Public Comments: Education Department’s Student Tuition and Transparency System and Earnings Accountability Proposal

In July 2025, the Department of Education announced its intent to establish two negotiated rulemaking committees to prepare regulations necessary to implement the One Big Beautiful Bill Act. One committee, the AHEAD committee, addressed the new “Do No Harm” accountability standard and the Department’s Gainful Employment regulations.

On May 20, 2026, the New America Higher Education program submitted public comments that offer recommendations on ensuring students receive value from enrollment in their academic programs and are not left worse off. Our recommendations focused on the inclusion of undergraduate certificate programs, data transparency, the measurement of earnings and the appeals process, consequences for failing the earnings metric, other guardrails, and warnings and disclosures for students.