Broker Check
MWM Newsletter – The Government Just Admitted What the Data Already Knew
May SeriesFamily StewardshipPillar 7
The Government Just Admitted What the Data Already Knew
When Washington Finally
Catches Up to the Data.
A new federal law now ties student loan access directly to whether a degree actually delivers. For families choosing a program today, the clock is already running.  ·  Rodd R. Miller, CFP®
247%→42%
College wealth premium collapse over one lifetime (Fed data)
6%
Share of all higher education programs projected to fail the new earnings test
29%
Estimated failure rate for undergraduate certificate programs specifically

For several articles, we have been making the case — with Federal Reserve data, National Association of Realtors (NAR) homeownership statistics, and a decade of earnings research — that the conventional college promise is empirically broken for a significant share of American families. As it turns out, Congress has reached the same conclusion.

In July 2025, the federal government signed into law a provision that does something it has never done before at the statutory level: it makes a college program's access to federal student loan dollars contingent on whether graduates actually out-earn people who never attended. It is called the "Do No Harm" earnings standard. And it changes the rules for every family making a college decision right now.

One Big Beautiful Bill Act · Signed July 4, 2025

"Federal student loans shall not flow to programs that leave graduates financially worse off than if they had never attended."

— U.S. Department of Education, stated rationale for the earnings premium rule
How the Rule Works

The Mechanics of "Do No Harm"

The rule establishes an earnings premium test — a direct comparison between what a program's graduates earn and what they would have earned without the degree. The benchmark is not generous.

Undergraduate Programs Must out-earn high school graduates

Median graduate earnings must exceed the median earnings of working adults ages 25–34 with only a high school diploma in the same state.

Graduate Programs Must out-earn bachelor's degree holders

Median graduate earnings must exceed those of working adults ages 25–34 with only a bachelor's degree — the degree they already held before enrolling.

Consequence of Failure Loss of federal loan access

Programs failing the earnings test in two of three consecutive years are designated "low earning outcome programs" and lose access to federal Direct Loans.

Scope Every program. Every institution.

For the first time, the rule applies equally to certificate programs, bachelor's degrees, master's degrees, and doctoral programs — at for-profits, nonprofits, and public universities alike.

That last point deserves emphasis. Previous gainful employment rules applied only to for-profit institutions and certificate programs. Elite nonprofit universities were largely exempt. That exemption is gone. A fine arts bachelor's degree at a prestigious private nonprofit now faces the same earnings test as a cosmetology certificate at a for-profit school. The credential's prestige is no longer a shield.

Who's At Risk

The Programs Families Are Choosing That May Lose Federal Funding

The Department of Education's own analysis projects that approximately 6% of all higher education programs will fail the earnings premium test. That figure understates the risk in specific fields. Undergraduate certificate programs carry an estimated failure rate of 29%. The failures are concentrated in fields millions of families are actively choosing right now.

Field of Study Risk Level
Culinary Arts & Food Services High Risk
Cosmetology & Personal Services High Risk
Drama, Theatre & Fine Arts High Risk
Religious Studies High Risk
Alternative & Complementary Medicine High Risk
Certain Liberal Arts Programs Moderate Risk
Select Master's Degrees in Low-Earning Fields Moderate Risk

To be clear: the federal government is not saying these fields have no value. It is saying that taxpayer-funded student loans should not finance programs where graduates systematically earn less than people who skipped the program entirely. That is a statement the data has supported for years. Washington has simply formalized it into law.

"The credential's prestige is no longer a shield. A fine arts degree at a prestigious nonprofit now faces the same earnings test as a cosmetology certificate at a for-profit school."
— U.S. Department of Education AHEAD Committee Rulemaking, 2025–2026
The Timeline That Matters

When Does This Actually Affect Families?

The rule is moving quickly by federal standards. Families choosing programs today need to understand the timeline they are operating inside.

