Federal Rules Could Impact Schools Across the Country

Update: June 21, 2023

As you may know, the US Department of Education (USDOE) released new gainful employment rules that could impact skin care schools and students across the country.

This week, ASCP advocated on your behalf and submitted formal feedback and concerns to the USDOE regarding the proposed gainful employment regulations. As always, please reach out to the ASCP Government Relations team with any questions.


The US Department of Education (USDOE) released new gainful employment rules that could impact both esthetics schools and students across the country.

What’s Happening Now?
The USDOE released proposed rules in May to safeguard students against burdensome debt from attendance at career training programs. In the USDOE’s words, the proposal would create “the strongest-ever Gainful Employment (GE) rule, which would terminate access to Federal financial aid for career training programs that routinely leave graduates with unaffordable debt burdens or with earnings that are no higher than workers without any education beyond high school.”

On its face, the idea of ensuring student protection from undue debt burdens is a worthwhile endeavor. However, the USDOE’s debt-to-earnings ratio being used does not accurately interpret skin care professionals’ income and employment level. For example, “employment” ranges from some professionals working a few hours a week to full-time employment. Earnings from across the profession vary because of this reality. Thus, the USDOE’s debt-to-earnings ratio cannot correctly interpret the value schools add and could place many high-quality, well-intentioned programs in peril. As currently written, the USDOE Gainful Employment Rule potentially would make schools ineligible to offer financial aid.

ASCP believes in a vibrant education community in which healthy competition spurs all schools to strive for continuous improvement in the quality of their instructional offerings. The foundation of such commerce should be a “fair trade” ethic, one in which prospective students can make informed career and educational choices based upon presented information that is accurate and comprehensive. That’s why it’s imperative for educators to advocate for rules that are written to more fully interpret the earnings from the field.

In our opinion, the USDOE’s debt-to-earnings ratio does not accurately interpret skin care professionals’ income and employment level.

What are Gainful Employment Rules?
In 2014, the Obama Administration finalized gainful employment rules that sought to curtail predatory for-profit colleges. Under these rules, for-profit schools had to provide data showing the success or failure of their students’ wages. If schools didn’t reach a certain threshold, they were stripped of their ability to collect Title IV federal funding (funding typically used by schools to provide financial assistance). The idea is simple: Schools must provide students with a meaningful path to a livable wage. Gainful employment is a policy lever to hold schools, specifically for-profit schools, accountable.

How Can I Advocate?
For this reason, it’s important that you elevate your voice today. The USDOE is accepting public comments through June 20.
Add your voice to the growing list of professionals asking the USDOE to revise its debt-to-earnings ratio to better reflect the reality of our community. You can submit your comments to the USDOE here.

If you have questions or concerns about gainful employment, please contact the ASCP Government Relations team at gr@ascpskincare.com.

Please note: We have recently updated our Privacy Policy and Terms of Use. Learn more...