AASA Joins Ed Orgs to Comment on Professional Student and Degree Definitions

March 03, 2026

Yesterday, AASA joined 12 other education organizations to submit comments on a proposed rule from the Department of Education (ED) to amend the regulations for the Federal student loan programs to implement the changes from the One Big Beautiful Bill Act (OBBBA).

As part of OBBBA, Congress established a new aggregate borrowing limit for graduate students depending on the type of program they are enrolled in. Individuals enrolled in programs defined as “professional degrees” are considered “professional students” and eligible for $50,000/year with an aggregate borrowing limit of $200,000. Students enrolled in other graduate or doctoral programs are considered “graduate students” and limited to $20,500/year ($10,250 for part-time students) with an aggregate borrowing limit of $100,000.  

The proposed rule details the definitions of professional degree and professional student and—most notably for K-12 education—the definition does not include education, social work, occupational therapy and nursing. By limiting access to federal student loans, the new definitions could dissuade potential students from entering these programs and may result in less graduates qualified to fill critical vacancies in school districts, ranging from teachers to school administrators to SISPs.  Further, it could force students to instead rely on private loans which are ineligible for the Public Service Loan Forgiveness (PSLF) program.

In our comments, we requested specific revisions to ensure students enrolled in education programs are considered professional students and education is included in the definition of professional degree. These changes will ensure future educators are able to access the resources they need to complete their course of study. Read the full letter here.