Ensuring Value for Federal Financial Aid
Table of Contents:
Executive Summary
Introduction
High School Earnings Threshold
Debt-to-Income Threshold
Targeted Metrics Avoid Unintended Consequences
Conclusion
Appendix — Policy Design Questions
Executive Summary
The federal government places few guardrails on its $120 billion yearly provision of grants, work study, and student loans for higher education.1 As a result, billions of taxpayer dollars go toward degrees with little or no payoff: more than 1 in 4 bachelor’s programs leave students with a negative financial return.2 Congress must tighten federal aid eligibility to protect students from low-value degrees and save taxpayers money – a key goal for the ongoing reconciliation bill. Policymakers should start with two metrics:
- High school earnings threshold: The median graduate of any postsecondary program must earn more than the median 25- to 34-year-old with a high school diploma in the same state to qualify for federal aid.3
- A 20% debt-to-discretionary-income (DTI) ratio: All undergraduate and graduate programs should provide a minimum level of earnings relative to the amount students borrow. Monthly payments should not exceed 20% of income above 150% of the federal poverty line (above $23,475 in 2025).
These metrics would not only save up to $15 billion4, they would also effectively address common concerns about stronger higher education accountability.
- Targeted standards mitigate closure risks: Program-level metrics impact only the worst-performing fields of study while preserving institutional stability and student access.
- Socially valuable careers still qualify: Graduate teaching and social work programs generally meet these thresholds, especially at public institutions.
- Students usually have better local alternatives: Experience with career education suggests that students in low-performing programs likely have access to options nearby, or even at the same institution, with higher earnings and lower debt.
- Stronger standards protect marginalized students: Low-income and underrepresented students are disproportionately harmed by low-value programs.
- HBCUs and MSIs largely meet the bar: Despite historical underfunding, most programs at Historically Black Colleges and Universities (HBCUs) and minority-serving institutions surpass these thresholds.
Introduction
The United States hosts many of the best higher education institutions in the world, but it also subsidizes programs that leave students worse off than when they enrolled. Attention to college costs and student debt frequently obscures the profound impact educational quality has on student success. Medical students routinely borrow hundreds of thousands of dollars for expensive degrees, but doctors almost always earn enough to repay their student loans. Meanwhile, a student who borrows a few thousand dollars for an associate’s degree but leaves before completing it runs a high risk of default.5
The latter case occurs far more often than many realize. Two-thirds of community colleges graduate fewer than half of their students. Nearly 1 in 4 students pursuing a postsecondary certificate enrolls in a program where the typical graduate earns less than someone with only a high school diploma.6 And though bachelor’s degrees usually lead to higher earnings, more than 1 in 4 programs leave students with a negative financial return on investment.7 Despite the wide range of outcomes, the federal government places few guardrails on its $120 billion yearly disbursement of grants, work study, and student loans for higher education.8
In theory, the national “triad” of accreditors, state governments, and the U.S. Department of Education sets and enforces quality standards. In practice, they frequently tolerate dismal results. By the federal government’s own admission, accreditors rarely sanction schools for low performance.9 States have little capacity to fill the void. In 2023, 61% of states had 3 or fewer fulltime equivalent (FTE) staff dedicated to reviewing and authorizing higher education programs.10 The federal government’s main accountability standard — cohort default rates — only applies in the most egregious cases, is easily sidestepped by institutions, and has not functioned properly since the pandemic repayment pause.11
Program Level Metrics
Both proposed metrics would apply to specific educational programs rather than entire institutions. The U.S. Department of Education uses a 6‑digit Classification of Instructional Programs (CIP) codes to identify programs that roughly correspond to colleges majors like accounting or political science. Program-level metrics reduce the risk of pulling all financial aid from colleges at once, allowing schools to focus on offerings that meet minimum standards.12
Students understandably assume that an accredited program qualifying for federal financial aid is a safe investment of time and money. They learn too late that certain programs bearing a stamp of approval from the U.S. Department of Education do not pay off. Federal policymakers must do better. Higher education should deliver a reasonable return for students and taxpayers alike.
