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Will your program pass the new earnings test? (2026)

Degree Sources Editorial Updated 7 min read
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A new federal earnings test checks whether a program’s graduates out-earn people who never enrolled. An undergraduate program passes if its graduates’ median pay four years after finishing matches or beats working adults aged 25 to 34 with only a high school diploma. Source · Duane Morris, July 9, 2026

A program that fails in two of three years loses access to federal Direct Loans. The first loss can come no earlier than the award year that starts in July 2028. Most programs will pass, and you can check yours now.

61,900
Programs ED estimates are covered
Final rule, July 2026
3,302
Programs that could fail in year one
About 5.3% of covered programs
July 2028
Earliest loss of federal loans
After failing 2 of 3 years
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What you're working toward

Graduates must out-earn high school graduates

The test compares two medians. One is what the program’s graduates earn in the fourth tax year after they finish, from IRS data. The other is a threshold built from Census Bureau data. Source · Duane Morris

What each kind of program is measured against
Program level Graduates must earn at least Whose earnings set the bar
Undergraduate certificates and degrees The median for working adults 25 to 34 with only a high school diploma The school's state, or the nation if fewer than half its students are in-state
Graduate programs The median for working adults 25 to 34 with only a bachelor's degree The lowest of the state, state same-field and national same-field figures
Program level Undergraduate certificates and degrees
Graduates must earn at least The median for working adults 25 to 34 with only a high school diploma
Whose earnings set the bar The school's state, or the nation if fewer than half its students are in-state
Program level Graduate programs
Graduates must earn at least The median for working adults 25 to 34 with only a bachelor's degree
Whose earnings set the bar The lowest of the state, state same-field and national same-field figures

Small programs are pooled. If fewer than 30 graduates finish in a year, the Department adds earlier years and then related programs until the group reaches 30. Source · Duane Morris The Department publishes the thresholds each year, and it will post every program’s result.

Most bachelor’s programs clear the bar

The Department’s analysis of the proposed rule found that failing programs cluster in certificates and at for-profit schools. About 31% of undergraduate certificate students attended a program projected to fail, and about 55% of students in failing programs attended a for-profit school. Source · ED, AHEAD earnings test results

The same analysis put the share at 4% for associate degree students and under 1% for bachelor’s students. Source · TICAS Fields with the highest fail rates included culinary services, cosmetology, drama and fine arts, religious studies, and alternative medicine.

Students in programs projected to fail, by credential (ED estimates on the proposed rule)
Credential Share of students in failing programs
Undergraduate certificate About 31%
Associate degree About 4%
Bachelor's degree Under 1%
Credential Undergraduate certificate
Share of students in failing programs About 31%
Credential Associate degree
Share of students in failing programs About 4%
Credential Bachelor's degree
Share of students in failing programs Under 1%

What happens if a program fails

One failing year brings a warning, not a loss. The school must warn current students within 30 days, and new students must acknowledge the warning before they enroll or get federal aid. Source · Duane Morris

A program's results and what they mean for you

Passes

Graduates out-earn the bar

Federal loans
Available
Pell Grant
Available
What the school must do
Nothing new

Fails once

First failing year

Federal loans
Still available
Pell Grant
Still available
What the school must do
Warn current and new students

Fails 2 of 3 years

Low-earning outcome program

Federal loans
Ends for the program
Pell Grant
Usually still available
What the school must do
Stop Direct Loans; it may appeal a calculation error within 30 days

Pell can end too in one case. If more than half of a school’s federal aid students, or more than half of its federal aid dollars, are in low-earning programs, those programs can lose all federal aid, Pell included. Source · ED fact sheet

The dates to watch

  1. Schools send their first program data

    Schools report enrollment and cost data each year by October 1. Source · ED fact sheet

  2. First calculation

    The Department runs the first test with 2025 earnings, applying to the 2027-28 award year.

  3. Rule takes full effect

    First official results follow, and a single failure triggers student warnings. Source · Duane Morris

  4. Earliest loss of federal loans

    Programs that fail in both 2027 and 2028 can lose Direct Loans for the 2028-29 award year.

Programs tied to jobs where most workers earn tips, such as cosmetology and massage therapy, get at least a one-year delay in consequences. Source · TICAS

How to check a program before the results

The official results don’t exist yet. The closest public figure is the College Scorecard’s median earnings for a program’s graduates four years after finishing, which also covers federal aid recipients who are working.

Here’s how that looks for some online-heavy bachelor’s programs in fields with lower pay.

Graduates' earnings 4 years out, lower-paying bachelor's fields (College Scorecard)
School Program Scorecard field Median earnings, 4 yrs after Median federal debt Graduates, 2022-23
Southern New Hampshire University Liberal arts Liberal Arts and Sciences, General Studies and Humanities (bachelor's) $66,656 $13,023 1,312
ASU Digital Immersion Criminal justice Criminal Justice and Corrections (bachelor's) $59,973 $20,151 238
ASU Digital Immersion English English Language and Literature, General (bachelor's) $50,205 $21,375 232
University of Maryland Global Campus General studies Liberal Arts and Sciences, General Studies and Humanities (bachelor's) $48,298 $12,833 48
School Southern New Hampshire University
Program Liberal arts
Scorecard field Liberal Arts and Sciences, General Studies and Humanities (bachelor's)
Median earnings, 4 yrs after $66,656
Median federal debt $13,023
Graduates, 2022-23 1,312
School ASU Digital Immersion
Program Criminal justice
Scorecard field Criminal Justice and Corrections (bachelor's)
Median earnings, 4 yrs after $59,973
Median federal debt $20,151
Graduates, 2022-23 238
School ASU Digital Immersion
Program English
Scorecard field English Language and Literature, General (bachelor's)
Median earnings, 4 yrs after $50,205
Median federal debt $21,375
Graduates, 2022-23 232
School University of Maryland Global Campus
Program General studies
Scorecard field Liberal Arts and Sciences, General Studies and Humanities (bachelor's)
Median earnings, 4 yrs after $48,298
Median federal debt $12,833
Graduates, 2022-23 48

Source: U.S. Department of Education College Scorecard, field-of-study data updated June 10, 2026. Earnings and debt cover every graduate of that field and credential at the school, online and on campus together, so they describe the school's graduates, not what any one student will earn. Earnings are the median for graduates working and not enrolled four years after finishing (2017-18 and 2018-19 graduates, in 2024 dollars); debt is the median federal loan debt of graduates (2018-19 and 2019-20); "Not published" means Scorecard suppresses the figure for a small cohort. Scorecard pages: Southern New Hampshire University, ASU Digital Immersion, University of Maryland Global Campus.

Interactive decision tree

Is your program at risk under the earnings test?

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Frequently asked questions

Does the test apply to online programs?

Yes. It covers programs in every sector and credential level, online or on campus. Source · ED fact sheet

Can I still get Pell at a program that fails?

Usually yes. Pell ends only if the school also fails the half-of-students or half-of-dollars test described above.

Where will the results be posted?

The Department will publish whether each program passes or fails, with graduates’ earnings. Schools that get a warning must point students to that site.

Your next step is the payback math

The earnings test sets a floor, not a goal. The ROI calculator shows how long a program takes to pay back for you, using BLS pay for the job you want.

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