Which graduate programs are exposed under the new earnings rule?

Against a single national bachelor's-holder earnings line of $58,000 to $66,000, 1,804 to 3,593 graduate programs fall below it on the most recent earnings data, out of 11,863 with reported four-year earnings (about 1 in 5 of 62,561; the rest are privacy-suppressed). Treat this as a likely overestimate. The final rule does not hold graduate programs to one national line: each is held to the lowest of three bachelor's-holder figures, and many get a $1 threshold that exempts them. The true count is very likely lower, and we cannot yet say by how much.

This is exposure on the most recent snapshot, not a prediction. The rule fails a program only after two of three consecutive years below its threshold. ED has not published the thresholds; first results are expected in 2027. For scale, ED's own estimate in the final rule is about 3,302 programs failing in the first year across all programs, undergraduate and graduate together, under coverage rules that differ from this page's, so the two figures are not directly comparable.

Exposure by benchmark

Single national line	Grad programs below	Share of grad programs with earnings
$50,000	520	4.4%
$55,000	1,202	10.1%
$58,000 (likely national figure)	1,804	15.2%
$60,000 (likely national figure)	2,273	19.2%
$62,000 (likely national figure)	2,723	23.0%
$64,000 (likely national figure)	3,163	26.7%
$66,000 (likely national figure)	3,593	30.3%
$70,000	4,408	37.2%

Grad-program four-year earnings run higher than undergraduate: median $79,592 (10th percentile $54,926, 75th $106,688). The high-school-graduate benchmark used for undergraduate programs is about $36,082; graduate programs are held to the higher bachelor's-holder line instead.

By credential (at an illustrative $60,000 benchmark)

Credential	With reported earnings	Below benchmark
Master's Degree	9,594	2,120
Doctoral Degree	1,102	41
First Professional Degree	684	26
Graduate/Professional Certificate	366	61
Post-baccalaureate Certificate	117	25

Fields with the most programs below a national $60,000 line

Field of study	Programs below	Median earnings
Teacher Education and Professional Development, Specific Levels and Methods	216	$54,717
Student Counseling and Personnel Services	182	$55,320
Teacher Education and Professional Development, Specific Subject Areas	114	$55,865
Clinical, Counseling and Applied Psychology	112	$54,569
Special Education and Teaching	111	$55,280
Music	108	$47,630
Mental and Social Health Services and Allied Professions	105	$55,401
Social Work	93	$57,587
Curriculum and Instruction	82	$56,291
Education, General	82	$55,406
Sports, Kinesiology, and Physical Education/Fitness	79	$55,054
Educational Administration and Supervision	62	$55,880
Theological and Ministerial Studies	54	$53,233
Fine and Studio Arts	52	$47,468
Communication Disorders Sciences and Services	49	$56,783

Read this list with more caution than anything else on this page. Where the data allows, the rule compares a graduate program with bachelor's holders in the same field, and bachelor's holders in teaching, counseling, social work and the arts also earn modestly. For these fields the real threshold is likely well below $60,000, so many of these programs would pass. The list shows where graduate earnings are low in absolute terms, not which programs will fail.

Method and caveats

Who is counted. Graduate programs (post-baccalaureate certificate, master's, doctoral, first-professional, and graduate certificate) with a reported four-year median earnings figure: 11,863 of 62,561. The rest are privacy-suppressed and never guessed.
What the rule actually compares against. For a graduate program the threshold is Census median earnings of working bachelor's-degree holders aged 25 to 34 who were not enrolled, taking the lowest of three figures: the state where the institution is located, the same field of study in that state, or the same field nationally. National figures replace state ones when most of an institution's students come from out of state. Where same-state, same-field data is too thin, the threshold is set to $1, which ED estimates exempts about 2,650 graduate programs.
What this page applies instead. One figure, a national bachelor's-holder median. NCES puts it at $66,600 for full-time year-round workers (2022), and the rule's broader working population runs lower, hence the $58,000 to $66,000 band. This page does not apply the same-field comparison or the $1 exemption, because the field-level Census figures are not in this dataset. The exemption can only reduce the count, and the field comparison lowers most thresholds, especially in modestly paid fields and lower-earning states. It can raise one in a high-earning state and field, so the range is a likely overestimate rather than a strict ceiling.
The horizon. Earnings are median earnings in the fourth tax year after completing, the same measure the rule uses.
Not a verdict. A program only loses Direct Loan eligibility after failing two of three consecutive years. This is exposure on one recent snapshot, an early-warning picture, not a list of programs that will lose funding.

Reproduce this: graduate rows of value_check.parquet (credential levels 4 to 8) with earnings_median_4yr below the benchmark. Script: pipeline/build_stats_exposure.py. Full method: methodology. Sources: U.S. Department of Education College Scorecard (release 2026-06-10); the final STATS / Earnings Accountability rule (Federal Register, 2026-07-01).

Download the dataset ↓