Though college presidents are in the middle of graduation season, Philip Dearborn, the head of the Association for Biblical Higher Education, found 21 of them willing to make a last-minute trip to Washington, DC, at the end of April.
In dozens of meetings with lawmakers, they pleaded their case against a new Department of Education regulation they say could crater their programs. The regulation would label a bachelor’s or master’s program a “failure” if its graduates don’t earn more than their peers without the degree.
Students in these “failing” programs would be ineligible for federal financial aid.
The new rule portends a problem in particular for seminaries, theological schools, and Bible colleges at a time when clergy are aging and sometimes in short supply.
By the government’s own estimate, 53 percent of bachelor’s degrees for religion and religious studies would be considered “failing” under this new metric. Those programs, which would not qualify for federal loans, are projected to have the highest failure rate of any undergraduate program.
For master’s degrees, the outlook is especially bleak: The government estimates that 89 percent of religion or religious studies degrees would be considered failing.
“It’s an existential threat to the future of religious higher education in the US—I don’t think that’s an overstatement,” Dearborn told CT. “It came out of left field.”
The Council for Christian Colleges & Universities, representing 170 schools, and The Association of Theological Schools, representing 270 graduate theology schools, are also voicing serious concerns about the regulation.
Dearborn thinks religious education became the unintended target of a regulation designed to rein in certain for-profit programs accused of saddling students with high debt and low-value degrees.
The One Big Beautiful Bill that Congress passed last year included a requirement for an earnings test on undergraduate and graduate programs to determine their eligibility for federal loans. Even as it was being drafted, leaders of Christian colleges voiced concerns.
“An accountability framework that reduces a faith-based school’s value to the future earning potential of graduates will minimize or alter its self-understanding and effectively punish those institutions for advancing a service ethos driven by their religious convictions,” wrote Asbury University president Kevin Brown in a Deseret op-ed in June 2025, before the bill was signed into law.
On April 20, the Education Department released details of the regulation, and the public has a month to comment before the regulation becomes final. As of May 8, the regulation had drawn more than 2,700 comments, a much higher number than other regulations that are in a similar comment period.
One commenter, Linda Adler-Kassner, noted that comparing the median income of an entire demographic to a small college program that may have only a few students didn’t make any sense mathematically. One graduate with low earnings could drag down the whole program.
“It seems to disproportionately impact programs in religious institutions, as well as majors like theater, dance, and music. This reality, as well as the mathematical calculations underscoring the requirement, suggest that smaller programs and programs designed to foster faith-based engagement need different measurement metrics,” Adler-Kassner wrote.
The regulation states that if the program has fewer than 30 graduates, the government will add more graduates’ earnings from other years until it reaches 30 graduates as the minimum.
To evaluate earnings, the federal government would use US Census and International Revenue Service data to compare the median salary of those with undergraduate degrees four years after their graduation to the median salary of those with high school degrees ages 25 to 34. (University administrators contend this comparison is also unfair: A high school graduate who has potentially been in the workforce for 16 years may reasonably be earning more than a college graduate with only four years of experience.)
A program’s graduates who are mostly from the college’s state have to beat the state median, but if they’re from around the country, as is the case with many religious schools, they would have to beat the national median.
For graduate programs, the government would compare the median salaries of master’s degree holders with median salaries of undergraduate degree holders.
If a college program, such as a biblical studies major, flunks the earnings test two years in a row, the government would label it as failing. Biblical studies majors at that school would no longer be eligible for Title IV federal loans, and the college would have to disclose that the program was considered “failing.”
The Education Department did not return a request for comment on the concerns of religious colleges.
“Financial outcomes matter, but they don’t totally measure whether an education is worthwhile,” said David Hoag, president of the Council for Christian Colleges & Universities (CCCU).
Frank Yamada, head of the Association of Theological Schools, recently held a webinar informing its members of the regulation.
“If folks want to get their degrees in these areas, but they’re not eligible for financial aid, it’s going to significantly impact the religious workforce,” Yamada said. “In many Christian traditions now, there are often more job openings or calls available than there are candidates to fill those calls.”
Hoag said the regulation is part of the Trump administration’s reaction to Biden-era student loan forgiveness programs that did little to restrict how loans are distributed in the first place. The CCCU leader is glad that schools now can advise students against borrowing more than they need to, for example. He also thinks schools should be transparent with students about what they are likely to earn in the job market. Some of those numbers are already available on the Obama-era “college scorecard” that shows median earnings for particular schools.
But Hoag added: “One of the other areas that’s targeted is culinary arts. We’re going to have lousy food in the future and fewer people in ministry. Those are not good combinations.”
Music training will be hit hard, too.
Kyle Werner is a faculty member at Manhattan School of Music, which had a series of meetings recently with faculty and staff to warn them about the new policy’s fallout. The school doesn’t have lucrative degrees to balance out its lower-earning arts degrees, he said.
“By five years from now, when all students have come in under the new policies, our school could be facing penalties that amount to about 10 percent of our annual budget, which would be untenable for us,” Werner said in an email.
In the meeting, attendees asked whether the government could measure graduates’ income eight years after graduation instead of four, because musicians often have a longer runway to success. Werner said that was true for him as a composer: He worked for about seven years before securing regular commissions. Before that, he pieced together jobs as a teacher, administrator, and church music director.
“If you looked at my life four years after graduation, the current policies would not deem me a ‘success,’ but if you looked eight years after graduation, things were looking much better,” Werner said.
Pastoral work is not lucrative, either.
Joshua Christy earned a bachelor’s in biblical studies from Anderson University in 2005. When he became the senior pastor of a small church in Missouri in 2011, a part-time job, he earned $225 a week. Under the proposed federal regulation, his post-graduation income would not pass the earnings test. He did not choose his major based on future compensation.
“Learning to study the Bible and minister to a congregation was something I found, and still find, deeply fulfilling and meaningful,” he wrote in an email. “It was never about money, and money has never really interested me as a goal worthy of pursuit.”
Jon-Michael Shelley graduated from Covenant College in 2019 and picked up a ministry internship at a Southern Baptist church in Tennessee where he made $8.50 an hour. He worked as a barista to make ends meet.
“For the first two years out of college, being a barista was more lucrative than my ministry job,” Shelley said. He’s now a youth pastor at an Anglican church in Atlanta.
An earnings test also can’t capture nonmonetary ways churches take care of their workers, such as by offering a parsonage. The Southern Baptist church Shelley interned for after graduation found him a host home where he could live for free.
He graduated with significantly less debt than his friends who attended state schools, he said, which also doesn’t factor into the proposed earnings test of college programs.
Dearborn, who now represents roughly 200 postsecondary schools, is not sure he would have passed the earnings test when he graduated from Lancaster Bible College in 1994 and became an admissions counselor.
Though Dearborn began his career with a humble salary, money was not the reason he earned a Bible degree. He later became the college’s provost.
“God has always provided and been so, so generous,” he said. “And I’m thankful for my college degree.”
It taught him intangible skills like how to relate to people, how to see the world in context of a greater narrative, and how to fulfill commands from the Bible for ministry, he said.
“Churches are going to need leaders and leaders are going to have to be trained,” Dearborn said. “Whether we do it through our current understanding of how it goes, or a new way of thinking, I’m confident the church will rise up and figure it out. It sure would be nice if our government allowed our students to use loan dollars as well as grant dollars.”
– Aaron Morrison contributed data reporting to this piece.
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