Department of Education Releases Final Rule on Reimagining and Improving Student Education

May 06, 2026

The U.S. Department of Education (ED) has released its Reimagining and Improving Student Education—Federal Student Loan Program Final Regulations. This final rule codifies the higher education provisions that Congress included in the One Big Beautiful Bill Act (OBBBA), which established new aggregate lifetime loan limits for students and restructured loan repayment systems. Here’s what K-12 leaders should be aware of:

Loan Limits: Congress placed specific limitations on the amount of federal loans a graduate student could receive based on their program. Individuals enrolled in programs defined as “professional degrees” are considered “professional students” and are eligible for $50,000 per 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 per year with an aggregate borrowing limit of $100,000.  

In the final rule, ED established the definition 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.

These loan limitations may also apply to existing borrowers. For example, if a district leader is looking to go back to school to earn an Ed.D but already borrowed money for a Master’s, those existing loans count against the $100,000 graduate school limit. There is a narrow exception for students who are currently enrolled in a program of study as of June 30, 2026 and have received a Direct Loan before July 1, 2026. They will not be subject to the limits during the duration of their program.

Changes to Repayment and Impact on PSLF: The new student loan repayment system includes just two “streamlined” options that become available in July: Tiered Standard Repayment Plan (TSRP) and Repayment Assistance Plan (RAP). The final rule clarified that TSRP does not qualify for PSLF. This means that if new borrowers choose or are placed in the program, or if existing borrowers switch from the old Standard Repayment Plan to the new TSRP, payments made will not count towards PSLF’s 120 qualifying payments.

The exclusion of TSRP from PSLF will add unnecessary confusion and increase the administrative burden associated with the program. Borrowers may not be aware of this nuance and could lose credit for otherwise qualifying payments for PSLF. The other income-contingent options will sunset in July 2028.

ܲAVƵis a proud member of the PSLF coalition, which is urging Congress to pass a technical fix to include all plans in PSLF. In the meantime, current or prospective participants in PSLF should be aware of the current limitations as they prepare to switch to a different plan.