Policy & Advocacy

H.R. 1 Title IV Rulemaking Committees

To assist the department in developing the regulations associated with the accountability provisions in the new law, the department has opened a formal process to accept nominations from interested and qualified stakeholders to serve on a committee.

Contact us.

The Department of Education has announced a Negotiated Rulemaking (Neg Reg) process to develop the required regulations related to Title IV policy provisions included in the budget reconciliation bill (Pub. L. 119-21).

The Federal Register announcement contains all relevant information about the process. The department has also created a web page to post all relevant information and resources related to the Neg Reg.

Please contact any member of AASCU’s government relations team with questions about the process to create new regulations or the topics expected to be negotiated.

IMPortant notice

The Department of Education has issued an updated announcement in the Federal Register to correct the Docket ID included in the original posting, which was found to be in error.

  • The correct Docket ID is ED–2025–OPE—0151. This ID number must be included in all communications to the department involving this specific Neg Reg. 

Virtual Hearing

In anticipation of the work to prepare for the Neg Reg and to inform the initial draft of the proposed regulations for the negotiators to discuss, the department has scheduled a virtual hearing on August 7, 2025, from 9:00 a.m. to 4:00 p.m., with a one-hour recess from noon to 1:00 p.m. to hear from the public concerning recommendations and ideas. Prior registration is required to be allotted three minutes to testify. Further information on the public hearing is available.

Committees

Two separate committees will be seated, representing different topics related to provisions included in the new law.

Reimagining and Improving Student Education (RISE) Committee

To address loan issues

Schedule for Negotiations

The RISE Committee will meet in-person in Washington, DC for two multi-day sessions on the following dates: 

  • Session 1: Sept. 29, Sept. 30, Oct. 1, Oct. 2, and Oct. 3, 2025. 
  • Session 2: Nov. 3, Nov. 4, Nov. 5, Nov. 6, and Nov. 7, 2025. 
Topics
  • Phase-out of graduate and professional PLUS Loans.
  • Establishment of new annual loan limits for graduate and professional students and parent borrowers, and implementation of new lifetime borrowing caps.
  • Simplification of student loan repayment plans into a standard repayment plan and a single income-based Repayment Assistance Plan (RAP) for new borrowers, elimination of the Income-Contingent Repayment (ICR) plan, and streamlining requirements for Income-Based Repayment plans for existing borrowers.
  • Institutional flexibility to apply lower annual limits for student and parent borrowers for selected programs of study.
  • Modifications to loan rehabilitation, including allowing defaulted borrowers to rehabilitate their loans a second time and setting minimum monthly payment amounts for such loans, phase-out of unemployment and economic hardship deferments, and limitations on a borrower’s ability to receive a general forbearance.
  • Other provisions included in Pub. L. 119-21 that are effective upon enactment, on July 1, 2026, on July 1, 2027, or on July 1, 2028.
Constituency groups  represented
  • Student loan borrowers, including borrowers in school, deferment, forbearance, delinquent, default, and currently in repayment.
  • Student loan borrowers who are veterans, U.S. military service members, or groups representing them.
  • Legal assistance organizations that represent students and borrowers, consumer advocates, and civil rights groups that represent students.
  • State officials, including state student grant agencies, state higher education executive officers, and representatives of state authorizing agencies.
  • Public institutions of higher education, including institutions eligible to receive Federal assistance under Title III and Title V of the HEA, Tribal Colleges and Universities, and Historically Black Colleges and Universities.
  • Private nonprofit institutions of higher education, including institutions eligible to receive Federal assistance under Title III and Title V of the HEA, Tribal Colleges and Universities, and Historically Black Colleges and Universities.
  • Proprietary institutions of higher education, as defined in 34 CFR 600.5.
  • Student loan servicers, collection agencies, lenders, and guaranty agencies.
  • Organizations representing taxpayers and the public interest.

Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee

To address institutional and program accountability, Pell Grants, and other issues 

Schedule for Negotiations

The AHEAD Committee will meet in-person for two multi-day sessions on the following dates:

  • Session 1: Dec. 8, Dec. 9, Dec. 10, Dec. 11, and Dec. 12, 2025.
  • Session 2: Jan. 5, Jan. 6, Jan. 7, Jan. 8, and Jan. 9, 2026.
Topics
  • Changes in institutional and programmatic accountability measures, including loss of Direct Loan eligibility for certain programs with low earnings outcomes for 2 out of 3 years, and Financial Value Transparency and Gainful Employment.
  • Establishment of program eligibility requirements for a new Workforce Pell Grant for students enrolled in programs that last a duration of 8-15 weeks, are transferable to a recognized postsecondary credential or degree, are approved by the state governor, and have strong outcomes.
  • Exclusion of Pell Grant assistance for students who receive grant or scholarship aid covering their entire cost of attendance or for students with a Student Aid Index in excess of twice the maximum Pell Grant award.
  • Other provisions included in Pub. L. 119-21 that are effective upon enactment, on July 1, 2026, on July 1, 2027, or on July 1, 2028.
Constituency groups represented
  • Students who are currently enrolled and receiving assistance from the Title IV, HEA programs.
  • Students who are veterans, U.S. military service members or groups representing them.
  • Employers and groups representing the business community, including small, medium, and large businesses.
  • Legal assistance organizations that represent students, consumer advocates, and civil rights groups that represent students.
  • Public institutions of higher education, including institutions eligible to receive Federal assistance under Title III and Title V of the HEA, Tribal Colleges and Universities, and Historically Black Colleges and Universities.
  • Private nonprofit institutions of higher education including institutions eligible to receive Federal assistance under Title III and Title V of the HEA, Tribal Colleges and Universities, and Historically Black Colleges and Universities.
  • Proprietary institutions of higher education, as defined in 34 CFR 600.5.
  • State workforce agencies and workforce development boards.
  • State grant agencies, and other state and non-profit higher education financing organizations.
  • State higher education executive officers, State authorizing agencies, and other State regulators.
  • Accrediting agencies recognized by the Secretary of Education.
  • Organizations representing taxpayers and the public interest

