The Earnings Thresholds Behind the Federal Accountability Test
The federal earnings test, created by the One Big Beautiful Bill Act and sometimes called the do-no-harm test, measures each undergraduate program against the median earnings of working adults aged 25 to 34 with only a high school diploma in the institution's state. For the program earnings published now, that bar runs from $30,554 in Mississippi to $41,984 in Alaska. Counting graduate programs, which face bachelor's medians, 3,158 programs nationwide fall below the threshold for their credential level.
The rule takes effect July 1, 2027, and no program can lose federal loan eligibility before the award year that begins in July 2028 (Public Law 119-21, section 84001; final rule, 91 FR 40136; first sanctions year at 91 FR 40238). Everything on this page is free to use: the thresholds, the program-level results, and the code.
Terms used on this page
- Earnings threshold
- The median earnings a program's completers must reach, set from Census survey data on working adults aged 25 to 34.
- Low-earning outcome program
- The statute's term for a program whose completers fall below the threshold in two of three years.
- Direct Loan eligibility
- Whether students in the program can borrow federal student loans; this is what a failing program loses.
- ACS 5-year file
- The Census Bureau's American Community Survey, pooled over five years so small states and fields have enough people surveyed. This page uses the 2019 to 2023 file, the latest one ending in the last year of the published earnings.
- Field of study
- A program's subject, grouped by the federal Classification of Instructional Programs (CIP) at its broadest, two-digit level.
- One-dollar threshold
- Where fewer than 16 people in the survey hold a bachelor's degree in a field in a state, the same-field bar is set at $1, so graduate programs there pass at institutions drawing most students from the state.
- In-state-serving institution
- An institution where at least half of students come from its own state; it is measured against the state threshold rather than the national one.
- Title IV completers
- Students who finished the program with federal grants or loans, as the Department counts them.
- PPD:2026
- The Department of Education's January 2026 program performance data file, released for the rulemaking.
- Award year
- The federal aid year, July 1 to June 30.
- Question
- What earnings threshold does a program in each state face under the federal earnings accountability test, and which programs fall below it?
- Who it serves
- Students and families, institutional research and program staff, system offices, state agencies, legislative staff, and researchers.
- Data
- 2019 to 2023 American Community Survey 5-year public microdata; College Scorecard field-of-study file (October 15, 2026) and institution file (November 2, 2026); the Department's PPD:2026 file.
- Downloads
- Thresholds by state; bachelor's thresholds by state and field; every program's result; comparison with PEER Center (all CSV); methodology note (PDF). Free, CC BY 4.0.
- Updated
- Follows each ACS 5-year release and each College Scorecard release.
What earnings threshold does my program face?
Choose a credential level, the institution's state, and whether at least half of its students come from that state. For graduate programs, also choose the field. The answer uses the 2019 to 2023 figures, the survey file ending in the last year of the program earnings published now, with the 2020 to 2024 figure beside it.
The Department decides whether an institution serves mostly in-state students from FAFSA addresses; the program file carries the flag the Department used in its January 2026 estimates. Territories without Census earnings data (American Samoa, Guam, the Northern Mariana Islands, the U.S. Virgin Islands, and the Freely Associated States) have a one-dollar threshold (34 CFR 668.2).
Key numbers
- What is the earnings threshold for undergraduate programs?
- The median earnings of working adults aged 25 to 34 with only a high school diploma in the institution's state: $35,442 nationally, from $30,554 in Mississippi to $41,984 in Alaska, in 2024 dollars. These are the figures from the 2019 to 2023 American Community Survey, the file ending in 2023, the last year of the program earnings the College Scorecard publishes now.
- Which survey years set the threshold?
- The regulation counts adults who worked during the year of the measured earnings (34 CFR 668.2), and the Department's own impact analysis used the 2023 ACS 5-year file (91 FR 40214). The Scorecard's program earnings were measured in 2022 and 2023, so this page uses the 2019 to 2023 file. The College Scorecard has displayed thresholds from the 2020 to 2024 file since October 15, 2026 ($35,678 nationally). The rule does not say which five-year file goes with which earnings years, and the Department calls the pooled file no temporal mismatch (91 FR 40161).
- Which threshold applies to graduate programs?
- The lowest of three bachelor's medians: same state and same field, same state, and national same field. The national bachelor's median is $62,167.
- How many programs fall below the threshold?
