Fate of Accountability for Undergraduate Certificates Likely to Loom Over ED Talks
Jessica Blake
December 5, 2025
The Education Department is crafting regs to carry out a congressionally mandated earnings test for colleges. The contentious gainful-employment rule is also on the table.
Starting next July, colleges and universities’ access to federal student loans will hinge on how much their graduates make after Congress’s new earnings test, known as the Do No Harm standard, takes effect.
This monumental shift in how the federal government holds degree programs accountable is one that’s years in the making. But when Congress passed the law, one key type of degree program was left out—undergraduate certificates.
Lawmakers from both parties have long said holding colleges accountable for cost is critical in order to drive down borrower-default rates and protect students from paying high tuition without a guaranteed return on investment. Yet, the very students and programs Republicans left out of the earnings test are expected to face the worst return on investment, studies show.