  • July 4, 2025The One Big Beautiful Bill Act is signed into law, codifying the "Do No Harm" earnings standard for the first time in federal statute.
  • April 2026The Department of Education publishes proposed regulations for public comment, currently open through May 20, 2026.
  • July 1, 2026Regulations take effect. The Department begins calculating earnings premium results for all programs nationwide.
  • Early 2027First earnings premium calculations released. Programs are notified of results. Families gain access to program-level data through the new Student Tuition and Transparency System (STATS).
  • Early 2028Second round of calculations. Programs failing in both 2027 and 2028 are designated as low earning outcome programs.
  • July 1, 2028Earliest date a failing program loses access to federal Direct Loans. Students must seek private financing — which requires good credit, stable income, or a cosigner.

The practical implication: a student enrolling in a vulnerable program today — fall 2026 or fall 2027 — may find federal loan access disappears before they graduate. They will not be grandfathered. If private loans become the only option, the terms will be significantly less favorable, often requiring a cosigner. Which means the parent.

Why This Validates Everything

The Market Already Knew. The Government Just Caught Up.

Step back and look at what this series of articles has established. Federal Reserve data showed the college wealth premium collapsing over decades — not because college stopped having value, but because the cost of accessing it began consuming the returns. The family dependency data showed the downstream consequence: a generation of young adults who cannot achieve financial independence, and a generation of parents whose retirement savings are funding the gap.

Now a bipartisan federal law has drawn the same conclusion and acted on it. It has said, in statutory language, that a program which leaves graduates worse off than if they had never enrolled should not have access to the public financing that made enrollment possible in the first place.

This is not a political statement. It is an accounting statement. And it is one that every family sitting across from an admissions officer — or signing a FAFSA — deserves to understand before the ink is dry.

What Families Should Do Right Now

  1. Ask the institution directly: has this program been assessed under the new earnings premium framework, and what were the results? They are required to disclose this.
  2. Look up program-level earnings data on the Department of Education's College Scorecard before choosing a major — not the school's average, but the specific program's median earnings at three and five years post-graduation.
  3. If the program falls in a high-risk field category, model two scenarios: one with federal loan access intact, one where private financing becomes the only option. Know what that cost difference looks like.
  4. Factor the timeline into enrollment decisions. Students starting a four-year program in fall 2026 will graduate in 2030 — two years after the earliest date programs can lose federal loan access. Their financing environment may look very different than it does today.
  5. Have the conversation with a financial advisor before the enrollment deposit is paid. The college decision has always been a financial planning event. Federal law now makes that undeniable.

The system is being forced to reckon with what the data has shown for years. For families paying attention, that reckoning is not a threat. It is information. And information — applied before the decision is made, not after — is the only thing that reliably changes the outcome.

MWM Newsletter – The College Decision Is a Real Estate Deal
May SeriesBalance Sheet OptimizationPillar 2
How to Make the College Decision Like a Sophisticated Investor
The College Decision
Is a Real Estate Deal.
Start Treating It Like One.
Two articles of data. One uncomfortable truth. Now: the framework that separates the families who get this right from the ones still writing checks a decade later.  ·  Rodd R. Miller, CFP®
42%
College wealth premium for families born after 1980 — down from 247%
40×
Median homeowner net worth vs. the median renter
$275K
Lost retirement assets over 10 years when parent support displaces savings

The first two articles in this series made a case most parents didn't want to hear.

The data was never meant to be comforting. But data without a framework is just anxiety. So here is the framework.

The Mental Model You're Missing

Nobody Buys a House Because the Kitchen "Feels Right"

Here is how most families approach a college decision: emotionally, sequentially, and in isolation. The student gets excited about a school. The parent visits the campus. Everyone agrees it "feels right." The financial aid letter arrives. The family compares it to the sticker price, decides it's "not that bad," and signs the promissory notes.

At no point in that sequence did anyone treat this as what it actually is: a leveraged investment in a depreciating asset with an uncertain yield.

