Department of Education’s Proposed STATS Rule Threatens to Dismantle Music Education in America

Joined by sister societies, the AMS warns that a proposed Department of Education policy will severely damage music education in the US.

NEW YORK, NY, UNITED STATES, May 19, 2026 /EINPresswire.com/ -- The American Musicological Society (AMS) has submitted a public comment to the US Department of Education regarding the Notice of Proposed Rulemaking (NPRM) for the STATS (Student Tuition and Transparency System) and earnings accountability framework. Co-signed by the College Music Society (CMS), the Society for American Music (SAM), the Society for Ethnomusicology (SEM), and the Society for Music Theory (SMT), the letter outlines deep concerns over the rule’s potential to severely damage music education in the United States.

While the AMS supports the Department of Education’s stated aims of reducing student loan debt and increasing transparency in higher education, its public comment argues that the proposed STATS and earnings accountability framework will have harmful unintended consequences. Under the proposed rule, the Department would terminate access to federal student loans for students enrolled in programs whose prior graduates failed to meet specific income benchmarks. Furthermore, if half of an institution’s students fall short of these income benchmarks (as measured four years after graduation), all subsequent enrollees at that institution could lose access to Pell Grants and other Title IV funding.

As described in the NPRM, this accountability framework relies strictly on short-term earnings data and as such fails to accurately capture the educational value and vital public contributions of graduates in music and related fields. Moreover, as currently formulated, the rule struggles to accurately assess the real income of music program graduates and other individuals who earn significant amounts of their income from freelancing, sole proprietorships, and other “gig” work. Freelance or “gig” work income is often underreported or reported as business income, which would have the effect of underestimating earnings of music program graduates.

Also worth noting is that the One Big Beautiful Bill Act of 2025 (OBBBA) raised the 1099 per-payee reporting threshold for non-employee compensation, rent, and other services from $600 to $2,000, greatly exacerbating the challenge of assessing the incomes of musicians, music educators, and other “gig” workers.
Although the Department of Education’s proposed rule is intended to support “program quality,” the AMS believes its practical impact will be to severely damage music education in America. As explained in the public comment: “The proposed rule is likely to disqualify students at The Juilliard School, regularly ranked the best music school in the country and the world, from receiving both federal student loans (which must be repaid) and Pell Grants that do not add to student indebtedness (because they need not be repaid).”

The Juilliard School is just one of over eighty US music schools and programs which the Department’s own AHEAD data suggests will lose access to federal direct student loans and possibly other forms of Title IV funding (Pell Grants, FSEOG, and work study) should the rule be implemented as proposed.
The AMS encourages individuals and institutions who share these concerns to submit their own comments to the Department of Education before the deadline on 20 May 2026. A robust public response is essential to prompt administrative revisions and mitigate potential harms to higher education.

About the American Musicological Society

The American Musicological Society (AMS) is a nonprofit organization dedicated to advancing our understanding of music and sound. Founded in 1934, the AMS is the oldest and largest music studies nonprofit in the country. It serves a diverse membership of educators, researchers, performers, administrators, students, and creative professionals. The Society works to foster a vibrant musical culture and advocates for the sustained support of music education at all levels.

Siovahn A. Walker
American Musicological Society Inc.
+1 212-992-6340
ams@amsmusicology.org
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