A Market Test

Degrees that don’t deliver face a federal cutoff—just as the job market grows less forgiving.


For decades, nearly any college degree program was subsidized by federal tax dollars with little regard for results. Poor student outcomes—sometimes leaving graduates financially worse off than if they had never enrolled—rarely affected eligibility for taxpayer-backed aid. That is now being upended.

On January 9, the U.S. Department of Education announced consensus on a new accountability framework developed by its Accountability in Higher Education and Access Through Demand-driven Workforce Pell (AHEAD) negotiated rulemaking committee. The rules implement provisions of the Working Families Tax Cuts Act, also known as the “One Big Beautiful Bill,” which President Trump signed into law in July 2025.

The framework rests on a simple principle that programs should not leave students financially worse off. Degree programs whose graduates consistently earn less than the average high-school graduate will lose access to federal Direct Loans if they fail the earnings threshold in two out of any three years. This outcome-based standard applies uniformly across all sectors and credential levels, without regard to institutional type. Programs that account for at least half of an institution’s Title IV aid recipients or federal dollars will also place the institution’s Pell Grant eligibility at risk.

The new approach replaces the prior Gainful Employment regulations’ debt-to-earnings test with a simpler earnings metric. It identifies failing programs with less complexity and administrative burden, creating a stable, transparent, and harder-to-evade system after years of shifting enforcement.

This reform is good news because student loans were never intended to underwrite every academic preference, regardless of economic return. When a program reliably fails to deliver earnings above a high-school diploma, continued public subsidy merely transfers risk from students and institutions to taxpayers. That risk properly belongs with those who choose and offer the program.

Of course, the labor market is an imperfect signal of individual potential or societal need. Exceptional students with rare talents or deep callings may thrive in lower-paying fields, and that has always been true. Public policy, however, cannot be designed around exceptions. Students and institutions should weigh the real costs of low-return choices.

Many universities are likely to respond by closing or shrinking programs. The fine arts, humanities, social sciences, ethnic studies, and gender studies are likely on the chopping block, as graduates in these fields consistently underperform the high-school earnings benchmark. Students pursuing these fields will make more deliberate and sacrificial choices than many do today. This reform does not reduce education to earnings alone. Colleges remain free to teach what they wish, and students remain free to study what they wish. The only question is whether taxpayers should be compelled to finance programs that systematically leave graduates worse off financially.

Lastly, this reform arrives at a challenging moment. By late 2025, the labor market for recent graduates had weakened sharply, with unemployment among young bachelor’s-degree holders exceeding levels seen during the 2008 recession. In this environment, programs that fail to improve graduates’ prospects will face swift exposure.

A degree should improve a graduate’s economic prospects, and taxpayers deserve nothing less.

Follow the National Association of Scholars and Jared Gould on X.

  1. Jared, How can anyone know if a graduated student’s earning level is below the level of a high-school student, 2 out of 3 years, until the student has graduated and started work? And, at that point, the school-support money has already gone to the student and the school in question, hasn’t it? How do you suspend payments at this point? Maybe I need more coffee?!

    1. As I understand it, they would be using IRS data on the earnings of the graduated students to determine the institutions’ eligibility to award loans and grants to its current students.

      Two immediate problems come to mind: The first being if an institution cleans up a problematic program and while the past graduates don’t have earning ability, the current ones will. The argument will be made that the current program is being punished for the older program that no longer exist — and that the institution may not survive long enough for the current students to show their earning potential.

      The flipside of this is to simply rename a low performing program. For example, women’s studies can become gender and sexuality studies, a completely different degree from a completely new program, which may also have had, say, gay studies merged with it.

      It will be the same low performing program, but it will have no record, no graduates currently working at Starbucks. And you could conceivably do this every three years and wind up with your low performing programs never ever showing up to ding you.

      A third potential way to game the system would be to combine a program where graduates get jobs, e.g. K 12 certification, with one where they don’t, e.g. social justice. In states with high K 12 population growth, e.g. Florida, you would have enough graduates being hired as teachers to obscure the fact that your social justice graduates are working at Starbucks.

      The general principle is that the people who graduate 2 to 3 years ago, got essentially the same education that the current students are getting, and hence are fungible for statistical purposes.

  2. When I graduated from the University of Massachusetts with a doctorate in education, the absolute best suggestion of the campus placement office was that I attempt to become an unpaid volunteer with a social service agency in hopes that — if I worked really hard — I might be promoted to a minimum wage job in a year or two.

    Yes, I could and did do much better driving a truck, and there’s a big difference between being told what one should apply for and actually being hired.

    But when the absolute best suggestion that the institution can provide is attempting to become an unpaid volunteer in something completely unrelated to your field, doing something that doesn’t even require a high school diploma, it raises real questions about the purported value of a degree that they charge a whole lot of money to earn.

    It also clearly demonstrated the extent to which the institution engages in false advertising — and how quickly that would end if there were an available government statistic indicating what the actual median (not mean) earning of program graduates was.

    A lot of people with six figure salaries in academia seem to believe that a college degree has some intrinsic value in and of itself. At least one could eat tulips — during WWII, the Dutch did…

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