The Department of Education has proposed a new “accountability” system that would judge higher-education programs largely by graduates’ earnings, prompting concern from liberal arts institutions and education advocates who argue that this is a test that music, visual arts, and filmmaking programs would, by their nature, be likely to fail.
The proposed guidelines, known as the Student Tuition and Transparency System (STATS) and Earnings Accountability rule, are intended to provide students with information about the costs and economic prospects of their intended degree programs while, as the name implies, holding those programs accountable for their graduates’ outcomes. The framework would apply across higher education, and programs whose graduates fail to meet its earnings benchmark in two out of three years could lose eligibility for federal student loans.
The consequences for students enrolled at the time of such a ruling remain uncertain, but critics warn they could be forced to transfer to other programs, institutions, or fields of study. Over time, critics add, the system could threaten the viability of smaller academic departments and schools reliant on “low-performing” programs.
Broadly speaking, the threshold for passing these tests has been significantly raised. Previously, the agency measured the earnings of program graduates four years after completion against the wages of working adults with high school diplomas. Under the new proposal, those earnings would instead be compared against the median salary of workers aged 25 to 35 who hold a bachelor’s degree. Programs that repeatedly fail to exceed this threshold could lose eligibility for federal Direct Loans and, in some cases, other forms of federal student aid, including Pell Grants, which help subsidize tuition for low-income students.
Notably, the new rules would eliminate the debt-to-earnings metric used in earlier accountability regulations, relying primarily on earnings outcomes calculated by the government. The Department argues that taxpayers should not subsidize programs that fail to leave graduates in a better financial position than they would have been in without attending college. Critics, including some of the country’s largest education networks, say the government’s framework does not provide a fair or realistic measure of success for creative professionals.
In a comment filed directly on the document, the Association of American Universities (AAU)—representing Harvard, Columbia, Yale, among others—raised “serious concerns” about the proposed framework’s “consequences for disciplines whose graduates produce substantial public value that wage data alone cannot capture.” The AAU also raised “a significant procedural concern,” noting the “stark omission of stakeholders—including representatives from the financial aid community”—whose participation, the group said, would have led to a “more comprehensive conversation.”
A preliminary analysis of economic data released by the Education Department, first reported by the New York Times, suggests that many of the country’s leading graduate programs would fail to meet the updated earnings test, including Yale University’s master’s programs in visual arts and music; Harvard University’s master’s program in museum studies; and the Juilliard School’s undergraduate and graduate music programs, among the most prestigious in the world. Meanwhile, according to the Department’s calculations, 90 percent of religious studies graduate students and 100 percent of recipients of culinary certificates would fail the updated earnings test.
The revised earnings test was introduced alongside last year’s domestic policy package, a sweeping tax-cut and spending bill that also scaled back several safety-net programs. The package cleared the House by a narrow margin. A July deadline has been set to finalize the rule’s guidelines.
The Education Department received nearly 8,800 public comments on the proposed rule, including submissions from alumni of graduate liberal arts programs across the country as well as participants in technical programs such as cosmetology. Some critics note that the test’s reliance on “gross income” fails to capture the full income picture for workers in the gig economy, while others argue that four years of data is not an adequate time frame to assess long-term earnings potential, particularly in the visual arts and music, where practitioners often do not achieve immediate post-graduation success
“In my first year after graduating from my undergraduate program, I completed a nine-month apprenticeship at one of the most esteemed institutions in the world, the Juilliard School,” wrote one commenter, who continued: “This apprenticeship paid me $16.72 an hour, which amounts to a monthly gross income of approximately 165 percent of the federal poverty level in 2024… It’s critical to note that one of the most competitive and challenging post-graduate programs for early-career artists and arts administrators barely pays them.”
Another commenter wrote: “I own a school in a very poor area in Michigan. This will kill us.”
