On March 2, 2026, Gap Funding Group LLC submitted a public comment to the U.S. Department of Education in response to the Notice of Proposed Rulemaking (NPRM) titled “Reimagining and Improving Student Education” (Docket ID ED-2025-OPE-0944).

This NPRM proposes the regulations that will implement the OBBBA’s elimination of Graduate PLUS Loans and the new borrowing caps for graduate and professional students, effective July 1, 2026. For a full explanation of the rulemaking process, see our overview article.

What we submitted

The Department asked for data-driven evidence and feedback on how it applied the “professional student” definition — which programs get the $50,000/year cap versus the $20,500/year cap. Our comment provided program-level funding gap data across more than 7,000 programs at nearly 2,000 universities, covering the impact of these classification decisions.

Why public comments matter

The NPRM is a proposed rule, not a final one. The Department has to review all substantive comments and can change the proposed regulations before publishing the final rule. Comments that include original data, cite specific regulatory sections, and suggest alternative language carry the most weight.

Our comment was one of more than 81,000 submitted during the 30-day comment period. The Department will now review these comments, draft the final regulatory text, and publish a final rule before the July 1, 2026 effective date. That final rule is expected sometime in May or June.

View the comment

Our comment is now published on Regulations.gov:

What happens next

We are tracking the rulemaking process as it moves through the remaining steps toward July 1, 2026. Follow our Policy Tracker for continuing coverage.