that it “shall contain all and only the information required or specifically permitted,” and that “A separate Performance Fact Sheet shall be prepared for each program” (5 CCR 74112(a)). A school with six programs maintains six fact sheets, each on the Bureau’s prescribed content.

Two narrow exceptions: ABA-accredited law schools have an alternative disclosure path (CEC 94910.5), and accredited institutions need not provide a fact sheet to a non-California resident enrolling in an accredited distance-education degree program (CEC 94909(d)). For everyone else, the rules below apply.

What the fact sheet must contain

CEC 94910 sets the minimum contents:

• Completion rates (CEC 94910(a))
• Placement rates, required “if the educational program is designed to lead to, or the institution makes any express or implied claim related to preparing students for, a recognized career, occupation, vocation, job, or job title” (CEC 94910(b))
• License examination passage rates, for programs leading to a state licensing exam (CEC 94910(c))
• Salary or wage information (CEC 94910(d))
• For programs too new to have data, the exact required statement beginning “This program is new. Therefore, the number of students who graduate...” (CEC 94910(e))
• Methodology disclosures: how the figures are calculated, where to get the list of employment positions counted as in the field, and where to get the objective salary sources (CEC 94910(f))
• Two mandatory statements, including “This fact sheet is filed with the Bureau for Private Postsecondary Education...” (CEC 94910(g))
• If the institution participates in federal financial aid: the three-year cohort default rate and the percentage of enrolled students with federal loans (CEC 94910(h))
• Optionally, exclusion of out-of-state student data - paired with a bar on actively using fact sheet data to recruit students who are not California residents (CEC 94910(i))

How the numbers are calculated

The rates are defined terms, not house methodology. The uniform data regulations in 5 CCR 74112 control who counts, when measurement happens, and what evidence supports each figure.

Completion rate

The completion table reports the number of students who began the program, the number available for graduation, the number of on-time graduates, and the resulting completion rate (5 CCR 74112(h)). “Began” is itself defined: students scheduled to complete the program within 100 percent of its published length during the reporting year, excluding those who cancel during the cancellation period (5 CCR 74112(d)(1)). An institution may add an optional second table showing 150 percent completion; programs longer than one year that report 150 percent data must provide four calendar years of data (5 CCR 74112(h)).

Placement rate and gainful employment

“Placement is measured six months from the graduation date of each student” - or, for programs leading to a licensure exam, six months after the announcement of the results of the first exam available after graduation (5 CCR 74112(i)(2)). The rate is graduates gainfully employed in the field (CEC 94928(e)(1); 5 CCR 74112(d)(3)) divided by graduates available for employment (CEC 94928(d)) (5 CCR 74112(i)(4)).

Gainful employment is the load-bearing definition (5 CCR 74112(d)(3)): work of 30 or more hours per week sustained for at least 5 weeks (35 calendar days), or 20 or more hours per week where the student signed a part-time election, with parallel prongs for continuing work with a single employer. Self-employment and freelance work count only when evidenced - by a business license, advertising, a website, receipts, or a signed attestation from the graduate. Where the majority of placed graduates are in self-employment or freelance work, that disclosure must be separately initialed by the prospective student (5 CCR 74112(i)(5)).

License examination passage rate

Exam passage rates come from the state licensing agency where that data is published. If the agency does not make the data available, the institution must collect results from its graduates directly, and must report the number of graduates it could not contact using the prescribed statement (5 CCR 74112(j)).

Salary and wage data

Graduate salary data is reported in $5000 increments (CEC 94929.5(a)(3)), and the fact sheet must tell the reader where to find the objective sources behind any salary information presented (CEC 94910(f)).

