1. Are cosmetology students required to be paid under U.S. labor law?
Answer:
In most cases, cosmetology students enrolled in a licensed beauty school are considered students in training rather than employees. Under state cosmetology regulations, such as Kentucky KRS 317A and 201 KAR 12, students must complete a required number of training hours to qualify for licensure. Services performed in school clinics are considered part of the educational training process, not employment. However, federal labor law under the Fair Labor Standards Act (FLSA) sometimes raises questions about whether certain activities could be classified as work, which creates ongoing regulatory discussion.
2. Why is there a conflict between state cosmetology laws and federal labor laws?
Answer:
The potential conflict exists because state licensing laws treat cosmetology students as trainees, while federal labor laws focus on whether a person is performing productive work for a business. If an activity primarily benefits the student’s education, it is generally considered training. If the activity primarily benefits the business, federal regulators may examine whether wage laws apply. This difference in legal frameworks is the central issue discussed in the research.
3. Do beauty schools have to follow both state cosmetology regulations and federal labor laws?
Answer:
Yes. Beauty schools must comply with state cosmetology board regulations, which govern licensing, training hours, and curriculum requirements. At the same time, all businesses in the United States must follow federal labor laws administered by the U.S. Department of Labor. Schools therefore must carefully structure their training programs so that student clinic activities remain clearly part of educational instruction rather than employment.
4. How many training hours are required to become a licensed cosmetologist in Kentucky?
Answer:
In Kentucky, the state cosmetology regulations require 1,500 hours of training to qualify for the cosmetology licensing examination. These hours include a combination of classroom instruction, scientific theory, and supervised clinical practice performed within a licensed cosmetology school.
5. How are federal education accountability rules affecting cosmetology schools?
Answer:
New federal education transparency and accountability policies, including Gainful Employment and Financial Value Transparency regulations, are increasing scrutiny of vocational programs. These rules measure outcomes such as graduate earnings, debt levels, and program value. As a result, schools are placing greater emphasis on affordable tuition, transparent outcomes, and strong compliance systems.
DTU Research Disclaimer
This publication is an independent academic research analysis prepared by the Di Tran University — College of Humanization Research Team.
The material is provided for scholarly discussion, public policy analysis, and educational purposes only. It does not constitute legal advice, regulatory interpretation, or official guidance regarding Kentucky Board of Cosmetology (KBC), the U.S. Department of Education, or any governmental authority.
All statutes, regulations, and policy discussions referenced are cited from publicly available sources. Institutions, organizations, or schools referenced in this research are discussed solely within the context of academic analysis of vocational education policy.
Di Tran University encourages readers to consult official regulatory agencies or qualified legal counsel for formal interpretation of laws or compliance obligations.
State cosmetology law treats students as trainees who are not paid, while federal labor law could interpret the same activity as work requiring wages — creating a regulatory tension that vocational schools must carefully navigate.
The current environment for postsecondary vocational education in the Commonwealth of Kentucky is undergoing a period of unprecedented transformation, characterized by the intersection of state-level institutional reform and a comprehensive federal overhaul of educational accountability. For an institution operating as a state-licensed beauty school under the jurisdiction of the Kentucky Board of Cosmetology (KBC), navigating this landscape requires a sophisticated understanding of both the statutory mandates of Kentucky Revised Statutes (KRS) Chapter 317A and the evolving federal frameworks established by the U.S. Department of Education. This report provides a high-level analysis of the federal Financial Value Transparency (FVT) and Gainful Employment (GE) regulations, the subsequent codification of these principles in the One Big Beautiful Bill Act (OBBBA) of 2025, and the specific administrative shifts within the Kentucky Board of Cosmetology that signal a new era of data-driven oversight.
