Public Comment Opportunity: Final OBBBA Student Loan Rules

On January 30, 2026, the Department of Education published final rules implementing the One Big Beautiful Bill Act student loan provisions. The public comment period is now open through March 2, 2026, and this is an important opportunity for advocates and stakeholders to build the administrative record for future advocacy.

 

Why Public Comments Matter:

Let’s be honest: Public comments are not likely to change these rules. Negotiations have already happened, negotiators have already voted, and these are likely to be the final rules (or very close).

But public comments do accomplish critical strategic goals. Comments become part of the permanent federal record that can be referenced in legal challenges, congressional oversight, and future rulemaking. They document real-world harms to borrowers, employers, and communities. They establish which organizations and constituencies oppose these changes and why. And they signal to ED and Congress that these changes will create significant implementation problems and are not acceptable to affected communities.

 

What’s at Stake:

Starting July 1, 2026:

• Strict borrowing caps – Graduate students capped at $20,500/year with $100,000 lifetime limit; professional students at $50,000/year with $200,000 lifetime limit; Parent PLUS at $20,000/year with $65,000 lifetime limit per dependent
• Elimination of repayment plans – PAYE and ICR eliminated by July 2028, ending access for over 2.5 million Southern borrowers currently enrolled in SAVE; only two options remain for anyone borrowing or consolidating after July 1, 2026: RAP or Tiered Standard Repayment
• Higher monthly payments – The new RAP plan calculates payments based on adjusted gross income with no cap, unlike current plans that use discretionary income to protect living expenses; over 40% of borrowers have household incomes of $30,000 or less and will pay up to $50/month instead of $0
• Parent PLUS borrowers excluded from income-driven repayment – New Parent PLUS borrowers after July 2026 have no access to RAP or any income-driven plan, despite having the highest interest rates
• PSLF eligibility gutted – The new Tiered Standard Repayment Plan is NOT PSLF-eligible, even though the old Standard 10-year plan has qualified since 2007
• Rural communities hit hardest – With over 100 rural hospitals closed since 2005 and 134 currently at risk of closing in the South, rural students need access to graduate and professional degrees more than ever; rural areas have lower median household incomes, making families more reliant on student loans; rural college graduates who return to their hometowns are critical to combating professional shortages
• Forced into private loans – Over 440,000 borrowers took out Grad PLUS loans in 2023-2024, making up almost half of a typical graduate borrower’s loan package; eliminating these loans forces students toward less protected private loans with higher interest rates or abandoning their programs entirely
• Reduced safety net – Elimination of unemployment deferment and economic hardship forbearance; forbearance capped at 9 months per 24-month period

For detailed analysis of these changes, see our brief HR1’s Impacts on the South, Explained: Student Loans.

 

What to Include in Your Comment:

Focus your comments on specific harms and impacts relevant to your work or constituency. Document how these changes will affect workforce recruitment and retention in your field. If you have data on current or projected professional shortages, include it. Explain why excluding Tiered Standard Repayment from PSLF is arbitrary and harmful to your service area. Describe the economic impacts on educational institutions, employers, or communities you serve. Be specific about implementation concerns and legal or procedural problems you identify.

The most powerful comments tell real stories. How will these changes affect the populations you serve? What evidence do you have that communities will lose access to qualified professionals? How does breaking the PSLF promise affect your ability to recruit people into public service careers? Make it concrete.

 

Submit Your Comment:

Link: https://www.federalregister.gov/d/2026-01912
Deadline: March 2, 2026
Sample language and resources from Student Debt Crisis Center, available HERE! https://www.studentdebtcrisis.org/post/major-overhaul-or-major-harm-what-s-happening-to-student-loans-how-to-take-action 

These changes will push prospective students toward private loans with no forgiveness, no income-driven repayment, and no borrower protections. They will price qualified candidates out of public service careers and leave communities—especially rural and underserved areas—without the professionals they need. Your comment builds the record. It documents the harm. It shows we’re paying attention.