Setting stronger quality standards will require congressional action followed by consistent enforcement from the U.S. Department of Education. Congress should start by requiring all undergraduate programs to deliver a minimum level of earnings and all postsecondary programs to maintain typical student borrowing proportionate to their graduates’ incomes. The following two metrics for federal financial aid eligibility would effectively establish those standards:
- High school earnings threshold: The median graduate of a postsecondary program must earn more than a typical person with a high school diploma in the same state for the program to qualify for federal financial aid.
- A 20% debt-to-discretionary-income (DTI) ratio: All undergraduate and graduate programs should provide a minimum level of earnings relative to the amount students borrow to access federal loan programs. Monthly payments should not exceed 20% of income above 150% of the federal poverty line ($23,475 in 2025).
These metrics would be an important first, but not final, step toward shifting incentives in higher education. Both measures evaluate graduating students, but additional tools that account for students who do not complete a credential would provide a critical complement.13 Beyond a minimum eligibility threshold, the federal government should also embed positive incentives for student success in our financial aid system. Nevertheless, an earnings test and debt-to-income ratio would provide a strong foundation on which to raise college quality standards. The following brief provides additional information on these metrics and how they address common concerns about
stronger accountability policies. A detailed appendix addresses several design and implementation questions.
High School Earnings Threshold
Students routinely list getting a good job with decent pay as the top reason for attending college.14 Americans understand that, on average, college graduates earn much more than people with a high school diploma15, and most graduating high school seniors soon enroll in postsecondary education.16 Adults frequently return to college to acquire valuable skills.
Uneven college outcomes reflect, to some extent, natural population variance.17 Not every college graduate will enter the most lucrative field or have a successful career.18 On the other hand, nearly 70 four-year institutions nationwide leave the typical graduate earning less than someone with a high school diploma. Despite spending time and money, students from these colleges end up worse off than if they had simply started working after high school. This fails a basic intuitive test of what college should deliver.
Congress should set a minimum standard that ensures students can reasonably expect to earn more than a high school graduate if they take out federal grants and loans to attend college. An effective rule will account for variation in employment outcomes by geography. Specifically, to qualify for federal financial aid, the median annual earnings of program completers should exceed that of individuals aged 25 – 34 with only a high school diploma or GED, within the state where the higher education institution is located. Online programs or those where more than half of students reside out of state should meet a national median earnings threshold for individuals with only a high school diploma.
Even the institutions cited above, where the median graduate earns less than a person with a high school diploma, will likely have programs that meet this threshold. Conversely, colleges with high median earnings might discover that some of their majors fail to prepare students for the job market.
The overwhelming majority of college programs, particularly at 4‑year institutions, would pass the low bar of a high school earnings threshold. Despite concern about humanities fields, the median bachelor’s degree graduate in Journalism or History earns over $50,000 four years after leaving — far more than a typical high school graduate in the states where they reside.19 Drama and theatre arts degrees would face the greatest hurdles at the 4‑year level: the median graduate earns just $31,198 after 4 years. At 2‑year institutions, cosmetology, massage therapy, and some health-related administrative support fields would have the lowest passing rates.20
There may be sub-fields such as early childhood education where graduate earnings would fail the proposed test although the majority of education programs overall would pass.21 Early-childhood fields tend to elicit more concern because of their central role in the modern economy. However, just under half of center-based childcare providers in the U.S. have an associate’s degree or higher, with lower rates for home-based providers.22 Moreover, only 3 states require an Associate of Art (AA) degree or higher to hold a center-based early childhood teaching position.23
More importantly, neither employers nor state regulators should require degrees from job applicants that cost far more to attain than an employer is willing to pay. Nor should taxpayers subsidize the practice by giving out grants and loans to programs that we know will not deliver financial security, much less the ability to pay back any student debt. Colleges would do better to consider lower-cost ways to provide training in low-wage fields, such as through apprenticeships.
Debt-to-Income Threshold
While an earnings threshold focuses on workforce outcomes, it does not account for return on investment or student loan repayment. A program’s graduates may earn more than a high school graduate, but if the college charges high tuition, students may need to take out loans they cannot afford to repay. In fact, the best evidence suggests that low-value academic programs explain a substantial portion of student loan defaults.24 A debt-to-earnings metric for all undergraduate and graduate programs would protect students and taxpayers from low-ROI degrees.
