Rulemaking

On this page you will find comments in response to Notices of Proposed Rulemaking or Interim Final Rules With Comments Invited, and comments dealing with negotiated rulemaking.

NASFAA Comments on Regulations for Pell Provisions of OBBBA
April 9, 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).
NASFAA, Higher Ed Organizations Call on ED to Expand the List of Professional Degree Programs, Improve Neg Reg Process
March 2, 2026 - As part of the ED's proposed regulations related to the RISE negotiated rulemaking committee, NASFAA and dozens of higher education organizations are urging ED to expand the list of professional degree programs.
NASFAA Comments on Regulations for Student Loan Provisions of OBBBA
March 2, 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 Submits Comments Regarding PSLF
September 17, 2025 - NASFAA submitted comments to the Department of Education (ED) on Wednesday, strongly opposing the department’s proposal to narrow the definition of qualifying employers for PSLF.
NASFAA Submits Comments Regarding ED's NegReg Committees Focused on New Provisions Under the 'One Big Beautiful Bill Act'
August 28, 2025 - NASFAA submitted comments on ED's 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 Act.'
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.
NASFAA’s Comments on Proposed Hardship Provisions of Student Loan Debt Relief Regulations
December 2, 2024 - NASFAA is pleased to share our comments on proposed regulations that would grant loan cancellation to borrowers experiencing financial hardship.
NASFAA Comments on Master Promissory Note Form
July 30, 2024 - NASFAA submitted to the Department of Education (ED) its response to the department's request for comments on its Master Promissory Note (MPN) form.
NASFAA Comments on Gainful Employment, Administrative Capability, Ability to Benefit
June 20, 2023 - NASFAA submitted comments to the Department of Education on its proposed rules for financial value transparency and gainful employment, financial responsibility, administrative capability, certification procedures, and ability to benefit.
NASFAA Urges for Extensions of the Third-Party Servicer Guidance Comment Period and Reporting Deadline
February 24, 2023 - NASFAA signed on to a letter sent by the American Council on Education urging the Department of Education (ED) to extend the comment period and reporting deadline tied to its solicitation of feedback on third-party servicers.
NASFAA Joins Higher Ed Community Comments on ED’s Proposed New IDR Plan and Calls for a Comprehensive HEA Review
February 13, 2023 - NASFAA signed on to a letter sent by the American Council on Education with feedback on the Department of Education’s (ED) new income-driven repayment (IDR) plan, which the group found to contain promising elements.
NASFAA Joins Higher Ed Community in Expressing Concern Over Data Limitations for ED’s Request of Information on Ways to Identify Low-Value Postsecondary Programs
February 13, 2023 - NASFAA signed on to a letter sent by the American Council on Education regarding ED's request for information on how best to identify low-value postsecondary programs, cautioning that usage of existing data would have pose limitations.
NASFAA Submits Comments to ED on Proposed New IDR Plan
February 10, 2023 - NASFAA submits comments to the Department of Education on its new income-driven repayment plan.
NASFAA Comments on Proposed Low-Financial-Value Programs List
February 10, 2023 - NASFAA submitted comments to the Department of Education in response to its request for information on creating a list of low-financial-value programs.
NASFAA Comments on ED Proposed Rule on Prison Education Programs, 90/10 Rule, Changes of Ownership
August 26, 2022 - NASFAA generally supported the proposed changes but asked a number of clarifying questions.
NASFAA Comments on ED’s Affordability and Student Loans Regulatory Package
August 12, 2022 - NASFAA submitted comments to the Department of Education (ED) on its proposed regulatory changes considered by the Affordability and Student Loans committee.
NASFAA Signs Letter With Comments on Student Loan Forgiveness NPRM
August 12, 2022 - NASFAA, along with 23 other higher education associations, sent a letter with comments to the Department of Education in response to the notice of proposed rulemaking regarding targeted student loan forgiveness.
NASFAA Submits Comments on DACA Notice of Proposed Rulemaking
November 30, 2021 - NASFAA joined a number of other higher education organizations in comments on the Department of Homeland Security's Notice of Proposed Rulemaking for the DACA program.
Negotiated Rulemaking Written Comments
July 1, 2021 - This letter aimed to provide ED with additional details for the negotiated rulemaking process & focused on issues surrounding gainful employment, PSLF, prison education program, administrative capability, and other topics.
Community Sends Comments on DHS H-1B Visa Interim Final Rule
November 9, 2020 - NASFAA and 32 other higher education organizations in writing to USCIS expressing concern for the interim final rule on "Strengthening the H-1B Nonimmigrant Visa Classification Program."
Community Sends Comments on DOL H-1B Prevailing Wage IFR
November 9, 2020 - NASFAA joined 18 other associations in submitting comments on the Department of Labor (DOL)'s October 8 Interim Final Rule titled Strengthening Wage Protections for the Temporary and Permanent Employment of Certain Aliens in the United States.
NASFAA Joins Amicus Brief Opposing New H-1B Visa Rules
October 30, 2020 - NASFAA and 23 other higher education associations filed a brief submitted in the U.S. District Court for the District supporting a pair of legal challenges to new Trump administration rules restricting H-1B visas for highly skilled workers.
NASFAA Joins Amicus Brief Opposing New H-1B Visa Rules
October 30, 2020 - NASFAA & 23 other higher ed associations filed a brief submitted in the U.S. District Court for the Northern Dist. Court of CA supporting a pair of legal challenges to new Trump administration rules restricting H-1B visas for highly skilled workers.
NASFAA Joins Comments on DHS Duration of Status Rule
October 26, 2020 - The higher education community submitted comments to the Department of Homeland Security (DHS) expressing opposition to a proposed rule which creates a fixed duration of admission of either two years or four years for international...
