The U.S. Department of Education has initiated the rollout of a new accountability test that could strip federal financial aid from college programs whose graduates fail to out-earn those without degrees. Known as the “do no harm” rule, this measure targets undergraduate programs where graduates do not earn more than individuals who never went to college. For graduate programs, the benchmark is out-earning those with only a bachelor’s degree.
Under Secretary of Education Nicholas Kent defended the policy in a recent statement, asserting that if a program cannot demonstrate that it leaves its graduates financially better off than if they had never enrolled, it should not be underwritten by federal taxpayers. The rule stems from last year’s One Big Beautiful Bill Act, which introduced several higher education policy changes aimed at addressing the escalating costs and perceived value of college.
To pass the test, undergraduate programs in many states will require graduates to earn a minimum of roughly $30,000 to $41,000 annually. Christopher Madaio, a senior adviser at the nonprofit The Institute for College Access & Success, called this “a very low floor,” adding that high school earnings is not an exceedingly high metric for a program to meet. Programs will fail the test if they miss these earnings requirements for two out of three consecutive years.
According to Education Department estimates, the vast majority of undergraduate and graduate programs should easily pass the new earnings test. However, data indicates that over 800,000 students are currently enrolled in programs likely to fail. Roughly half of these students attend for-profit schools. Notably, the current test does not factor in student loan debt, meaning there is no distinction between a low-earning graduate who is debt-free and one burdened by significant loans.
Creative and performing arts programs are facing significant scrutiny under the new metrics. Department data predicts that 14% of bachelor’s degree music programs could fail, including prestigious institutions like The Juilliard School in New York City, the New England Conservatory in Boston, and Indiana University Bloomington’s Jacobs School of Music. But are these metrics a fair way to measure the value of such programs? Some advocates for postsecondary arts education think not.
This prospect has sparked concern among arts advocates. “Looking at earnings as the sole metric of success is very limited, and that’s because artists have nonlinear careers,” said Lee Ann Scotto Adams, executive director of the Strategic National Arts Alumni Project (SNAAP). “For the most part, people who graduate from these programs move into careers that they’re personally satisfied with.” Doug Dempster, president of SNAAP, warned that schools might preemptively slash creative programs in music, theater, studio art, and design. Dempster noted that while society understands the need for nurses, journalists, and early childhood educators, eliminating access to arts programs would impoverish the nation’s cultural life.
The impact is also personal for educators like Cindy Flores, a graduate of Portland State University’s (PSU) undergraduate music program—another program projected to fail. Flores, who went on to obtain an educator’s license from Western Oregon University and now teaches mariachi to middle and high school students at Salem-Keizer Public Schools in Oregon’s Willamette Valley, accumulated nearly $55,000 in federal student loan debt. Under the new rules, future PSU music students might lose access to the loans she relied on.
Flores emphasized that her career choice was never about the money, tracing her passion back to the eighth grade when her own music teachers served as role models. She stated that without PSU and the federal loans she received, she would not have been able to become a Mexican American mariachi teacher for her Mexican American students. Adams echoed this sentiment, explaining that creative workers often prioritize independence, social consciousness, and cultural impact over straightforward financial metrics.
The implementation of the accountability test will be phased in over the coming years, meaning students in at-risk programs will not lose aid immediately. The Education Department plans to begin calculating the first year of graduate earnings in early 2027, with the potential for low-earning designations to impact financial aid eligibility starting in the 2028–2029 award year.
