Lessons from Gainful Employment: Improvements to Replicate and a Mistake to Avoid
Texas Public Policy Foundation Research
Andrew Gillen, Ph.D.
February 2022
Executive Summary
Higher education needs more accountability, and a promising approach was a set of federal regulations called gainful employment, which sought to identify and terminate federal financial aid for college programs that left students with excessive student loan debt relative to their earnings after graduating. Introduced in 2011 and 2014, the regulations were rescinded in 2019. The Biden administration is considering reimposing gainful employment. If they do so, they should build upon two improvements gainful employment pioneered (the focus on program level rather than institution level evaluation, and the inclusion of students’ post-graduation earnings as an outcome metric), while avoiding the fatal mistake of the regulations (selective rather than universal application of accountability).
Introduction
Many believe that higher education needs enhanced accountability. The most noteworthy recent approach to accountability was a set of regulations introduced by the Obama administration and called gainful employment. These regulations pioneered two promising new approaches to accountability in higher education. First, they focused on programs rather than colleges or institutions. Second, the regulations accounted for students’ post-graduation earnings relative to their student debt—an important outcome. Both were improvements in the federal approach to accountability that should be replicated in future accountability systems.
