On behalf of its membership, COHEAO is responding to the USDOE’s request for comments concerning the upcoming negotiated rulemaking.
Two negotiating committees will be convened:
- The Reimagining and Improving Student Education (RISE) Committee will address the following issues:
- Phase-out of graduate and professional PLUS Loans.
- Establishment of new annual loan limits for graduate and professional students and parent borrowers, and implementation of new lifetime borrowing caps.
- Simplification of student loan repayment plans into a standard repayment plan and a single income-based Repayment Assistance Plan (RAP) for new borrowers, elimination of the Income-Contingent Repayment (ICR) plan, and streamlining requirements for Income-Based Repayment plans for existing borrowers.
- Institutional flexibility to apply lower annual limits for student and parent borrowers for selected programs of study.
- Modifications to loan rehabilitation, including allowing defaulted borrowers to rehabilitate their loans a second time and setting minimum monthly payment amounts for such loans, phase-out of unemployment and economic hardship deferments, and limitations on a borrower’s ability to receive a general forbearance.
- Other provisions included in Public Law 119-21 that are effective upon enactment, on July 1, 2026, on July 1, 2027, or on July 1, 2028.
- The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee will address the following issues:
- Changes in institutional and programmatic accountability measures, including loss of Direct Loan eligibility for certain programs with low earnings outcomes for 2 out of 3 years, and Financial Value Transparency and Gainful Employment.
- Establishment of program eligibility requirements for a new Workforce Pell Grant for students enrolled in programs that last a duration of 8-15 weeks, are transferable to a recognized postsecondary credential or degree, are approved by the state governor, and have strong outcomes.
- Exclusion of Pell Grant assistance for students who receive grant or scholarship aid covering their entire cost of attendance or for students with a Student Aid Index in excess of twice the maximum Pell Grant award.
- Other provisions included in Public Law 119-21 that are effective upon enactment, on July 1, 2026, on July 1, 2027, or on July 1, 2028.
COHEAO has drafted a letter to outline our concerns and feedback. We would like input and feedback from COHEAO members before we submit the final letter. Use the button below to review the letter and offer your thoughts and feedback.

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