By Bianca Licitra
Last week, AAU submitted a comment letter urging the Department of Education to delay finalizing a proposed rule that would implement changes to the federal student loan programs initially enacted last year in the H.R. 1 reconciliation bill. If implemented soon as currently drafted, AAU argued, the rule could cause serious problems for many students – and particularly those from lower- and middle-income backgrounds – in graduate and professional degree programs.
Based on the consensus language agreed to by negotiators from the Reimagining and Improving Student Education (RISE) rulemaking committee and the department, beginning in July 2026, H.R. 1 will impose a lifetime cap of $100,000 in borrowing for graduate students and $200,000 for professional students, while also terminating the Graduate PLUS program and limiting Parent PLUS loans.
As a result of the bill’s passage, the Department of Education is responsible for developing the regulations that implement the law, including determining which degree programs would qualify as “professional” and, therefore, be eligible for the higher loan caps. Following negotiations with the RISE committee, the department expanded the list of professional programs provided in the legislation by one program, to 11.
In its comment letter, AAU urged the department to delay implementation of the professional and graduate student loan caps until July 1, 2027, noting that institutions have not been given sufficient time to revise policies and procedures to carry out the changes.
The letter also argued that students require both additional time and further guidance to understand the changes. “Implementing this policy shift with so little lead time could be devastating to students who lack financial resources or outside support to absorb the impact,” the letter said. It added that, “Without clear government guidance articulating what has changed and who is affected, students may be surprised when reviewing financial aid offers and unable to cover funding gaps that are the result of the changes in H.R.1.”
"Implementing this policy shift with so little lead time could be devastating to students who lack financial resources or outside support to absorb the impact."
AAU also joined another letter from the higher education community (led by the American Council on Education) that emphasized the importance of expanding the list of professional degree programs. These programs, the letter said, “help educate students in highly skilled, in-demand professions that are critical to our economy, such as nursing, education, and social work.” The community letter suggested that institutions should be able to determine which programs on their campuses are considered professional degree programs, as they currently do.
More than 150 members of Congress also signed a bipartisan, bicameral letter pointing specifically to the exclusion of post-baccalaureate nursing degrees from the professional degree category. “At a time when our nation is facing a health care shortage, especially in primary care, now is not the time to cut off the student pipeline to these programs,” they wrote. Many lawmakers have also urged the department to reconsider the list of professional programs and have proposed legislation to change the law.
AAU emphasized in its own letter that the ambiguous definitions provided by H.R.1 offer an opportunity for the department to recognize a broad range of professional programs, describing the limited list as “outdated” and failing to “reflect the realities of today’s graduate and professional landscape.” The letter argued that “the Department should facilitate innovation, not constrain it, particularly given the impossibility of anticipating which fields will emerge and evolve.”
As the letters make clear, changes offered in the proposed rule are likely to reduce access to advanced degrees for many Americans, while also creating or worsening labor shortages in high-demand professions.
The department will now consider the thousands of comments it received in response to the proposed rule before finalizing the regulations.
Bianca Licitra is editorial and communications assistant at AAU.