A proposed federal rule that would sharply limit how much graduate students can borrow in federal loans is facing mounting resistance from higher education associations, health care advocates, and some members of Congress, who argue the regulation could hollow out the workforce pipeline for fields already contending with critical shortages.
The controversy stems from the One Big Beautiful Bill Act (OBBB), signed into law in July 2025, which overhauled federal student lending and eliminated the Grad PLUS loan program effective July 1, 2026. Under the law, students in programs designated as A”professional” can borrow up to $50,000 per year with a $200,000 aggregate cap. Students in all other graduate programs face a much tighter ceiling: $20,500 annually and $100,000 total, counting toward a lifetime borrowing limit of $257,500 including undergraduate debt.
The problem, according to critics, is how the Department of Education has chosen to define “professional.” In its proposed implementing regulations through what it calls the RISE — Reimagining and Improving Student Education — process, the department limits the higher borrowing tier to just 11 degree programs. That would leave out nursing, social work, physician assistant studies, occupational and physical therapy, audiology, public health, architecture, accounting, and special education, among others.
The American Council on Education (ACE) and 40 allied higher education associations filed formal comments with the department in early March, arguing that the proposed definition is far narrower than what the statute intends and would exclude programs that require professional licensure and meet rigorous academic standards. Their analysis found that roughly 28 percent of all graduate borrowers already need to take out more than the proposed limits allow. In health-related fields, the figures are starker: 39 percent of master’s-level health students and 67 percent of doctoral-level health students currently borrow above the proposed caps.
The American Association of Physician Associates (AAPA) moved quickly to gauge the impact. After surveying more than 4,500 PAs, PA students, and prospective students, the organization found deep concern about the financial math involved. PA programs typically run two years and cost around $100,000 in tuition alone — meaning students under the proposed caps could access only $41,000 in federal loans for their entire degree.
“It’s important to keep in mind that most PA programs are 2 years long. That means students can only get a total of $41,000 in federal student loans under this rule,” said Lisa Walker, PA-C, founding director of the PA program at Endicott College. “The typical tuition for programs is around $100,000 plus fees. Most people can’t work while in PA school, so they also need money to live on. And the reality is, if you have to come up with an extra $30-40,000 each year from your own pocket or from higher-interest private loans, PA school is going to be out of reach for a lot of people.”
The department has said it wants the caps to drive down graduate program costs and reduce student debt. Critics are skeptical of both goals. If fewer students can access federal loans, they argue, many will turn to private lenders — often at significantly higher interest rates, potentially reaching the high teens for borrowers with limited credit histories. Todd Pickard, DMSc, PA-C, president and board chair of AAPA, said the caps would effectively reserve professional education for those who can already afford it.
“What these caps ultimately do is make it so only those who have the personal means to go into these programs will have the ability to do so,” Pickard said. “It de-incentivizes the people who would be best positioned to go back and practice in rural and socially disadvantaged areas.”
On Capitol Hill, Rep. Mike Lawler (R-NY) has introduced the Professional Student Degree Act, which would expand the statutory definition of “professional student” to encompass nursing, social work, teaching, audiology, and public health. Other legislation would raise graduate borrowing limits more broadly or delay the caps’ implementation.
The higher education associations are also challenging the timeline for the rules, arguing that the Higher Education Act’s “master calendar” — which requires final regulations affecting student aid to be published by November 1 before the award year they take effect — still applies. Because OBBB contains no language explicitly suspending that requirement, the groups contend that any final RISE regulations issued in 2026 should not take effect until July 1, 2027 at the earliest.
Whether the department adjusts its approach before the rule is finalized remains to be seen, but the breadth of opposition — spanning health care advocates, professional associations, and bipartisan congressional offices — signals that the current proposal faces a difficult path.