The Kentucky Statutory Framework and the Modernization of the Board of Cosmetology
The foundational authority for beauty education in Kentucky rests in KRS Chapter 317A, which establishes the Kentucky Board of Cosmetology and empowers it to regulate the practices of cosmetology, esthetics, and nail technology. Under KRS 317A.060(1)(h), the board is specifically tasked with promulgating administrative regulations that govern the hours and courses of instruction required for licensure.1 These mandates are further detailed in 201 KAR Chapter 12, specifically 201 KAR 12:082, which defines the clinical and scientific lecture hours necessary for a student to qualify for the state examination.1 For cosmetology students, the requirement remains a minimum of 1,500 hours, a figure that serves as a critical benchmark in both state compliance and federal aid eligibility discussions.1
The recent administrative trajectory of the KBC has been defined by a shift toward heightened enforcement and operational transparency. Following the removal of long-standing leadership in September 2024, the board, under the direction of Executive Director Joni Upchurch, has implemented more rigorous reporting protocols intended to verify the “administrative capability” of licensed schools.3 This shift is exemplified by the June 2025 memorandum, which introduced new requirements for the annual school renewal process. Most notably, all licensed schools are now mandated to submit current student contracts as a component of their renewal application.4 The rationale provided for this requirement is the necessity of ensuring that institutional records are not outdated and that the financial and educational terms offered to Kentucky students align with current regulatory standards.4
The KBC has also established a strict distinction between minor clerical errors and substantive reporting violations. Enrollment correction fees, which were previously a source of some ambiguity, are now strictly limited to minor “human errors,” such as typographical mistakes in names or license numbers.4 In contrast, the failure to report student hours, enrollments, withdrawals, or to validate required documentation is classified as a violation of state statutes and regulations. Such failures subject the institution to disciplinary actions, which can include significant fines, the probation of the school’s license, or, in severe cases, license suspension or revocation.4 This move indicates that the KBC is adopting a “compliance by design” philosophy, where the accuracy of student data is viewed as a prerequisite for the legal authority to operate.
| Kentucky Regulatory Requirement | Statutory/Regulatory Reference | Institutional Action Required |
| Annual School Renewal | KRS 317A.090; 201 KAR 12:030 | Submission of current student contracts and renewal fees by July 1 annually. |
| Instructional Hours (Cosmetology) | 201 KAR 12:082 | 1,500 total hours (375 lecture, 1,085 clinic, 40 law). |
| Student Registration | 201 KAR 12:030 | Registration with KBC 8 months prior to graduation (cosmetology) or 75 days (nails). |
| Reporting Compliance | 201 KAR 12:082; KRS 317A.060 | Timely submission of enrollments, withdrawals, and hour validation. |
The historical context of “regulatory capture” within the KBC has also played a role in these reforms. Research into the “Cosmetology Board Capture Index” previously suggested a correlation between minimal public representation on state boards and lengthy training mandates that may not align with modern educational efficiencies.3 The recent inclusion of diverse industry representatives, such as the board’s first-ever nail technician member, Michael Carter, and the appointment of an Executive Director with a background in cosmetology education, suggests a balanced effort to uphold professional standards while modernizing the board’s oversight functions.3
The Federal Accountability Revolution: Gainful Employment and Financial Value Transparency
Parallel to state-level changes, the U.S. Department of Education (ED) has implemented the most comprehensive set of accountability measures in its history. The 2023 Final Regulations on Gainful Employment and Financial Value Transparency, which became effective on July 1, 2024, establish a dual framework for measuring the economic value of postsecondary programs.5 The Gainful Employment (GE) rule applies to all programs at proprietary (for-profit) institutions and all non-degree programs at public and private non-profit institutions.7 These programs are required by law to “prepare students for gainful employment in a recognized occupation”.5
The GE/FVT framework utilizes two primary metrics to assess program performance: the Debt-to-Earnings (D/E) test and the Earnings Premium (EP) test. The D/E test is designed to ensure that graduates are not burdened with unmanageable student loan debt relative to their income. Specifically, the annual median debt payments of graduates must not exceed 8% of their annual earnings or 20% of their discretionary income.10 The Earnings Premium test requires that the median graduate of a program earn more than a typical high school graduate in the same state between the ages of 25 and 34 who has no postsecondary education.10
Programs that fail either of these metrics twice within a three-year period lose eligibility for federal student aid programs, specifically Title IV funding.2 For beauty schools, which are primarily for-profit institutions, this poses a significant risk. Preliminary data estimates suggest that approximately 98% of cosmetology programs currently receiving federal aid would fail the earnings premium benchmark if the rules were applied today.2 This high failure rate is attributed to the fact that many graduates in the beauty industry report initial earnings that are near poverty levels, often due to part-time work or the underreporting of tip income.2
| Federal Metric | Failure Threshold | Administrative Consequence |
| Debt-to-Earnings (D/E) | > 8% of annual earnings OR > 20% of discretionary income. | Mandatory student warnings; loss of Title IV eligibility if failed 2 of 3 years. |
