Hypersurfaces of constant $2$-mean curvature in spaces of constant sectional curvature are known to be solutions to a variational problem. We extend this characterization to ambient spaces which are Einstein. We then estimate the $2$-mean curvature of certain hypersurfaces in Einstein manifolds. A consequence of our estimates is a generalization of a result, first proved by Chern, showing that there are no complete graphs in the Euclidean space with positive constant $2$-mean curvature.