AACC submits comments on proposed student loan rules
On Wednesday, the American Association of Community Colleges (AACC) submitted formal comments on the Department of Education’s (ED) Notice of Proposed Rulemaking (NPRM) on the Reimagining and Improving Student Education (RISE) negotiated rulemaking. The NPRM reflects the consensus language reached by negotiators to implement the loan origination and repayment changes of H.R. 1, the One Big Beautiful Bill Act (OBBBA).
As a reminder, the RISE committee met throughout the fall to implement significant changes to the federal loan programs, including new loan origination policies, enacting new borrowing caps, and creating a new, singular Income-Driven Repayment (IDR) plan, to be called the Repayment Assistance Plan (RAP). Despite significant debate around key issues (most notably the definition of a professional student for the purpose of annual and aggregate loan limits), the negotiators reached consensus on all 17 proposals put before them.
In the comments, AACC thanks the Department for making efforts to align regulations closely with the statute while minimizing additional institutional burden. However, we highlight remaining areas of concern and ask for additional clarity and further policy changes that would serve community colleges and our students.
AACC’s primary concern centers on the new loan proration requirements based on enrollment intensity. Although only 12 percent of community college students borrow, many attend part time or experience fluctuating enrollment due to work and family obligations. Financial aid administrators need comprehensive subregulatory guidance from the Office of Federal Student Aid (FSA) on how proration will apply across varied scenarios, including students enrolled in programs that are less than a year in length, post-disbursement enrollment changes, withdrawals before and after the 60 percent mark, and differing credit loads across semesters. AACC highlights a particular concern that students with uneven enrollment across fall and spring terms could receive less than their proportional annual loan eligibility, contrary to statutory intent.
AACC urges FSA to publish expeditious guidance and technical specifications to allow institutions and vendors to update systems and avoid disruptions for students in the 2026–27 award year.
Beyond the loan proration issue, AACC raises concerns about preserving loan access for postbaccalaureate nursing students who serve as the pipeline for community college nurse educators, particularly in rural and high-need areas. The association urges the Department to include nursing in the list of qualifying professional programs for higher loan limits to avoid undermining faculty supply.
AACC also calls for additional support for low-balance borrowers—who are more likely to be low-income and at higher risk of default despite typically borrowing less than $10,000—by considering implementing shorter timeline to forgiveness under the Repayment Assistance Plan (RAP) in the future.
Finally, AACC reiterates its opposition to the Department’s decision to merge representation of two-year and four-year public institutions on negotiated rulemaking committees, including the RISE committee. AACC urges the Department to restore a designated seat for two-year public institutions in future rulemakings, including the forthcoming Accountability, Innovation, and Modernization (AIM) Committee.
Few mentions of higher education or training in the SOTU
On Tuesday, President Trump delivered the 2026 State of the Union (SOTU) address before a joint session of Congress. As with most presidential SOTU addresses, the speech focused on trumpeting the Administration’s accomplishments and defining its agenda for the coming year and years.
Despite a significant set of actions on higher education, neither higher education nor job training policy issues received significant airtime. In the only reference made to higher education, President Trump proclaimed “We ended D.E.I. in America.” The President made several comments focused on job creation, including reducing regulations, but no specific policy initiatives were outlined in the speech.
Despite these omissions, we expect the Trump Administration to pursue additional higher education policy changes in the next year. While the SOTU gave few new clues, we know that the Administration remains focused on accreditation reform and implementing Workforce Pell. We expect to have more information on the President’s higher education and workforce priorities when the Trump Administration releases its Fiscal Year 2027 (FY 27) budget request in the next month or so.