Negotiated Rulemaking
Negotiated Rulemaking (or "neg reg") is a process used by the U.S. Department of Education and other federal agencies, in which representatives from a government agency and affected interest groups negotiate the terms of a proposed administrative rule. The agency publishes the proposed rule in the Federal Register and then follows the usual rulemaking procedure of soliciting public comments, which are evaluated for inclusion in the final rule. NASFAA has historically participated in negotiations pertaining to federal student aid program regulations by supporting and sending financial aid administrators from member institutions, NASFAA staff, and others to the negotiating table.
To view NASFAA's official comments on negotiated rulemaking and proposed/interim final rules, please visit NASFAA On the Record.
For ongoing legal challenges focused on the rulemaking process and the department's final rules, visit NASFAA's Financial Aid Litigation page, where we are tracking litigation that affects federal student aid, financial aid administration, and higher education policy.
Participating in the Public Comment Process
- Understanding the Regulatory Process
- How to Submit Comments on Proposed Regulations
- Top Five Reasons Aid Administrators Should Read the Preamble to a Final Rule
2026-27 Sessions
The Department has announced its intent to hold negotiated rulemaking sessions on the following topics: (dates to be determined).
- Rescinding the Saving on a Valuable Education (SAVE) Plan
- Reducing Anti-Competitive Regulatory Barriers
- Campus Safety and Security Reporting pursuant to the Clery Act
- Addressing Title IV Eligibility Issues
- Documentation of Foreign Source Gifts and Contracts
*NEW* Download our chart summarizing the 2026-27 Negotiated Rulemaking topics and statuses.
2025-26 Sessions
The 2025-26 Negotiated Rulemaking cycle has concluded. See below for details on each committee's sessions and outcomes:
- Public Service Loan Forgiveness (PSLF)
- Reimagining and Improving Student Education (RISE)
- Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD)
Download our chart summarizing the 2025-26 Negotiated Rulemaking topics and statuses.
NASFAA Negotiated Rulemaking Coverage
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Summary Chart of 2026-27 Rulemaking Topics and Current Statuses
August 20, 2026 - NASFAA created this chart to summarize the 2026-27 Negotiated Rulemaking topics and current statuses. -
ED Publishes Final Regulations Implementing OBBBA Accountability Framework
July 1, 2026 - The Department of Education (ED) on Wednesday released its final rule covering the new Student Tuition and Transparency System and Earnings Accountability (STATS) framework, created by the One Big Beautiful Bill Act (OBBBA), also referred to as the W... -
Following Legal Action, ED Temporarily Adds New CIP Codes Eligible for Professional Degree Designation, Removes Others
June 30, 2026 - Less than a week after a federal court temporarily halted (or “stayed”) key parts of the Department of Education’s (ED) narrowed professional degree definition, ED issued an Electronic Announcement (EA) (GENERAL-26-42) clarifying ho... -
ED Outlines Guidance on Institutional Authority to Set Program-Level Loan Limits
June 29, 2026 - The Department of Education (ED) on Friday released a Dear Colleague Letter (DCL) reminding institutions of their new authority, effective July 1, 2026, to establish lower annual loan limits for specific programs through the One Big Beautiful Bill Ac... -
ED's Updated PSLF Form Request Adds Urgency to Court Challenge
June 26, 2026 - With July 1 just under a week away, a lawsuit challenging the Department of Education’s (ED) new Public Service Loan Forgiveness (PSLF) employer eligibility rule has gained urgency in the past week, with the department seeking emergency clearan... -
Court Temporarily Pauses Key Parts of Professional Student Definition Days Before July 1 Effective Date
June 25, 2026 - A federal court has temporarily halted the implementation of a portion of the Department of Education’s (ED) narrowed professional degree definition from its Reimagining and Improving Student Education (RISE) final rule, just days before the ru... -
Court Faces Pre-July 1 Deadline on RISE Final Rule Challenge
June 24, 2026 - With July 1 just a week away, two federal lawsuits are pressing courts to act before a wave of student aid rule changes from the One Big Beautiful Bill Act (OBBBA) take effect. The lawsuits challenge the Reimagining and Improving Student Education (R... -
NASFAA Deep Dive: ED Releases Final Rule for Pell Grant Provisions of OBBBA
May 20, 2026 - The Department of Education (ED), on Tuesday, released its final rule covering the Pell Grant changes made in the One Big Beautiful Bill Act (OBBBA), which ED noted it will now refer to as the Working Families Tax Cuts Act (WFTCA). Pell Grant el... -
