When the Obama administration implemented the first gainful employment (GE) rule in 2014 to protect students from education credentials that lead to unaffordable debts, virtually all programs at public institutions passed the test. The Biden administration is developing its own GE rule after the Trump administration repealed the Obama-era rule. A discussion draft of the rule released earlier this year included a new minimum earnings test based on high school graduates' earnings. One in five certificate programs at public institutions could fail this requirement, causing them to fail the overall GE rule and lose eligibility for federal aid. This essay examines the undergraduate certificate programs at public institutions that fail this proposed high school earnings test. Understanding the characteristics of these programs and the students they enroll can inform the ongoing development of the GE rule. This information can help policymakers judge whether the GE rule effectively targets low-quality programs and whether these programs leave students worse off than if they had never enrolled, the commonly cited rationale for a high school earnings test. [Additional funding for this essay was provided by the Stand Together Trust.]