- 3,158 of 49,660 programs with published four-year earnings in the College Scorecard, 6.4 percent. They had at least 180,160 federally aided completers in 2024-25, and their 2022-23 and 2023-24 completers borrowed at least $3.0 billion in federal loans.
- What happens to a program below the threshold?
- A program whose completers fall below the threshold in two of three consecutive award years loses Direct Loan eligibility, no earlier than the award year that begins in July 2028 (91 FR 40238).
- When is a graduate threshold set at one dollar?
- When fewer than 16 people in the survey hold a bachelor's degree in the field in the state. That applies to 564 of 1,924 state-and-subject pairs.
How to cite: Rowe, B. (2026). The earnings thresholds behind the federal accountability test. Opportunity Data, version 2026-11-06. https://opportunitydata.org/earnings-accountability-thresholds.html
What is the earnings threshold in each state?
The state thresholds span $11,430. 21 states are below the national figure of $35,442 and 30 are above it. A program whose completers earn a median of $34,000 clears the threshold in 17 states and falls short in 34. Among the 38,150 undergraduate programs with published four-year earnings in the College Scorecard, 1,038 change result depending on whether the state or the national threshold applies.
The earnings threshold for undergraduate programs, by state
Median earnings of working adults aged 25 to 34 with only a high school diploma, 2019 to 2023, in thousands of 2024 dollars. Darker tiles are higher thresholds.
Scroll sideways to see the full map; the table below lists every state.
- Under $33,000 (7 states)
- Mississippi $30,554
- New Mexico $31,084
- Alabama $31,488
- Montana $31,488
- Arkansas $31,802
- Louisiana $32,537
- West Virginia $32,537
- $33,000 to $34,999 (13 states)
- Michigan $33,056
- Georgia $33,414
- North Carolina $33,414
- Florida $33,519
- Kentucky $33,519
- Oklahoma $33,519
- Tennessee $33,519
- Texas $33,519
- Missouri $33,570
- South Carolina $33,570
- Kansas $34,067
- New York $34,636
- Ohio $34,636
- $35,000 to $36,999 (18 states)
- Delaware $35,371
- Indiana $35,563
- Illinois $35,686
- Idaho $35,802
- Oregon $35,802
- Pennsylvania $35,802
- South Dakota $35,802
- Virginia $35,802
- Arizona $35,808
- Nebraska $36,057
- Nevada $36,057
- California $36,664
- Connecticut $36,664
- DC $36,664
- Iowa $36,664
- New Jersey $36,664
- Hawaii $36,735
- North Dakota $36,735
- $37,000 to $38,999 (8 states)
- Wisconsin $37,031
- Maryland $37,114
- Maine $37,155
- Minnesota $37,300
- Utah $37,542
- Vermont $37,542
- Rhode Island $38,188
- Wyoming $38,188
- $39,000 or more (5 states)
- Washington $39,106
- Massachusetts $39,108
- Colorado $39,787
- New Hampshire $41,768
- Alaska $41,984
- Puerto Rico, different survey
- Puerto Rico $16,163
| Jurisdiction | Rank, lowest first | Threshold, 2019 to 2023 | 2020 to 2024, as the Scorecard displays | Difference from national | Same-state bachelor's median | Fields at one dollar |
|---|---|---|---|---|---|---|
| Alabama | =3 | $31,488 | $31,484 | −$3,954 | $51,954 | 12 of 37 |
| Alaska | 51 | $41,984 | $40,610 | +$6,542 | $58,101 | 24 of 37 |
