AAPA Files Formal Comments Opposing Proposed Federal Student Loan Rule

Here’s What We Told the Department of Education — and Why It Matters for PAs

February 26, 2026

The American Academy of Physician Associates (AAPA) has filed formal public comments with the U.S. Department of Education (ED) opposing its proposal to exclude PA programs from higher federal “professional” student loan limits and urging the Department to align the final rule with the statute by classifying PAs under the professional loan tier. 

This rule, if finalized as written, would place PA students in the lower “graduate” borrowing tier, limiting annual federal loans to $20,500 beginning July 1, 2026. For most PA programs, that cap would fall far short of tuition alone, not to mention living expenses given that most PA programs have strict limitations on being able to work while in PA school. This change will force students to rely heavily on private loans or personal wealth to finance their education. 

AAPA’s formal comments focused heavily on the fact that PA programs meet the statutory definition of a professional degree, and ED’s proposal is inconsistent with federal law. 

Here’s a breakdown of what we argued and what it means for the profession:

1. PA Programs Meet the Definition of a “Professional Degree” 

Public Law 119-21 (H.R. 1) created new federal student loan limits and defined who qualifies as a “professional student.” Instead of establishing a new definition, Congress pointed to an existing federal regulation (34 C.F.R. § 668.2) and said that definition must be used. 

Under this straightforward and clear regulation, a professional degree is defined as one that prepares someone to begin practice in a profession, requires education beyond a bachelor’s degree, and generally requires professional licensure. PA programs clearly meet all of those standards. 

PA education is graduate-level, culminating in a master’s degree. Students complete approximately 2,000 hours of clinical rotations in healthcare settings. To become licensed, graduates must attend an ARC-PA–accredited program and pass a national certifying exam. Every state, the District of Columbia, and U.S. territories require licensure to practice as a PA. 

AAPA’s public comments highlighted how PA programs satisfy every element of the definition Congress incorporated into the law. The comments further clarify that Congress did not give ED the authority to rewrite or narrow that definition. The statute explicitly says the existing regulation must be applied “as in effect on the date of enactment.”  AAPA reasoned that ED is required to use the definition Congress referenced and not create a new, more restrictive one that excludes PA programs. 

2. The Proposed Rule Adds Requirements That Do Not Exist in the Law

The proposed rule introduces new limitations that are not contained in the statute or the referenced regulation, including: 

• Requiring doctoral-level programs 

• Requiring programs to fall within specific four-digit Classification of Instructional Programs (CIP) code groupings 

• Suggesting that variation in state scope of practice disqualifies PAs 

AAPA’s comments call out that none of these requirements appear in the law. 

3. ED’s Scope of Practice and Supervision/Collaboration Argument is Flawed 

In the proposed rule, ED introduces a new justification for excluding PA programs from the “professional” loan category, arguing that variation in state scope of practice laws, particularly referencing collaboration or supervision requirements, means PA degrees do not qualify as professional degrees. 

AAPA’s public comments make clear that this rationale is legally unsupported and is  inconsistent with how healthcare education and regulation work. Congress did not include any references to how a profession is regulated at the state level beyond licensure in Public Law 119-21. The statute directs ED to apply the existing regulatory definition of a “professional degree.” That definition focuses on education, training, and licensure — not on whether state law uses the word “collaboration” or “supervision.” 

The comments further explain that ED’s reasoning is inconsistently applied. Scope of practice and state practice laws vary widely across healthcare professions that remain included under the proposed “professional” category. For example: 

• Scope varies for podiatrists from state to state. 

• Clinical psychologists cannot prescribe in most states. 

• Other included professions also operate under varying regulatory structures depending on jurisdiction. 

If variation in state scope were truly disqualifying, the same logic would exclude nearly every licensed healthcare profession. 

Today’s healthcare system is team-based. Physicians consult PAs. PAs consult physicians. Specialists consult primary care providers. Collaboration is not a marker of diminished professional status, instead it is the backbone of coordinated, patient-centered care. AAPA also argued that ED’s reliance on scope-of-practice variation is not grounded in longstanding federal recognition of PAs as licensed health professionals under Medicare, the Public Health Service Act, and other federal laws. 

4. The Financial Reality: The Proposed Cap Does Not Match the Cost of PA Education

PA programs are intensive, condensed medical education programs. They require highly trained faculty, clinical placements, simulation labs, and specialized facilities. 

There are currently 322 PA programs nationwide, with median tuition for in-state students averaging $96,900, while non-resident tuition averages about $101,229. When you factor in housing, fees, supplies, and other required expenses, the total cost of attendance often exceeds $200,000. At the same time, nearly all PA programs prohibit students from working during enrollment because of the program’s intensity. 

Under ED’s proposed rule, however, PA students would effectively be limited to borrowing just $41,000 total in federal loans for two-year programs and $61,500 for three-year programs. These amounts fall dramatically short of both tuition and full cost of attendance. 

In our public comments, we emphasized that this gap would push students toward higher-cost private loans, greater overall debt burden, and increased financial pressure to choose higher-paying specialties. Further, we shared findings from a recently conducted AAPA survey of PAs and aspiring PAs about how this proposed rule would shrink the PA pipeline.  

5. This Rule Is Misaligned With Broader Federal Workforce Goals 

Congress and the Administration have repeatedly emphasized the importance of expanding primary care capacity, strengthening rural health systems, and ensuring providers can practice at the top of their license. They have also focused on reducing unnecessary barriers that limit entry into the healthcare workforce. The Centers for Medicare & Medicaid Services (CMS), through the Rural Health Transformation Program, is actively incentivizing states to expand practice authority and increase provider supply. 

Yet, this proposed rule would restrict financing for one of the fastest-growing and most in demand healthcare professions, one that disproportionately serves rural and underserved communities. Our comments underscore this inconsistency. 

What Happens Next? 

The Department of Education will review all public comments before issuing a final rule. Individuals may submit comments directly to the ED until 11:59 p.m. ET on March 2. 

In addition to submitting comments, PAs, PA students, and supporters are encouraged to contact their Members of Congress and speak out about the impact this proposal will have on the PA profession and the broader healthcare workforce. 

Additional background, resources, and engagement opportunities are available through AAPA’s federal student loan resource hub. 

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