| Earnings Premium (EP) | Median earnings < Median state high school graduate earnings. | Loss of Title IV (GE) or Direct Loan (FVT/OBBBA) eligibility. |
| FVT Disclosure | Failure to report required student/program data. | Administrative capability violation; “Red Flag” on College Scorecard. |
The reporting requirements for these regulations are extensive and require a sophisticated data management system. Institutions must report student-level data to the National Student Loan Data System (NSLDS), including the total cost of attendance (tuition, fees, books, and supplies), the amount of institutional and private financial aid received, and enrollment dates.5 While the initial deadline for these reports was significantly delayed to allow institutions to adapt, the current critical deadline for the first 2025 reporting cycle is September 30, 2025.5 Failure to meet this deadline or providing inaccurate data can result in the loss of “administrative capability” certification, effectively barring a school from participating in federal aid programs.4
Statutory Codification: The One Big Beautiful Bill Act (OBBBA) of 2025
A pivotal development in the regulatory landscape occurred on July 4, 2025, with the passage of the One Big Beautiful Bill Act (OBBBA). This legislation represents the statutory codification of many of the accountability principles previously found only in federal regulations.11 The OBBBA introduced the “Do No Harm” earnings provision, a statutory requirement that programs must demonstrate graduates earn more than individuals with only a high school diploma.16
The OBBBA effectively overhauls the existing GE/FVT framework into a more unified system. The transparency component of the FVT regulations has been renamed the Student Tuition and Transparency System (STATS), while the accountability portion for GE programs has been transitioned into the “Earnings Accountability” framework.12 One of the most significant changes under the OBBBA is the elimination of the Debt-to-Earnings metric as an eligibility requirement for non-GE programs, replacing it with a singular, statutory Earnings Premium test for determining program eligibility for Direct Loans.12
The OBBBA also introduced “Workforce Pell Grants,” which expand access to Pell Grant funds for students enrolled in shorter, career-focused programs that meet high-value outcome standards.17 However, this expansion of Pell eligibility is offset by tighter borrowing limits in other areas. The OBBBA eliminated the Graduate PLUS loan program and placed new caps on Parent PLUS loans, which is projected to reduce available higher education financing by approximately 12%.19 For the beauty school sector, these changes are likely to drive students toward lower-cost programs that do not require extensive federal borrowing.
| OBBBA Provision | Effective Date | Impact on Postsecondary Institutions |
| Student Tuition and Transparency System (STATS) | July 1, 2026 | Replaces FVT; mandatory reporting of costs, aid, and completion data for all programs. |
| Earnings Accountability | July 1, 2026 | Loss of Direct Loan eligibility for programs failing the EP test twice in 3 years. |
| Workforce Pell Grants | Academic Year 2025-26 | Expansion of Pell to short-term, high-outcome vocational programs. |
| Graduate/Parent Loan Caps | July 1, 2026 | Elimination of Grad PLUS; $50,000 annual cap on unsubsidized graduate loans. |
The transition to the STATS framework also introduces new data-sharing requirements. For undergraduate programs, the Department of Education will calculate the earnings threshold based on the median earnings of working adults aged 25 to 34 who hold only a high school diploma in the state where the institution is located.11 For programs with more than 50% out-of-state enrollment, a national median will be used.18 The department will utilize a four-year aggregation method to ensure that smaller programs—those with fewer than 30 Title IV completers in a single year—can still be assessed with statistical reliability.14
Judicial Review and the “Bare Minimum Rule” Litigation
The implementation of these federal rules has not been without significant judicial challenge. One of the most controversial provisions was the “Bare Minimum Rule” (BMR), which became effective on July 1, 2024. The BMR restricted Title IV aid to only those programs whose length did not exceed the minimum number of hours a state mandates for licensure in a given field.10 This rule fundamentally altered the landscape for beauty schools, many of which had operated programs under the “150% Rule,” allowing for training that exceeded state minimums by up to 50%.20
The cosmetology school industry challenged the BMR in several lawsuits, including 360 Degrees Education, LLC v. U.S. Department of Education and American Massage Therapy Association (AMTA) v. U.S. Department of Education.10 In June 2024, the U.S. District Court for the Northern District of Texas entered a preliminary, nationwide injunction against the BMR, finding that the rule was likely “arbitrary and capricious” and represented a “sea-change” that the Department of Education had not adequately justified.10 Following this injunction, the Department announced it would revert to enforcing the 150% Rule while the litigation remains pending.10
As of November 2025, the BMR remains enjoined and the Department of Education has indicated it intends to reconsider the rule through a new negotiated rulemaking process expected to take place in late 2025 or 2026.10 In contrast, the broader Gainful Employment rule was upheld by the Northern District of Texas in October 2025. The court concluded that the Department was within its statutory authority to use debt and earnings metrics to define “gainful employment” and that its reliance on IRS earnings data was rational.10 This judicial split indicates that while specific procedural restrictions on program length are currently vulnerable, the core principle of outcome-based accountability is legally robust.
