ACE and more than 40 higher education associations have submitted comments to the Department of Education (ED) on proposed regulations implementing key student loan provisions of the One Big Beautiful Bill Act (OBBB), warning that ED’s narrow definition of “professional” degree programs could significantly restrict access to graduate education in workforce-critical fields. Under OBBB, students in programs designated as “professional” may borrow up to $50,000 annually, with a $200,000 aggregate limit. All other graduate students would be capped at $20,500 annually and $100,000 in total, subject to an overall lifetime limit of $257,500 including undergraduate loans. The law also eliminates the Grad PLUS loan program beginning July 1, 2026.
In its proposed rule, ED limits the higher borrowing caps to just 11 professional degree programs. ACE and the other associations argue that this interpretation is far narrower than the definition reflected in the statute and would exclude programs that meet rigorous academic standards and require professional licensure.
Programs that could lose professional designation include nursing and nursing specialties, social work, physician assistant studies, occupational and physical therapy, audiology, public health, architecture, accounting, and special education, among others.
The financial impact would be substantial. Analysis cited in ACE’s regulation summary indicates that about 28 percent of graduate borrowers need to borrow amounts exceeding the new limits. The effect is particularly acute in health-related fields: 39 percent of students in master’s-level health programs and 67 percent of doctoral-level health students borrow above the proposed caps.
More than 3.3 million students are enrolled in post-baccalaureate master’s, doctoral, and professional programs, and more than 1.3 million rely on federal loans to finance their education.
The associations warn that students who cannot borrow sufficient federal aid will be pushed toward private loans, which often carry higher interest rates and fewer borrower protections. Federal Grad PLUS loans currently carry interest rates below many private alternatives, which can reach into the high teens for borrowers without strong credit histories.
Higher Ed Dive has reported on the associations’ concerns, highlighting the stakes for fields such as health care and education.
At minimum, the groups urge ED to create and publish a comprehensive list of professional degree programs that reflect licensure requirements and workforce needs.
Congressional Activity and ACE Advocacy
Members of Congress have introduced legislation to address the issue. Rep. Mike Lawler (R-NY) authored the Professional Student Degree Act, which would expand the statutory definition of “professional student” to include additional fields such as nursing, social work, teaching, audiology, and public health. Other bills would raise graduate loan limits more broadly or delay implementation of the new caps.
ACE recently partnered with Rep. Lawler to host a bipartisan Capitol Hill briefing focused on ED’s proposed implementation and its impact on workforce-critical fields. ACE also addressed the issue in a recent dotEDU podcast episode featuring Valerie Fuller, president of the American Association of Nurse Practitioners, who discussed how the proposed definition could affect access to nurse practitioner education and patient care.
Implementation Must Comply with the Higher Education Act
In addition to raising concerns about the definition of professional programs, the associations’ comments challenge ED’s proposed implementation timeline.
Under the Higher Education Act’s “master calendar,” final regulations affecting Title IV student aid programs must be published by Nov. 1 prior to the award year in which they take effect. If that deadline is missed, implementation must be delayed until the following award year.
The associations argue that OBBB does not waive these statutory requirements. In prior legislation, Congress explicitly suspended master calendar and negotiated rulemaking provisions when it intended to do so. OBBB contains no such language.
Accordingly, the groups maintain that final RISE regulations issued in 2026 should not take effect until July 1, 2027, at the earliest, allowing institutions adequate time to update systems and advise students.
The associations’ comments urge ED to revise the proposed regulations to ensure that implementation of OBBB complies with federal law and preserves access to graduate and professional education in fields essential to the nation’s economy and communities.