The Biden administration is developing regulations around gainful employment (GE) that would protect students from career-oriented college programs that don't adequately serve their students. A draft GE rule released earlier this year would require that graduates of certificate programs at public and nonprofit colleges and nearly all programs at for-profit colleges meet a debt-to-earnings test to be eligible for federal aid. Using debt to measure value involves major limitations, however, and programs with poor outcomes can pass a debt-to-earnings test if students finance their tuition with federal grant aid or out-of-pocket funds instead of loans. Using data to examine the effects of several thresholds, the authors analyze a tuition-to-earnings test for the GE rule and compare it with the effects of the Biden administration's proposed debt-to-earnings test. This test more directly measures what a program costs, is not affected by the share of students borrowing, and measures prices charged to all students regardless of the type or amount of federal aid they received. [Additional funding for this essay was provided by the Stand Together Trust.]