| Arizona | 29 | $35,808 | $36,661 | +$366 | $59,218 | 6 of 37 |
| Arkansas | 5 | $31,802 | $32,399 | −$3,640 | $50,279 | 12 of 37 |
| California | =32 | $36,664 | $36,661 | +$1,222 | $70,870 | 4 of 37 |
| Colorado | 49 | $39,787 | $40,610 | +$4,345 | $67,039 | 5 of 37 |
| Connecticut | =32 | $36,664 | $37,781 | +$1,222 | $70,323 | 7 of 37 |
| Delaware | 21 | $35,371 | $35,534 | −$71 | $59,218 | 20 of 37 |
| District of Columbia | =32 | $36,664 | $38,184 | +$1,222 | $89,215 | 14 of 37 |
| Florida | =11 | $33,519 | $33,516 | −$1,923 | $53,632 | 4 of 37 |
| Georgia | =9 | $33,414 | $33,516 | −$2,028 | $58,664 | 4 of 37 |
| Hawaii | =37 | $36,735 | $36,661 | +$1,293 | $54,997 | 15 of 37 |
| Idaho | =24 | $35,802 | $35,797 | +$360 | $50,976 | 16 of 37 |
| Illinois | 23 | $35,686 | $35,797 | +$244 | $65,635 | 4 of 37 |
| Indiana | 22 | $35,563 | $35,534 | +$121 | $54,997 | 7 of 37 |
| Iowa | =32 | $36,664 | $36,661 | +$1,222 | $55,950 | 10 of 37 |
| Kansas | 18 | $34,067 | $34,216 | −$1,375 | $57,727 | 11 of 37 |
| Kentucky | =11 | $33,519 | $33,516 | −$1,923 | $52,480 | 8 of 37 |
| Louisiana | =6 | $32,537 | $32,488 | −$2,905 | $53,632 | 9 of 37 |
| Maine | 41 | $37,155 | $36,661 | +$1,713 | $52,480 | 20 of 37 |
| Maryland | 40 | $37,114 | $36,731 | +$1,672 | $67,039 | 5 of 37 |
| Massachusetts | 48 | $39,108 | $39,880 | +$3,666 | $73,329 | 4 of 37 |
| Michigan | 8 | $33,056 | $33,411 | −$2,386 | $59,886 | 4 of 37 |
| Minnesota | 42 | $37,300 | $38,184 | +$1,858 | $64,653 | 6 of 37 |
| Mississippi | 1 | $30,554 | $30,550 | −$4,888 | $48,281 | 15 of 37 |
| Missouri | =16 | $33,570 | $35,438 | −$1,872 | $55,950 | 7 of 37 |
| Montana | =3 | $31,488 | $33,516 | −$3,954 | $50,122 | 21 of 37 |
| Nebraska | =30 | $36,057 | $36,549 | +$615 | $55,950 | 14 of 37 |
| Nevada | =30 | $36,057 | $36,549 | +$615 | $53,743 | 15 of 37 |
| New Hampshire | 50 | $41,768 | $41,763 | +$6,326 | $61,926 | 14 of 37 |
| New Jersey | =32 | $36,664 | $36,661 | +$1,222 | $69,274 | 4 of 37 |
| New Mexico | 2 | $31,084 | $30,723 | −$4,358 | $49,986 | 16 of 37 |
| New York | =19 | $34,636 | $34,633 | −$806 | $71,602 | 3 of 37 |
| North Carolina | =9 | $33,414 | $33,516 | −$2,028 | $56,984 | 5 of 37 |
| North Dakota | =37 | $36,735 | $40,610 | +$1,293 | $57,194 | 22 of 37 |
| Ohio | =19 | $34,636 | $35,438 | −$806 | $59,668 | 4 of 37 |
| Oklahoma | =11 | $33,519 | $32,429 | −$1,923 | $52,096 | 11 of 37 |
| Oregon | =24 | $35,802 | $36,549 | +$360 | $59,680 | 7 of 37 |
| Pennsylvania | =24 | $35,802 | $35,797 | +$360 | $61,108 | 3 of 37 |
| Puerto Rico (PRCS) | $16,163 | $16,423 | −$19,279 | $23,624 | 22 of 37 | |
| Rhode Island | =45 | $38,188 | $39,880 | +$2,746 | $58,664 | 18 of 37 |
| South Carolina | =16 | $33,570 | $33,516 | −$1,872 | $52,480 | 8 of 37 |
| South Dakota | =24 | $35,802 | $35,797 | +$360 | $52,553 | 22 of 37 |
| Tennessee | =11 | $33,519 | $34,519 | −$1,923 | $53,712 | 7 of 37 |
| Texas | =11 | $33,519 | $33,516 | −$1,923 | $62,975 | 3 of 37 |
| Utah | =43 | $37,542 | $38,580 | +$2,100 | $56,678 | 7 of 37 |
| Vermont | =43 | $37,542 | $40,610 | +$2,100 | $53,702 | 22 of 37 |
| Virginia | =24 | $35,802 | $36,244 | +$360 | $65,997 | 5 of 37 |
