On April 20, 2026, the U.S. Department of Education published a proposed rule that could change which college programs keep access to federal student loans and grants. It is called the "Do No Harm" earnings test, and if it takes effect as planned on July 1, 2026, it will quietly reshape the list of schools and majors that families can pay for with federal aid in the years ahead. If you are helping a student pick a college right now, this is one of those policy changes worth slowing down and understanding, because it can affect both the cost of the degree and the value of the degree after graduation.
The rule is technical, but the idea behind it is simple: a college program should not leave graduates worse off financially than if they had stopped their education at high school. This article breaks down what the rule says, which programs are most at risk, how to check the earnings data for any program today, and what steps your family can take before the rule becomes final.
What the "Do No Harm" Earnings Test Actually Says
The "Do No Harm" rule grew out of the One Big Beautiful Bill Act (OBBBA), signed into law in 2025. The Department of Education is using a negotiated rulemaking process to turn the law's earnings requirement into a specific, measurable test that colleges must pass to keep their federal aid eligibility.
Here is the heart of the rule in plain language:
- For an undergraduate program (certificate, associate, or bachelor's degree), the typical graduate's earnings four years after finishing must be at least as high as what a typical working adult with only a high school diploma earns.
- For a master's or doctoral program, the typical graduate's earnings must be at least as high as what a typical worker with a bachelor's degree earns.
- The Department uses the median earnings of program graduates between the ages of 25 and 34 who are working and not enrolled in more school.
The benchmark for the high school comparison is currently about $35,490 per year nationwide. That number will shift a bit over time with the data, but it gives you a rough sense of the floor.
If a program fails the test for two of any three consecutive award years, it loses access to federal student loans. The earliest possible loss of aid would be July 1, 2028, based on program performance in the 2026-27 and 2027-28 years. In later years, the rule could also cut failing programs off from Pell Grants and other federal aid.
The public comment period runs through May 20, 2026. After that, the Department will review comments and publish a final rule, still targeting a July 1, 2026 effective date.
Why This Matters for Families Choosing a College Right Now
If your student is deciding between schools this spring or planning ahead for next year, the "Do No Harm" rule touches two things families care about most: access to federal aid and the long-term value of a degree.
Here is what it means in practice:
- A program that barely passes the test today might tighten admissions or cut costs to stay eligible. Some schools may quietly close programs that are at risk.
- A program that fails the test could lose federal loans, which usually means students would need private loans instead. Private loans carry higher rates and fewer protections than federal loans, so the overall cost of attending can jump.
- Schools are starting to pay more attention to graduate outcomes. That is a good thing for students, but it also means that rankings, marketing, and what you hear at orientation may start to emphasize earnings more than before.
None of this means you should pick a major based only on starting salary. But it does mean the earnings picture four years after graduation is about to become an official gatekeeper for federal aid, so it is worth looking at before you commit.
Which Programs Are Most Likely to Struggle
The "Do No Harm" test is designed to catch programs where graduates consistently earn less than a high school worker four years out. Based on the federal earnings data the Department of Education will use, and earlier gainful employment reviews, the programs most often flagged tend to share a few traits.
Programs That Tend to Fail Earnings Tests
- Short certificate programs in fields with modest wages, especially in cosmetology, some health technician roles, and some culinary programs.
- Some for-profit associate and bachelor's programs where tuition is high and graduate earnings have lagged.
- Certain liberal arts and fine arts programs at schools where graduates enter low-paying fields and do not go on to graduate school within four years.
- Some master's programs in fields where the pay ceiling is close to the bachelor's-level wage, so the degree does not move earnings enough.
It is important to say this clearly: a program failing the earnings test does not mean the program is "bad." Teaching, social work, and the arts are deeply valuable, and many graduates go on to meaningful careers. But the federal government will stop underwriting programs where graduate earnings do not clear the benchmark, and that is the reality families have to plan around.
Programs That Usually Pass Easily
Nursing, engineering, computer science, business, and most health professional programs usually sit comfortably above the benchmark. That does not automatically make them the right choice for every student. Fit, graduation rate, and total cost still matter. But the federal aid picture for these programs is steadier.
How to Check a Program's Earnings Data Today
You do not have to wait for the rule to take effect to see how a program is doing. The same federal earnings data that will feed the "Do No Harm" test is already public, and CollegeLens pulls it directly into your plan.
Use the CollegeLens Compare Schools Tool
The fastest way to see earnings and outcome data for the schools on your student's list is the Compare Schools tab inside your free CollegeLens plan. Once you add a school, the tool shows:
- Median earnings of graduates one to four years after completion
- Median debt taken on by students in that program
- Completion and graduation rates
- The net cost your family would actually pay, side by side with other schools
The advantage is that you are not reading raw federal data in one browser tab and your award letter in another. Compare Schools puts the earnings numbers next to the real net cost for your family, so you can see at a glance whether the tradeoff makes sense. Compare the median earnings for each program against the $35,490 high school benchmark for undergraduate programs as you scan.
