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3/2/26 – Comment on the US Department of Education Reimagining and Improving Student Education

On behalf of the National Hispanic Health Foundation, a nonprofit organization with the mission to Transform the healthcare system with leadership, research and education to improve the health of all Americans, and our Coalition, the Hispanic Health Professionals Network, comprised of all national associations representing physicians, nurses, dentists, pharmacists, PAs, public health workers, hospital executives, social workers, dietitians and mental health workers we strongly oppose this effort.

 Section 492 of the Higher Education Act (HEA) requires that the Secretary of Education solicit public involvement in the development of proposed regulations before publishing an NPRM to implement programs authorized under Title IV. 

 In November 2025, the Department of Education created the Reimagining and Improving Student Education (RISE) negotiated rulemaking Committee that reached consensus on the entire package of proposed regulations. 

Beginning in July 2026, the Act limits new graduate students to $20,500 in federal student loans per year (with a $100,000 aggregate limit) and new professional students to $50,000 in federal student loans per year (with a $200,000 aggregate limit). Previously, graduate students could borrow up to the cost of attendance, which has contributed to steep increases in graduate school tuition. 

 This proposed decision will drastically reduce borrowing power for advanced-degree essential health students, such as nurses, physical therapists, occupational therapists, and public health workers, while leaving other professionals’ limits untouched.

Prior to H.R. 1, post-baccalaureate students could borrow up to the cost of attendance under the Grad PLUS program. However, H.R. 1 eliminated this program and established a two-tiered system for direct unsubsidized loans: a higher $50,000 annual limit for “professional” degrees (such as MDs, JDs, and PharmDs) and a slashed $20,500 annual limit for “graduate” degrees (such as nursing, PT, OT, and Public Health). The LEAP Act creates parity by raising the cap for graduate students, ensuring these vital professionals have the same borrowing capacity as their peers.

 The Department of Education’s decision to impose stricter federal loan limits on certain advanced-degree programs would force students in high-demand healthcare fields to take on more private loan debt to complete their education. This would lead to many students not applying to graduate health professional schools and programs, and would lead to fewer healthcare workforce shortages, higher morbidity among under-resourced communities, and eventually, higher healthcare costs in the United States.