This paper provides a brief overview of the current state of federal accountability and the need for change, and a summary of the landscape of state accountability reforms through funding structures for public colleges and universities. It explores key questions or decision points that must be addressed in designing a federal accountability system and provides recommendations for each, in an attempt to form a set of guiding principles for thinking about the system's objectives. And it identifies recommendations both for what needs to be measured and how, with a focus on the goals of completion, equity, and safeguards against risk to borrowers and taxpayers. Overall, the paper argues for a combined system of consequential and report-card accountability, with the former including both bright lines for eligibility and graduated sanctions and rewards to drive continuous improvement.