| Washington | 47 | $39,106 | $40,219 | +$3,664 | $73,471 | 6 of 37 |
| West Virginia | =6 | $32,537 | $32,695 | −$2,905 | $48,044 | 20 of 37 |
| Wisconsin | 39 | $37,031 | $37,564 | +$1,589 | $59,668 | 7 of 37 |
| Wyoming | =45 | $38,188 | $37,985 | +$2,746 | $53,339 | 25 of 37 |
| United States | $35,442 | $35,678 | $62,167 | 564 of 1,924 |
The 2019 to 2023 thresholds are computed by Opportunity Data and agree with PEER Center's independent computation within one dollar in 53 of 53 jurisdictions. The 2020 to 2024 column is the College Scorecard's published figure, which the same code reproduces to the dollar in 52 of 52 cases; its final year, 2024, is later than any published program earnings. Between the two files 12 states move by $1,000 or more, from North Dakota (−$3,875) to Alaska (+$1,374), measured as the 2019 to 2023 figure minus the 2020 to 2024 figure. Puerto Rico is from the Puerto Rico Community Survey. American Samoa, Guam, the Northern Mariana Islands, the U.S. Virgin Islands, and the Freely Associated States have no Census earnings data, and the rule assigns one dollar there (34 CFR 668.2, earnings threshold, paragraph (3); 91 FR 40174). "Fields at one dollar" counts the 37 two-digit CIP fields in the Department's crosswalk with fewer than 16 respondents in the state, including fields with none.
How many programs fall below the threshold in each state?
3,158 of 49,660 programs with published earnings, 6.4 percent, fall below the threshold for their credential level. They had at least 180,160 federally aided completers in 2024-25, and their 2022-23 and 2023-24 completers borrowed at least $3.0 billion in federal student loans.
Each program is compared with the threshold for its level, using the state or national column that the Department's out-of-state flag selects for its institution. On the 2020 to 2024 figures the count would be 3,303. The program file names every program with its earnings, threshold, gap, both results, the Department's own January 2026 result, and the student and loan counts.
| State | Programs with published earnings | Below the threshold | Share below | Below on 2020 to 2024 figures | Title IV completers in programs below, 2024-25 | Federal loans of 2022-24 completers in programs below, at least |
|---|---|---|---|---|---|---|
| Alabama | 727 | 25 | 3.4% | 25 | 878 | $12,469,493 |
| Alaska | 78 | 9 | 11.5% | 8 | 193 | $3,952,186 |
| Arizona | 814 | 55 | 6.8% | 57 | 6,704 | $110,700,740 |
| Arkansas | 585 | 41 | 7.0% | 44 | 1,035 | $14,929,573 |
| California | 3,890 | 365 | 9.4% | 367 | 27,872 | $468,379,487 |
| Colorado | 843 | 81 | 9.6% | 90 | 4,067 | $82,940,202 |
| Connecticut | 619 | 23 | 3.7% | 27 | 1,086 | $17,758,036 |
| Delaware | 165 | 9 | 5.5% | 9 | 295 | $3,797,484 |
| District of Columbia | 323 | 6 | 1.9% | 6 | 210 | $3,092,359 |
| Florida | 2,197 | 225 | 10.2% | 227 | 23,284 | $507,085,019 |
| Georgia | 1,337 | 104 | 7.8% | 108 | 4,131 | $71,868,622 |
| Hawaii | 132 | 5 | 3.8% | 4 | 151 | $3,424,349 |
| Idaho | 322 | 24 | 7.5% | 25 | 1,478 | $24,391,476 |
| Illinois | 1,959 | 114 | 5.8% | 118 | 5,810 | $87,674,736 |
| Indiana | 1,111 | 45 | 4.1% | 46 | 1,976 | $44,665,441 |
