Proposed Federal Rule Threatens Student Loan Access

A set of rules creating a new accountability standard for higher education programs with low earnings outcomes has been proposed by the US Department of Education (ED). The rules, if formalized, will make a school ineligible for Title IV Higher Education Act (HEA) funds if it fails a do-no-harm test that sets an earnings standard for its graduates. While all postsecondary institutions could face repercussions from these rules if passed, schools in the wellness, somatic, and beauty professions could see significant impacts.

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When the proposed rules were released in January, ABMP immediately called for an exemption for massage therapists and bodyworkers and encouraged ABMP members and schools to submit comments by the March 2 deadline. ABMP is also working with ED and congressional representatives to find a resolution that protects schools and students. 

What Are the Impacts?

The do-no-harm test weighs whether a graduate of a program earns more than an adult with no degree beyond a high school diploma. The intent is to ensure students are not financially worse off after completing a program of study than they would have been without it. If a program fails the earnings test for two out of three award years, the institution will be placed on provisional status and won’t be eligible to participate in the Direct Loan program for two years. Current students will not be impacted; the earliest a school could lose eligibility is July 2028. 

Under the proposed rules, two undergraduate certificate programs that will fail the test are: 

  • Cosmetology and related personal grooming services: 92.5 percent of Title IV students will not meet the standard

  • Somatic bodywork and related therapeutic services: 89 percent of Title IV students will not meet the standard

Flawed measures in the rules will disproportionately harm these schools because of how the professions are structured:

  • Median earnings are compared to other professions without adjusting for wage differences due to gender, age, or racial disparities. 

  • Unreported income (like tips), which makes up a large part of income in these professions, is not accounted for.

  • Regional variation within states is not accounted for (e.g., an MT in Chicago is likely not making the same as one in Woodstock, Illinois).

  • Wage differences between part-time and full-time work is not accounted for, meaning if a practitioner works 25 hours a week, they are compared to the average high school graduate in another profession who works 40-plus hours a week. This is a huge problem in the beauty and wellness professions, where most pros work part time. 

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