As the son of a minister, I understand very well that people don’t go into ministry for the money — it’s a calling. In raising a family of seven, my dad never earned more than $36,000 a year. This is clearly not a living wage, but he made it work. Never did he wonder if his attending seminary would be a big return on his investment. And yet, the Trump administration is saying that religious education and public service isn’t worth it.

For the first time in statute, the One Big Beautiful Bill Act (OBBBA) introduced an earnings accountability measure that conditions federal student loan eligibility on post-graduation earnings. This earnings test narrowly defines and focuses on wages and is designed to determine whether academic programs provide economic value. And it’s drawing sharp criticism from an unlikely corner: religious colleges and seminaries.

Many college graduates fear they may struggle to pass the earnings test, and the data suggests their fears are not unfounded. But the religious education critique is a window into a much larger problem: when accountability is reduced to a single economic metric, entire fields that prepare students for essential careers, which might be poorly compensated — like teaching, social work, public service, and ministry — are rendered invisible. Colleges should be accountable for their outcomes. But the real question is whether an earnings test alone is sufficient to distinguish between programs that exploit students and programs that prepare them for work our society cannot function without. A more robust accountability system — one that accounts for a measure of debt-to-earnings, upward mobility, and completion rates — would get us much closer to the answer.

The framework, dubbed “do no harm,” requires undergraduate programs to demonstrate that their graduates earn more than a high school diploma holder four years after completing their degrees. For master’s programs, graduates must out-earn people with a bachelor’s degree in a similar field.

Supporters argue that students deserve transparency and protection from programs that consistently leave them with debt and poor outcomes. Critics worry the test reduces the value of education to a paycheck and disadvantages programs that intentionally prepare students for service-oriented careers rather than high-paying professions. Public comments on the proposed rule, which drew more than 10,000 submissions, reflect that tension directly, with religious institutions raising urgent concerns about the consequences for ministry-related programs.

Failing the Earnings Test

The concerns are not unwarranted. According to Education Department data cited by the Council for Christian Colleges and Universities, more than half of undergraduates studying religion or religious studies would fail the earnings test. For master’s programs in religious studies, the failure rate climbs to 90%. While the Education Department has cited lower shares of enrollment in failing programs, nearly 25% for undergraduate 15% for graduate programs, based on two versus four digit CIP codes, it’s clear that the metric will have a disproportionate impact on certain programs.

The president of one evangelical institutions warned: “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.” Maybe he’s right?

The data is stark: failing religious programs carry average loan amounts nearly twice those of passing religious programs, while their graduates earn roughly half the median earnings of graduates from passing programs. In other words, students in these programs are borrowing more and earning less, not because they were misled, but because they made a deliberate choice to pursue a vocation over a paycheck. And that raises a harder question than the earnings test was designed to answer: if students knowingly enter fields that will never make them wealthy — ministry, public service, community leadership — fields that our society depends on but refuses to pay, should they have to take on debt to do it at all? A more honest accountability system would not penalize these programs. It would ask whether we should be subsidizing them, and whether a country serious about religious liberty and civic life can justify building its higher education system on debt while treating a true calling as a financial liability.

The Original Purpose of Colleges

Before higher education in America was preparing software engineers, accountants, or consultants with LinkedIn profiles that read “thought leader,” “innovator,” “disruptor,” and “tech leader,” colleges were largely students for public service and the clergy.

Harvard was founded in 1636 primarily to train Puritan ministers. Yale followed a similar path. Princeton began as a school designed to educate clergy and religious leaders. The College of William and Mary had an Anglican minister as president for 50 years. Baptists, Methodists, Presbyterians, and Quakers all built their own colleges because they believed education was inseparable from faith and moral formation. Early American colleges were not established because colonial leaders desperately needed a workforce pipeline into management consulting. They were founded to prepare individuals for religious and civic leadership.

The same political movement that has made “celebrating our history” a near-religious obligation has advanced a rule that, by its own logic, would have declared Harvard’s founding mission economically insufficient.

Beyond the Clergy

To be fair, religious programs are not the only ones in the crosshairs. As Inside Higher Ed and others have documented, the programs most likely to fail the earnings test are concentrated in religious studies, cultural studies, education, the arts, and public service — fields that produce teachers, social workers, clergy, community organizers, and artists, and programs at the undergraduate certificate level. Most healthcare, STEM, and business programs sail through.

This is not a question of program quality. A seminary producing deeply trained, community-rooted ministers is not a failing program. A social-work program whose graduates serve struggling families is not a failing program. These programs are doing what they were designed to do. The test simply doesn’t measure their value. But the answer is not exemptions. Carving out religious programs opens the door to every other field arguing for special treatment — and that path leads nowhere good. The answer is a more robust accountability system, one with multiple measures. A debt-to-earnings measure, for instance, would capture what matters here: not whether graduates earn a lot, but whether what they earn is sufficient to manage what they borrowed. That is a question worth asking, even for programs we value, because students pursuing a calling should not have to choose between their vocation and financial ruin.

For years, critics of narrow accountability measures argued that economic metrics alone risk overlooking fields that generate social, civic, or community value but do not necessarily produce high salaries. Religious studies and ministry programs are now making precisely that argument. And they may have a point — not because accountability doesn’t matter, but because our accountability systems need to be sophisticated enough to distinguish between programs and institutions that create value that simply doesn’t show up on a W-2.

Teachers rarely top earnings charts. Neither do social workers. Nor public defenders. And certainly, many clergy do not. Yet few would argue these roles lack value to communities, families, or the American story we keep saying we want to celebrate.

Less Earnings, More Debt

There are genuinely good reasons to ask whether some programs leave students with debt they cannot repay, and to demand transparency about outcomes. EdTrust has argued for years that students from low-income backgrounds and students of color deserve rigorous protections from programs that exploit them, accountability in higher education matters. But we should also be asking a harder question: why is our higher education system built on debt in the first place?

Accountability done poorly does not protect students. A blunt earnings test that condemns religious studies and seminary programs while leaving predatory for-profit programs free to operate because their graduates happen to earn slightly more than a high school graduate is wrong. It is producing bad outcomes and calling it progress.

The question is not whether accountability matters. It does. and EdTrust has argued for years that a well-designed accountability system is one of the most important tools we have for protecting students from programs that exploit them and leave them worse off. But accountability done right requires more than a single earnings benchmark. EdTrust has called for a holistic framework that measures whether programs are accessible, affordable, and producing strong outcomes, disaggregated by race and income, with meaningful consequences for programs that consistently fail students, and real investment in institutions committed to equity.

A debt-to-earnings measure, rather than an earnings floor alone, would better capture what matters for students in low-wage vocations: not whether they earn a lot, but whether what they earn is enough to manage what they borrowed. And if we are serious about fields that serve the public good, there are policy options worth debating: restoring and strengthening gainful employment rules that protect students from predatory programs while building in protections for high-value, low-wage fields; pursuing an affordability guarantee that stops loading students with debt for professions that should pay back but don’t; or maybe, clear guardrails for degrees that prepare students for public service and religious life. None of these are a perfect solution. But all of them are more honest than a system that declares a religious education economically insufficient and calls it accountability.

Because if we define educational value only through wages, the earnings test isn’t just coming for religious education. It’s coming for the very idea that education was ever about anything else except money.