The School of Visual Arts (SVA) in New York City is to aspiring illustrators, fine artists, and photographers what Johns Hopkins University Medical School is to aspiring doctors: a challenging, prestigious institution where their craft can be best learned and skills honed. Both institutions are well-respected, with exceptional track records of preparing their students for their chosen fields.

Just as the Johns Hopkins student will leave his or her graduation ceremony with a diploma and, in GE Rule parlance, a substantial debt-to-earnings ratio, so, too, will the SVA graduate — but for a very different reason. It’s not the cost of their training and tuition, but rather that artists are rarely compensated at the same level, nor do they enjoy the same job security, as their white-collar peers once they finish their schooling (hence the old cliché about “starving artists”). Indeed, it is because of the high initial unemployment rates and low earnings that await recent graduates with degrees in fine arts, graphic design and photography — the very types of programs in which SVA specializes — that these majors were listed among the least valuable ones to pursue in a study by Georgetown University’s Center on Education and the Workforce.

Most art students, if not all, know upon entering an arts program that turning their creative passions into lucrative careers can be difficult and that their job opportunities will be somewhat limited. If you ask them, however, the refrain you will likely hear most often is that the lack of financial gain is a fair price to be paid to hone the talents and creative skills that will enable them to pursue more personally meaningful and fulfilling endeavors. And, in fact, adults who are engaged in an artistic practice are more likely to say they are satisfied with their lives, according to a recent study published by The Curb Center for Art, Enterprise, and Public Policy at Vanderbilt University.

That’s not to say that the traditional definition of career “success” is out of reach for art school attendees and graduates. Among SVA’s celebrated alumni, for example, are renowned artists Keith Haring, Sol LeWitt and Elizabeth Peyton, illustrator Paul Davis, director Carlos Saldanha, composer Michael Giacchino, cinematographer Harris Savides, journalist Pete Hamill, and comic book artist Phil Jimenez, among many other artists. Their level of popular acclaim and commercial success, however, is just not a commonly reached one.

By holding proprietary art schools such as SVA accountable to the proposed Gainful Employment Rule, however, the Department of Education disempowers students at institutions such as SVA of their right to define success for themselves. Through the metrics the Department has adopted as the end-all, be-all measurements of program success, the message being sent to aspiring artists and creative talents is simple and clear: following your bliss is irrelevant. The only thing that matters is your earnings power.

Make no mistake: SVA is a long-established and well-respected member of the creative community that produces sound outcomes for the aspiring artists that choose to attend it. This is not a school that deserves to be in the Department’s target sights, not when so many other schools — including community colleges and other taxpayer-supported schools — are posting abysmal results that cannot compare to those of SVA. As the 67 year-old institution noted in its comments to the Department on the GE Rule, SVA graduates 65% of its first-time, full-time freshman, as well as 72% of transfer students, and more than 80% of its graduate students. Further, of the independent colleges of art with which SVA competes, it has the second-lowest percentage of students who borrow and the level at which they borrow is in line with what its public peer institutions are experiencing. The quality of the programs  offered — many of which, at the graduate level, are ranked among the top 10 in the country by U.S. News & World Report — is compelling, yet none of the above matters for purposes of the GE Rule. It should.

Do we really want to arbitrarily put strong programs producing strong outcomes for their students at risk simply because they serve individuals who aspire to something greater than being in the 39% tax bracket? Surely there’s nothing meaningful to be gained from doing so. The unfair and undeserved impact on schools such as SVA is just one more reason why APC opposes the proposed GE Rule and respectfully requests that the Department take a more pragmatic approach to the issue.