What does the federal "Do No Harm" provision mean for Michigan students?
On July 1, the U.S. Department of Education began rolling out an accountability test that aims to hold colleges accountable for the earnings outcomes of their graduates.
The measure uses a "do-no-harm" framework, mandating colleges demonstrate that their graduates earn more than those with only a high school diploma in a comparison group of adults aged 25-34.
The same rule applies to graduate programs, where institutions must show their graduates earn more than bachelor's degree holders.
If a program fails to demonstrate this for two out of three consecutive years, it will lose its ability to participate in federal student loans. Calculations will be released in 2027, and potential aid cutoffs would begin in the 2028-2029 academic year.
"If a program cannot show that it leaves its graduates financially better off than if they had never enrolled, it should not be underwritten by federal taxpayers," said Under Secretary of Education Nicholas Kent
The bar, however, is relatively low. According to 2025 state data, median annual wages for those with a high school diploma are $33,100 five years after graduation.
"The undergrad programs that are affected are those at for-profit colleges, particularly in certificate programs, and then particularly in cosmetology," said Kevin Stange, professor of public policy at the University of Michigan.
According to data from the Education Department, 9,380 Michigan graduates between 2017 and 2018 would fail the earnings test. The vast majority of which are cosmetology and allied health certificate programs, with a few arts undergraduate and master's programs.
Cosmetology at Douglas J Aveda Institute ranks first with 878 graduates, and the allied health certificate program at Ross Medical Education Center-Flint ranks second with 868.
Ryan Fewins-Bliss, Executive Director of the Michigan College Access Network, told CBS News Detroit that many impacted students would be those who aren't necessarily in it for the money, or those pursuing careers that take longer to grow in income.
"The arts — things that just don't have high wages that people go into for reasons other than money, and you could say contribute to the culture of the United States in ways that are not necessarily economic," Fewins-Bliss said. "It also hinges on early earnings, so it's something like four years out, when we know a lot of careers take a while."
Fewins-Bliss said higher education institutions would likely feel the pressure sooner than students, but they do have time to adjust their course if their program is alerted not to meet the threshold after the first year.
"It's a two out of three year window, so the institution has some time," Fewins-Bliss said. "If they hit that threshold in year one, they have some time — two more years — to figure out how to change that process, how to change the cost, the debt, how those things act, so hopefully they don't meet the two out of three year threshold."
If students are met with federal loan ineligibility, Fewins-Bliss said there are a few alternative options, although it's likely the program would just be eliminated.
"They could pay for the program themselves, but most likely institutions would close down programs that were not eligible for federal funds because who can afford to pay full freight for a program that now has been proven that you won't make enough money when you get out of it," Fewins-Bliss said. "Or they could transfer into another program within their institution."
Stange said the policy's added transparency to the higher education landscape may benefit students.
"There are many programs that are just not serving their students well," Stange said. "And the whole point of this policy is to incentivize students to leave those programs or shut down those programs entirely. If it incentivizes those programs to change, that's the whole point of the policy."
The measure comes amid a wave of policies from President Trump's administration cracking down on higher education through initiatives including research funding cuts, loan limits and student visa revocations.
Fewins-Bliss said the rule won't immediately influence how people view higher education as a whole.
"Right now, they can still sign up for classes in their program," Fewins-Bliss said. "They can still get financial aid. Nothing has functionally changed for their day-to-day life today, so I don't think it's going to shake people up until we see these programs actually get shut down."