| Iowa | 784 | 38 | 4.8% | 38 | 996 | $12,047,429 |
| Kansas | 574 | 26 | 4.5% | 27 | 1,610 | $23,149,099 |
| Kentucky | 801 | 38 | 4.7% | 39 | 1,606 | $21,243,233 |
| Louisiana | 690 | 82 | 11.9% | 78 | 4,968 | $104,855,850 |
| Maine | 258 | 15 | 5.8% | 14 | 1,230 | $26,767,144 |
| Maryland | 760 | 40 | 5.3% | 41 | 1,811 | $43,891,502 |
| Massachusetts | 1,592 | 80 | 5.0% | 85 | 2,061 | $23,854,165 |
| Michigan | 1,566 | 74 | 4.7% | 78 | 5,316 | $111,014,150 |
| Minnesota | 1,368 | 55 | 4.0% | 58 | 3,691 | $16,032,154 |
| Mississippi | 498 | 53 | 10.6% | 54 | 936 | $14,904,773 |
| Missouri | 1,187 | 65 | 5.5% | 83 | 2,531 | $40,377,110 |
| Montana | 164 | 5 | 3.0% | 7 | 39 | $1,803,254 |
| Nebraska | 443 | 13 | 2.9% | 17 | 551 | $8,929,122 |
| Nevada | 209 | 13 | 6.2% | 13 | 1,694 | $32,763,844 |
| New Hampshire | 329 | 14 | 4.3% | 14 | 749 | $9,673,994 |
| New Jersey | 1,040 | 53 | 5.1% | 53 | 3,436 | $50,922,534 |
| New Mexico | 268 | 15 | 5.6% | 14 | 616 | $13,187,477 |
| New York | 3,561 | 193 | 5.4% | 195 | 9,659 | $136,120,255 |
| North Carolina | 1,695 | 106 | 6.3% | 116 | 2,348 | $36,693,664 |
| North Dakota | 213 | 6 | 2.8% | 9 | 112 | not published |
| Ohio | 2,053 | 129 | 6.3% | 145 | 5,196 | $105,727,504 |
| Oklahoma | 651 | 42 | 6.5% | 38 | 1,541 | $24,963,014 |
| Oregon | 559 | 36 | 6.4% | 42 | 1,607 | $26,767,833 |
| Pennsylvania | 2,554 | 141 | 5.5% | 142 | 5,874 | $101,220,746 |
| Puerto Rico | 628 | 40 | 6.4% | 41 | 2,248 | $2,595,502 |
| Rhode Island | 304 | 8 | 2.6% | 9 | 145 | $584,829 |
| South Carolina | 746 | 49 | 6.6% | 48 | 2,147 | $52,513,237 |
| South Dakota | 264 | 11 | 4.2% | 11 | 192 | $2,157,682 |
| Tennessee | 1,098 | 91 | 8.3% | 100 | 6,046 | $129,383,940 |
| Texas | 3,081 | 219 | 7.1% | 219 | 18,573 | $229,706,041 |
| Utah | 501 | 47 | 9.4% | 53 | 2,674 | $35,372,222 |
| Vermont | 206 | 12 | 5.8% | 16 | 128 | $1,551,177 |
| Virginia | 1,324 | 87 | 6.6% | 92 | 3,537 | $42,861,225 |
| Washington | 823 | 54 | 6.6% | 62 | 2,489 | $34,362,645 |
| West Virginia | 417 | 20 | 4.8% | 21 | 461 | $9,185,181 |
| Wisconsin | 1,232 | 49 | 4.0% | 62 | 1,184 | $16,966,241 |
| Wyoming | 100 | 8 | 8.0% | 8 | 988 | $6,695,705 |
| All jurisdictions | 49,660 | 3,158 | 6.4% | 3,303 | 180,160 | $3,007,974,680 |
Completers are Title IV completers in award year 2024-25 from the Department's PPD:2026 file; suppressed counts are treated as zero, so the totals are lower bounds. Loans are Stafford and Grad PLUS borrowing by the program's 2022-23 and 2023-24 completers at every institution they attended, the College Scorecard's borrower count times its mean; 1,760 of the 3,158 programs below have no published loan figures, so the loan totals are lower bounds too, and "not published" marks states where none do. Both describe recent students, not the earlier cohorts whose earnings are measured. The total includes 17 programs in 4 territories not listed separately, 0 of them below.
Which earnings threshold applies to which program?
Undergraduate programs, including certificates, are measured against a high-school median. Graduate programs are measured against the lowest of up to three bachelor's medians.
