Protecting the PA Pipeline: Frequently Asked Questions about the ED’s Proposal to Cap Student Loans

November 20, 2025

The November 7th announcement from the Department of Education (ED) regarding how it plans to implement caps on graduate student loans has created an uproar in the PA community – and in several other healthcare professions that stand to be significantly impacted.

But what is the negotiated rulemaking process, and what does this mean for current PA students?

To answer those questions and others that have surfaced, AAPA has prepared the following FAQ to provide PAs with the facts.

AAPA will continue to update the PA community about developments regarding the ED’s proposal and opportunities to push for change! If you have a question that is not captured below, please contact [email protected].

Q: Why did the Department of Education engage in this negotiated rulemaking?

A: H.R. 1, the One Big Beautiful Bill Act, eliminated the Grad PLUS loan program and put in place new borrowing limits depending on program classification. ED must create new regulations to define and implement these classifications through the rulemaking process.

Under the Higher Education Act, the Department of Education is required to convene a committee of stakeholders to negotiate the proposed regulatory text, with the goal of reaching a consensus. This consensus-driven process is known as “negotiated rulemaking.”

Q: What does H.R. 1 say about new student loan limits?

A: H.R. 1 eliminates the Grad PLUS loan program, which previously allowed students to borrow up to the full cost of attendance. Beginning July 1, 2026, the law establishes two federal borrowing tiers: graduate programs and professional programs, each with different loan limits.

Before July 1, 2026 (Current System)

• Grad PLUS Loans: No annual or lifetime cap; students could borrow up to full cost of attendance.
• Direct Unsubsidized Loans: $20,500/year; $138,500 lifetime limit (separate from Grad PLUS borrowing).

After July 1, 2026 (New System Under H.R. 1)

• Grad PLUS Loans: Eliminated for new borrowers.
• Graduate Programs: $20,500/year; $100,000 lifetime limit.
• Professional Programs: $50,000/year; $200,000 lifetime limit.

The law defines a professional degree program as one that meets the requirements of section 668.2 of title 34 of the Code of Federal Regulations, which says:

A degree that 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. Professional licensure is also generally required. Examples of a professional degree include but are not limited to 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.), and Theology (M.Div., or M.H.L.).

Q: What definition of “professional” program did negotiators agree to?

A: Negotiators agreed to limit the definition of “professional” to only the 10 programs explicitly mentioned in 668.2 of Title 34 of the Code of Federal Regulations, plus PsyD and psychology PhD programs that lead towards licensure. All “professional” degree programs, as defined by the agreement, would need to have a 4-digit classification of instructional program (CIP) code, which is in the same group of codes all the fields of student mentioned in section 668.2, Title 34 in the Code of Federal Regulations. This excludes PAs, nurse practitioners, occupational therapists, and many other healthcare professionals.

Q: If PA programs meet the criteria for a professional degree under H.R. 1, why are PAs excluded from the higher loan limits?

When the Department of Education concluded its negotiated rulemaking process to implement student loan portions of H.R. 1, it announced that an agreement was reached by the negotiators that would, among other things, exclude PAs and many other healthcare professionals from newly created “professional” loan limits. Because PA programs were not included in that narrowed list of professional programs, they are excluded from the higher loan caps and categorized under the lower “graduate” limits. This interpretation contradicts Congressional intent and is why we are urging the Department to revise the proposal.

During negotiations, representatives of the Department argued that if they had adopted a more expansive definition of “professional” that went beyond the 10 programs explicitly mentioned in the Code of Federal Regulations (and Psychology programs included in the same 4-digit CIP code group as those 10) while excluding some other programs, they would have opened themselves up to legal action because their regulation would not have a clear basis in law. The Department also argued that they would need more Congressional guidance to adopt a more expansive definition of “professional” program. However, AAPA believes the negotiated agreement also does not have a clear basis in law.

Q: Are the agreed-upon changes effective now?

A: No. Changes to federal graduate student loan limits set in motion by H.R. 1 will not take effect until July 1, 2026. And, importantly, the negotiators coming to an agreement does not make what they agreed upon official. The Department of Education still needs to issue a “notice of proposed rulemaking,” which will trigger a public comment period.

Public comment periods are usually between 30-60 days long, and AAPA expects the comment period for this proposed rule to be 30 days long. Once the comment period is over, the Department of Education will release a final rule that will take effect on July 1, 2026.

Q: What happens now that the negotiated rulemaking process is over?

A: Although these changes are not yet finalized through the regulatory process and the law does not take effect until July of 2026, the Department of Education will use the agreed-upon language to write their proposed rule to implement the new loan limits.

Q: Does this affect current students who already have been issued federal loans?

A: No. If finalized, the new limits will only apply to new federal borrowers after July 1, 2026. Borrowers who already have loans will not be affected.

Q: When can we expect the Department of Education’s proposed rule including the agreed-upon changes to be published?

A: We cannot know for sure when the Department of Education will publish its rule, but the Department has indicated it will likely be published early 2026.

Q: What can we do right now to oppose these changes that will make it more difficult to afford PA school, decrease access to care for patients, and worsen the shortage of healthcare providers across the country?

A: Here’s what you can do right away:

• Sign Our Petition: AAPA is asking as many PAs, PA students, and aspiring PAs as possible to sign our petition to the Department of Education urging them to revise this proposal. We need a strong showing of public outcry, so please share the petition with colleagues, PA students, and aspiring PAs in your networks and encourage them to sign, too.
• Share Your Personal Experience: We are also collecting personal stories from those willing to share why student loans were essential to their education and what it would mean if future students could not access the funds needed to cover their training. Your voices and stories will help us put a human face on this issue and show the Department what’s truly at stake for our workforce and the patients we serve.
• Stay Engaged: Once the public comment period opens and as this rulemaking process continues to unfold, AAPA will coordinate additional actions for PAs to take part in. A unified and coordinated voice from the profession will be critical.

Q: What does AAPA plan to do to prevent this from being finalized?

A: AAPA worked to inform negotiators and other stakeholders from the start to ensure that PAs’ voices were heard. We began contacting legislators, the Department of Education, and other healthcare professional associations as soon as the agreement to inappropriately limit the definition of “professional” program was confirmed.

AAPA will comment on the proposed rule once it is published and will explore every available avenue to ensure that PA programs are included under the definition of “professional program,” as consistent with the law as passed by Congress.

Q: Won’t limiting the amount students can borrow in federal loans influence educational institutions to reduce the cost of programs?

A: While we cannot be sure about the effects of this policy change, the stated rationale for eliminating the unlimited Grad PLUS program and setting a lower limit for most graduate borrowing was to push educational institutions to lower costs. However, the same effect would presumably apply to the “professional” education programs the Department of Education ultimately included in the proposal negotiators agreed on, and AAPA believes the law does not limit the definition of “professional” to just those programs.

Further, the programs explicitly mentioned in the Code of Federal Regulations as examples of “professional” programs have little in common, and thus it is unlikely they were intended to be singled out as professional programs more deserving of higher federal loan limits than PA programs and other healthcare professional programs.

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