The Department of Education and federal stakeholders reached consensus on a new earnings-based metric that could strip postsecondary programs of Federal Direct Loan eligibility. Under the proposed rule, programs that fail the earnings test in two of three years risk losing access to Title IV loans; if those programs represent half of an institution’s Title IV enrollment or revenue, broader sanctions could follow. Federal, state and accreditation leaders debated the specifics during the ED rulemaking session; analysts at The HEA Group estimate about 2% of associate’s and bachelor’s programs would fail. Third Way’s Ben Cecil called the threshold a "low bar" with major implications for students and taxpayers. Institutions will face a warning-and-suspension timeline before any loan cuts are finalized, creating short-term compliance and messaging risks for college leaders.