Low-Earning Degrees Will Soon Lose Access to Federal Loans—Is Yours on the List?
Preston Cooper
January 15, 2026
The One Big Beautiful Bill Act (OBBB) created a new system of accountability for higher education programs that depend on federal subsidies—colloquially known as the “Do No Harm” principle. Degrees and certificates which fail to increase their graduates’ earnings potential are on notice—within a couple years, they could lose access to federal student loans.
Last week, the Education Department convened a negotiated rulemaking committee to draft regulations to implement this provision of OBBB. (For more on the regulations that emerged from that committee, see my companion post.) To aid the process, the Department released a preliminary dataset—officially the 2026 Program Performance data; unofficially the One Big Beautiful Dataset—including nearly 50,000 degree and certificate programs and whether they are likely to pass the new accountability test.
The “Do No Harm” test compares how much graduates of a particular program earn four years after leaving school to a benchmark—the earnings of comparable high school graduates (for undergraduate programs) or the earnings of comparable bachelor’s degree holders (for graduate programs). If the program’s earnings fall below the benchmark earnings for two out of three consecutive years, the program can no longer enroll students using federal loans.