Congress should require that a program’s median graduate allocate less than 20% of discretionary earnings toward monthly debt repayments. This is a very conservative threshold. Previously, Congress deemed 10% of income above a protected amount — 150% of the federal poverty level ($23,475 for a single person in 2025) — affordable for its statutory income-based repayment plan.25 A recently proposed income-driven plan achieves similar repayment amounts while topping out at 10% of total income for the highest income borrowers.26 Setting the threshold at 20% of discretionary income would disqualify programs when a typical graduate owes a monthly payment twice that deemed affordable by Congress.27
The proposed metric remains a very low bar that would penalize only the lowest performing programs. A typical master’s in social work student borrows $41,000 and earns over $50,000 in an entry level role.28 A program with these outcomes would pass the test.
Consequences would only arise only at the highest levels of tuition and borrowing. For instance, a social work program at a private nonprofit college that charged $100,000 in tuition and whose median borrower takes $94,000 in loans (the 90th percentile for all borrowers in social work master’s programs) would likely fail the metric. Even if its graduates earned $70,000, their median monthly loan payment would exceed 20% of their discretionary income.29 Such a program should not qualify for federal loans. The college is charging exorbitant rates for a degree with only above average pay — a degree that other colleges, including some private institutions, offer for a lower price. Students and taxpayers should not countenance that behavior. The institution should lower prices and reduce borrowing or forgo federal financial aid.
Targeted Metrics Avoid Unintended Consequences
The prospect of eliminating eligibility for federal financial aid typically invites concerns, often from colleges themselves, that stronger standards will result in worse outcomes than we currently have. The proposed earnings and debt-to-income metrics address the most common critiques.
For instance, higher education institutions warn that cutting off federal aid could cause colleges to close altogether, eliminating economic opportunities for students and strong sources of local jobs. Program-level metrics reduce that risk by removing eligibility only for the lowest-performing majors and graduate degrees. Institutions with other, higher-value programs can continue to operate — and ideally prioritize — those that pay off for students and taxpayers.
Another common concern is that socially valuable careers that require postsecondary education, but deliver modest earnings, could face outsized consequences. However, as we note above, a typical social work program with median levels of debt will pass the debt-to-earnings threshold. Teachers typically borrow less than $40,000 for a master’s program30, meaning that graduate education programs, particularly in public institutions, should have little trouble meeting these low bars.
Some accountability critics acknowledge poor outcomes but would prefer to keep low-performing programs in place out of a fear that students will have no alternatives nearby. Putting aside that a lack of options does not justify offering loans to a student we know cannot afford to repay, the limited available evidence should assuage these fears. A U.S. Department of Education analysis estimated that a typical student in a low-performing career program had at least 5 other options available nearby in similar fields. Those options had 43% higher earnings and 22% lower debt.31 Career programs represent about a fifth of federal financial aid eligible programs, suggesting that students in low-performing traditional degree programs likely have additional high-performing options nearby.
Another common concern arises around Historically Black Colleges and Universities (HBCUs), Tribal Colleges and Universities, and other minority-serving institutions. These colleges serve a less well-resourced student body, and especially in the case of HBCUs and Tribal colleges, they have been systematically underfunded for decades. However, an analysis of similar metrics found that the vast majority of programs at HBCUs and other MSIs would pass.32
A final criticism points out that low-income and other marginalized students disproportionately enroll in low-performing programs. Yet this is the strongest argument to raise standards. In a recent paper entitled, What Went Wrong with Federal Student Loans? Looney and Yannelis find the following:
Starting in the late 1990s, policymakers weakened regulations that had constrained institutions from enrolling aid-dependent students. This led to rising enrollment of relatively disadvantaged students, but primarily at poor-performing, low-value institutions whose students systematically failed to complete a degree, struggled to repay their loans, defaulted at high rates, and foundered in the job market.33
Enrolling disadvantaged students in debt-financed, low-value programs left many worse off than had they not enrolled at all. Raising standards to ensure a minimum financial return would do much more to help these students compared to maintaining the status quo.
Conclusion
An effective earnings and debt-to-income test provides a strong foundation on which to improve higher education quality. Eventually, federal policymakers should add to these proposals to address low completion rates and provide stronger incentives for continuous improvement. At bottom, the U.S. Department of Education should not put its “stamp of approval” on higher education programs where graduates earn less than those with a high school diploma or face unaffordable debt levels compared to their expected earnings. Students and taxpayers deserve better.
