Earnings Test Gets Mixed Reviews in Public Comments

A proposed federal accountability metric would set a minimum earnings requirement for graduates and compare their earnings to those of students with only a high school diploma. Department data indicate that about 9% of undergraduate religious studies programs and 6% of graduate programs would fail the test. Commenters argued the impact could be much higher, citing shared data showing 53% of religious studies bachelor’s programs and 89% of religious studies master’s programs failing. Programs failing in two consecutive years could lose access to federal student loans, and some could later lose access to Pell Grants. Commenters said the metric could disproportionately affect faith-based higher education because of institutional mission and program specialization.

"Religious colleges warned the Education Department that its proposed new accountability metric, which essentially sets a minimum earnings requirement for graduates, could devastate them, in part because their core programs would fail."

"About 9 percent of undergraduate religious studies programs and 6 percent of graduate ones would fail the test that compares students' earnings after they graduate to those with only a high school diploma, according to department data. Several commenters, responding to the agency's proposal in the public comment period, said the impact could be far higher than those numbers show."

"The Association for Biblical Higher Education Commission on Accreditation shared ED data in its comment showing that 53 percent of religious studies bachelor's programs and 89 percent of religious studies master's programs would fail the metric. Programs that fail the earnings test in two consecutive years could lose access to federal student loans, and some could eventually be cut off from the Pell Grant as well under the department's proposal."

""It appears that the proposed earnings test will have a disproportionate, negative effect on faith-based higher education," ABHE wrote. "When specialized institutions offer only religious/ministry studies programs, there is increased risk that institutions might be placed on provisional status or lose access to [federal student aid] altogether, simply as a function of institutional mission. Consequently, the proposed accountability measure goes beyond managing loan repayment risk for taxpayers and puts student access to religious/biblical studies and ministry programs at significant risk.""

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