The "Do No Harm" Test: What Happens If Your Kid's Major Fails the Federal Earnings Benchmark
Starting this year, the U.S. Department of Education is grading college majors on a simple pass/fail test, and if a program fails, the students in it could eventually lose access to federal loans.
How are majors being evaluated?
The rule, nicknamed "Do No Harm," requires undergraduate programs to show that their graduates earn more than a typical working adult with only a high school diploma, measured four years after graduation. A program that fails this bar in two out of three consecutive years risks losing eligibility for the federal Direct Loan program, the loans most families rely on to pay for college.
Secretary of Education Nicholas Kent framed the logic bluntly: taxpayers shouldn't underwrite a program that leaves its graduates worse off financially than if they'd skipped college entirely.
The bar is low, but not zero
Education experts across the political spectrum describe the earnings threshold as modest. Depending on the state, bachelor's degree graduates generally need to earn somewhere between roughly $30,000 and $41,000 a year to clear it, which isn’t much higher than a full-time high school graduate's typical wage.
The Department expects most undergraduate programs to pass easily. But its own data shows more than 800,000 students are currently enrolled in a program that would likely fail today, with roughly half of them at for-profit schools. Certificate programs are especially exposed: about 18% of undergraduate certificate programs are projected to fail, with cosmetology and somatic bodywork programs carrying the highest predicted failure rates.
What does this evaluation miss?
The test has a real blind spot: it doesn't account for debt. A graduate earning a modest salary debt-free looks identical, under this measure, to a graduate earning the same salary while carrying tens of thousands in loans.
Some arts-education advocates also argue that earnings alone undersell fields like fine arts, where careers are often nonlinear and satisfaction doesn't track neatly with a paycheck. Doug Dempster, the president of the Strategic National Arts Alumni Project (SNAAP), a nonprofit that studies the careers of arts graduates, comments: "We know we need nurses. We know we need journalists. We know we need early childhood educators. We don't know how many artists we need, but I can guarantee that if you eliminate access, we will impoverish our cultural life nationally."
When will see this impact?
Nothing changes overnight. The Department plans to calculate the first year of graduate earnings data in early 2027, and a program couldn't actually lose loan eligibility before the 2028–2029 award year. But if your student is weighing a specific major, especially a career-focused certificate or a program at a for-profit institution, it's worth asking the admissions or financial aid office directly whether that program has historically cleared this bar. A "yes" is reassuring. A dodge can be telling too.
Bottom line: this rule is aimed mostly at low-earning certificate and for-profit programs, not your average four-year bachelor's degree, but it's a new data point worth checking before your student commits to a specific major or school.
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