Which Public Comment Requests on Loan Limits Are Feasible, and Which Aren't

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The Reimagining and Improving Student Education (RISE) rules focusing on new student loan limits and related repayment and proration rules are in the final stage before a scheduled July 1st implementation date. OBBB was passed into law in July 2025 with requirements for July 1, 2026 implementation, which overrode the master calendar and is shockingly fast.

After the RISE committee reached consensus last fall, the Department of Education (ED) published the Notice of Proposed Rule Making (NPRM) at end of January, allowing 30 days of public comments. More than 75,000 public comments were submitted, and roughly 18,900 of these comments have been posted as of this morning. The final step is for ED to interpret and react to the comments and then publish the final rules.

The lobbying in the media and public statements has been intense lately, which is correlated with the huge number of comments. For On EdTech+ readers, I’d like to go deeper than what we have seen in the media thus far and give some insight into what might change (or not).

Note: I used NotebookLM, Gemini, Grok, ChatGPT, and Claude to help with this analysis. If you thought that I read all 18,900 comments and coded them, well, that would be incorrect.

Summary of the Comments

The overall sentiment from the public comments regarding the proposed Reimagining and Improving Student Education (RISE) rules is overwhelmingly against the measure. The vast majority of commenters express deep concern over the proposal to classify advanced healthcare and public service degrees—including advanced practice nursing (such as CRNAs and NPs), physical therapy, physician assistant studies, social work, public health, and mental health counseling—as "graduate" rather than "professional" degrees. Commenters argue that this narrow classification—only expanding from 10 to 11 degrees— and the resulting reduction in federal student loan limits, fails to recognize the clinical rigor, specialized training, and immediate licensure requirements of these programs.

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