Last week, ASPPH joined the American Council on Education (ACE) and other higher education organizations in submitting comments to the U.S. Department of Education on proposed regulations implementing accountability and Workforce Pell provisions under the One Big Beautiful Bill Act (OBBBA). The coalition raised concerns that the proposed earnings-based accountability measures could negatively affect institutions and students, particularly programs preparing graduates for public service and community-based careers. The letter also urged the Department to provide institutions with additional time and flexibility as colleges and universities work to comply with sweeping new federal requirements.

ASPPH joined ACE and a coalition of higher education organizations in raising concerns about proposed Department of Education regulations that would evaluate academic programs using graduate earnings thresholds established under OBBBA. In its comments, the coalition argued that certificate and degree programs should not be assessed using identical earnings benchmarks because graduates pursue different workforce pathways with varying timelines for salary growth and career advancement.

The coalition also challenged the Department’s proposal to potentially remove all Title IV aid eligibility for institutions with large numbers of low-earning programs. The organizations noted that Congress authorized restrictions on Direct Loan eligibility under the legislation, not the loss of all federal student aid eligibility, and warned that broader penalties could create unintended consequences for students and institutions.

For academic public health programs, the proposed accountability framework presents particular concerns because many graduates enter careers in public service, prevention, governmental public health, and community health settings that provide substantial societal value but may not yield high salaries early in graduates’ careers. Public health leaders remain concerned that earnings-based accountability systems could unintentionally disadvantage programs designed to address workforce shortages and population health needs.

The coalition also emphasized the importance of giving institutions adequate implementation time and access to reliable data before new accountability measures take effect, particularly as colleges and universities continue adapting to major federal student aid and reporting changes.

View ASPPH’s full list of Policy & Advocacy Efforts here.