Negotiated Rulemaking 2025
Reimagining and Improving Student Education (RISE) Committee
Blog Post
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Oct. 30, 2025
Last updated on November 7, 2025.
On July 25, 2025, the Department of Education announced its intention to establish a negotiated rulemaking committee—the Reimagining and Improving Student Education (RISE) Committee—to implement certain higher education provisions in Public Law 119-21 (the One Big Beautiful Bill Act). Among other provisions in P.L. 119-21, the RISE Committee is negotiating 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.
This website provides information about the RISE Committee, including issue papers, proposals from negotiators, data, and more with a focus on the second session, held from November 3-7, 2025. (You can register to watch RISE Session 2 here.)
New America’s higher education team will continue to update this website as the rulemaking progresses.
Materials from Session 1 (September 29 - October 3, 2025):
- Materials posted by the Department of Education during Session 1 can be found here.
- A list of RISE Committee members can be found here.
- RISE Session 1 Regulatory Text Draft as of 10.03.2025
Materials Submitted by Negotiators Between Sessions 1 and 2:
- Proposals from Negotiators after Session 1
- Proposal to Streamline IDR Enrollment After Borrower Exits Default (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal on Less Than Full-Time Enrollment (Submitted by Scott Kemp)
- Proposal to Increase Accessibility of Rehabilitation (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal on Revised Professional Degree Definition and Aligning Definitions in the Code of Federal Regulations (Submitted by Alex Holt & Andrew Gillen)
- Proposal to Increase Successful Borrower Transition Into Repayment Through Rehabilitation (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal on Principles for Application of Interest and Principal Subsidies (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal for Clarifying Text on “Applicable Amount” in 34 CFR 682.215 (Submitted by Alex Ricci & Lori Hartung)
- Proposal on Loans for Less-Than Full-Time Students (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal to Clarify “Applicable Amount” in 34 CF 685.215 for Accuracy and Consistency with OBBB (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal to Set a Minimum Payment Amount for Fixed Repayment Plans (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal to Remove References to “Applicable Amount” in 34 CFR 685.209 for Accuracy and Consistency with OBBB (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal with Technical Notes/Questions on New Reg Language (Submitted by Alex Holt & Andrew Gillen)
Materials from Session 2 (November 3-7, 2025):
You can register to watch RISE Session 2 here.
- Agenda
- Discussion Drafts from the Department of Education Prior to Session 2
- RISE Discussion Draft 674.39 - Loan Rehabilitation
- RISE Discussion Draft 682.215 - Income Driven Repayment
- RISE Discussion Draft 682.405 - Loan Rehabilitation Agreement
- RISE Discussion Draft 685.102 - Definitions
- RISE Discussion Draft 685.200 - Borrower Eligibility
- RISE Discussion Draft 685.201 - Obtaining a Loan
- RISE Discussion Draft 685.203 - Loan Limits
- RISE Discussion Draft 685.203 - Loan Limits (Updated)
- RISE Discussion Draft 685.304 - Deferment
- RISE Discussion Draft 685.205 - Forbearance
- RISE Discussion Draft 685.208 - Fixed Repayment
- RISE Discussion Draft 685.209 - Income-Driven Repayment
- RISE Discussion Draft 685.210 - Choice of Repayment Plan
- RISE Discussion Draft 685.211 - Miscellaneous
- RISE Discussion Draft 685.219 - PSLF
- RISE Discussion Draft 685.220 - Consolidation
- RISE Discussion Draft 685.221 - Alternative Repayment
- Materials Shared on November 3, 2025
- Proposals and Questions from Negotiators
- Loan Limits Clarification (Submitted by Alex Ricci & Lori Hartung)
- Less Than Full-Time Clarification (Submitted by Jenna Colvin)
- Proposal to Prorate RAP Payment for Married Borrowers Filing Jointly (Submitted by Ashley Naporlee & Tamar Hoffman)
- Notes of New Regulatory Drafts (Submitted by Ashley Naporlee & Tamar Hoffman)
- Drafts or Responses from the Department of Education
- Proposals and Questions from Negotiators
- Materials Shared on November 4, 2025
- Proposals and Questions from Negotiators
- Questions/Hypotheticals (Submitted by Ashley Naporlee)
- Proposal to Set Minimum Rehabilitation Payment Amount to Avoid Future Default (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal for Loan Limits for Parent PLUS Borrowers during Transition (Submitted by Alex Holt, Andrew Gillen, Alex Ricci, & Lori Hartung)
- Hypothetical for Legacy Qualifications and New Professional Loan Limits (Submitted by Patti Kohler)
- HEAL Questions (Submitted by Andy Vaughn)
- Drafts or Responses from the Department of Education
- Proposals and Questions from Negotiators
- Materials Shared on November 5, 2025
- Proposals and Questions from Negotiators
- Proposal for Advanced Payments under RAP (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal for the Definition of Professional Programs (Submitted by Timothy King)
- Proposal to Change the Phase-In Loan Limits (Submitted by Ashley Naporlee & Tamar Hoffman)
- Proposal to Clarify the “Program of Study” in 685.203(m)(2) (Submitted by Alex Ricci & Lori Hartung)
- Proposal to Limit PSLF Qualifying Time (Submitted by Ashley Narpolee & Tamar Hoffman)
- Proposal on PSLF: RAP and Buyback (Submitted by Deborah Lilly)
- Proposal on Subscription-Based Programs (Submitted by Ashley Naporlee & Tamar Hoffman)
- Drafts or Responses from the Department of Education
- Proposals and Questions from Negotiators
- Materials Shared on November 6, 2025
- Proposals and Questions from Negotiators
- Clarifying Question on Licensure Requirements (Submitted by Alex Holt)
- Example: Proposed 685.102 Language Impact on Missouri (Submitted by Bennett Bogg)
- Proposal to Add Ph.D. to the Clinical Psychology Parenthetical Notation (Submitted by Deborah Lilly)
- Proposal to Add to the Definitions of Professional Students (Submitted by Jenna Colvin)
- Technical Assistance Request on Degree Name Clarifications (Submitted by Scott Kemp)
- Drafts or Responses from the Department of Education
- Proposals and Questions from Negotiators