Appendix — Policy Design Questions
The proposed metrics enforce a straightforward standard for Title IV aid eligibility: postsecondary programs should leave students better off than high school graduates and with affordable levels of federal student loans. Implementing these metrics requires several nuanced policy choices. This appendix identifies key decision points, discusses tradeoffs, and offers solutions.
Calculating Standard Monthly Loan Payments for Debt-to-Income Metrics
Since borrowers currently repay on several different plans with different interest rates, Congress would need a standard way to calculate monthly payments. While using the 10-year standard plan is a natural option, it may prove unrealistic given the number of students who use income-driven plans over a longer period, paying more as their careers progress. The following schedule would amortize the median debt standard over more years for higher-level degrees:
- Associate’s degrees: 10 years
- Bachelor’s and master’s degrees: 15 years
- Doctorate or professional degrees: 20 years
Completers vs. Non-Completers
Both the earnings and debt-to-income metrics track college completers. Program level metrics provide the strongest near-term opportunity for strengthening our accountability system. However, it is nearly impossible to assign some non-completers and their earnings to a program — many undergraduate students who are seeking a degree enter college with their major undeclared, and some drop out without ever having declared a major. Additionally, including non-completers in the measure might both understate their earnings and understate their debt loads. Non-completers are less likely to have reaped the benefits of their education, since they didn’t earn a credential; but also likely accrued less debt because they were not in school as long. Including the debt and the earnings only of completers is both fairer to institutions and allows for apples-to-apples comparisons of students’ debt and earnings. While this paper does not address completion metrics, future policy debates should also include discussions of appropriate thresholds for completion.
Earnings Timing — Measurement and Enforcement
Setting an earnings threshold poses challenges in part because incomes increase —sometimes substantially — in the years after graduation.34 A minimum earnings threshold should allow completers to gain a foothold in the job market but avoid funding low-performing programs for too long, or establishing consequences that are too many years removed from what institutions are doing now. We propose using data from 3 years after completion to measure program success. Most college graduates earn more than high school graduates at this stage. A 5‑year timeframe would provide a more lenient, though still reasonable standard for some programs where earnings take longer to develop.35
Waiting a longer time can have implications for enforcement consequences such as the loss of Title IV aid. Higher education institutions will frequently point out that a program failing a metric measured 3 years after graduation might require nearly a decade to adopt sufficient changes to pass. If a 4‑year college makes program changes in the first year that it faces a new accountability metric, it will take 7 years at the absolute earliest to see impacts of those on entering freshmen, assuming most students graduate on time and the initial changes prove effective. The argument follows that enforcement of earnings metrics should wait up to a decade or more for consequences to come into effect.
While this may be “fairer” to institutions, we prioritize students and taxpayers. These proposals provide very low standards. Allowing students to attend programs that do not pay off and leaving them with unaffordable debt for a decade is too high a price. We envision immediate consequences within the first two to three years of implementation.
College Price vs. Full Cost of Attendance
Another implementation decision is whether to hold institutions accountable for all the loans that their students take out, or just the loans that go toward tuition and fees. Living expenses such as housing and food are often the most expensive part of a postsecondary education. However, because institutions set the full cost of attendance, they may have an incentive to reduce total borrowing by limiting projected costs for food, housing, transportation, and other essentials while keeping tuition high.
A better approach is to hold institutions accountable for loan debt up to the cost of the education itself including all mandatory tuition, fees, and required course materials. This would provide a stronger incentive for institutions to lower the costs that they can control without limiting financial aid for living costs that students need. Because most students pay less than the published price of tuition, another option is to use the actual net price paid of a program’s completers. This is a reasonable approach, although it adds complexity.
Title IV vs. Non-Title IV Data
Right now, federal law limits available data on program performance to students who received Title IV financial aid. On one hand, this provides sufficient, if imperfect, information to federal regulators since the federal government’s primary interest is in outcomes for students who receive federal funding. However, we continue to support greater college transparency that would make outcomes for all students available, improve understanding of which degrees provide value, and ultimately improve accountability policies. This would better protect students in federally supported programs even when their costs are paid out-of-pocket, via veterans or servicemember benefits, or using state and other financial aid.