ED Must Cushion the Blow of OBBBA; Protect Students in High-Need Fields From Being Pushed Toward Risky Private Loans or Out of Fields Entirely 

March 3, 2026 | WASHINGTON, D.C. — Nearly a hundred organizations representing millions of student loan borrowers submitted a comment to the U.S. Department of Education (ED) urging officials to protect student loan borrowers from the unprecedented, vast, and harmful changes to the student loan system dictated by the One Big Beautiful Bill Act (OBBBA). 

The 86 groups warn that ED’s proposed Reimagining and Improving Student Education (RISE) regulations will raise monthly payments for millions—including those with the lowest incomes—push graduate students in critical fields like nursing, social work, and education toward risky private loans or out of their fields entirely, and trigger a surge in defaults, which are already sky high. This is coming as Americans face a severe affordability crisis spanning every aspect of their financial lives.

A copy of the joint comment is available here: https://protectborrowers.org/wp-content/uploads/2026/03/RISE-Coalition-Comment-3.2.26.pdf 

From the comment:

“The law and these regulations will significantly exacerbate challenges most student loan borrowers already face in attempting to repay student loan debt, especially when that debt has not led to improved economic outcomes. Cuts to federal loan access will make it increasingly difficult for all but the wealthiest students to pay for college or to attend graduate programs in critical fields such as nursing, education, and social work without turning to risky, expensive private loans. Changes to the student loan repayment system will increase payments for most borrowers, including those with very low incomes, likely driving many more people into student loan default.

“Moreover, the scale and speed at which the student loan system must change to accommodate this overhaul will likely lead to more harm for borrowers as ED may struggle to communicate with servicers and enact the proposed rule with ED’s remaining skeleton staff. We urge ED to ensure that borrowers are protected during the transition.”

Protect Borrowers also submitted a comment here.

While rescinding OBBBA’s harmful provisions is beyond ED’s rulemaking authority, the comment details critical ways that ED can cushion the impact of these changes on borrowers, including:

  • Extend the pause on involuntary collections and hold borrowers harmless from administrative delays and servicing errors
  • Work closely with loan servicers to ensure borrowers receive clear, timely, and actionable information and resources about the changes and new plans
  • Reconsider its narrow definition of “professional degrees” to ensure students in nursing, social work, and other critical professions retain access to federal loans
  • Establish guardrails on institutional decision-making for program-level loan limits

The public comment period closed on March 2, 2026.

Further Reading

Protect Borrowers Deep Dive on impact of OBBBA on borrowers: The OBBBA Law Makes Paying for College More Expensive and Risky

TICAS blog on how OBBBA would affect low-income borrowers: How House Republicans’ Student Loan Repayment Plan Would Disproportionately Harm Low-Income Borrowers

Protect Borrowers, AFT, and National Nurses United blog on the proposal’s definition of professional degrees: What is All the Buzz About Nursing No Longer Being Designated as a Professional Program?

EdTrust report on elimination of Grad PLUS loans: How the Elimination of Grad PLUS Loans and  Classification of Professional Degrees Harm Women and Students of Color

Protect Borrowers blog on elimination of Grad PLUS loans: Eliminating Grad PLUS Loans Without Making Higher Education More Affordable Would Be a Disaster for Students and Borrowers

The Century Foundation report on OBBBA’s effect on access to college: The FICO Factor: GOP Megabill Will Limit Who Gets to Access College

Protect Borrowers report on private student lending: Private Student Lending

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About Protect Borrowers

Protect Borrowers (formerly Student Borrower Protection Center) is a nonprofit organization led by a team of experts, lawyers, and advocates fighting to build an economy where debt doesn’t limit opportunity. We investigate financial abuses, take predatory companies to court, and push for policies to protect working people from debt traps. We aim to deliver immediate relief to families while building power, driving systemic change, and fighting for racial and economic justice.

Learn more at protectborrowers.org or follow us on social @BorrowerJustice.