Ask the School Directly
Admissions offices and financial aid offices can usually share program-level outcomes. Reasonable questions to ask:
- "What is the median salary for graduates of this program four years after they finish?"
- "What percentage of graduates are employed in their field within one year?"
- "Has the Department of Education flagged any of your programs under the gainful employment or financial value transparency rules?"
You will learn a lot from how quickly and clearly a school answers these questions. Schools that are confident in their outcomes usually share data willingly.
Read the Net Cost Against the Earnings
A low-earning program is not automatically a bad choice. A low-earning program plus a high net price is. Before committing, compare the net cost of attending against expected earnings. A rough rule of thumb: total borrowing for a degree should not be much higher than the first-year salary a graduate can expect.
What Happens if a Program You Want Loses Federal Aid
If a program your student is considering fails the "Do No Harm" test, the effects will roll out in stages. The program does not disappear overnight. The school can still enroll students and charge tuition. What changes is how those students can pay.
Families in this situation typically face a few options:
- Shift to a different program at the same school that does pass the test and is still eligible for federal loans, Pell Grants, and work-study.
- Transfer to a school with a similar program that is passing the test. Transferring can be smart, but it can also reset some aid, so weigh the decision carefully before moving.
- Pay for the program with savings, scholarships, employer tuition benefits, and private loans. This is the most expensive path, because private loans carry higher interest and fewer safety nets. If this is the only option, read our piece on what to do when financial aid isn't enough before signing anything.
If you are a current student in a program that loses eligibility, the Department of Education typically requires schools to notify students and, in many cases, help them "teach out" the program so they can finish. Ask the financial aid office in writing what their plan is. Do not rely on hallway conversations.
How This Fits With Other 2026 Federal Aid Changes
The "Do No Harm" rule does not exist on its own. It lands at the same time as several other big changes from OBBBA:
- Parent PLUS loans are now capped at $20,000 per year and $65,000 lifetime per dependent student.
- Grad PLUS loans are going away for new borrowers starting July 1, 2026, with a three-year grandfather for existing grad students.
- The SAVE repayment plan is ending, and a new plan called RAP (Repayment Assistance Plan) is launching July 1, 2026, charging 1 to 10 percent of income for up to 30 years.
- Federal loan rates for 2025-26 sit at 6.39 percent for undergrads, 7.94 percent for grads, and 8.94 percent for PLUS loans.
Put together, the federal aid system is getting stricter about what it will finance and how much it will lend. Families who plan ahead and understand how to build a college funding stack will be much better positioned than families who assume federal loans will cover whatever tuition is left.
What Families Can Do Right Now
You cannot control what the final rule looks like, but you can control how you prepare. A few steps worth taking this month:
- File or update your FAFSA so you know what federal aid the student qualifies for before any rule changes kick in.
- Add every school on your student's short list to the Compare Schools tab in your CollegeLens plan and save the earnings numbers next to each school's net cost. If a program is close to the benchmark, weigh that against net price carefully.
- If your student is between two similar programs, favor the one with stronger graduate earnings data. All else equal, it is the more durable federal aid bet.
- If you are looking at master's or doctoral programs, plan for the Grad PLUS phase-out. That usually means comparing federal direct unsubsidized loans, school-based aid, fellowships, and private loans side by side. Our guide on how to compare private student loan options can help.
- If your student is already enrolled in a program you are worried about, ask the financial aid office in writing what they plan to do if the program does not meet the new benchmark.
Build a Plan That Accounts for the New Rules
The single biggest mistake families are making right now is treating 2026 like 2024. The aid landscape is different. The borrowing limits are different. And starting this summer, access to federal aid will depend in part on how much the program's graduates earn. The families who sit down, run the real numbers, and compare total cost to likely earnings are the ones who avoid ugly surprises.
If that feels like a lot to hold in your head, you do not have to do it alone. You can create your free CollegeLens plan to see every cost layer, every aid source, and the gap you would need to cover, school by school. The tool is built for exactly this kind of decision, and it is free.
The Bottom Line
The "Do No Harm" earnings test is a real policy change, but it does not need to derail your planning. It simply puts a number to something families have always wondered about: is this program going to pay off? Starting July 1, 2026, the federal government will begin answering that question on behalf of taxpayers. Your family can ask the same question earlier, and you can use the answer to choose a program that is both affordable now and more likely to hold its federal aid eligibility through graduation.
Paying for college is already stressful, and another federal rule does not make it easier. But this one gives families a new reason to do the homework that we always recommend: look at program-level earnings, compare that against what you would actually pay, and make a choice you can feel good about five years from now, not just on decision day.
-- Sravani at CollegeLens