The Department of Education's new “Do No Harm” test sounds like something conservatives should cheer. Its premise: if graduates of a certificate or college program don't earn more than high-school diploma holders, then the program is a poor investment, and Washington should stop backing it with student loans.
After decades of soaring tuition and student debt, accountability is overdue. And for many in the MAGA base, anything that sticks it to institutions painted as liberal and elite is bound to be popular. But the department's own projections tell a different story: while four-year degree programs pass the test easily, many blue-collar short-term certificate programs — the kind that have produced generations of small business owners — are likely to fail.
The good news is that Congress can fix this with a single amendment, and it has until 2028 to act. The test measures earnings four years after graduation, a point at which many entrepreneurs are still building their ventures. Consider Linda McMahon, the current Education Secretary. She graduated in 1969 with a French degree, worked as a paralegal, and later faced food stamps and bankruptcy before co-founding what became WWE. At the four-year mark, her earnings would have been negligible, yet her eventual success created billions in value and thousands of jobs.
McMahon, who also ran the Small Business Administration, knows that early-stage business owners often reinvest profits rather than take big salaries. The “Do No Harm” formula doesn't capture business appreciation or dividends. It only looks at wages, missing the full picture of return on investment.
The programs most at risk are those that produce the most entrepreneurs: culinary arts, massage therapy, cosmetology, and arts and design. For cosmetology, which requires a license to practice, more than 90% of programs could fail and close, creating an existential crisis for the profession. That's unfair to workers and to consumers who can't get a haircut from an AI agent.
Why would anyone pursue a certificate that doesn't boost earnings? The same question could be asked of ministers and teachers, who often enter fields for reasons beyond money. Service and fulfillment matter, especially as AI forces us to reconsider the purpose of work. But there's a more practical argument: these programs support the administration's pro-natal agenda. Many graduates are women who use these skills to set their own hours, crucial for raising children when childcare costs are prohibitive.
Early-childhood educators, for example, earn a median of about $27,000. The department's data projects that 77% of students in human-development programs would attend failing schools. That's Kafkaesque: the state requires a credential, sets wages through subsidies, and then punishes the school for producing someone who accepts the wage. As childcare options shrink, more couples may decide they can't afford families.
Congress can avoid this by creating a safe harbor for programs where graduates carry modest debt — under $20,000 median total — and have a track record of repaying it. These programs should still disclose earnings data, but modest earnings with successful repayment shouldn't trigger a lending ban. This isn't a new idea; the department previously used a debt-to-earnings test. Any entrepreneur knows you can't measure return without looking at both return and investment.
Conservatives should embrace this fix. It's about fairness and supporting the small businesses that are the backbone of the economy. Without it, the rule could do real harm to the very people it claims to help.
