Consensus Reached on Reforms to Federal Student Aid

The Department of Education concluded the Reimagining and Improving Student Education (RISE) negotiated rulemaking committee, which covered a wide range of reforms to the federal student financial aid system enacted under the One Big Beautiful Bill Act (OB3).

Negotiators reached consensus on the entire package of 17 provisions, and the Department anticipates publishing a Notice of Proposed Rulemaking in early 2026. Following a public comment period, the Department will move to publish final rules in spring 2026. Despite the short turnaround time, the finalized rules will go into effect on July 1, 2026. Because the negotiated rulemaking committee reached consensus on the policy package, NAICU expects the final rules to mirror the policy parameters outlined in the negotiated rulemaking process.

Many of the provisions were not controversial, and negotiators quickly reached agreement on the terms of their implementation. The Department also made several concessions that will benefit students and institutions, such as including healthcare programs that currently have higher borrowing limits in OB3’s grandfathering exception.

The most closely scrutinized provision was the new definition for “professional” programs, which determines whether enrolled students have access to the new higher federal loan limits of $50,000 annually and $200,000 in aggregate. Students enrolled in programs that do not qualify as professional will only be eligible for $20,500 annually and $100,000 in the aggregate. The new definition adds only one field, Clinical Psychology, to the original list of ten in the proposed rule.

According to the Department’s presentation during the negotiation, the new list of eligible programs consists almost entirely of clinical psychology programs, with a small number of doctoral divinity programs. Approximately 150 new programs will be added to the prior list, with a total enrollment of just under 13,000 students. Of the students enrolled in potentially eligible programs, about 3% will now qualify for professional borrowing limits.

This result omits many critically important programs that could satisfy the requirements to be considered professional, such as physicians assistants, physical and occupational therapists, audiologists, civil, mechanical, electric, chemical, and industrial engineers, architects, and more.

Despite these ommissions, negotiators agreed to the restrictive definition to prevent the Department from removing the positive concessions made in other areas. The agency made clear that these concessions would be eliminated if consensus was not reached.

The text of the definition is:

1. A professional degree is a degree that:
   1. Signifies both completion of the academic requirements for beginning practice in a given profession, and a level of professional skill beyond that normally required for a bachelor’s degree;
   2. Is generally at the doctoral level, and that requires at least six academic years of postsecondary education coursework for completion, including at least two years of post-baccalaureate level coursework;
   3. Generally requires professional licensure to begin practice; and
   4. Includes a four-digit program CIP code, as assigned by the institution or determined by the Secretary, in the same intermediate group as the fields listed in paragraph (2)(i) of this definition.

2. A professional degree may be awarded in the following fields:
   1. Pharmacy (Pharm.D), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), Theology (M.Div., or M.H.L.), and Clinical Psychology (Psy.D. or Ph.D.).

3. A professional student under this definition:
   1. May not receive title IV aid as an undergraduate student for the same period of enrollment; and
   2. Must be enrolled in a program leading to a professional degree under paragraph (2) of this definition.

In short, to qualify as professional, a program must: 1) lead to licensure; 2) be at least two years long beyond a bachelor’s degree; and 3) be within these Classification of Instructional Program codes:

• 01.80 (Veterinary Medicine)
• 22.01 (Law)
• 39.06 (Theological and Ministerial Studies)
• 42.28 (Clinical, Counseling and Applied Psychology)
• 51.01 (Chiropractic)
• 51.04 (Dentistry)
• 51.12 (Medicine)
• 51.17 (Optometry)
• 51.20 (Pharmacy, Pharmaceutical Sciences, and Administration)

NAICU will continue to work with the Department, Congress, and the higher education community to strengthen access to federal student aid funding to support student access to graduate education.

For more information, please contact:
Justin Monk