New RISE Neg Reg Issue Papers Reveal Revised Definition of Professional Student
Maria Carrasco
November 7, 2025
Shortly before the Reimagining and Improving Student Education (RISE) committee convened for its second session of negotiated rulemaking (neg reg), the Department of Education (ED) released a new round of issue papers on several provisions it seeks to implement, including adjustments to its definition of professional student.
The RISE committee first met in late September, with its goal of implementing several provisions of the One Big Beautiful Bill Act (OBBBA) by July 1, 2026. One of the outstanding issues brought up during the committee’s first session was the topic of new loan limits enacted under OBBBA and what this could mean for graduate and professional students and programs.
OBBBA created new annual and aggregate borrowing limits for each credential level. Currently, graduate and professional students are not treated differently under federal loan limits. However, under OBBBA, graduate students will face an aggregate cap of $100,000 with an annual limit of $20,500, while professional students will have a $200,000 aggregate limit and a $50,000 annual cap.