The regulatory definition is "earnings threshold" in 34 CFR 668.2 (91 FR 40281). Table 5.5 of the rule's impact analysis (91 FR 40213) assigns a threshold to each credential level, and the choice between the state column and the national column depends on where the institution's students live. The Department determines that share for the whole institution from the address on each student's most recent FAFSA, using the location of the main campus.
| Credential level | Half or more of students from the state | Fewer than half of students from the state |
|---|---|---|
| Undergraduate certificate, associate's degree, bachelor's degree, post-baccalaureate certificate | In-state high-school median | National high-school median |
| Master's degree, doctoral degree, professional degree, graduate certificate | Lowest of: same-state same-field bachelor's median, same-state bachelor's median, national same-field bachelor's median | Lowest of: national same-field bachelor's median, national bachelor's median |
Source: Table 5.5, "List of Earnings Thresholds used in the Revised Earnings Premium Measure in the Final Regulation," 91 FR 40213. Fields of study are grouped at the 2-digit CIP level (91 FR 40161). All six thresholds count a person as working when wage, salary, or self-employment income for the year is positive, and exclude people enrolled in college (91 FR 40212 to 40214). The survey year follows "the year of the associated measured earnings" (34 CFR 668.2).
What are the bachelor's thresholds for graduate programs?
The national median for working adults aged 25 to 34 with only a bachelor's degree is $62,167. Same-state medians range from $48,044 in West Virginia to $89,215 in the District of Columbia. A graduate program at an in-state-serving institution is measured against the lowest of three figures, and the same-state same-field figure is the lowest in 585 of 1,808 state-by-field cells, the same-state bachelor's median in 402, and the national same-field median in 373.
In the remaining 448 observed cells fewer than 16 survey respondents hold a bachelor's degree in the field in the state, and in another 116 state-and-field combinations there are none. The preamble to the rule reads the regulation to set the same-state same-field threshold to one dollar in those cases (91 FR 40159), and because the graduate threshold is the lowest of three, graduate programs in those fields at in-state-serving institutions pass. Counting both, 564 of 1,924 state-and-field combinations, 29.3 percent, carry a one-dollar threshold, concentrated in small states: Wyoming 25 of 37, Alaska 24 of 37, North Dakota 22 of 37, Puerto Rico 22 of 37, South Dakota 22 of 37, Vermont 22 of 37. The rule's impact analysis used a cutoff of 30 respondents for its own estimates; 643 observed cells fall below 30. Where two candidates tie, the counts above credit the same-state same-field figure first, then the same-state bachelor's median.
| Field of study | Threshold that applies | Respondents | Same state, same field | National, same field | Same state, all fields |
|---|---|---|---|---|---|
| Agricultural and related sciences | $54,997 | 121 | $63,552 | $55,950 | $54,997 |
| Natural resources and conservation | $54,997 | 54 | $61,453 | $55,866 | $54,997 |
| Architecture and related services | $54,997 | 25 | $55,531 | $67,039 | $54,997 |
| Area, ethnic, cultural, gender and group studies | $1a | 9 | $56,953 | $52,480 | $54,997 |
| Communication and journalism | $49,733 | 370 | $49,733 | $61,108 | $54,997 |
| Communications technologies | $37,886 | 38 | $37,886 | $49,733 | $54,997 |
| Computer and information sciences | $54,997 | 401 | $68,224 | $85,551 | $54,997 |
| Culinary, entertainment and personal services | $1a | 9 | $40,934 | $43,517 | $54,997 |
| Education | $47,735 | 879 | $47,735 | $48,887 | $54,997 |
| Engineering | $54,997 | 580 | $89,386 | $90,503 | $54,997 |
| Engineering technologies | $54,997 | 142 | $79,440 | $75,843 | $54,997 |
| Foreign languages and linguistics | $49,330 | 69 | $52,186 | $49,330 | $54,997 |
| Family and consumer sciences | $45,922 | 56 | $49,162 | $45,922 | $54,997 |
| Legal professions and studies | $1a | 13 | $50,279 | $55,308 | $54,997 |
| English language and literature | $42,458 | 162 | $42,458 | $50,279 | $54,997 |
| Liberal arts and general studies | $46,927 | 159 | $46,927 | $48,887 | $54,997 |
| Biological and biomedical sciences | $53,632 | 267 | $53,632 | $56,089 | $54,997 |
| Mathematics and statistics | $54,997 | 56 | $61,108 | $73,329 | $54,997 |
| Multi/interdisciplinary studies | $41,768 | 53 | $41,768 | $55,866 | $54,997 |
| Parks, recreation, fitness and kinesiology | $50,279 | 238 | $50,279 | $52,480 | $54,997 |
| Philosophy and religious studies | $54,997 | 33 | $59,668 | $55,866 | $54,997 |
| Theology and religious vocations | $44,633 | 83 | $44,633 | $47,231 | $54,997 |
