I don’t often write about federal higher-education regulation, mostly because it’s the kind of story that dies in committee rooms and trade publications before it ever reaches the people it actually affects. But this one deserves attention, because if it goes through as written, it will hit ministry training and seminary education in this country harder than almost anyone currently discussing it seems to realize.
The Department of Education has been rolling out an accountability framework tied to H.R.1, using what’s being called a “Do No Harm” earnings standard. The mechanics are straightforward on paper: colleges have to demonstrate that graduates of a given program earn more than people with only a high school diploma, measured against a comparison group of adults ages 25 to 34. Programs that fail get cut off from federal student loans. If enough of a school’s students or revenue sit in failing programs, the entire institution can lose access to federal financial aid, including Pell Grants.
Here’s where it gets specific to faith communities. Data from the Council for Christian Colleges and Universities shows the looming earnings test will fail more than half of undergraduates studying religion or religious studies. For master’s-level programs — which is to say, seminary, the actual pipeline through which this country trains its pastors, chaplains, and ministry leaders — the failure rate is worse. Ninety percent of students in religious studies master’s programs don’t clear the bar.
Sit with that for a second, because I don’t think the framers of this rule were thinking about seminaries when they wrote it, and that’s precisely the problem. An earnings test built around “does this credential out-earn a high school diploma” makes a certain kind of sense for, say, a for-profit cosmetology program that saddles someone with debt for a credential that doesn’t translate into a living wage — and it’s worth noting that cosmetology schools are lobbying against this rule for exactly that reason, which tells you the standard is already controversial even in its intended lane. But ministry was never structured around maximizing individual earnings. A pastor serving a congregation of 200 people in a struggling neighborhood, a chaplain working hospital nightshifts, a missionary running a nonprofit — these are vocations built on a value system that explicitly does not optimize for personal income. Measuring them by the same yardstick as a business degree isn’t neutral accountability. It’s applying a market logic to a vocation that has never claimed to operate by market logic, and then punishing it for failing a test it was never trying to pass.
The practical stakes are real and immediate. If seminaries and religious-studies programs lose access to federal loans and Pell Grants, the students most affected won’t be the ones from wealthy congregations who can self-fund a master of divinity. They’ll be exactly the students the ministry pipeline most needs and most struggles to reach already — first-generation college students, students from working-class Black and Latino churches, students called into ministry later in life after a full career elsewhere who don’t have savings sitting around for a theology degree. Restricting federal aid access to seminary education doesn’t shrink the number of people called to ministry. It shrinks the number of people from under-resourced communities who can afford to answer that call.
I want to be careful here not to turn this into a story about persecution, because I don’t think that framing is accurate or useful, and UNJ isn’t in the business of manufacturing grievance where the more honest read is bureaucratic overreach. This isn’t the government targeting Christianity specifically — it’s a regulation written with secular career outcomes in mind, applied uniformly, that happens to devastate religious vocational training as a side effect of not accounting for it. That’s actually the more important story, because it means the fix isn’t a culture-war fight, it’s a technical one: religious and ministry-training programs need either a carve-out in the earnings-comparison methodology or a separate accountability framework built around outcomes that actually apply to vocational ministry — congregational placement rates, ordination completion, chaplaincy employment — rather than raw income comparison to a bachelor’s-in-business graduate.
There’s a version of church-state engagement here that I think gets lost in how polarized that phrase has become. Faith institutions asking the federal government to apply an earnings-outcomes rule sensibly isn’t asking for special treatment or exemption from accountability. Seminaries should be accountable for whether their graduates actually go into ministry, get placed, and serve effectively — that’s a legitimate outcome to measure. They shouldn’t be accountable for whether ministry pays as well as consulting, because nobody enrolling in a Master of Divinity program thinks it will, and treating that as a regulatory failure misunderstands what the credential is for.
The comment period on this rule is still open, which means this is genuinely still a fixable problem rather than a fait accompli. If you’re part of a congregation, a denominational body, or a seminary community, this is worth more than a passing concern — it’s worth an actual comment filed, a call made, a conversation with your representatives about carving ministry training out of a metric that was never built to measure it. Quiet regulatory decisions like this one rarely get undone after they take effect. They mostly get undone, if they get undone at all, before the deadline passes and nobody was paying attention.
— Marcus Hart