| Case Name | Ruling/Status | Primary Legal Finding |
| 360 Degrees Education v. ED | Nationwide Injunction (June 2024) | BMR likely arbitrary and capricious; sea-change in practice. |
| AACS & Ogle School v. ED | Summary Judgment for ED (Oct 2025) | GE Rule is within statutory authority; IRS data use is rational. |
| AMTA v. ED | Stayed until July 2026 | Litigation paused pending new negotiated rulemaking on BMR. |
| Sweet v. Cardona | Settlement Approved | $6 billion in debt discharge for students at 151 identified schools. |
The upholding of the GE rule means that the reporting requirements for 2025 and 2026 remain fully in effect. For institutions in Kentucky, this means that even though the BMR is currently enjoined, they must still demonstrate that their programs meet the Earnings Premium and Debt-to-Earnings standards to maintain federal aid eligibility. The Department’s projected $14 billion in taxpayer savings from these rules was cited by the court as evidence of the rule’s rational basis.10
The Role of National Councils and Data Aggregation Systems
A critical area of inquiry involves the role of “national councils” in collecting data from beauty schools. While the KBC is the primary state regulator, several national entities facilitate the exchange of data between states and the federal government.
The National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA is a prominent entity that develops and implements reciprocal state-level authorization processes for postsecondary distance education.21 Its mission is to increase the quality and value of higher learning credentials earned via distance education while ensuring students are served in a rapidly changing environment.21 For beauty schools, NC-SARA is relevant if they offer any distance education components or clinical placements across state lines.
NC-SARA mandates that all participating institutions, including those that do not participate in federal Title IV programs, must report data annually.21 This includes exclusively distance education enrollment (EDEE) and out-of-state learning placements (OOSLP).21 This requirement creates a national data dashboard that makes the enrollment patterns of even non-accredited or non-Title IV schools visible to regulators. This “Data Sharing Agreement” aligns with the broader push for transparency found in the federal FVT and STATS frameworks.21
The National-Interstate Council of State Boards of Cosmetology (NIC)
The NIC is responsible for developing the national licensing exams used by state boards, including the exam administered in Kentucky. While the NIC’s primary focus is on standardizing the “minimum competency standards” for public health and safety, it also serves as a central repository for state-level statistics on “examinations, licensing, administrative penalties, and disciplinary information”.3 In the context of the OBBBA and the STATS framework, there is an increasing likelihood that licensure exam pass rates will be integrated into the federal “Earnings Accountability” calculations to provide a more holistic view of program quality.23
The National Center for Education Statistics (NCES)
The NCES, through the National Cooperative Education Statistics System (Cooperative System), assists in producing and maintaining uniform data on vocational and workforce outcomes.24 The NCES’s “National Forum on Education Statistics” deals with issues in education data policy and provides technical assistance to improve state and local data systems.24 This cooperative framework is the mechanism through which state boards like the KBC share information that eventually informs federal reporting on “educator supply and demand” and vocational success.24
The Impact on Non-Title IV, State-Licensed Beauty Schools
A central concern for institutions like the Louisville Beauty Academy (LBA) is whether these federal and state actions affect schools that do not accept Title IV federal student aid. The evidence suggests that while these schools are shielded from the immediate penalty of losing federal funds, they are increasingly integrated into the national data environment and are subject to the same state-level “administrative capability” requirements as Title IV schools.
The “Market Corrector” and the Non-Title IV Model
Research identifies schools like LBA as “low-cost competitors” and examples of a “debt-free vocational pathway”.3 Because LBA operates outside the federal loan system, its tuition is significantly lower than that of Title IV-dependent schools. For example, LBA reports tuition between $6,000 and $8,000, contrasted with $15,000 to $25,000 at traditional accredited institutions.3 Furthermore, LBA reports high pass and placement rates, often exceeding 90%.3
However, the “Red Flag” system in the FAFSA and the accountability measures in the OBBBA are intended to perform a “market correction” by steering students away from programs with high debt-to-earnings ratios.3 This benefits non-Title IV schools by highlighting their value proposition. Simultaneously, state boards are using the “contract submission” requirement to track the economics of all schools, ensuring that the non-Title IV model remains “accountable to state regulators and customers” even in the absence of federal audits.3
Data-Sharing Ripple Effects
The NC-SARA data-sharing agreements demonstrate that non-Title IV schools are not invisible to national databases.21 If a non-Title IV school participates in state reciprocity agreements, it must report its enrollment data following the same timeline and process as Title IV schools.21 This is a critical “upcoming action” for schools like LBA, as the push for universal data collection under the STATS framework may eventually mandate reporting for all licensed postsecondary providers, regardless of their aid status, to provide a complete national picture of educational value.14
Administrative Capability at the State Level
The KBC’s Joni Upchurch memo signals that state boards are adopting the “administrative capability” standards of the federal government.4 By requiring current student contracts and imposing fines for failure to report enrollments or withdrawals, the KBC is essentially auditing the business operations of all schools.4 This ensures that even debt-free schools are maintaining the “standards and integrity” of the profession.4 For a school like LBA, this means that internal record-keeping and data submission to the KBC are now high-stakes compliance activities.
