Grassroots Action Center
- Graduate programs: Graduates must earn more than median bachelor’s degree holders aged 25–34. For a graduate program, the earnings threshold for an eligible institution is based on data for the median earnings of working adults in the institution’s state, aged 25–34 with only a baccalaureate degree who worked and were not enrolled in an eligible institution at the time earnings were measured. Of note, the earnings threshold for graduate programs will be the lowest of (1) the median earnings of working adults in the state; (2) the median earnings of working adults in the same field of study under the 2-digit or 4-digit Classification of Instructional Programs (CIP) code in the state; or (3) the median earnings of working adults nationally in the same field of study under the 2-digit or 4-digit CIP code.
Here's the problem:
“Do No Harm” evaluates counselor education programs exclusively on graduate earnings 4 years after completion. Programs failing to meet federal earnings benchmarks in 2 of 3 consecutive years lose federal Direct Loan eligibility for 2 years. Once loan eligibility is lost, institutions are typically barred from enrolling new students into those specific programs and risk being placed on provisional status. According to data from the Department of Education, an estimated 60% of Title IV students enrolled in mental and social health services and allied profession programs are at risk of failing this earnings test. Though we agree that Counselors should certainly be paid more and compensated fairly for the critical service they provide to society, we also recognize that society cannot afford to risk having fewer Counselors and that access to federal financial aid is necessary to recruit students into counselor education and other health professional programs. The earnings benchmark punishes programs preparing Counselors for critical public service roles.
The consequences are catastrophic:
- 100,000+ Counseling students lose educational access as programs close or restrict admissions.
- Mental health shortage worsens: We already lack sufficient providers; destroying the Counselor pipeline will create crisis.
- Rural mental health collapse: Rural communities depend on Counselors; program closures eliminate rural access.
- Public service abandoned: School Counselors, Substance Use Counselors, and community mental health providers disappear.
The earnings metric is fundamentally flawed. It ignores that Counselors prevent suicides, help trauma survivors heal, support addiction recovery, and serve vulnerable populations. These outcomes save lives and reduce community costs of untreated mental illness—yet earnings benchmarks cannot measure this value.
Congress must modify “Do No Harm” immediately to incorporate workforce need, public service contribution, and community benefit alongside earnings data.
