CAP Urges Stronger Accountability Metrics and Greater Transparency in Federally Funded Postsecondary Programs

The Center for American Progress recently urged the U.S. Department of Education to reconsider proposed changes that could weaken safeguards for higher education students. As written, the proposal risks allowing low-value postsecondary programs to continue receiving federal aid, potentially steering students, especially those with limited financial resources, into pathways that fail to deliver meaningful economic returns.

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The Department of Education released a notice of proposed rulemaking in late April outlining changes to institutional eligibility and the direct loan program under Title IV of the Higher Education Act, as amended by the Big Beautiful Bill. The proposed federal rules could reshape which college programs qualify for student aid and whether those programs are actually worth the cost for students. The Department of Education’s plan would loosen key accountability measures, potentially allowing low-value programs to continue accessing federal funding while weakening transparency around student outcomes. For students, especially those relying on financial aid, the changes could make it harder to identify programs that lead to strong earnings and easier to enroll in ones that do not.

In a letter submitted on May 20, 2026, the Center for American Progress commented on the proposed regulations, raising concerns about key elements of the proposal. CAP cautions that the removal of the debt-to-earnings (D/E) metric, increased reliance on a single earnings-based measure, and the limitation of sanctions to direct loans weaken the current accountability framework.

The comments include recommendations to:

Strengthen accountability metrics by:
- Expanding beyond a single earnings-based measure to better capture program quality and student outcomes.
- Reconsider the removal of the D/E metric to preserve a more comprehensive assessment of student debt burden relative to earnings.
Address limitations of earnings-based measures by:
- Incorporating considerations of labor market conditions, including regional wage variation and economic cycles.
- Ensuring metrics do not disproportionately disadvantage programs serving older, part-time, or geographically constrained students.
Reinforce consequences for low-performing programs by:
- Reevaluating the limitation of sanctions to direct loans and considering broader Title IV eligibility implications.
- Reducing the risk that Pell Grant funds support programs with consistently weak earnings outcomes.
Expand the Student Tuition and Transparency System (STATS) to include more comprehensive and disaggregated data.

Click here to read CAP’s comment letter.

The positions of American Progress, and our policy experts, are independent, and the findings and conclusions presented are those of American Progress alone. American Progress would like to acknowledge the many generous supporters who make our work possible.

AUTHOR

Madison Weiss

Senior Policy Analyst, Higher Education

Team

Higher Education Policy

The Higher Education team works toward building an affordable and high-quality higher education system that promotes economic mobility, racial equity, and a strong democracy.