That is exactly how a sophisticated buyer approaches real estate. When a family purchases a home, they analyze the costs against expected appreciation. They evaluate the financing terms. They consider the neighborhood's trajectory, the liquidity timeline, the opportunity cost of the down payment. They do not write a check for $200,000 because the kitchen felt right.

Apply that same discipline to higher education and the entire decision tree changes.

The Four Variables That Actually Matter

A Rigorous College ROI Analysis Has Four Inputs

Every other factor — prestige, campus culture, rankings, proximity to home — is downstream of these four. Build the analysis here first, then let everything else find its place.

The Four-Variable Framework
1

The All-In Cost, Net of Aid

Not the sticker price. Not the net price calculator estimate. The actual, documented, four-year cost of attendance after grants, scholarships, and work-study — with a realistic assumption for annual tuition inflation, which has run at roughly 3 to 4 percent per year over the past decade (College Board). This is the capital outlay. Everything else flows from here.

2

The Expected Starting Salary in the Intended Field

Not the median wage for all college graduates. The median starting salary for graduates in the student's declared field, from institutions in the school's peer group, in the likely geographic market. The Bureau of Labor Statistics Occupational Outlook Handbook and the New York Fed's labor market outcomes tool publish this by major and degree level. They are public, free, and almost never consulted before enrollment.

3

The Debt-to-Income Ratio at Graduation

There is a rule of thumb used by every competent student loan counselor, and almost no admissions office will volunteer it: total student loan debt at graduation should not exceed expected first-year salary. Borrow $80,000 to earn $45,000 per year and you have not made an investment. You have written yourself into a financial constraint that delays the homeownership that, per the St. Louis Fed, is the primary driver of middle-class wealth accumulation.

4

The Opportunity Cost of the Capital

The most important variable — and the one almost no family models. The $150,000 in total college costs, including four years of foregone entry-level earnings, is not just an expenditure. It is capital with an alternative use. Invested at 7% annually over 40 years, $150,000 becomes approximately $2.24 million. That is not an argument against college. It is an argument for making the decision with the seriousness of any other seven-figure capital allocation.

The Spectrum of Outcomes

Same Decision. Completely Different Results.

Applying these four variables produces a spectrum of outcomes, not a binary verdict. Consider what the same decision looks like at opposite ends of that spectrum.

Strong ROI

A student borrowing $18,000 total to attend a state flagship, graduating in four years with a nursing degree into a $65,000 starting salary in a market with consistent demand. Debt-to-income ratio under 0.3. Clear path to homeownership within three to five years of graduation.

Compounding Risk

A student borrowing $120,000 total at a private liberal arts school, graduating in five years with a communications degree into a $38,000 starting salary in a saturated market. Debt-to-income ratio over 3.0. The ten-year repayment schedule consumes the entire wealth-building window identified as irreplaceable.

Both students went to college. The outcomes are not remotely comparable. And note what's absent from both scenarios: any mention of campus culture, rankings, or which school "felt right."

"42.5% of recent college graduates are currently underemployed — working in jobs that don't require a degree at all. That is not a rounding error. That is the modal outcome."
— Federal Reserve Bank of New York, Q4 2025
What To Do Before the Deposit Is Paid

The Questions Worth Asking With Data in Hand

Before a family writes the enrollment check, five questions deserve honest, data-sourced answers. Not estimates. Not gut feelings. Numbers — from the BLS, the NY Fed, the College Board, and the financial aid office.

Five Questions Before the Enrollment Deposit:

  1. What is the documented median starting salary for graduates in this major, from this institution's peer group, in our likely market — per Bureau of Labor Statistics or NY Fed data?
  2. What is the four-year all-in cost, net of grants and scholarships, with realistic annual tuition inflation factored in — not the financial aid letter's first-year figure?
  3. What is the projected debt-to-income ratio at graduation, and does it clear the one-to-one threshold that student loan counselors consider the outer limit of manageable?
  4. What does the four-year alternative look like — community college plus transfer, trade certification, employer-sponsored training, or deferred enrollment with intentional savings — modeled against the same financial timeline?
  5. What does the parent's own retirement picture look like if this degree does not produce the expected salary outcome? Is that a recoverable scenario, or does it extend financial support through the highest-impact savings years?