NASFAA Comments on Regulations for Accountability Framework of OBBBA
May 20, 2026 - On Wednesday NASFAA submitted comments to the Department of Education (ED) in response to its proposed regulations for changes related the institutional accountability framework created by the One Big Beautiful Bill Act (OBBBA). -
Summary Chart of 2025-26 Rulemaking Topics and Current Statuses
May 19, 2026 - NASFAA created this chart to summarize the 2025-26 Negotiated Rulemaking topics and current statuses. -
ED Publishes Final Regulations Implementing OBBBA Federal Student Loan Changes
May 1, 2026 - On Friday, the Department of Education (ED) issued its final rule detailing changes to the federal student loan programs under the One Big Beautiful Bill Act (OBBBA). While ED responded to over 80,000 comments, including NASFAA’s, received in r... -
ED Issues Proposed Regulations for New STATS Earnings Accountability Framework
April 21, 2026 - On Monday, the Department of Education (ED) released its Notice of Proposed Rulemaking (NPRM) with proposed regulations on the new Student Tuition and Transparency System and Earnings Accountability (STATS) framework. -
ED Convenes Negotiated Rulemaking Committee Focused on Reforming Accreditation
April 14, 2026 - The Department of Education (ED) on Monday kicked off the first day of its newest negotiated rulemaking (neg reg) committee focused on reforming the accreditation process, which Under Secretary Nicholas Kent said could “upend” higher educ... -
NASFAA Comments on Regulations for Pell Provisions of OBBBA
April 8, 2026 - On Wednesday NASFAA submitted comments to the Department of Education (ED) in response to its proposed regulations for changes related to the Pell Grant in the One Big Beautiful Bill Act (OBBBA). -
Understanding the Regulatory Process
March 19, 2026 - Negotiated rulemaking, or “neg reg,” is a process some federal agencies follow to obtain stakeholder feedback on proposed regulations. -
ED Publishes NPRM to Implement Pell Provisions Enacted Under OBBBA
March 9, 2026 - The Department of Education (ED) on Monday published a Notice of Proposed Rulemaking (NPRM) to implement statutory changes to the Pell Grant program enacted under the One Big Beautiful Bill Act (OBBBA). -
NASFAA Comments on Regulations for Student Loan Provisions of OBBBA
March 5, 2026 - On Monday NASFAA submitted comments to the Department of Education (ED) in response to its proposed regulations for the student loan changes in the One Big Beautiful Bill Act (OBBBA). -
NASFAA, Higher Ed Organizations Call on ED to Expand the List of Professional Degree Programs, Improve Neg Reg Process
March 4, 2026 - As part of the Department of Education’s (ED) proposed regulations related to the Reimagining and Improving Student Education (RISE) negotiated rulemaking (neg reg) committee, NASFAA and dozens of higher education organizations are urging ED to... -
ED Issues New Proposed Interpretive Rule Warning Against Use of 'Regional Accreditation' Terminology
February 17, 2026 - On Friday, the Department of Education (ED) issued a proposed interpretive rule intended to “revise and clarify” its position on the use of the term “regional accreditation” by accreditors and institutions of higher education ... -
ED Publishes NPRM to Implement Student Loan Changes Enacted Under OBBBA
January 30, 2026 - The Department of Education (ED) today published a Notice of Proposed Rulemaking (NPRM) to implement statutory changes to the federal student loan programs enacted under the One Big Beautiful Bill Act (OBBBA). The proposed regulations largely mirror ... -
ED Seeks Nominations for New Neg Reg Committee Focused on Accreditation
January 27, 2026 - The Department of Education (ED) on Monday announced in the Federal Register that it will create a new negotiated rulemaking (neg reg) committee to reform the accreditation system, which will meet for two in-person sessions in April and May. -
Deep Dive: NASFAA Summary of Consensus on Accountability Language from Last Week’s AHEAD Negotiated Rulemaking Committee
January 13, 2026 - Last Friday, the Department of Education (ED) concluded its negotiated rulemaking session to implement the new low earnings outcomes accountability metric from the One Big Beautiful Bill Act (OBBBA). The Accountability in Higher Education and Access ... -
AHEAD Committee Reaches Consensus On Entire Accountability Package
January 12, 2026 - Amidst much debate over the new accountability framework, negotiators of the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee reached consensus on Friday on a package of accountability measures prop... -
AHEAD Committee Continues Discussion on Teach-Out Proposal
