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# Your college program could come with an earnings warning under new federal rules
- URL: https://www.readfoxtalk.com/your-college-program-could-come-with-an-earnings-warning-under-new-federal-rules/
- Published: 2026-08-10T15:53:18.000Z
- Updated: 2026-08-10T16:04:46.000Z
- Description: Colorado higher-ed chief JB Holston says students need clearer data on what graduates of different programs earn. Under a final federal rule, programs that fail an earnings test in two of three years can lose access to federal Direct Loans.
- Author: Andy Green
- Tags: News

Colorado students considering a degree or certificate could eventually get a warning before they enroll: Graduates from this program are not clearing a federal earnings standard, and the program could lose access to federal student loans.

Under a [final U.S. Department of Education rule published July 1](https://www.federalregister.gov/documents/2026/07/01/2026-13286/accountability-in-higher-education-and-access-through-demand--driven-workforce-pell-student-tuition?ref=readfoxtalk.com), colleges must warn current and prospective students when a program has failed the earnings standard and could lose Direct Loan access based on its next calculated result. A prospective student generally cannot enroll, register or make a financial commitment to that program until at least three business days after receiving the warning.

That puts a direct student consequence behind a phrase JB Holston, executive director of the Colorado Department of Higher Education, discussed in a July 24 interview with me: the “earnings premium.”

For a student who has never heard the term, Holston gave a simple definition.

“Can you make more money if you pursue this pathway or that degree or that program than if you pursue a different program or pathway or certificate or degree or minor or other?” he said.

For most undergraduate programs, the federal test compares the median earnings of former students with the earnings of working 25- to 34-year-olds whose highest credential is a high school diploma. The Education Department measures program completers’ earnings in the fourth tax year after they finish.

That means the rule is not just about four-year universities. Associate degree and other undergraduate programs that participate in federal student aid are part of the new accountability system.

A program does not lose federal loan access because of one bad result. It must fail the earnings measure in two of three consecutive award years for which the measure is calculated before it is classified as a low-earning outcome program and faces the loss of Direct Loan eligibility.

### What if you are already halfway through?

I asked Holston what would happen to a student who is halfway through a program when it receives a failing earnings result.

“Nothing,” he said. “I mean, these are all going to take effect over time.”

A single failing result does not automatically remove a student from a program or close the program. But the federal rule does create steps that students may notice before a program reaches the point of losing loan access.

Once a program is at risk of losing Direct Loan eligibility based on its next result, the college must send a warning to students already enrolled in it. Students receiving federal aid must acknowledge that warning before the school can disburse Title IV federal aid to them. Prospective students also must receive the warning before enrolling.

Holston said the longer-term effect could come from the decisions colleges make if students can no longer finance a program with federal loans.

“Over time, the program probably won’t continue to, it may not continue to exist because the institution may decide that if students can’t get funding to pursue that path, they’ll have fewer students pursuing the path,” he said.

He said he was not hearing, for the most part, that Colorado institutions were already cutting programs because of the earnings test. Colleges are under financial pressure for other reasons, he said, and may still reduce programs based on demand and cost.

### What about teaching, nursing and other needed jobs?

I also asked Holston whether a program Colorado needs could fail an earnings test because graduates enter a modest-paying field, including teaching, social work or nursing.

He said that question is already part of a national debate.

“I think the question of what is an earnings premium, what’s a sufficient level of earnings, etc., it’s going to be an ongoing question,” Holston said.

The Education Department considered that concern while writing the final rule. Commenters specifically raised fields including education, social work, counseling and health care.

In its [final analysis](https://www.federalregister.gov/documents/2026/07/01/2026-13286/accountability-in-higher-education-and-access-through-demand--driven-workforce-pell-student-tuition?ref=readfoxtalk.com), the department estimated that some undergraduate education and humanities programs would fail at higher rates than under its baseline. It estimated that health-related undergraduate programs, along with business and vocational or technical programs, would fail at lower rates.

Holston said he was not hearing that Colorado colleges planned to retreat from high-demand fields such as nursing.

“The fastest growing programs we have in the state right now are nursing,” he said. “That’s not going to change based on any of the earnings or other kinds of tests.”

The federal rule does not guarantee that any particular Colorado program will pass or fail. The outcome will depend on the earnings data and benchmark calculated for that program.

### Students still need the data

Holston said students already care more about the economic payoff of college, but the information needed to compare programs is still too difficult to find.

“I think from a student perspective, I think one of the benefits of the reorganization is we need to do a better job getting students that data so that if folks are interested, if they’re making choices based on what the earnings outcomes might be for the pathway, it’s an easy thing to find out,” he said.

“Right now, it’s pretty difficult.”

Holston also mentioned Workforce Pell while discussing the growing federal focus on program outcomes. That program is different from the loan accountability system. [Workforce Pell began July 1](https://www.ed.gov/about/news/press-release/us-department-of-education-issues-final-rule-create-new-workforce-pell-grant-program?ref=readfoxtalk.com) and allows eligible students to use Pell Grants for certain short-term workforce programs. Pell Grants are grants, not loans.

The separate earnings-accountability rule can end a low-earning program’s participation in the federal Direct Loan program after repeated failures. Other federal aid, including Pell Grants, can be affected under additional institution-level conditions in the rule.

Most of the final earnings-accountability regulations are scheduled to take effect July 1, 2027\. Before then, the central question for students is the one Holston said Colorado needs to make easier to answer: What do people who finish this program actually earn?