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

Our comment drew on Gap Funding Group’s research analyzing funding gaps across more than 7,000 graduate and professional programs at nearly 2,000 universities.

The Department asked commenters to provide data-driven evidence and to upload relevant datasets and findings. Our research quantifies the program-level dollar gap between total cost of attendance and the new federal loan limits, which is the kind of empirical input the NPRM requested.

The NPRM also asked for feedback on how the Department applied the “professional student” definition, specifically how it used the illustrative list of degrees to determine which programs get the higher loan limits ($50,000/year, $200,000 aggregate) versus the lower graduate limits ($20,500/year, $100,000 aggregate). Our analysis covers the impact of these classification decisions across every affected program in the dataset.

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 60,000 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

Public comments submitted through Regulations.gov are published after the Department reviews them. Once ours is posted, we will link to it here.

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.