January 9, 2026 - The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee met on Thursday to discuss updated proposed language from the Department of Education (ED), based on feedback from negotiators, as part of incorp... -
AHEAD Committee Discusses Details on New Earnings Accountability Reporting Requirements, Appeals Process
January 8, 2026 - The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee on Wednesday continued working through the proposal from the Department of Education (ED) regarding institutional reporting requirements and the ... -
AHEAD Committee Debates Impact of Eliminating Debt-to-Earnings Metric, Earnings Premium Benchmarks as Rulemaking Continues
January 7, 2026 - The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee gathered on Tuesday to continue discussion on the Department of Education’s (ED) proposal to overhaul the Gainful Employment and Financial ... -
AHEAD Committee Kicks Off Second Neg Reg Session Focused on New Accountability Framework
January 6, 2026 - The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee began its second session of negotiated rulemaking on Monday, focusing on the new accountability framework enacted under the One Big Beautiful Bil... -
Consensus Reached: AHEAD Committee Approves ED’s Workforce Pell Package
December 15, 2025 - The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee reached consensus on Friday on the Department of Education’s (ED) entire package of seven issue topics, which primarily focuses on creating... -
AHEAD’s Fourth Day of Rulemaking Revisits Workforce Pell Definitions, Distance Ed Limits, and Eligibility Consequences
December 12, 2025 - The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee gathered for a fourth day of negotiating rulemaking, with the Department of Education (ED) on Thursday proposing amended language and technical c... -
AHEAD’s Third Day of Rulemaking Focuses on Losing and Regaining Eligibility of Workforce Pell
December 11, 2025 - The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee met for its third day of negotiated rulemaking (neg reg), focusing on the language concerning how institutions could lose and regain Workforce Pe... -
AHEAD’s Second Day of Rulemaking Explores Revisions to Regulatory Text and ED’s Effort to Implement Workforce Pell by 2026-27
December 10, 2025 - The Department of Education (ED) reconvened the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee on Tuesday to review revised regulatory language, work through initial conversations on several outst... -
AHEAD Committee Kicks Off Negotiations on Workforce Pell Program
December 9, 2025 - The Department of Education (ED) convened its latest Negotiated Rulemaking (neg reg) committee on Monday, focusing on new regulations for the Workforce Pell Program, which would allow Pell Grants to be applied to short-term programs. The Account... -
AHEAD Committee Set for First Week of Neg Reg, Will Discuss New Regulations for Workforce Pell Program
December 8, 2025 - The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) committee is scheduled to meet on Monday for its first day of negotiated rulemaking (neg reg), which will discuss new regulations for the Workforce Pell Pr... -
You Have Questions; We Have Answers: Making Sense of the Student Loan Changes from OBBBA’s RISE Committee
November 20, 2025 - The Department of Education (ED) inched closer to implementing regulations for the loan-related provisions of the One Big Beautiful Bill Act (OBBBA) earlier this month with the conclusion of its Reimagining and Improving Student Education (RISE) nego... -
Final RISE Issue Papers
November 12, 2025 - The Reimagining and Improving Student Education (RISE) committee reached consensus on the entire package of 17 proposals by the Department of Education (ED) related to changes enacted under the One Big Beautiful Bill Act (OBBBA). -
Consensus Reached: RISE Committee Supports Entire Package of OBBBA Provisions
November 7, 2025 - Amid much debate over the definition of professional student, degree, and other key student aid provisions, negotiators of the Reimagining and Improving Student Education (RISE) committee on Thursday reached consensus on the entire package of 17 prop... -
Neg Reg Continues Discussion of ‘Program of Study,’ Legacy Provisions, and New Professional Degree Definition
November 6, 2025 - The Reimagining and Improving Student Education (RISE) committee reconvened on Wednesday, focusing its discussion on a new proposal from the Department of Education (ED) on how to define “program of study” as it relates to the legacy elig... -
ED's Proposal for Defining Professional Programs
November 6, 2025 - ED presented a slideshow show statistics of what it's proposed definiton of professional student could mean for higher education programs. -