Nominations Process

Any person or institution interested in nominating a negotiator needs to submit a letter to the Department of Education by August 25, 2025, to the following addresses:

The letter must include the following information:

  1. The name of the nominee.
  2. The name of the constituency (or constituencies) for which the nominee is being nominated (see Constituency Groups for Negotiator Nominations in the announcement).
  3. The nominee’s place of employment or institution at which they are or were enrolled and, if different, the organization the nominee represents.
  4. A resume or evidence of the nominee’s expertise and experience in the topics proposed for negotiations.
  5. The nominee’s contact information, including email address, telephone number, and mailing address; and
  6. Committee nominated to—the RISE Committee or the AHEAD Committee.
  7. IMPORTANT NOTICE: The Department of Education has issued an updated announcement in the Federal Register to correct the Docket ID included in the original posting, which was found to be in error. The correct Docket ID is ED–2025–OPE—0151. This ID number must be included in all communications to the department involving this specific Neg Reg. 

Anyone wishing to nominate the same person for both committees must submit two nominations, one to each corresponding email address.

A Primer on Neg Reg

Negotiated rulemaking is a process where a federal agency brings together representatives of diverse interest groups and agency staff to negotiate the text of a proposed rule. The goal is to reach a consensus on the rule’s content, which the agency then uses as the basis for a proposed rule. This approach, also known as “reg-neg,” can be particularly useful when dealing with complex issues involving multiple stakeholders.

Participants

Representatives from various affected interest groups (e.g., industry, public interest groups, government agencies) and the agency developing the rule.

Process

The committee, facilitated by a neutral third party, works to build consensus on the rule’s content through structured discussions and negotiations.

Goal

To reach a consensus on the rule text, which the agency then uses as the basis for a proposed rule.

Outcomes

Negotiated rulemaking can lead to increased compliance, reduced litigation, and better-informed rules due to the involvement of stakeholders in the process.

The Department of Education’s Office of Federal Student Aid has additional information about Neg Reg.

Want to know more about these committees? Let us know.

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Joint Associations Group on Indirect Costs

AASCU has joined several national organizations and renowned experts to identify a new, clearer, and transparent process for determining federal indirect cost rates associated with federal grants and programs.

Developing a streamlined process to calculate cost structure.

AASCU has joined several national organizations and renowned experts in the Joint Associations Group (JAG) on Indirect Costs to identify a new, clearer, and transparent process for determining federal indirect cost rates associated with federal grants and programs. The goal of the effort is to find and share with Congress and the Trump Administration a more efficient process for determining facilities and administrative (F&A) cost structure while streamlining federal regulatory burdens.

FAQ on JAG effort and FAIR model.
Overview

The federal government uses the F&A structure to fund the indirect expenses that universities and other research organizations incur when conducting federally funded research. The JAG had previously solicited feedback on the provisional models it had developed. Based on this feedback, it has synthesized a final model to present to policymakers.

One of the proposals would set rates for indirect costs based on just two factors: the institution type and the type of research funded by the grant. The other would treat indirect costs as direct, breaking down the indirect costs as line items for each individual grant, with an additional fixed percentage for “general research operations” not easily assigned to a project.

The NIH (National Institutes of Health) had previously implemented a policy that caps indirect cost rates for research grants at 15%. This means that, regardless of an institution’s previously negotiated indirect cost rate, NIH grants will now only cover a maximum of 15% of direct costs for facilities and administrative expenses.  The agency’s one-sided plan would result in a cut of billions of research support dollars for colleges and universities.

This change, already copied by the Department of Energy and the National Science Foundation, has sparked controversy and legal challenges from universities and research institutions concerned about the impact on their research funding and operations. A U.S. District Judge in Massachusetts has ruled that the NIH had violated federal statute in a way that was “arbitrary and capricious” in creating the cap, failed to follow rulemaking procedures when doing so, and violated constitutional prohibitions on applying new rules retroactively.

JAG Members

  • American Association of State Colleges and Universities (AASCU)
  • American Council on Education (ACE)
  • Association of American Universities (AAU)
  • Association of American Medical Colleges (AAMC)
  • Association of Independent Research Institutes (AIRI)
  • Association of Public and Land-grant Universities (APLU)
  • Council on Governmental Relations (COGR)
  • National Association of College and University Business Officers (NACUBO)
  • National Association of Independent Colleges and Universities (NAICU)
  • Science Philanthropy Alliance (SPA)

JAG Information Links

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Want to know more about AASCU’s role in the JAG? Let us know.

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