UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF POSTSECONDARY EDUCATION

400 Maryland Avenue, S.W., Washington, DC 20202

www.ed.gov

The Department of Education’s mission is to promote student achievement and preparation for global Competitiveness 

by fostering educational excellence and ensuring equal access.

2/11/22

Analysis of the Effect of Capping Total Loan Debt at Tuition, Fees, Books and Supplies Session 2: 

February 14-18, 2022

Under the 2014 Gainful Employment (GE) regulations, institutions reported the total amount charged to

each student in tuition, fees, books and supplies and this amount was used to cap each student’s total 

loan amount before computing the median and mean debt levels ofstudents in a program. Here we briefly 

describe the influence this cap on student loans had on measured median debt levels, and on whether 

programs were ultimately deemed to be passing the debt-to-earnings metrics in the rule.

This analysis uses the original student-level data used to compute the official debt to earnings metrics, 

released in early 2017 (the so-called 2015 GE rates). The data released contained debt-to-earnings (DTE) 

metrics for 8,650 programs, of which 6,422 were deemed to “pass” the DTE metrics, and 2,228 either 

“failed” or were in the “zone.” DTE metrics were re-estimated without applying the cap on student 

borrowing, and compared to the official DTE metrics estimated with the cap.

Of the 8,650 programs in the data, in 5,838 programs (67.5 percent) the median cumulative debt of 

completers was identical (unchanged) whether the loan cap was used or not. The table below shows the 

fraction of programs where applying the cap leads to a lower measured median debt for completers 

generally rises with the credential level: about 25 percent of undergraduate certificate programs have 

higher debt when the cap is not applied, whereas more than 97 percent of graduate programs have higher 

debt when the cap is not applied.

Credential Level

Total Number of 

Programs

Fraction where applying the cap 

reduces median total loan debt

Undergraduate Certificate 6,093 25.2

Associate 1,464 35.9

Bachelor’s 598 47.5

Post-Bacc. Certificate 49 73.5

Master’s 267 97.8

Doctoral 47 100

Professional 17 94.1
Page 2 –Gainful Employment Data on Loan Debt Caps 1 

400 Maryland Avenue, S.W., Washington, DC 20202

www.ed.gov

The Department of Education’s mission is to promote student achievement and preparation for global Competitiveness 

by fostering educational excellence and ensuring equal access.

Credential Level

Total Number of 

Programs

Fraction where applying the cap 

reduces median total loan debt

Graduate Certificate 115 94.8

For the 2,812 programs (32.5 percent) where calculating median total debt levels without the cap results 

in higher median debt, the change in measured median debt levels varies considerably. For 25 percent of 

these programs, the change is less than $285; the median increase is $1,161; and 25 percent of programs 

see increases of more than $3,882. Further, 10 percent (of the 2,812 with changes) see changes of over

$10,348, and 94 programs have increases in measured median debt of over $20,000 (88 of which are 

graduate programs).

Recalculating the 2015 GE rates without applying the cap would result in 148 programs being reclassified 

from “passing” (i.e., 2.3 percent of the 6,422 programs deemed “passing” under the 2014 methodology) 

the rule to either “failing” or being in the “zone.”

2/11/22