Today, the U.S. Department of Education (ED) published final regulations to implement congressional changes to student loans and student loan repayment passed through the One Big Beautiful Bill Act (OBBBA).
Catch up quick: As we’ve covered previously, the regulations were developed and finalized through the negotiated rulemaking process. ED first convened the Reimagining and Improving Student Education (RISE) negotiated rulemaking committee to craft the regulations in September 2025. The regulations have since undergone a public comment period in which the regulations received over 80,000 public comments, and are now final.
This package of regulations does not implement all of the changes Congress made through OBBBA (which will be finalized through succeeding packages of regulations); however, it makes significant alterations to student loan borrowing and repayment programs available to borrowers post-graduation.
One of the most debated issues addressed by this package is the designation of post-graduate programs as either “graduate” or “professional” programs. As mandated by Congress in OBBBA, students in “graduate” programs will only be able to borrow $20,500 annually for their program while students in “professional” programs can borrow up to $50,000 annually for their program.
With the regulations, ED defines the following programs as “professional.” All other graduate programs are now considered “graduate” programs by ED:
- Pharmacy (Pharm.D.)
- Dentistry (D.D.S. or D.M.D.)
- Veterinary Medicine (D.V.M.)
- Chiropractic (DC or DCM.)
- 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.)
- Clinical Psychology (Psy.D. or Ph.D.)
Despite objections in the public comment period, and pressure from a coalition of state attorneys general, ED opted to exclude nursing programs from its definition of “professional” programs, confining students enrolling in those programs to the lower $20,500 annual cap on student loans.
The regulations also operationalize OBBBA provisions sunsetting the federal Grad PLUS loan program, and eliminates existing income-contingent repayment programs (including the Biden administration SAVE repayment plan). In their place, the regulations establish a new Tiered Standard repayment plan and a new income-driven repayment plan. The final rule will allow a borrower to rehabilitate a defaulted loan twice over the loan’s lifetime, where previous rules only allowed rehabilitation once.
What’s Next
Typically, new Title IV higher education regulations published by ED before November 1 in a given year cannot go into effect until July the following year. However, given that OBBBA specifically mandated that the changes go into effect on July 1, 2026, these regulations will go into effect on that date.
We also expect ED to finalize two other packages of regulations in the next few months that include regulations operationalizing the new federal Workforce Pell grant program and implementing new accountability requirements for higher education programs. More to come. In the meantime, reach out to us if you have any questions.
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