The gap is not concentrated at a handful of elite schools. It is everywhere: flagship publics, regional privates, research universities, teaching colleges, across every state and program type.
Of the 7,333 program-institution combinations in our dataset, 6,983 (95.2%) have an annual cost of attendance that exceeds the applicable federal loan cap. Only 350 programs (4.8%) would be fully covered by federal loans alone.
The Gap by Classification
The policy creates a two-tier system with dramatically different outcomes:
| Classification | Cap | Programs | With Gap | Gap % | Median Annual Gap |
|---|---|---|---|---|---|
| Professional | $50,000 | 1,022 | 786 | 76.9% | $27,688 |
| Graduate | $20,500 | 6,311 | 6,197 | 98.2% | $20,210 |
| All Programs | — | 7,333 | 6,983 | 95.2% | $20,750 |
Median annual gap computed among programs with gap > $0.
Graduate students, who outnumber professional students more than 6:1, are almost universally affected. Their $20,500 cap is below the cost of attendance at virtually every institution in the country.
Cost of Attendance Distribution
The median annual COA across all programs is $42,808. The $20,500 graduate cap falls below the 25th percentile of costs ($32,758), meaning the cap is lower than even the cheapest quartile of programs.
| Annual COA Range | Programs | Share | Implication |
|---|---|---|---|
| Under $20,000 | 112 | 1.5% | Below both caps |
| $20,000–$29,999 | 1,073 | 14.6% | Gap for graduate students |
| $30,000–$39,999 | 2,060 | 28.1% | Gap for graduate students |
| $40,000–$49,999 | 1,329 | 18.1% | Gap for graduate students; approaching professional cap |
| $50,000–$74,999 | 1,680 | 22.9% | Gap for both tiers |
| $75,000–$99,999 | 770 | 10.5% | Large gap, both tiers |
| $100,000+ | 309 | 4.2% | Extreme gap |
Programs Where the Gap Is Universal
Several program types have a funding gap at every single institution in our dataset:
| Program | Programs with Gap | Total | Gap Rate |
|---|---|---|---|
| Physician Assistant (PA) | 180 | 180 | 100% |
| Physical Therapy (DPT) | 202 | 202 | 100% |
| Occupational Therapy (OT) | 94 | 94 | 100% |
| Audiology (AuD) | 37 | 37 | 100% |
| Architecture | 59 | 59 | 100% |
| Engineering (General) | 135 | 135 | 100% |
| Psychology | 57 | 57 | 100% |
| Social Work (MSW) | 114 | 114 | 100% |
| Law (LLM) | 95 | 95 | 100% |
Our dataset covers 99.7% of IPEDS-listed institutions with graduate programs. There is no PA program, no DPT program, no OT program where the new cap would fully cover costs.