Dr. Kristin Blagg
The analysis examines implementation challenges for the "do no harm" standard established under the One Big Beautiful Bill Act, which threatens to revoke federal student loan eligibility for programs whose graduates fail to meet minimum earnings thresholds four years after completion.
The research reveals a fundamental tension in the policy: while the rule aims to hold all federally funded programs accountable, many programs are too small to generate the statistically valid earnings data required for evaluation.
"Even after five years of cohort aggregation, more than half of all programs of study (serving more than 10 percent of all graduates) do not have enough eligible graduates to meet the minimum cohort size for the DNH standard," wrote Dr. Kristin Blagg, a principal research associate at the Urban Institute and author of the report.
The legislation requires at least 30 program graduates to be identified in federal earnings data before a program can be evaluated. This threshold poses particular challenges for specialized programs, graduate certificates, and doctoral degrees, which typically enroll fewer students than undergraduate programs.
The analysis identifies significant geographic disparities in which programs would be subject to the new accountability measures. Programs located in rural areas are least likely to meet the 30-student threshold, even after combining multiple years of graduate cohorts and grouping similar programs together.
While programs in large cities have approximately 95 percent of their graduates represented in fully aggregated data, rural programs fall below 90 percent representation. The most remote rural programs fare worst, with only 79 percent of graduates captured under the broadest aggregation approach examined.
