A new accountability rule under OB3 measures every program at every degree level by graduate earnings, with the first measurement drawn from the pandemic shutdown of live performance. We have one window to push back. It closes May 20.
Submit button opens the official federal comment form for Docket ED-2026-OPE-0100-0001 at regulations.gov. We do not collect or store your information.
The Issue
The proposed rule, officially titled the Student Tuition and Transparency System (STATS) and Earnings Accountability framework, implements OB3's "do no harm" mandate. It replaces the existing Debt-to-Earnings rate with a new "Earnings Premium" metric applied to every program at every degree level. Programs that fall below the threshold risk losing access to federal student aid, which is the lifeline most performing arts students rely on to enroll. Final rule is set to take effect July 1, 2026.
Every program at every credential level must clear the median earnings of the next-lower credential. Associate's and bachelor's programs are compared to typical high school graduates. Master's, MFA, doctoral, and professional programs are compared to typical bachelor's degree holders. Programs that fall short in two of three measurement years lose Title IV federal aid eligibility.
The initial assessment uses earnings from graduates who entered the workforce during or just after the COVID-19 shutdown, when live performance employment fell more than 50 percent. That measurement becomes the foundation of a permanent rule.
Because every degree level is held to the next-lower credential's earnings, MFA, MM, DMA, and other graduate performing arts programs face an even higher bar than undergraduate programs. Talented students from working and middle-class families lose the only realistic path into advanced training.
Why It Matters
Theaters closed. Tours canceled. Concert halls went dark. Dance companies shuttered. Opera companies furloughed their entire rosters. From March 2020 forward, the live performing arts experienced the deepest and longest employment collapse of any major U.S. industry. Our graduates did not enter a slow market. They entered a profession that had been told, by public health necessity, to go silent.
Using the earnings of those graduates as the foundation of a permanent accountability rule does not measure program quality. It measures a global crisis. Recovery in live performance is still ongoing in 2026. A snapshot taken in 2021 cannot fairly represent the long term value or trajectory of an arts education, and it cannot represent the worth of the artists who chose to keep training during the hardest years our field has ever faced.
Theater, dance, music, and opera produce educators, civic leaders, healers, storytellers, and cultural stewards. None of that shows up on a wage report.
Even setting the pandemic aside, the premise of judging arts programs by early-career income breaks with how the arts function in society and with why students, families, and institutions invest in artistic training. The earnings horizon for performing artists is long. Careers are built through residencies, fellowships, freelance work, ensemble membership, and nonprofit leadership roles that rarely yield high W-2 income in the first three to five years after graduation.
The tiered structure of the Earnings Premium test makes the problem worse. Every program at every credential level must clear the median earnings of the next-lower credential. That means bachelor's programs are compared to typical high school graduates, while MFA, MM, DMA, and other graduate-level performing arts programs are compared to typical bachelor's degree holders, a benchmark pulled up by graduates of finance, technology, engineering, and other high-paying industries. Holding terminal degrees in the arts to that benchmark in the early-career window is a near-automatic failure, regardless of program quality, regardless of the careers our graduates actually go on to build.
A performing arts education also develops the precise skills that drive value across the broader economy: collaboration, communication, creative problem solving, project management, public speaking, leadership, and the ability to perform under pressure. To reduce the worth of an arts education to a single income figure is to abandon a value-based investment in the arts that has shaped American higher education for more than a century.
We do not measure social workers by their salaries. We do not measure teachers by their tax returns. We should not measure performing artists that way either.
Take Action
Federal rulemaking responds to the volume, specificity, and credibility of public comment. Every submission becomes part of the public record. Silence becomes part of the record too.
Use the template below or write your own. Submit through the official Department of Education docket on regulations.gov.
Open the federal docket →Send the toolkit below to faculty, alumni, students, parents, donors, and community partners. Make it simple to participate.
Get the toolkit →Loop in national partners across theater, dance, music, and opera so our voice is unified and unmistakable.
See partner organizations →Comment Template
This template is a starting point. The most effective comments include your name, role, institution, and at least one specific story about your program or graduates. Personalize before you submit.
Comments are public. Use your real name and affiliation. Edit the bracketed fields and add a personal story if you can. Specificity matters more than length.
Organizer Toolkit
Open any card to see the full content. Copy what you need. Share it through email, text, social media, and faculty meetings.
A direct message asking colleagues to comment, with full context.
A personal ask to graduates with full context on the rule.
For families and supporters who care about access.
For Facebook, LinkedIn, or substantive posts.
Punchy version with the essential ask.
For faculty meetings, dean conversations, board updates.
For local papers, alumni magazines, professional publications.
For studio bulletin boards, group chats, classes.
National Partners
Speak with your discipline's national leadership before submitting. Coalitions amplify volume and signal credibility to federal rulemakers. Suggested partners across the performing arts include:
If you have a partner organization to add, please contact us using the link in the footer.
Frequently Asked
Anyone. U.S. citizens and non-citizens, individuals, students, faculty, alumni, parents, donors, community members, and organizations. There is no eligibility test. The federal record values volume, specificity, and credibility.
No. Public comments submitted to the federal docket become part of the public record. Use your real name and affiliation. This adds credibility and weight.
Specificity matters more than length. A focused comment of 300 to 600 words with a personal story is more effective than a generic two-page essay. The template above is roughly 450 words and is meant to be personalized, not submitted verbatim.
Yes, but they carry less weight. Federal rulemakers can identify form letters and treat them as a single voice. Personalization (your name, role, institution, story) makes your comment count more.
OB3 is shorthand for the One Big Beautiful Bill Act. Its "do no harm" provisions direct the U.S. Department of Education to assess academic programs based on graduate earnings outcomes, with consequences (including loss of federal student aid eligibility) for programs that fall below defined thresholds. The implementing rule is officially titled Accountability in Higher Education and Access Through Demand-Driven Workforce Pell: Student Tuition and Transparency System (STATS) and Earnings Accountability. It was published in the Federal Register on April 20, 2026, and the public comment window closes May 20, 2026. The final rule is scheduled to take effect July 1, 2026.
The proposed rule replaces the existing Debt-to-Earnings (D/E) rate with a tiered "Earnings Premium" test applied to every credential level. Associate's and bachelor's programs must produce graduates whose median earnings exceed those of a typical high school graduate. Master's, MFA, doctoral, and professional programs must produce graduates whose median earnings exceed those of a typical bachelor's degree holder. Programs that fall short in two of three measurement years are flagged as failing and lose Title IV federal student aid eligibility. Performing arts programs are uniquely vulnerable because careers build slowly across multiple income streams, and the metric measures only early-career W-2 income. Graduate-level programs (MFA, MM, DMA) face an especially steep bar, since the bachelor's-holder benchmark is pulled up by high earners from finance, technology, engineering, and other fields.
Directly to the federal docket on regulations.gov. Every "Submit Your Comment" button on this site goes straight to the comment form at regulations.gov/commenton/ED-2026-OPE-0100-0001. The docket ID is ED-2026-OPE-0100-0001. The Federal Register document number is 2026-07666.
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Contact The Organizer
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Five minutes. One submission. Multiplied across our field, this is how the rule changes.