NASFAA Comments on CARES Act Interim Final Rule
July 20, 2020 - In comments in response to the Department of Education's interim final rule on CARES Act emergency grant eligibility, NASFAA highlighted the chaos the rapidly changing guidance caused for institutions and students.
NASFAA Submits Comments on Proposed Distance Education and Innovation Rules
May 4, 2020 - NASFAA on Monday submitted comments on the Department of Education's (ED) proposed rules on distance education and innovation. Many of the proposed changes fall in line with NASFAA's Modernizing Title IV Aid task force recommendations.
NASFAA Comments on TEACH Faith-based Entities
January 10, 2020 - NASFAA submitted comments in response to a Department of Education (ED) Notice of Proposed Rulemaking (NPRM) detailing proposed changes to Title IV eligibility for faith-based entities and on the TEACH grant program.
NASFAA Submits Comments on Proposed Changes to 2019 Gainful Employment Disclosure Template
January 8, 2019 - NASFAA submitted comments in response to a Department of Education (ED) information collection request seeking feedback on proposed changes to the 2019 gainful employment (GE) disclosure template.
NASFAA Response to Intent to Re-Negotiate Borrower Defenses to Repayment and Gainful Employment
July 14, 2017 - NASFAA offers comments on the Intent to Re-Negotiate Borrower Defenses to Repayment and Gainful Employment.
NASFAA Comments on ED Renegotiation Proposal
July 13, 2017 - NASFAA submitted comments yesterday on the Department of Education's announcement that it intends to renegotiate two controversial areas of regulation: borrower defense to repayment and gainful employment. Borrower defense final rules were scheduled ...
NASFAA Encourages ED to Strike a Balance Between Institutional Accountability, Student Protections
July 11, 2017 - The tale of two regulations – gainful employment (GE) and borrower defense to repayment (DTR) – continued Monday during a day-long hearing at the Department of Education’s (ED) Washington, D.C., headquarters regarding its intent to ...
NASFAA Submits Comments to ED on Final Rules on Borrower Defense Processes
March 21, 2017 - Docket ID ED– 2015–OPE–0103 Comments on Final Rules on Borrower Defense Processes March 20, 2017 The National Association of Student Financial Aid Administrators (NASFAA) submits these comments in response to the final rule published Januar...
NASFAA Submits Comments on State Authorization of Distance Education Programs
August 24, 2016 - NASFAA offers comments on the Notice of Proposed Rulemaking published on July 25, 2016 concerning state authorization of distance education programs.
NASFAA Submits Comments on Borrower Defense NPRM
August 3, 2016 - NASFAA submitted comments to the Department of Education (ED) on Monday concerning a Notice of Proposed Rulemaking (NPRM) that would describe grounds and processes for borrowers to claim institutional misconduct as a reason to set aside repayment of ...
NASFAA Signs on to ACE Borrower Defenses NPRM Comments
August 1, 2016 - NASFAA signs on in support of the American Council on Education (ACE)'s comment letter addressing recommendations related to the NPRM’s provisions on borrower defenses to repayment.
NASFAA Signs on to NACUBO Borrower Defenses NPRM Comments
August 1, 2016 - NASFAA signs on to the National Association of College and University Business Officers (NACUBO)'s letter asserting student borrowers should be protected from misleading, deceitful, and predatory practices of institutions.
NASFAA Submits Comments on REPAYE Proposed Rules
August 11, 2015 - The regulatory addition of a new income‐driven repayment plan, which will co‐exist alongside four other income‐driven plans, is a step in the opposite direction of the momentum in the entire higher education community, NASFAA declared in its comments...
NASFAA Submits Comments on Cash Management
July 7, 2015 - On July 2 NASFAA submitted comments on the Notice of Proposed Rulemaking (NPRM) on cash management issues published on May 18.
NASFAA Submits Comments on Gainful Employment NPRM
May 28, 2014 - In comments submitted to ED yesterday, NASFAA supported fair, reasonable, and well-targeted regulations that ensure Title IV funding for programs that lead to gainful employment. Among other issues, NASFAA commented that the proposed rules: Provi...
NASFAA Comments on the Loan Issues NPRM
August 16, 2012 - NASFAA responds to the Department of Education's request for comment on the Loan Issues Notice of Proposed Rulemaking published on July 17, 2012. We support the Department's proposed changes, which streamline the process for all involved parties, ...
NASFAA Comments for Fall 2012 Negotiated Rulemaking
May 31, 2012 - In preparation for another round of negotiated rulemaking this fall, NASFAA submits its comments on proposals for regulatory action. The Department of Education has suggested establishing or revising regulations to address fraud, disbursement prov...
NASFAA Supports NPRM Changing Requirements on New Gainful Employment Programs
November 16, 2011 - NASFAA supports the Department of Education’s (ED) proposed changes to the requirements related to new gainful employment programs and appreciates ED’s efforts to reduce administrative burden wherever possible, NASFAA President Justin Draeger wrot...
NASFAA Letter Urges ED to Use 2011 Negotiated Rulemaking to Reduce Regulatory Burden
May 20, 2011 - This letter urges the Department to use the 2011 negotiated rulemaking process to reduce regulatory burdens for financial aid offices.
NASFAA President Testifies at Gainful Employment Hearing
November 5, 2010 - NASFAA supports the Department of Education's effort to define useful gainful employment metrics but highlights some concerns about how the rules could be implemented.
NASFAA Responds to Gainful Employment NPRM
September 9, 2010 - NASFAA President Justin Draeger expresses concerns about details of the Department of Education's proposed Gainful Employment regulations.
NASFAA Submits Comments on Program Integrity NPRM
August 2, 2010 - NASFAA President Justin Draeger submits comments on the U.S. Department of Education's proposed program integrity regulations.

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