| Physical sciences | $54,997 | 152 | $60,876 | $62,056 | $54,997 |
| Science technologies | $1a | 3 | $30,438 | $67,219 | $54,997 |
| Psychology | $48,380 | 326 | $48,380 | $50,122 | $54,997 |
| Homeland security, law enforcement and firefighting | $52,480 | 245 | $52,480 | $55,866 | $54,997 |
| Public administration and social service | $42,458 | 126 | $42,458 | $47,735 | $54,997 |
| Social sciences | $49,733 | 270 | $49,733 | $65,635 | $54,997 |
| Construction trades | $54,997 | 45 | $80,816 | $84,546 | $54,997 |
| Mechanic and repair technologies | $1a | 3 | $50,122 | $54,997 | $54,997 |
| Transportation and materials moving | $54,997 | 36 | $77,569 | $77,569 | $54,997 |
| Visual and performing arts | $43,998 | 433 | $43,998 | $48,887 | $54,997 |
| Health professions | $54,997 | 876 | $59,827 | $64,653 | $54,997 |
| Business, management and marketing | $54,997 | 1471 | $61,453 | $69,051 | $54,997 |
| History | $48,929 | 82 | $48,929 | $55,866 | $54,997 |
Computed by Opportunity Data from the 2019 to 2023 ACS 5-year public microdata under the final rule's definitions, in 2024 dollars. Fields follow the Department's crosswalk from ACS degree fields to 2-digit CIP codes (PPD:2026 technical appendix, Appendix Table 1). a. Fewer than 16 survey respondents in the state and field; the rule sets the threshold at $1. The same-state same-field column still shows the computed median for reference. The threshold that applies is the lowest of the three candidates.
How do these figures compare with the Department's and PEER Center's?
Two independent computations of the 2019 to 2023 thresholds agree: this page and PEER Center's agree within one dollar for every high-school threshold, and for 1,810 of 2,014 graduate thresholds. The Department has published six sets of thresholds; PEER Center finds that five depart from the rule's method in the working definition, the data file, or the dollar adjustment, and the sixth is on the 2020 to 2024 file.
PEER Center published its thresholds and code on November 6, 2026 (The Fine Print: A Guide to Calculating Earnings Thresholds). Its national high-school figure is $35,442.40; the figure here is $35,442. The 204 graduate thresholds that differ by a dollar or more all come from one choice: PEER adds Puerto Rico to the national bachelor's medians, while this page leaves Puerto Rico out of every national figure, as the Department does for the national high-school figure. With Puerto Rico added, all 204 of them match. Both computations average the two middle people when survey weights split exactly in half.
| Release | Survey years | Who counts as working | National high-school figure |
|---|---|---|---|
| FAFSA lower-earnings indicator, December 7, 2025 | 2015 to 2019 and 2016 to 2020, averaged | Employed at the survey date; wages only | $35,490 |
| PPD:2026 program performance data, December 2025 (replaced January 2, 2026) | 2019 to 2023 | Employed at the survey date | $34,808 |
| FAFSA lower-earnings indicator, March 23, 2026 | 2019 to 2023 | Positive earnings | $34,635 |
| College Scorecard, March 23, 2026 | 2019 to 2023 | Positive earnings | $32,842 |
| College Scorecard, June 10, 2026 | 2019 to 2023 | Employed at the survey date | $36,082 |
| College Scorecard, October 15, 2026 (current display) | 2020 to 2024 | Positive earnings | $35,678 |
| PEER Center, November 6, 2026 | 2019 to 2023 | Positive earnings | $35,442.40 |
| This page | 2019 to 2023 | Positive earnings | $35,442 |
Release dates, survey years, definitions, and values as published, from PEER Center's release comparison table (November 6, 2026), which also documents each release's dollar adjustment. PEER reports that the PPD:2026 file and the March 2026 releases used an IPUMS version of the 2019 to 2023 file posted before IPUMS corrected its inflation adjustment on March 18, 2026. The final rule counts a person as working when earnings are positive, including people unemployed at the survey date (91 FR 40212, footnote 58).
| Check | Result |
|---|---|
| High-school thresholds, 2019 to 2023, within $1 of PEER Center | 53 of 53 |
| Graduate thresholds, 2019 to 2023, within $1 of PEER Center | 1,810 of 2,014 |
| High-school thresholds, 2020 to 2024, matching the College Scorecard to the dollar | 52 of 52 |
| Programs where this page and the Department's January 2026 result agree | 99.35% of 49,264 |
| The same agreement on the 2020 to 2024 figures | 99.10% |
| Programs below here that the Department's estimate passes; the reverse | 306; 14 |
Program earnings are identical in the College Scorecard and the Department's file, so every difference in program results comes from the thresholds. The Department's January figures run about 0.9 percent below this computation on average and none of its 51 state figures matches to the dollar, consistent with the IPUMS inflation error PEER Center documents and with the employment condition in that file.