These are not pessimistic questions. They are the questions any rational buyer asks before making a leveraged, multi-year capital commitment. The fact that higher education has been culturally exempt from this standard of scrutiny is the entire reason this series exists.

What This Series Has Been

The Families Who Win Are Not the Ones Who Spent the Most

Our recent articles used data to challenge assumptions that most families accept without examination. This article uses data to build the alternative framework. The thesis was never that college is a bad investment. The thesis is that most families are making a six-figure financial decision with the analytical rigor they apply to choosing a vacation.

The cost of that gap — measured in depleted retirement accounts, delayed homeownership, and extended financial dependency — is now documented in Federal Reserve research, New York Fed labor market data, and the lived experience of 64% of parents currently supporting adult children.

The families who come out ahead are not the ones who spent the most on education. They are the ones who treated the decision like the capital allocation it is — running the numbers before the campus visit, not after the acceptance letter.

The data has changed. The decision-making framework should too.

MWM Newsletter – You Aren't Just Paying for Their Future. You're Risking Yours.
May SeriesBalance Sheet OptimizationPillar 2
When The Wrong College Decision Follows You Into Retirement
You Aren't Just Paying
for Their Future.
You're Risking Yours.
64% of parents are still financially supporting their adult Gen Z children. What the tuition brochure never told you is that a poor college ROI decision doesn't end at graduation — it can follow you all the way to retirement.  ·  Rodd R. Miller, CFP®

We ended our last piece with a question every parent should be asking before writing a tuition check: what does this decision actually cost in wealth-building years? But there's a second question that almost nobody is asking. It's more personal, more uncomfortable, and for millions of parents, it's already too late to avoid.

What does the wrong college decision cost you?

Not your child. You. Your retirement. Your financial independence. The years you spent building a nest egg while simultaneously funding a launch that never quite happened.

The Data Nobody Warned You About

64% Is Not a Rounding Error

A recent Fortune survey found that 64% of parents say their adult Gen Z children still rely on them financially — for money, housing, groceries, phone bills, health insurance, and more. This isn't a story about a handful of struggling families. It's the majority experience for parents of young adults right now.

And the cost is not abstract.

$1,589

Average amount parents spend monthly supporting adult children — compared to just $673 per month going into their own retirement savings.
Source: Savings.com / Fortune, 2025

Parents are spending 2.3 times more subsidizing their adult children's lives than they are building their own retirement. Nearly half — 47% — say they have already sacrificed their own financial security in the process. And the support isn't a short bridge. It's a sustained commitment: the average parent contributing $1,813 per month to a working-age Gen Z child.

That money has to come from somewhere. For most families, it's coming directly out of the future.

How We Got Here

The Chain of Decisions That Led to This Moment

The financial dependence of Gen Z on their parents didn't happen in a vacuum. It is the downstream consequence of a specific sequence of decisions — most of them made years earlier, with incomplete information, under enormous social pressure.

  • Year 0. A 17-year-old applies to colleges. The family compares acceptance letters, not debt-to-income projections for the chosen major. The most prestigious option wins.
  • Year 4. Graduation. Average student debt: $37,000+. The job market for new graduates has an underemployment rate of 42.5% — the highest since 2020. The degree that was supposed to open doors is competing with hundreds of identically credentialed applicants.
  • Year 5. The child moves home, or needs help with rent. It's temporary. Everyone agrees it's temporary.
  • Year 7. The parent has now spent an estimated $38,000+ in post-graduation support. That money, invested instead at a modest 7% annual return, would have grown to over $100,000 in a decade. The retirement account didn't get it. The adult child did.
  • Year 10+. Only 44% of adults ages 25–29 are completely financially independent of their parents, according to Pew Research. A third of adults ages 18–34 still live at home. The temporary situation has become structural.

