The U.S. Department of Education reached consensus on a regulatory package that would require every postsecondary program to pass an earnings test to keep access to Title IV student aid. The proposal—negotiated by the AHEAD committee and tied to the One Big Beautiful Bill Act—would compare graduates’ median earnings to peer benchmarks and strip federal loan eligibility from persistent underperformers. The rule reshapes accountability by moving from institution- or sector-specific gainful-employment rules to a uniform, earnings-based standard across public, private and proprietary programs. Board members, provosts and financial officers will need new metrics and rapid reporting systems to track program-level outcomes and avoid potential federal sanctions. Accreditation bodies and institutions are already retooling to comply. Accreditor competition and refreshed federal expectations mean institutions must both document program impact and align curricular offerings with measurable labor-market outcomes. For trustees, the change raises fiduciary stakes: failing programs could lose all Title IV aid and cascade into enrollment and budget shocks. Clarification: The proposed “earnings test” measures graduates’ median earnings against defined peer thresholds; failure triggers loss of federal student‑aid eligibility for the affected program.
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