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ARTICLE · 15 DECEMBER 2025

Frequently Asked Questions: FAFSA "Lower Earnings" Indicator

Thompson Coburn LLP
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According to a December 8 Electronic Announcement, students completing the FAFSA will now see a new disclosure flagging an institution as "lower earning" when that institution's undergraduate...

United StatesConsumer Protection
Aaron D. Lacey
Aaron D. Lacey
Hope Watson
Hope Watson
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According to a December 8 Electronic Announcement, students completing the FAFSA will now see a new disclosure flagging an institution as "lower earning" when that institution's undergraduate completers' median earnings are less than those of a high school graduate comparator group. The U.S. Department of Education (the "Department") has published a spreadsheet, identifying the institutions that fall into the "lower earnings" category. Cosmetology schools, theological seminaries, music conservatories, and art and design schools appear among the institutions most frequently listed.

How does the Department determine whether an institution is lower earning?

An institution is labeled lower earning when its undergraduate completers' median earnings (four years after graduation) are below the median earnings of high school graduates ages 25-34 in the same state. If an institution operates in multiple states or primarily enrolls first-year students from outside its

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