By CJ Powell
Earlier this month, a Department of Education-convened committee negotiated and reached consensus on draft regulations to implement student loan provisions in a bill (H.R.1) that Congress passed earlier this year. The new regulations will limit the number of degree programs that can be considered as “professional,” thereby curtailing the number of programs that will be eligible for higher loan limits set under H.R.1.
The bill, signed into law by President Trump this past July, imposes a lifetime cap of $100,000 in borrowing for graduate students and $200,000 for professional students. Annually, graduate students will be able to borrow no more than $20,500 while professional students will be able to borrow no more than $50,000 under the new law. The bill also terminates Grad PLUS loans, which graduate and professional students have used to pay for education expenses not covered by other financial aid, starting July 1, 2026.
Because of these changes, there was significant interest during the rulemaking session in determining which programs would qualify as “professional” and, therefore, be eligible for the higher $200,000 loan limit.
By the end of the session, the department and the Reimagining and Improving Student Education (RISE) committee agreed to recognize only 11 primary programs as well as some doctoral programs as professional degree programs. The 11 primary programs, which encompass 10 of the programs listed in H.R.1 plus one addition, include: pharmacy, dentistry, veterinary medicine, chiropractic, law, medicine, optometry, osteopathic medicine, podiatry, theology, and newly added, clinical psychology.
According to Inside Higher Ed, the committee adopted a narrow definition of a professional degree program despite stakeholders pushing for “high-demand health-care professions, such as physician assistants, nurse practitioners and audiologists, as well as programs in architecture, accounting, education and social work to all be considered professional and thus eligible for the higher borrowing limits.”
To reach consensus, in an unlikely move, the Education Department sought agreement on the entire package of proposals discussed during the negotiations instead of on each individual proposal. Given that the department had made several concessions regarding other provisions related to student loan repayment, negotiators chose not to negate the work they had done over the past several weeks and voted to grant consensus.
The $200,000 loan cap for professional degree programs, plus the small number of programs that would be eligible for it, is likely to reduce access to advanced degrees for many Americans and to create or worsen labor shortages in certain professions.
For example, The New York Times reported earlier this year that the loan cap on professional programs would worsen the country’s doctor shortage since federal loans will no longer cover the full cost of a medical degree (on average, $286,454 at a public university and $390,848 at a private institution, according to the Association of American Medical Colleges). Aissa Canchola Bañez, policy director at the Student Borrower Protection Center, told The New York Times that the loan caps “will either push students and families into the private loan market, where they take on more risk and have less consumer protection, or simply push people out of higher education altogether.”
Loan limits on graduate and professional degree programs also fail to take into account the fact that students with graduate and professional degrees tend to earn higher incomes and have lower default rates on their student loan debts than other student loan debtors.
The department plans to publish the agreed-upon regulatory language in the Federal Register early next year; institutions and the public will have the opportunity to comment before the rules are finalized.
The department is next scheduled to meet with the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) committee in December to negotiate regulations on institutional and program accountability, Pell grants, and other issues.
CJ Powell is associate vice president for government relations and public policy at AAU.