Strategic Outlook and Necessary Actions for Kentucky Institutions (2025-2026)
The convergence of federal accountability and state institutional reform creates a specific timeline of critical actions for beauty schools in Kentucky. The transition from the 2024 GE/FVT regulations to the 2026 OBBBA/STATS framework requires a proactive approach to data management and disclosure.
Critical Near-Term Compliance Deadlines
- July 1, 2025: Annual School Renewal window opens. Institutions must ensure their renewal application includes the mandatory “current student contract” and verify that all previously reported hour and withdrawal data is accurate.4
- September 30, 2025: Title IV Reporting Deadline. All programs participating in federal aid must submit their first full set of FVT/GE data to the NSLDS.5 Non-Title IV schools should monitor this data, as it will be used to establish national benchmarks that may impact state-level perceptions of “reasonable” tuition.3
- October 13, 2025: PSI School Training. Attendance at this state-mandated training is essential for understanding the KBC’s evolving standards for license verification and professional integrity.4
- July 1, 2026: STATS and Earnings Accountability Implementation. The OBBBA statutory requirements take full effect, replacing the GE/FVT regulations. Institutions will receive their first official “Earnings Premium” results based on 2025 tax data.11
Policy Shifts and Long-Term Trends
The “Workforce Pell” expansion under the OBBBA creates a significant opportunity for beauty schools that can demonstrate high-value outcomes without excessive debt.17 However, this opportunity is tied to a new “Administrative Capability” requirement: institutions must demonstrate that at least half of their aid volume is not tied to programs that fail the earnings premium test.14 This “50% rule” is intended to prevent schools from using a single “flagship” program to subsidize underperforming offerings.14
The elimination of Grad PLUS loans and the introduction of Parent PLUS caps will likely lead to a shift in the student demographic toward independent, adult learners who are seeking fast, career-focused credentials.19 Schools that emphasize a “debt-free” or “low-cost” model will have a significant competitive advantage as the private lending market becomes more restrictive for students in low-wage occupations.19
Navigating the Reporting Environment: The STATS Framework
The Student Tuition and Transparency System (STATS) represents the final evolution of postsecondary data collection for the foreseeable future. Under STATS, the Department of Education will publish a “College Scorecard” that includes not just graduation rates, but also net price, student debt levels, and post-enrollment earnings at the program level.14
The STATS framework requires institutions to report:
- Date of initial enrollment for every student.14
- Private education loan amounts received by students who complete or withdraw.14
- Institutional grants and scholarships provided for the student’s entire enrollment period to calculate an accurate net price.8
- Completion dates and median time to complete, differentiated by full-time and part-time status.11
This level of granular data collection is intended to “empower students to make more informed decisions”.25 For the KBC and state regulators, STATS data will provide a secondary verification mechanism to ensure that the hours reported at the state level align with the enrollment dates reported at the federal level.
Implications for State-Licensed, Non-Title IV Schools Like LBA
While the most severe federal penalties—the loss of Direct Loan eligibility—do not directly impact a school that does not participate in the loan program, the OBBBA and the STATS framework create an environment where the “non-participation” of a school is no longer a shield against transparency.
First, the “Do No Harm” provision is being used by researchers and policy analysts to contrast the outcomes of different school models.3 If LBA continues to achieve 90% placement rates with zero student debt, its data will likely be used by the Department of Education to justify further restrictions on higher-cost schools.3 Second, the KBC’s move to collect student contracts is a direct result of the federal “Financial Value Transparency” movement.4 The state is ensuring that it has a record of the financial terms of non-Title IV schools to protect students from potential predatory practices that exist outside the federal aid system.
