CSWE Advocacy Update - December 8, 2025

Department of Education Enters Negotiated Rulemaking on Changes in Institutional and Programmatic Accountability Measures

On December 8, the U.S. Department of Education (ED) began its second negotiated rulemaking committee as part of the process for implementing policy changes included in the One Big Beautiful Bill Act (OBBBA). The Accountability in Higher Education and Access through Demand Committee will meet to address the implementation of the new Workforce Pell Grant program, changes in institutional and programmatic accountability measures, including loss of Direct Loan eligibility for certain programs, and Financial Value Transparency and Gainful Employment.

For social workers, institutional and programmatic accountability measures will be of most importance. OBBBA established a “do not harm” standard, which would:
  • “Prohibit new federal student loans from paying for undergraduate degree programs where the majority of former students earn less than the median high school graduate in the same state
  • Prohibit new federal student loans from paying for graduate programs where the majority of former students earn less than the median bachelor’s degree recipient in the same field in the same state
  • Programs lose eligibility if they fail to meet the standard for two years in a three-year period.”

Researchers at the Postsecondary Education & Economics Research Center at American University noted that “fewer than 1 percent of students in [social work] programs, including fewer than one-half of one percent (0.3 percent) of students in master’s degree programs in social work, would fall short of the OBBBA threshold.” Nonetheless, ED still has to finalize the regulations which could determine programs excluded from receiving federal student loans. CSWE will continue to monitor the status of these negotiations. The second session will be scheduled for January 5 through January 9 of 2026.