The Department of Education (ED) will convene two negotiated rulemaking committees this fall to implement the reconciliation bill signed into law on July 4, along with other administration priorities, including controversial changes to the Public Service Loan Forgiveness (PSLF) program unveiled on Friday.One committee will focus on federal student loan programs, while the other will take up institutional accountability, Pell Grant eligibility, and broader Title IV issues.
Clarity Needed on Loan Limits and Repayment
At ED’s Aug. 7 virtual hearing on implementation of the reconciliation law (commonly referred to as the “One Big Beautiful Bill Act,” or OBBB), ACE’s Emmanual Guillory highlighted concerns raised by campuses about how these significant changes will be put into practice. He stressed that clear, timely communication will be essential, especially around new loan limits and repayment plans. With millions of students and families depending on federal loans, delays or confusion could have immediate consequences.
ACE is also urging ED to publish a comprehensive list of professional degree programs that qualify for higher loan limits. Without such guidance, institutions will face uncertainty about whether students in fields like nursing or other licensure-based programs are eligible for expanded borrowing.
Another major concern is staffing. ED was crippled by staffing cuts ordered by the Trump administration and upheld by the Supreme Court, reducing its workforce by nearly half earlier this year. Campuses are already experiencing processing delays, compliance gaps, and reduced support. At the same time, OBBB requires ED to build new data systems and administer a program-level earnings test that could cut off federal loans to some programs. ACE is calling for sufficient staffing and resources to carry out these responsibilities without further disruption to students.
Accountability and Transparency
The new accountability framework in the OBBB ties Title IV eligibility to graduates’ median earnings. ACE has emphasized that the underlying data must be made public in a clear, accessible format so institutions and students understand how programs are being evaluated. Limiting access to that data would undermine trust and hinder institutions’ ability to respond.
Similarly, the law makes changes to Pell Grant packaging rules that could alter how non-federal aid interacts with Pell. ACE cautions that without clear guidance, institutions risk misinterpreting congressional intent and disadvantaging students who rely on Pell as a first-dollar benefit.
PSLF Overhaul Turns a Safety Net Into a Political Weapon
In addition to OBBB implementation, ED has proposed a significant change to the Public Service Loan Forgiveness program that ACE strongly opposes. A proposed rule formally announced today would allow the secretary of education to redefine which employers qualify for PSLF by excluding organizations deemed to have a “substantial illegal purpose.”
This would mark a fundamental departure from the law Congress enacted, which clearly defines PSLF-eligible employers and does not authorize carve-outs based on administrative determinations. By granting the secretary unilateral authority to disqualify nonprofits, universities, school districts, or local governments without a court ruling or input from other agencies, the rule risks transforming PSLF into a political tool.
ED’s early focus on issues such as immigration and gender-affirming care underscores the danger of ideological targeting. If finalized, the rule could strip PSLF eligibility from tens of thousands of public service workers—undermining the program’s statutory purpose and eroding trust in federal commitments. ACE views this as a misuse of regulatory authority that threatens to destabilize a program vital to attracting and retaining a public service workforce.
Comments on the proposal are due by Sept. 17.