College Earnings — What the OBBBA Test Reveals

Headline numbers

Why some fails lose aid and most don’t

Under OBBBA, the earnings test is published for essentially every degree program with enough Title-IV completers to be tested. But the Title-IV-loss consequence — what makes a failing program AT RISK of closure — only attaches to the subset covered by the Gainful Employment rule. GE has always covered:

• All programs at for-profit institutions.
• Non-degree / certificate programs at any institution.

This dataset only carries Bachelor’s and Associate’s degrees, so the GE cohort here is essentially “for-profits.” That’s why the AT-RISK set (98 programs at 67 institutions) skews so heavily to Full Sail, LA Film School, Miller-Motte, Platt College, and other for-profits — while public and private-nonprofit failing programs (Johns Hopkins Music, UMass Anthropology, Berea Biology) show as FAIL but not AT RISK.

The OBBBA cliff — programs a rulemaking tweak away from AT RISK

56 programs currently pass the OBBB-aligned GE test but by less than $2,000 above the same-state HS-graduate benchmark. These are the programs next in line for Title-IV loss under two plausible scenarios:

1. Wage growth pushes the HS benchmark up. The benchmark is recomputed each cycle from HS-graduate earnings; a normal wage cycle can move it $500-$1,500 in a year.
2. The rule shifts from state to metro-area comparisons. Many currently-passing programs at urban campuses benefit from state HS medians that include lower-earning rural areas. An NYC-area program compared against NYC-metro HS earnings (much higher than statewide) would see its pass margin evaporate. A shift like this is exactly what a follow-on rulemaking cycle would consider first.

Total students in currently-cliff programs: 4,510.

Threshold: gap < $2,000 above the same-state HS benchmark, currently passing under OBBB-aligned GE. Sorted by gap ascending — smallest margin first, i.e., closest to the cliff.

By institution type

Of the 585 institutions with at least one failing program, how do they split across public, private-nonprofit, and for-profit? And where do the completers-in-failing-programs actually concentrate?

Read: for-profits are the smallest slice by institution count but concentrate a disproportionate share of the completers-in-failing-programs — a single for-profit like Ultimate Medical Academy can put thousands of completers in a failing program. Publics have the most institutions in the failing set (community colleges + regional publics), and the private-nonprofit share is dominated by a mix of small arts / religious / liberal-arts schools.

Where the completers are — top schools by completers-in-failing-programs

Ranked by the number of students who completed a currently-failing program at each school (from the earnings-test cohort). This is the completers-weighted concentration view: a school with 3 failing programs and 5,000 completers matters more than one with 10 fails and 200 completers.

Religious institutions with failing programs

17 institutions flagged as religious (Carnegie Basic 24 Faith-Related, plus name-pattern match on seminary / theological / bible / yeshiva / divinity / rabbinical / talmudical / pontifical / mesivta). Most fail on their single primary program, which is the intended offering — loss of Title IV eligibility on their sole program would functionally end the institution as a Title IV recipient.

US News Top 100 with failing programs

22 schools with a numeric US News rank of 100 or better (both National Universities and National Liberal Arts Colleges) that have at least one failing program. Zero of these are OBBBA AT-RISK — the failing programs underperform the state-HS earnings bar but do not trigger Title IV loss. Still, it’s striking to see who’s here: the pattern is overwhelmingly Music, Drama, Fine Arts, and a scattering of humanities and social sciences.

R1 research universities with failing programs (not already in US News Top 100)

Carnegie R1 (Doctoral / Very High Research Activity) is a peer-reviewed research- intensity classification independent of US News. 3 R1 schools outside the US News Top 100 have at least one failing program — typically regional flagship publics with strong overall standing but a specific professional/arts program that underperforms the earnings test.

Fragility × earnings — the doubly-precarious cohort

Orbuculum-native cross-tab. Every school with at least one failing program that also carries an Orbuculum fragility score in the moderate or high band. High-fragility schools lose meaningful revenue if a program closes; the intersection with the failing / AT-RISK set surfaces the schools where the combination of financial pressure and program-level failure could compound. Sorted with high-fragility first, then by composite score descending.

Pell × earnings — the equity story

Pell-heavy institutions attract low-income students seeking a wage lift via credentials. When those same schools run programs that don’t clear the HS-graduate earnings bar four years post-completion, the credential isn’t delivering what the student came for. And when the OBBBA rule pulls Title IV from an AT-RISK program at a high-Pell school, the students who most needed federal aid to attend are the ones who lose access.

High-Pell schools (≥60% UG on Pell) with any failing program

AT-RISK programs — sorted by school Pell share

Every AT-RISK institution with a Pell % on file, sorted highest Pell first. This is the cohort where the OBBBA aid-loss consequence hits low-income students most directly.

Most-common failed majors — two views

Two definitions of “most common”: by program count (how many schools run a failing version of this major) vs by completers (how many students are affected across the sector).

Traditional Majors Under Threat of Extinction

The subset of failing majors that correspond to the traditional Amherst/Williams-style liberal arts curriculum — humanities, arts, social sciences, and non-professional natural sciences. Sorted by completers to show which disciplines are broadly failing the earnings-vs-HS test at scale.

Filter (CIP-4 whitelist): English, Rhetoric, Foreign Languages, Philosophy, Religion (academic), History, Liberal Arts general, Fine Arts, Music, Drama, Dance, Visual & Performing Arts general, Psychology, Anthropology, Archaeology, Sociology, Social Sciences (general and other), Biology, Zoology. Excludes: business, teaching, health services, applied arts, seminary training, computer science, engineering.

State benchmarks — context

The earnings test compares program graduates to the same-state high-school-graduate earnings median. That benchmark varies from $15,979 (US territories) to $41,356 (Alaska). A “pass” margin means very different things in different states: a program passing by $9K in Puerto Rico ($15,979 bar) is not the same signal as a program passing by $9K in New Hampshire ($40,791 bar). Sorted low-to-high.