New York college programs face a federal earnings test tied to one key figure: $30,793. That is the median annual income for New Yorkers ages 25 to 34 who completed high school but did not attend college, according to the Census Bureau’s 2022 American Community Survey. The U.S. Department of Education published the figure in the Federal Register on the final day of 2024.

Under the new accountability rules, a New York undergraduate program passes if its typical graduate earns more than $30,793 annually. A program that falls below the threshold in two of three years can lose access to federal student loans. Continued underperformance can also put Pell Grant eligibility at risk.

The threshold offers important context for students comparing college programs. New York’s benchmark is below the national figure of $31,269. It also equals about $14.80 an hour for a full-time worker, less than the $34,320 earned annually by a full-time minimum-wage worker in New York City.

Students should therefore treat the federal earnings test as a warning signal, not a quality seal. Before enrolling, compare a program’s typical graduate earnings with its total cost, graduation rate, debt levels, and employment outcomes. Meeting the federal standard shows only that a program cleared a minimum accountability requirement. It does not prove that the program delivers strong value or career preparation.

What the test measures, and what it stopped measuring

The Department's 2023 Financial Value Transparency and Gainful Employment rule, effective July 2024, applied a debt-to-earnings test and an earnings premium test to roughly 32,000 programs, mostly at for-profit institutions and mostly certificates. The 2025 reconciliation law, Public Law 119-21, then built something far wider, and the Department published its final rule on July 1, 2026.

The new structure reaches every program at every institution that takes federal aid, which pulls SUNY and CUNY inside an accountability perimeter they had largely sat outside. It also drops the debt half of the equation. When the general effective date arrives on July 1, 2027, the debt-to-earnings ratio is retired and a single earnings premium test remains, which means the borrowing side of academic return on investment becomes a calculation families run for themselves.

Graduate programs face a steeper comparison, measured against what a working adult aged 25 to 34 with only a bachelor's degree earns. That matters more in New York than in most states. The Office of the State Comptroller reported that New York graduate students borrowed $2.9 billion in federal loans in 2022-23, more than the $2.5 billion borrowed by the state's undergraduates.

Nobody will see a score until 2027

Secretary of Education Nicholas Kent outlined the rule in the Department's announcement by saying that if a program "cannot show that it leaves its graduates financially better off than if they had never enrolled, it should not be underwritten by federal taxpayers."

Amendments to the Direct Loan regulations took effect on August 31, 2026. The Department says it intends to publish data derived from the reporting in 2027. The first earnings premium measures land in the 2027-28 cycle, and the earliest a program could actually lose loan eligibility is 2028. Every student enrolling this fall is choosing without the data the rule was written to produce.

The first calculation will also be looking a long way back. According to the Higher Learning Commission's account of the mechanics, the initial measures use 2025 earnings for students who completed their programs in the 2020-21 award year, a cohort that entered the workforce during the pandemic.

The floor is deliberately low

Christopher Madaio, a senior adviser at the Institute for College Access and Success, told NPR: "This is really a very low floor. I mean, high school earnings is not an exceedingly high metric for a program to meet."

Inside Higher Ed's analysis of the Department's modeling found roughly 825,000 students enrolled in programs that would fail, with about 18 percent of undergraduate certificate programs falling short against 6 percent of associate degree programs, 4 percent of master's programs and roughly 1 percent of bachelor's programs. Bachelor's programs in music failed at 14 percent.

Doug Dempster, president of the Strategic National Arts Alumni Project, told NPR: "We don't know how many artists we need, but I can guarantee that if you eliminate access, we will impoverish our cultural life nationally." His colleague Lee Ann Scotto Adams put the objection in six words: "Earnings is only a small piece of that puzzle."

New York's own wage data, and how old it is

A SUNY Office of Institutional Research study released in June 2020, built on New York State Department of Labor wage records for graduates employed in the state, put median wages two years after graduation at $38,377 for undergraduate certificates, $42,123 for associate degrees, $56,631 for baccalaureate degrees and $67,498 for master's degrees, with an overall median of $43,139. Every one of those medians clears $30,793 comfortably.

The report is six years old and predates both the pandemic labor market and the current threshold, so it forecasts nothing. It does establish that the programs New York's public systems run at scale are not the programs the federal test was built to catch.

SUNY Reconnect and CUNY Reconnect cover tuition, fees, books and supplies for adults aged 25 to 55 pursuing associate degrees in high-demand fields including nursing and allied health, advanced manufacturing, cybersecurity, engineering and green energy, with air traffic control, emergency management and supply chain added for 2026-27. Governor Kathy Hochul's office reported more than 12,000 enrollments statewide since the fall 2025 launch. Associate degrees in workforce fields are the credential tier with the lowest projected failure rate outside the bachelor's degree.

Enrollment is climbing alongside it. SUNY reported fall 2025 enrollment up 2.9 percent year over year and community college enrollment up 5 percent, while CUNY reported roughly 247,000 students, a 3.8 percent increase.

Two out of five institutions have not filed the data

Inside Higher Ed's August 19 analysis of the Department's own file found that of more than 4,640 institutions with eligible programs, about 1,930 were missing or underreporting required data, and 578 had submitted none of the seven required files. More than 492,600 undergraduates attend institutions in that last group, including over 283,000 at community colleges.

The Department's electronic announcement is blunt about what follows: "The Department will not grant further extensions to submit data for the 2024, 2025, or 2026 reporting cycles," with fines and sanctions on the table for institutions that miss the October 1, 2026 and January 15, 2027 deadlines.

Karen McCarthy, vice president of federal relations at the National Association of Student Financial Aid Administrators, told Inside Higher Ed that "compiling the necessary components for this reporting likely has and will continue to place an even more acute administrative burden on lower-resourced schools." Clare McCann of American University's Postsecondary Education and Economics Research Center was less forgiving: "Completing mandatory data reporting is absolutely a requirement of schools' agreements with the Department of Education."

What a student can actually do before 2027

The federal disclosure is not available yet, but its raw material largely is. College Scorecard at collegescorecard.ed.gov publishes median earnings and median debt by institution, and its Fields of Study tab breaks both down by program, which is the level the new test operates at. Comparing a program's median earnings against $30,793 reproduces the federal calculation closely enough to be useful.

Scorecard earnings cover only students who received federal aid, so cash-paying and non-borrowing graduates are invisible. Students who go straight to graduate school are excluded from the measurement year, which flatters some fields and punishes others. No earnings premium measure is published at all when fewer than 30 students completed a program in the cohort period, which will silently hide many small programs across upstate New York. And when a cohort is too small, the Department may pool every program nationally sharing the same credential level and four-digit classification code, so the number attached to a program may not describe that campus.

Existing rules already give applicants one lever. Under the transparency regulations, an institution may not let a prospective student seeking federal aid sign an enrollment agreement, complete registration or make a financial commitment until that student has completed an acknowledgment confirming they viewed the program's information. Once a program fails twice in three years, institutions must warn students within 30 days that loan eligibility is ending and that all federal aid could follow.

For families weighing cost before any of that arrives, the cheapest credits available in New York are still the ones earned in high school, which we covered in our guide to dual enrollment and college credit, and the state aid calendar we mapped in the free tuition deadlines guide has not changed. The federal earnings data is coming in 2027. The tuition bill is due now.