ED Explores Regulatory Tweaks As RISE Committee Dives into Loan Rehabilitation, Program of Study, Aggregate Limits, Professional Student, and More
November 5, 2025 - The Reimagining and Improving Student Education (RISE) committee resumed its second negotiated rulemaking (neg reg) session on Tuesday, with officials from the Department of Education (ED) working through several terms within the regulatory text. Thr... -
RISE Neg Reg Committee Convenes Again to Continue Discussion of New Loan Limit Provisions
November 4, 2025 - The Reimagining and Improving Student Education (RISE) committee kicked off its second session of negotiated rulemaking (neg reg) on Monday, focusing on multiple provisions enacted under the One Big Beautiful Bill Act (OBBBA), specifically the new pr... -
ED Publishes Final PSLF Regulations On Employer Eligibility Changes
November 3, 2025 - On Friday, the Department of Education (ED) issued its final rule detailing changes to the Public Service Loan Forgiveness (PSLF) Program. The changes were made in response to an Executive Order from President Donald Trump in March ordering ED to &ld... -
New RISE Neg Reg Issue Papers Reveal Revised Definition of Professional Student
November 3, 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 t... -
New RISE Neg Reg Issue Papers
October 31, 2025 - The Department of Education (ED) released a new round of issue papers on several provisions it seeks to implement for it's second session of negotiated rulemaking for the Reimagining and Improving Student Education (RISE) committee. -
RISE Committee Concludes First Round of Neg Reg Discussions With Definition of Professional Student Still Unclear
October 6, 2025 - The Reimagining and Improving Student Education (RISE) committee concluded its first week of negotiated rulemaking (neg reg) on Friday, continuing the discussion on the definition of professional students as negotiators raised several new concerns ov... -
RISE Neg Reg Committee Conducts ‘Pulse Checks’ and Details Updated Forbearance, Loan Limit Provisions
October 3, 2025 - The Reimagining and Improving Student Education (RISE) committee met on Thursday for a discussion focused on updated provisions regarding forbearance and loan limits, and conducted “pulse checks” to see where the committee stands before t... -
‘This Is a Whole New Territory:’ Neg Reg Committee Makes Progress on Definition of Professional Student
October 2, 2025 - The Reimagining and Improving Student Education (RISE) committee met again on Wednesday for another day of negotiated rulemaking, where officials from the Department of Education (ED), following a set of closed caucuses, reportedly presented negotiat... -
RISE Neg Reg Committee Continues Despite Government Shutdown
October 1, 2025 - The Reimagining and Improving Student Education (RISE) committee met on Tuesday for another day of negotiated rulemaking, continuing discussion on key provisions regarding loan limits, repayment plans, loan proration, loan rehabilitation and defermen... -
Chasing a July 1 Implementation Date, ED Kicks Off First Day of RISE Neg Reg
September 30, 2025 - The Department of Education (ED) convened its negotiated rulemaking (neg reg) committee on Monday to discuss the agency’s proposals for provisions included in the One Big Beautiful Bill Act (OBBBA), which is set to cover loan limits, repayment ... -
RISE Neg Reg Issue Papers Reveal ED’s Plans For OB3 Loan Provisions
September 26, 2025 - Issue papers for the first week of the Department of Education’s (ED) Reimagining and Improving Student Education (RISE) negotiated rulemaking committee, set to begin September 29, provide some hints to ED’s intent for implementing the st... -
NASFAA Submits Comments Regarding ED's NegReg Committees Focused on New Provisions Under the 'One Big Beautiful Bill Act'
August 29, 2025 - NASFAA submitted comments on the Department of Education's (ED) notice regarding its intent to establish two negotiated rulemaking committees to address the significant changes to federal student aid programs initiated by the One Big Beautiful Bill A... -
ED Publishes Proposed Rule on PSLF
August 19, 2025 - The Department of Education (ED) on Friday unveiled its Notice of Proposed Rulemaking (NPRM) for changes to the Public Service Loan Forgiveness (PSLF) program that seeks to bar organizations that engage in “activities that are unlawful” f... -
Experts Stress Need for Financial Aid Administrators in Neg Reg Committees at ED Public Hearing
August 8, 2025 - The Department of Education (ED) on Thursday hosted a public hearing regarding its two new negotiated rulemaking (neg reg) committees focused on implementing several provisions of the “One Big Beautiful Bill Act,” where several experts st... -
