The Obama administration implemented similar accountability rules, though they differed in scope and metrics from the 2026 earnings-premium standard.
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The Obama-era โgainful employmentโ regulations (first issued in 2011, revised and finalized in 2014, effective 2015) required most for-profit programs and certificate programs at public and nonprofit schools to meet debt-to-earnings tests. A typical graduateโs estimated annual loan payment could not exceed 8 percent of total earnings or 20 percent of discretionary income; repeated failures put a program at risk of losing federal student-aid eligibility, including Direct Loans.
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Those rules applied far more narrowly than the later across-the-board earnings test. They targeted career and vocational programs rather than all degree programs, used debt-service ratios instead of a simple comparison to high-school or bachelorโs-level earnings, and were repealed by the first Trump administration in 2019. A later Biden-era version added an earnings-premium element for covered programs. The core ideaโcutting off federal loan subsidies from programs whose graduates do not earn enough to justify the costโpredates the 2026 rule.