Wednesday, April 22, 2026

This Should Reduce Victim Studies a Lot

4/19/26 University Herald:

The U.S. Department of Education published a sweeping Notice of Proposed Rulemaking on April 17 that would — for the first time in the history of federal higher education policy — hold every postsecondary program at every type of institution to a single earnings-based accountability standard, with the loss of federal student loan eligibility as the consequence for programs that fail.

The proposed rule, the third and final of three rules the Department has issued to implement the One Big Beautiful Bill Act signed July 4, 2025, is now open for public comment through May 20, 2026 at regulations.gov. The Department may modify the rule in response to comments before publishing a final rule, which is expected to take effect July 1, 2026.


This is one of the most consequential higher education policy proposals in decades. Students, faculty, and anyone considering enrolling in a college or university program should understand what it proposes — and what it does not.
The Core Mechanism: The Earnings Premium Test

Under the proposed rule, every postsecondary program — from an eight-week culinary certificate to a doctoral program — must pass what the Department calls an "earnings premium test." The test compares the median earnings of a program's graduates against a benchmark based on the education level of typical workers in the broader labor market.

For undergraduate degree programs, the median earnings of graduates must exceed the median earnings of working adults aged 25 to 34 with only a high school diploma. For graduate programs, graduates' median earnings must exceed those of working adults aged 25 to 34 with only a bachelor's degree.

If a program fails this test in two of three consecutive years, it loses eligibility for federal Direct Loans — meaning students enrolling in that program can no longer borrow federal money to pay for it. Programs that fail cannot simply restart under a new name; the rule includes provisions preventing institutions from enrolling new students in "substantially similar" programs for at least two award years following closure.

Is there value in programs that do not contribute to a decent paycheck?  Certainly. But the government need not subsidize a program that satisfies your desire to learn about Victim Studies.

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