Graduate Loan Limits and Professional Degree Definitions Take Shape in ED Proposal

ACE has released a detailed regulation summary outlining the proposed changes adopted through the Reimagining and Improving Student Education (RISE) negotiated rulemaking process, including new loan limits, repayment structures, and borrower eligibility provisions, to help institutions understand the proposal and prepare their own public comments.

As proposed, the rule would phase out access to Graduate and Professional PLUS Loans for new borrowers, establish new annual and lifetime loan limits for graduate, professional, and parent borrowers, and restructure federal repayment options into a Tiered Standard Repayment Plan and a single income-based Repayment Assistance Plan.

The proposal also adopts a narrow definition of "professional" degree programs, limiting eligibility for higher federal loan caps to 11 fields, including medicine, law, dentistry, and veterinary medicine. Graduate programs outside these categories would be subject to substantially lower borrowing limits, regardless of licensure requirements or workforce demand.

ACE has raised concerns about this approach throughout the implementation process. In an August 2025 letter to ED, ACE urged officials to ground the definition of professional degree programs in licensure and workforce needs so that federal student aid aligns with preparation for critical careers. Following the conclusion of the RISE negotiated rulemaking in November 2025, ACE has continued to press these concerns on Capitol Hill.

Congressional interest is now intensifying. ACE is supporting the Professional Student Degree Act, introduced by Rep. Mike Lawler (R-NY), which would restore access to higher federal loan limits for students in additional professional fields. Other legislative proposals would take broader approaches, including increasing loan limits for all graduate students or delaying implementation.

To reinforce these concerns, ACE will host a congressional briefing on Feb. 9 examining how the proposed definition of professional degrees could restrict access to federal aid in high-demand workforce fields. The briefing is part of ACE's broader advocacy effort around the Professional Student Degree Act and will feature Lawler.

The public comment period on the ED's proposal closes March 2. ACE will submit formal comments and encourages institutions to use the ACE regulation summary as a resource when preparing their own responses and engaging with congressional offices.