The same median completer earnings of $34,000 pass in 17 states and fall short in 34. State thresholds track local wage levels, which is how the statute is built, and the same design produces different results for identical earnings. Six Department releases in under a year each used a different method, and the Scorecard now displays 2020 to 2024 thresholds beside earnings measured in 2022 and 2023: on those figures, 36 states, not 34, put a $34,000 median below the bar. The Department's first official calculation in 2027 will use a later survey file than either, so these are the current figures, not the final ones.
How to read these numbers
- Computed and published are labeled separately. The 2019 to 2023 thresholds are an Opportunity Data computation, confirmed by PEER Center's independent one; they are not official. The 2020 to 2024 high-school figures are the Department's published Scorecard values.
- The survey years follow the earnings, as a choice. The regulation counts adults who worked during the year of the measured earnings but does not say which five-year file pairs with which earnings years. The published program earnings were measured in 2022 and 2023, so this page applies the file ending in 2023, as the Department's impact analysis did (91 FR 40214); the 2020 to 2024 results are shown throughout. The first official calculation, in 2027, measures tax year 2025 earnings and will use a later file.
- Which column applies is the Department's determination. The share of an institution's students from its state comes from FAFSA addresses. The PPD:2026 data file reports the flag the Department used in its estimates, built from 2017-18 and 2018-19 enrollees; the official determination uses the award year being evaluated. Under the regulatory text an institution is measured against the national thresholds when fewer than 50 percent of its students are from its state (34 CFR 668.2); the rule's Table 5.5 labels the split as less than 50 percent and 50 percent or more from out of state, which differs only at exactly 50 percent.
- Fields follow the Department's crosswalk. The ACS records field of degree in its own codes. The Department maps 37 ACS degree fields to 2-digit CIP codes (PPD:2026 technical appendix, Appendix Table 1), and this page uses that table.
- Small cells are noisy before they are small enough to drop. A cell with 16 to 29 respondents has a threshold under the rule but rests on few observations. Both the 16 and the 30 flags are in the data file.
- A threshold is not a determination. A program loses Direct Loan eligibility only after falling below its threshold in two of three consecutive award years, measured on cohorts the Department assembles and pools.
Versioning and next validation
Version 2026-11-06. Thresholds: ACS and Puerto Rico Community Survey 2019 to 2023 5-year public microdata in 2024 dollars (CPI-U annual average, 2024 over 2023), with the 2020 to 2024 file for comparison. Programs: College Scorecard field-of-study file of October 15, 2026 and institution file of November 2, 2026. Department data: PPD:2026 (out-of-state flag, January 2026 result, Title IV completers). Compared with PEER Center's thresholds on November 6, 2026. The November 5 version applied the 2020 to 2024 figures; this version applies the 2019 to 2023 figures, the file ending in the last earnings year, which moves the national count from 3,303 to 3,158. Data files are dated and are not overwritten. The next validation is the threshold the Department applies in its first official calculation in 2027. Opportunity Data is an independent research platform; this analysis was produced without external funding or client sponsorship.
Data, code, and methods
Read the methodology note (PDF)
Data files (CSV, free, CC BY 4.0): thresholds by state, 2019 to 2023; bachelor's thresholds by state and field, 2019 to 2023; thresholds by state, 2020 to 2024, with the Scorecard replication; bachelor's thresholds by state and field, 2020 to 2024; every program's result; counts by state, credential level, and sector; cell-by-cell comparison with PEER Center. Code (Python): thresholds from the Census API; program screen; PEER comparison. Sources: Public Law 119-21; final rule, 91 FR 40136; College Scorecard data; ACS public use microdata; PEER Center thresholds.
Rowe, B. (2026, November). The earnings thresholds behind the federal accountability test. Opportunity Data. https://opportunitydata.org/earnings-accountability-thresholds.html