The two signature rules - on the fact sheet and in the agreement

There are two distinct signature requirements, and inspectors check both. The first lives on the fact sheet itself: “Prior to the execution of an enrollment agreement, the information required to be disclosed pursuant to subdivisions (a) to (d), inclusive, of Section 94910 shall be signed and dated by the institution and the student. Each of these items shall also be initialed and dated by the student” (CEC 94912). The completion, placement, exam passage, and salary disclosures each carry the student’s initials, and the document is signed by both parties before the enrollment agreement is executed.

The second lives inside the enrollment agreement: the agreement must contain the prescribed statement that the student must be given the catalog and the Fact Sheet before signing, along with an initial line carrying the prescribed certification text (CEC 94911(i)(1)-(2)). This is an acknowledgment in the agreement, not a substitute for the signed fact sheet - a fully initialed agreement does not cure an unsigned fact sheet, and vice versa.

The regulation then embeds initial blocks throughout the fact sheet itself: subsections (f), (g), (h), (i)(4), (i)(5), (j), and (k) of 5 CCR 74112 each end with a student initials and date line instructing the student to initial only after having sufficient time to read and understand the information. A compliant fact sheet collects initials section by section, not once at the bottom.

Formatting rules and the December 1 currency rule

Layout is regulated down to the point size: the fact sheet must be in “at least 12 pt. type, in an easily readable font, with 1.15 line spacing and all titles and column headings shall be in bold 14 pt. type” (5 CCR 74112(a)).

Currency is on a fixed calendar: “A Performance Fact Sheet shall be current and available not later than December 1st, and shall report data for the previous two calendar years,” based on the students scheduled to graduate in the reported years (5 CCR 74112(e)(2)). New programs show the program start date, the CEC 94910(e) statement, and the estimated date when two full years of data will exist (5 CCR 74112(b)).

The fact sheet also travels with a companion: a separate document containing the same cancellation disclosure as the enrollment agreement, captioned “STUDENT’S RIGHT TO CANCEL” in bold 14 pt type (5 CCR 74112(n)).

The five year backup documentation rule

Every figure on the fact sheet must be provable after the fact. All supporting documentation must be “maintained electronically by the institution for at least five years from the last time the data was included in either an Annual Report or a Performance Fact Sheet,” and provided to the Bureau on request (5 CCR 74112(m); see also CEC 94929.7(a)). The regulation’s minimum contents include:

• Student identifiers and the relevant dates
• The employer and position for each placement, with salary, hours, and the date the information was verified
• All written communications with employers
• The evidence behind any self-employment or freelance placement
• Descriptions of attempts to contact graduates who could not be reached
• Examination documentation for reported passage rates
• The identity of the institution representative responsible for the data

The practical reading: a placement is not a number, it is a file. If the backup for a reported placement does not exist in this form, the rate built on it is exposed.

Enforcement exposure

The Legislature removed any argument that fact sheet data problems are technical: a violation of the uniform data regulations is a material violation of the Act (CEC 94929.8(b)). The Bureau’s citation authority allows an administrative fine of up to $5000 per violation, weighing factors including the nature and seriousness of the violation, its persistence, good faith, and history (CEC 94936(b)(2)). The regulations grade fines into four classes: Class A ($2501 to $5000), Class B ($1001 to $2500), Class C ($501 to $1000), and Class D ($50 to $500) (5 CCR 75030).

Keep the signed fact sheet in the student file

The student records regulation requires each student’s file to contain “Copies of all documents signed by the student” (5 CCR 71920(b)(3)). The fact sheet is not named there expressly, but under CEC 94912 it is a document the student signs, so the standard reading is that the signed, initialed fact sheet belongs in the student file alongside the enrollment agreement - and that is what inspectors expect to pull. Keeping the signed copy filed per student, with the five-year data backup behind the reported rates, is the part of this obligation a records system can carry; Aegis Registrar keeps both organized so the document and its supporting data are retrievable when the Bureau asks. The calculations, judgment calls, and disclosures remain the institution’s.

Common questions

This guide is general information about California law, not legal advice. Regulations change; verify current requirements with the Bureau or counsel.