The US Department of Education (ED) has proposed a rule that imposes a “do-no-harm” earnings test that will cut off Title IV federal loan eligibility for most massage therapy, cosmetology, and esthetics programs that don’t meet the new standard. This potentially could force the closure of hundreds of schools in these fields. These rules were proposed by ED to determine if individuals are financially worse off after completing certain postsecondary programs, leaving them underemployed and unable to repay student loans. While ABMP applauds the spirit of that endeavor, the execution is deeply flawed, and we need your help in fighting this example of regulatory overreach.
Why This Matters
If the rule moves forward as written, wellness and beauty-related programs will be unfairly targeted. Graduates working in cosmetology, esthetics, and massage therapy, a significant portion of whom work part time, will have their earnings compared to individuals with four-plus year undergraduate and graduate degrees who work in 40-hour per week fields. The earnings formula does not account for the vast differences between professions, comparing, for example, the economic status of a part-time massage therapist to that of an individual with a master’s degree in aerospace engineering from MIT. Lumping all these programs together will lead to inaccurate and misleading results, which could put access to financial aid in jeopardy for thousands of future students. To see if your program would pass or fail these new thresholds, go to “Low-Earning Degrees Will Soon Lose Access to Federal Loans—Is Yours on the List?” and search for your program at the bottom of the article.
If you’re thinking, “I graduated decades ago, my school is no longer in operation, this doesn’t affect me at all,” you aren’t seeing the whole picture. If schools close, new graduates will stop entering the workforce. As the workforce shrinks, salons and spas will close. This won’t happen immediately. It will take a few years for the shortages to cause real problems. By the time we realize the depth of the worker shortage, it will be too late. It would potentially take the profession years to recover from the fallout of these proposed regulations. We have all worked too hard to advance our professions to allow all that work to be erased by these rules.
We Need Your Voice
Please submit a comment to the ED no later than May 20, 2026, and contact your congressional representative to let them know your school, spa, and profession need their help.
Urge the ED to revise the do-no-harm formula or exempt undergraduate certificate programs, specifically those in the beauty and wellness professions, entirely. Your perspective as a practicing professional (whether you received financial aid or not), a spa owner, an educator, or a school leader carries weight, particularly with your congressional representative. Your voice matters.
Here’s how to submit your comment:
**THIS IS NOT A TEMPLATE; THESE ARE TALKING POINTS. PLEASE DO NOT COPY AND PASTE.** It is critical to avoid everyone using identical language. Identical comments are grouped and counted as one. We need to flood ED with unique comments to show how important it is that they fix this potentially egregious error. If you need inspiration, consider using these talking points in your own words, along with your unique story:
- Part-time work misrepresented: Many massage therapists, estheticians, and cosmetologists work part time, yet the formula assumes full-time earnings, which dramatically skews professional income. The nature of the fields we serve do not lend themselves to a standard, 40-hour pay week; the regulations do not take this into account.
- Unreported tip income: The formula excludes tips and other unreported income, which is a major portion of income for licensed professionals in the wellness and beauty professions.
- Unfair wage comparisons: The formula compares massage, esthetics, and cosmetology graduates’ earnings to unrelated professions without adjusting for gender, age, or racial wage disparities that disproportionately affect the wellness and beauty fields.
- No regional adjustment: Earnings vary widely by region, which the do-no-harm test overlooks, while also treating all markets the same. This results in inaccurate and unfair comparisons.
- The economic impact would be devastating: Analysis shows over 92 percent of beauty schools and over 89 percent of massage schools would lose funding within two years and inevitably shut down if these rules were implemented today. That would be catastrophic on its own, but it gets worse. The ripple effects would spread to salons, spas, and clinics being unable to find employees and having to close, and vendors of tools and products taking huge sales losses.
- ED did not adhere to congressional intent when drafting these rules: The original intent of the provision in the One Big Beautiful Bill Act (OB3) that instigated the creation of this accountability framework was for these earning measures to be applied to undergraduate degree programs and above, not undergraduate certificate programs. ED’s overreach will decimate our professions if corrective action is not immediately taken.
- Make it personal: This part is so important. Include details specific to you, like how many people your business employs, how many students graduate from your school each year, how Title IV funding helped you pay for school, how your career has changed your life for the better, what your business means to your community, or anything you think makes your experience in your profession special. We need ED to understand the gravity of what we stand to lose.
The do-no-harm test, as it is currently written, threatens student access, school viability, and the future workforce pipeline. ED must amend the language to omit undergraduate certificate programs or completely rewrite the formula to allow a fair comparison between professions.
How to Submit Public Comment
Step 1: Go to this link, which will take you directly to the comment field for the AHEAD rules.
Step 2: Type your comment directly into the box or attach it as a document. You do not need to do both.
Step 3: Select “Private/For Profit Institution of Higher Education” under the field that asks what your comment is about. Choosing this comment category will make sure all the comments stay together and reach the right people at ED.
Step 4: Tell them who you are. Enter your email address and make a selection for if you’re representing yourself or an organization.
Step 5: Click “Submit Comment.”
Step 6: Send a copy of your remarks to your congressional representative (find your representative and their contact information here) and let them know why they must intervene to amend the AHEAD rules before our professions are decimated.
Submit your comments before May 20, 2026, and share this information with colleagues to help protect the future of the massage, esthetics, and cosmetology communities.
Thank you to everyone who takes a few moments out of their busy day to make a difference and help protect our students, schools, and professions. You are making a difference.