NASFAA Calls on ED to Include Financial Aid Administrators in Upcoming NegReg Committees
August 1, 2025 - NASFAA is urging the Department of Education (ED) to reconsider the makeup of its constituency groups for their upcoming negotiated rulemaking (Neg Reg) committees and provide financial aid administrators a seat at the table. -
NASFAA Letter to ED Negotiated Rulemaking - July 2025
July 30, 2025 - NASFAA leadership expresses concern regarding the exclusion of financial aid administrators from the constituency groups and the unnecessary risk to the successful implementation of the provisions of the One Big Beautiful Bill Act. -
ED Announces Two Neg Reg Committees Focused on New Provisions Under One Big Beautiful Bill Act
July 25, 2025 - The Department of Education (ED) on Friday, via the Federal Register, outlined its intent to convene two new negotiated rulemaking (neg reg) committees. The committees will focus on the federal student loan programs and institutional and programmatic... -
Final Day of Neg Reg Concludes Without Consensus on Proposed PSLF Rules
July 3, 2025 - The Department of Education (ED) began its final day of negotiated rulemaking (Neg Reg) with hopes of reaching a consensus on its proposed rules on changes to the Public Service Loan Forgiveness (PSLF) program. ED sent out updated proposed language T... -
Neg Reg Continues With Focus on Newly Proposed PSLF Provisions
July 2, 2025 - The Department of Education (ED) reconvened its negotiated rulemaking (NegReg) committee on Tuesday with newly proposed provisions for its Public Service Loan Forgiveness (PSLF) issue paper, which were sent to negotiators on Monday evening. -
ED Hosts First Day of NegReg for PSLF Walking Through Definitions and Updated Language
July 1, 2025 - The Department of Education (ED) convened its negotiated rulemaking (neg reg) committee on Monday to focus on the agency’s proposed definitions for the Public Service Loan Forgiveness (PSLF) program. The department aims to achieve consensus on ... -
ED Releases Issue Paper for Public Service Loan Forgiveness Neg Reg Committee
June 27, 2025 - On Friday the Department of Education (ED) released its documents — including issue papers, protocols, agenda, and a list of committee participants — related to its Public Service Loan Forgiveness (PSLF) negotiated rulemaking committee (n... -
Groups Representing Borrowers and Other Stakeholders Call on ED to Expand Negotiators in Upcoming Neg Reg
June 4, 2025 - As the Department of Education (ED) prepares to hold its negotiated rulemaking (Neg Reg) session on Public Service Loan Forgiveness (PSLF), income-driven repayment (IDR) and other financial assistance programs later this month, dozens of organization... -
NASFAA Signs Onto Letter Responding to OMB’s Information Request on Deregulation
May 12, 2025 - NASFAA signed onto a letter in response to the Office of Management and Budget’s request for information on rules to be targeted for rescission, or deregulation, providing a list of guiding principles and feedback to the administration. -
NASFAA Responds to OMB RFI on Deregulation
May 12, 2025 - On Monday, NASFAA submitted comments to the Office of Management and Budget (OMB) in response to a request for information asking interested parties to identify rules to be targeted for rescission. -
NASFAA Comments on Upcoming NegReg on PSLF, IDR and Other Financial Assistance Programs
May 6, 2025 - NASFAA has submitted comments on the Department of Education's (ED) notice regarding potential negotiated rulemaking topics. In this feedback, NASFAA addressed several key areas proposed for negotiation. -
Trump Administration Kicks Off Neg Reg With First Day of Public Hearings
April 30, 2025 - The Department of Education (ED) on Tuesday hosted its first day of public hearings as part of the negotiated rulemaking (neg reg) process, where stakeholders gathered in person to give their comments regarding several Title IV programs, including Pu... -
ED Announces Dates for Negotiated Rulemaking Public Hearings on PSLF and IDR Plans
April 4, 2025 - The Department of Education (ED) on Thursday released its public hearing dates for its intent to establish negotiated rulemaking committees that will touch on regulations that would streamline current federal student financial assistance programs. -
Summary Chart of 2023-24 Rulemaking Topics and Current Statuses
January 7, 2025 - NASFAA created this chart to summarize the 2023-24 Negotiated Rulemaking topics and current statuses. -
Negotiated Rulemaking Archive
January 1, 2025 - NASFAA’s archived coverage of the Negotiated Rulemaking process includes recaps of committees formed during previous administrations and explains how committee sessions sought to reach a consensus on a variety of topics.