None of this is inevitable. But it is predictable — once you understand that the college decision is not a four-year financial commitment. It is a decision with a potential ten-to-fifteen-year tail, and that tail lands squarely in the middle of the years that matter most for retirement savings.

"Working parents spend 2.3 times more on their adult children than on their own retirement accounts each month. 47% say they have already sacrificed their own financial security."
— Fortune / Savings.com Survey, 2025
The Compounding Problem

It's Not Just the Money. It's When You Lose It.

The cruelest part of this equation is timing. The years between 50 and 65 are the most powerful wealth-building years most people will ever have. Children are (theoretically) independent. Earnings are at their peak. The mortgage may be paid or nearly so. Every dollar invested in this window has the most compounding runway left before retirement.

These are exactly the years parents are spending $1,589 a month on adult children instead.

$275K Lost retirement savings if $1,589/mo goes to adult child instead of invested over 10 years at 7%
37% Of parents plan to cut off financial support within 2 years — because they simply cannot continue

The math is not forgiving. A parent who redirects $1,589 per month away from retirement investments for ten years doesn't just lose that $190,000. They lose every dollar that money would have compounded into. At a 7% annual return, that $190,000 in contributions becomes closer to $275,000 — consumed before it ever existed.

And this is before accounting for the original tuition investment, any co-signed loans, or the home equity that didn't get built because the down payment went to a school that didn't deliver the promised return.

The System Isn't Broken By Accident

The Rent Math That Makes Independence Nearly Impossible

To be clear: Gen Z is not failing to launch out of complacency. The structural headwinds they face are genuinely severe. Between 2017 and 2025, median weekly earnings grew by 38%. Rents increased by 50%. A college graduate entering the workforce today is immediately underwater on the basic cost of independence — before a single student loan payment is made.

54% of Gen Z adults do not pay for their own housing. Of those who do, nearly two-thirds spend more than 30% of their paycheck on rent alone — the traditional threshold for housing stress. Add student debt service on top of that, and financial independence becomes genuinely out of reach for a significant share of young adults, regardless of how hard they work.

The parents subsidizing this gap are not doing anything wrong. They are doing what parents do. But the gap they are filling was largely created upstream — by a college decision made without a full accounting of the financial consequences, at a time when the conventional wisdom said the degree was worth whatever it cost.

The conventional wisdom was wrong. The Federal Reserve said so. And millions of family balance sheets are now proving it.

What To Do Now

The Questions That Change the Outcome

If your child is still in high school, you have time. The decisions haven't been made yet. The debt hasn't been signed. The compounding clock hasn't started running in the wrong direction. What changes the outcome is asking better questions — the kind that treat a college decision like the six-figure financial event it actually is.

Before the Enrollment Deposit Is Paid, Know These Numbers:

  1. What is the median starting salary for this specific major at this specific school — not the school's average, the major's average?
  2. What is the projected monthly loan payment at graduation, and what percentage of that starting salary does it consume?
  3. At that repayment rate, how many years until your child can realistically save a down payment — and what does homeownership delayed by five years actually cost in lifetime wealth?
  4. What is your realistic exposure if this doesn't go as planned — and does your retirement plan survive that scenario?
  5. Are there paths to the same career outcome at materially lower cost that haven't been seriously considered?

These are not pessimistic questions. They are the questions a financial advisor would ask. They are the questions that separate families who emerge from the college years with their wealth intact from those still writing checks a decade later, wondering where the retirement account went.

The college decision has always been one of the largest financial decisions a family makes. The difference now is that the data makes clear it is also one of the riskiest — and the risk doesn't end at graduation. It ends when your child is truly, structurally, financially independent. For most families today, that's taking much longer than anyone planned.

Plan accordingly.