Federal proposal raises concerns for TX Baptist universities 

A newly proposed rule issued by the U.S. Department of Education has raised concerns among Texas Baptist universities.  

On April 17, the Department of Education issued a Notice of Proposed Rulemaking to establish an accountability framework for postsecondary educational institutions. Under the proposed rule, programs where typical graduates earn less than high school graduates may lose eligibility for federal student loans. The proposal is open for public comment until May 20, 2026. 

The framework exists as part of the Working Families Tax Cuts act, a legislative package signed into law July 4, 2025, and a component of the One Big Beautiful Bill. The proposal seeks to combat the federal student loan portfolio, which is approaching $1.7 trillion, with fewer than 40 percent of borrowers in repayment.

Undergraduate programs must prove alumni’s earnings equal or exceed the income of working adults aged 25 to 34 with a high school diploma four years after completing their degrees. For graduate programs, median earnings must equal or exceed the lower of the median earnings for working adults aged 25 to 34 with a bachelor’s degree or in the same field of study.

Students in programs that fail to meet the standard would be banned from receiving student loans and Pell grants. Ninety-five percent of students are enrolled in programs projected to pass.

However, the mandate could potentially devastate faith-based programs. According to a report by The Chronicle of Higher Education, many religion-focused programs have low earning levels, especially those at Talmudic schools. 

The Department of Education estimated in January, 53 percent of students in bachelor’s degree programs in “Religion/Religious studies” fail the proposed rule, and nearly 90 percent (89.4) of master’s programs in this category are projected to fail.  

Service, not revenue

Adam Wright, president of Dallas Baptist University, expressed how program success should not be measured based on median income levels.

“We share the deep concern that many Christian colleges and universities have expressed about this proposal. If implemented as written, the rule would label a degree program as ‘failing’ if its graduates do not out-earn peers who never attended college, measuring program success almost entirely by median income four years after graduation,” Wright said. 

According to Wright, religious universities should seek to equip students for service, not merely to produce income.

“For a university like DBU, this strikes at the heart of our mission. We exist not merely to produce high-earning graduates … but to form men and women of character who are equipped to serve God and the world across every vocation,” Wright stated. 

“Many of our most impactful graduates are pastors, missionaries, ministry leaders, teachers, and counselors. These are callings, not simply careers, and they are woven into the fabric of our Baptist identity and our commitment to the Great Commission,” he continued. 

In a comment filed with the Department of Education, DBU argues the regulations would harm faith-based institutions by prioritizing financial gain over vocational calling and by failing to account for regional differences.

“The earnings-based framework misunderstands religious education. Students pursue theology and ministry degrees in response to spiritual calling, not financial gain. Faithful ministry has never been synonymous with high earnings,” the comment reads. 

“DBU’s 29 evaluated programs all passed the proposed program-level accountability framework, with only our Masters in Pastoral Counseling … flagged as ‘at risk.’ While grateful, this reflects our DFW location, where churches can hire ministers at reasonable rates—not the reality in regions where churches struggle to maintain staff,” the statement continues. 

According to the statement, the proposal’s “at risk” designations represent a metrical flaw, as the program is intended to serve those in vulnerable populations, with social value dismissed as “program failure” due to serving in a lower-paying ministry context. 

Concerns expressed

DBU’s statement expressed concerns regarding violation of the Religious Freedom Restoration Act, a 1993 law preventing the government from substantially burdening a person’s religious exercise. 

“These regulations force institutions to choose between maintaining religious programs or retaining federal aid—not a ‘genuine choice.’ For Christian universities, eliminating theology programs fundamentally compromises religious mission,” the statement says. 

DBU urged the department to exempt philosophical and theological programs (those under Classification of Instructional Programs codes 38 and 39) from earnings-based metrics and eliminate Pell grant consequences under the Administrative Capability Standard, a regulatory requirement mandating colleges and universities possess adequate resources to efficiently manage federal aid programs.

DBU expressed concerns the Department of Education’s regulations would bar low-income students from pursuing ministry callings, disrupt enrollment and revenue at DBU due to losing federal aid eligibility, and force Christian universities to choose between mission fidelity and financial viability. 

Baylor echoes sentiments 

In a statement sent to Baptist Standard, Baylor University echoed DBU’s stated sentiments: 

“Beyond the intellectual life, the University fosters the social, physical, ethical, and spiritual development of each student. Relying only on the earnings of our graduates reduces their higher education experience to less than what our mission statement calls for and produces misaligned incentives for universities seeking to produce well-rounded members of society,” the statement reads. 

“As an example, graduates of religious programs frequently pursue lives of public service, mission, and contribution to society, rather than highly compensated employment. Applying the new earnings test to these programs disregards the many personal, communal, and spiritual benefits these graduates receive when serving in faith-based organizations post-graduation. 

“We believe the proposed rule penalizes and disincentivizes institutions from offering these programs despite their alignment with our Christian mission, lacks sufficient avenues for appeal, and imposes implementation burdens on institutions of higher education, and it is our hope that the U.S. Department of Education will consider our concerns and amend the final rule,” the statement concludes.