Although colleges receive funds from student loans, they have largely escaped accountability for their role when students take on unaffordable student loan debt. One partial exception was a set of regulations called "Gainful Employment" that sought to hold some higher education programs accountable for excessive student loan debt. If a targeted program's students had too much debt relative to their income, the program would lose access to the federal financial aid programs. "Gainful Employment" is no longer in effect, but some policymakers are considering reviving the regulations. This study explores the approach used by "Gainful Employment" to help policymakers develop the next iteration of accountability for higher education. It uses new U.S. Department of Education College Scorecard data (U.S. Department of Education, n.d.) and an updated approach called "Gainful Employment Equivalent" to help policymakers envision better accountability mechanisms for higher education by building on Gainful Employment's successes while avoiding its flaws.