ED Publishes NPRM to Implement Student Loan Changes Enacted Under OBBBA
By Megan Walter, Senior Policy Analyst
The Department of Education (ED) today published a Notice of Proposed Rulemaking (NPRM) to implement statutory changes to the federal student loan programs enacted under the One Big Beautiful Bill Act (OBBBA).
The proposed regulations largely mirror the consensus text agreed to by the OBBBA’s Reimagining and Improving Student Education (RISE) negotiated rulemaking committee, with only minor technical and conforming changes. Comments on the proposed regulations are due 30 days after publication in the Federal Register.
The proposed regulations would create a distinction between graduate and professional students for student loan borrowing limit purposes, revise annual and aggregate loan limits for graduate students, professional students, and parent borrowers, and phase out the Graduate PLUS Loan Program and additional borrowing limits for certain health professions (HEAL).
Graduate students would retain the current annual Unsubsidized loan limit of $20,500, but borrowing would be capped at $100,000 in the aggregate. Students enrolled in designated professional degree programs would be eligible for higher limits of up to $50,000 annually and $200,000 in the aggregate. A new lifetime limit of $257,500 would apply to all Direct Subsidized and Unsubsidized loans borrowed at any level, including amounts repaid, forgiven, canceled, or discharged.
The NPRM also imposes new limits on Parent PLUS Loans, capping borrowing at $20,000 per student per year and setting an aggregate limit of $65,000 per student.
All student loans would also be required to be reduced proportionally for students enrolled less than full-time.
In addition, the proposed regulations would streamline the federal student loan repayment system by phasing out existing Income-Contingent Repayment (ICR) plans and establishing two new repayment options for new borrowers: a Tiered Standard repayment plan and a new income-driven Repayment Assistance Plan, which would include features such as monthly interest cancellation and principal payment subsidies.
Finally, the proposal would expand relief options for borrowers in default by allowing loan rehabilitation twice per borrower, even if a borrower has previously completed a rehabilitation.
NASFAA plans to submit comments on the proposed regulations and will publish a draft version in Today’s News ahead of the comment deadline, allowing members to review the feedback and draw on it as they develop their own comments.
Members seeking additional context may wish to review NASFAA’s One Big Beautiful Bill Act Web Center, NASFAA’s “You Have Questions; We Have Answers: Making Sense of the Student Loan Changes from OBBBA’s RISE Committee” article, as well as NASFAA’s RISE Committee webinar, all of which offer a deeper discussion of the provisions included in this NPRM.
Publication Date: 1/30/2026
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