Question 1

What did Gap Funding Group's public comment address?

Accepted Answer

The comment responded to the Department of Education's proposed regulations implementing the OBBBA's elimination of Grad PLUS loans. It focused on the professional student classification, which determines whether a program gets the $50,000/year cap or the $20,500/year cap, and provided program-level data on funding gaps across more than 7,000 programs.

Question 2

How many public comments were submitted on the graduate loan limits NPRM?

Accepted Answer

More than 60,000 comments were submitted during the 30-day comment period, which closed March 2, 2026. The Department is required to review all substantive comments before publishing the final rule, expected by May or June 2026.

Question 3

Where can I view the public comment on Regulations.gov?

Accepted Answer

The comment was submitted to Docket ED-2025-OPE-0944 on Regulations.gov. Public comments are published after the Department reviews them. The docket page will be updated with the comment once it is posted.

Question 4

Which programs qualify as professional under the new Grad PLUS loan caps?

Accepted Answer

The Department of Education proposed 11 fields as professional: Pharmacy (Pharm.D.), Dentistry (D.D.S./D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C.), Law (J.D.), Medicine (M.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M.), Optometry (O.D.), Theology (M.Div.), and Clinical Psychology (Psy.D./Ph.D.). Professional students can borrow up to $50,000/year. Graduate students are capped at $20,500/year.

Question 5

What programs are excluded from the professional designation under the OBBBA?

Accepted Answer

Nursing (MSN/DNP), physical therapy (DPT), physician assistant (MSPAS), occupational therapy (MSOT/OTD), social work (MSW/DSW), education (M.Ed./Ed.D.), business (MBA), public health (MPH), and naturopathic medicine (N.D.) are all classified as graduate, not professional, and subject to the $20,500 annual cap. The Department of Education estimates 87% of postbaccalaureate borrowers fall into the graduate category.

Question 6

What is the current status of the Grad PLUS rulemaking process?

Accepted Answer

As of March 2026, five of eight steps are done: Notice of Intent (July 2025), Nominations (August 2025), Negotiated Rulemaking with full consensus (November 2025), OMB/OIRA Review (January 2026), and NPRM publication with over 60,000 comments (January-March 2026). Still ahead: OIRA review of the final rule, publication, and the July 1, 2026 effective date.

Question 7

Why is the Grad PLUS rulemaking timeline compressed?

Accepted Answer

The HEA's master calendar normally requires final regulations by November 1 for a July 1 effective date. The OBBBA was enacted July 4, 2025, leaving only 120 days before the deadline. The Department estimated a minimum of 149 days for rulemaking. Their legal position is that Congress implicitly waived the master calendar by setting an effective date that was mathematically impossible to meet through normal procedure.

Policy Tracker

Gap Funding Group Submits Public Comment on Graduate Loan Limits NPRM

How the Elimination of Grad PLUS Loans Becomes Law: The Rulemaking Process

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