Log In
Sign Up
The American Musicological Society (AMS) has officially submitted a public comment regarding the Department of Education’s Notice of Proposed Rulemaking (NPRM) on the Student Tuition and Transparency System (STATS) and earnings accountability framework published on 20 April 2026. The public comment was also signed by the College Music Society (CMS), Society for American Music (SAM), Society for Ethnomusicology (SEM), and Society for Music Theory (SMT), which joined the AMS in expressing concerns about the proposed policy rule and its potentially catastrophic effects on music education.
The STATS and earnings accountability framework aims to increase transparency and accountability in higher education by using the earnings outcomes of program graduates to determine eligibility for student loans and other federal support for students. Specifically, the framework proposes to evaluate academic programs based on the average earnings of their graduates (as measured four years out from the degree) to determine the eligibility of subsequent program enrollees for federal direct loans and other forms of Title IV funding (Pell Grants, FSEOG, and work study).
While the intent of the proposed rule is to encourage institutions of higher education to provide better value for students and taxpayers, the focus on earnings as the only meaningful benchmark of career or program viability is deeply problematic. It disproportionately disadvantages programs in fields like social work and the arts, or at institutions like conservatories or seminaries, where graduates tend to pursue careers with intrinsic social and cultural value but low to moderate financial returns.
Written in response to the Department of Education’s (DOE) request for feedback and suggestions on the proposed rule, the American Musicological Society’s public comment is intended to improve DOE rulemaking by spotlighting the ways in which the proposed rule may result in unintended harm to music students and programs. Those ways include: 1) failing to accurately assess the earnings of music program graduates; 2) misaligning earnings and career outcomes and thereby unfairly punishing smaller and less common educational programs; 3) leading to the loss not only of access to federal students loans (which can result in excessive indebtedness), but also to Pell Grants (which do not require repayment and do not increase indebtedness); and 4) effectively foreclosing the right to appeal punitive judgments or to correct or cure data, rights provided for in the Administrative Procedure Act.
We encourage you to read the public comment to see the details for yourself. However, please be aware that the possible solutions offered should not be viewed as an endorsement of the proposed rule, but as an attempt by the AMS to influence public policy–making in ways that reduce and mitigate harm. The AMS remains committed to the generous funding of music education at all levels and to the support of careers in music education, performance, administration, and advocacy that produce knowledge, goods, and services of enduring and intrinsic social and cultural value.
How You Can Take Action
If you share the Society’s concerns about the Department of Education’s proposed STATS and earnings accountability framework, we encourage you to submit your own public comment. The comments of both individuals and institutions matter, and the more public comments the DOE receives expressing concern about the adverse impacts of this rule, the more likely the Department is to amend or revise it or the plans for its implementation. Moreover, even if public comments do not alter the design or implementation of the proposed rule, they can provide a valuable basis on which to advance later administrative or legal challenges.
If you wish to submit a public comment to the Department of Education, you must do so no later than 20 May 2026. Before submitting your comment, you may wish to consult this list of concerns. It summarizes some of the American Musicological Society’s issues with the STATS framework and may be a useful resource as you draft your comment.
About AMS Advocacy
The mission of the AMS is to advance our understanding of music and sound. In service of that mission, the AMS regularly engages in advocacy on behalf of music students, teachers, researchers, performers, and other professionals, as well as the wider public that benefits from and supports their work. If you approve of AMS advocacy initiatives, please consider joining the AMS or donating to the Society’s unrestricted Annual Giving Fund to show your support.
