Federal higher‑education rulemaking is proposing a new earnings test that would force postsecondary programs to demonstrate graduates earn more than comparable peers or risk losing access to Federal Direct Loans. The Department of Education and education stakeholders reached consensus around an earnings metric during rulemaking discussions tied to the One Big Beautiful Bill Act. Under the proposal, programs that fail the test in two of three years would lose direct‑loan eligibility; programs that comprise half of an institution’s Title IV enrollment or revenue could trigger broader institutional penalties. Third Way and HEA Group analysts say the bar is low but the consequences are material for institutions heavily dependent on federal aid. Colleges could face rapid program restructuring, advising changes, and new reporting burdens if the metric is finalized. That will pressure mid‑tier and vocational programs to raise graduate earnings or risk students losing access to loans and Pell grants.