Third, the “Red Flag” system will likely include a designation for schools that are not Title IV eligible or have not submitted data to the STATS system.3 While this is not a legal barrier to operation, it is a significant consumer-facing signal. Schools like LBA should consider voluntarily providing data to national dashboards or maintaining their own “Clarity Reports” to demonstrate that their outcomes exceed federal and state benchmarks.3
Conclusion: The Professional Path Forward in the Commonwealth
The investigations into the federal and state context reveal that the beauty education sector in Kentucky is no longer an isolated industry. The Kentucky Board of Cosmetology’s recent communication regarding accreditation, Title IV, and reporting is a necessary response to a nationwide shift toward outcome-based accountability. Under the leadership of Joni Upchurch, the KBC is aligning its regulatory mechanisms with the transparency requirements of the OBBBA and the STATS framework.
For the Louisville Beauty Academy, the primary “upcoming action” is not a change in aid status, but a change in the level of scrutiny regarding administrative operations. The requirement to submit student contracts and the strict enforcement of enrollment and withdrawal reporting are evidence that the state is monitoring the “administrative integrity” of all schools. Simultaneously, the federal “Earnings Premium” test is creating a market where low-cost, debt-free schools are uniquely positioned for growth, as larger, aid-dependent schools face the risk of losing Direct Loan eligibility.
By maintaining its focus on high pass rates, affordable tuition, and meticulous compliance with the KBC’s reporting mandates, an institution can thrive in this new regulatory era. The upcoming PSI School Training in October 2025 and the July 1 renewal deadline are the most immediate milestones for ensuring continued compliance with the Commonwealth’s standards. The long-term trajectory toward universal data transparency under STATS and the OBBBA suggests that the “Louisville Beauty Academy model”—defined by lower costs and outcome-based accountability—is becoming the national blueprint for vocational education.
Works cited
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- Cosmetology Training Needs a Make-Over – The Century Foundation, accessed March 12, 2026, https://tcf.org/content/report/cosmetology-training-needs-a-make-over/
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- MEMORANDUM – Kentucky Board of Cosmetology, accessed March 12, 2026, https://kbc.ky.gov/Annoucements/6.25.2025%20School%20Memorandum.pdf
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- DEPARTMENT OF EDUCATION 34 CFR Parts 600 and 668 [Docket ID ED-2023-OPE-0089] RIN 1840-AD57 Financial Value Transparency and Gai, accessed March 12, 2026, https://www.ed.gov/sites/ed/files/policy/highered/reg/hearulemaking/2021/nfrgeunofficialcopy.pdf
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- (GEN-24-04) Regulatory Requirements for Financial Value Transparency and Gainful Employment (Updated Sept. 16, 2024) – FSA Partner Connect, accessed March 12, 2026, https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2024-03-29/regulatory-requirements-financial-value-transparency-and-gainful-employment-updated-sept-16-2024
- Subject: Program Integrity: Gainful Employment–Debt Measures | Knowledge Center, accessed March 12, 2026, https://fsapartners.ed.gov/knowledge-center/library/federal-registers/2011-06-13/subject-program-integrity-gainful-employment-debt-measures
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- The U.S. Department of Education’s Proposal on OBBB Accountability – Acenet.edu, accessed March 12, 2026, https://www.acenet.edu/Documents/Summary-ED-Proposal-OBBB-Accountability.pdf
- 2026 Gainful Employment – nasfaa, accessed March 12, 2026, https://www.nasfaa.org/ge_2026
- AACS and Ogle School Management File Briefs in Gainful Employment, accessed March 12, 2026, https://myaacs.org/aacs-and-ogle-school-management-file-briefs-in-gainful-employment/
- Department of Education and Negotiators Reach Consensus on …, accessed March 12, 2026, https://ticas.org/accountability/ahead-neg-reg-session-2-recap-jan-2026/
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- Implementing the Do No Harm Earnings Provision | Urban Institute, accessed March 12, 2026, https://www.urban.org/sites/default/files/2026-01/Final_Implementing_the_Do_No_Harm_Earnings_Provision.pdf
- State Policy Digest | November 2025 – The Institute for College Access & Success, accessed March 12, 2026, https://ticas.org/state-policy-network/state-policy-digest/november-2025/
- AHEAD Committee Kicks Off Second Neg Reg Session … – NASFAA, accessed March 12, 2026, https://www.nasfaa.org/news-item/37943/AHEAD_Committee_Kicks_Off_Second_Neg_Reg_Session_Focused_on_New_Accountability_Framework
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