By Maria Carrasco, NASFAA Staff Reporter
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 organizations are calling on ED to expand the number of negotiator constituencies to reflect more borrower voices.
Organizations representing student loan borrowers, union members, veterans, and other stakeholders, led by the Student Borrower Protection Center (SBPC), sent a letter to ED on Monday, calling on the department to allow for more constituencies to be included in its upcoming session.
Earlier in April, ED announced its intent to establish Neg Reg committees focused on regulations that would streamline current federal student financial assistance programs, particularly the PSLF and IDR programs. In late April and early May, ED held public hearings focused on these topics, where NASFAA and others submitted comments.
ED announced the official dates for its Neg Reg session on PSLF, IDR, and other financial assistance programs in mid-May, which will be conducted in-person in Washington, D.C. from June 30 to July 2. In the announcement, ED also called on nominations for negotiators for nine constituencies, with a deadline of Monday, June 2 for nominations.
While the list of constituencies largely mirrors past Neg Reg committees, it notably combines several groups, including public institutions of higher education, which has historically been split into separate constituencies for individuals representing 4-year and 2-year public colleges and universities. It also combines several constituencies that represent student and borrower voices.
The organizations, in their letter on Monday, stressed that during this Neg Reg session, it is critical ED has a diverse set of negotiators representing the broad set of stakeholders. Specifically, the organizations called on ED to include separate constituencies for negotiators representing legal aid organizations, consumer advocacy organizations, and civil rights organizations.
“The department’s currently planned combination of stakeholder seats for this table fails to elevate key views and does a disservice to the rulemaking process,” the letter reads. “We urge ED to provide distinct seats that enable a fuller set of needed perspectives at the negotiating table.”
Additionally, a constituency representing individuals with disabilities or groups representing them should be included, the organizations wrote. Neg Reg committees over the past several years have typically included this constituency.
The letter did not include several constituencies for which ED sought nominees, including separate representatives from 2-year public, 4-year public, private, and proprietary institutions of higher education; military service members, veterans, or organizations representing them; and Federal Family Education Loan Lenders (FFEL) or guaranty agencies.
The organizations included a list of nominations for multiple negotiator constituencies.
“The Trump administration’s proposal to cram civil rights, legal aid, and consumer advocacy groups into fewer seats is a naked attempt to stack the decks against borrowers and engineer a predetermined outcome for this rulemaking,” said Persis Yu, deputy executive director and managing counsel at SBPC, in a statement. “The financial lives of millions of borrowers are at stake. Our slate of experts understands how these changes will affect millions of public service workers, working families, and vulnerable borrowers.”
Publication Date: 6/4/2025
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