Key Points
- The final rule caps annual graduate borrowing at $20,500 and professional-student borrowing at $50,000, while also capping Parent PLUS loans for the first time at $20,000 per year and $65,000 per dependent.
- Two new repayment plans (the Tiered Standard plan and the Repayment Assistance Plan) replace the existing system for new borrowers starting July 1, 2026.
- The Department closed some loopholes in the final rollout of RAP that would have allowed cheaper RAP payments to capture shorter IBR loan forgiveness.
The U.S. Department of Education published its final rule implementing the student loan provisions of the Working Families Tax Cuts Act, ending Grad PLUS for new borrowers, capping Parent PLUS for the first time, narrowing the definition of “professional student”, and consolidating the federal repayment system into two plans for new borrowers.
Most provisions take effect July 1, 2026, with rehabilitation and deferment changes following on July 1, 2027, and the legacy income-contingent plans fully sunsetting on July 1, 2028.
The 647-page rule (PDF File) follows a negotiated rulemaking process that opened in late 2025 and drew more than 80,000 public comments. The Department says the package will save taxpayers $409 billion and reduce student debt by $224 billion by curbing over-borrowing.
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New Borrowing Limits Take Effect July 1, 2026
Federal student loan borrowing will operate under annual and lifetime limits for the first time across every type of loan.
Graduate students may borrow up to $20,500 per year, with a $100,000 aggregate cap. Students enrolled in qualifying professional programs may borrow up to $50,000 per year, with a $200,000 aggregate cap.
Parent PLUS borrowers face a new $20,000 annual cap and a $65,000 lifetime cap per dependent.
Most borrowers who take out a loan on or after July 1, 2026 are also subject to a $257,500 lifetime aggregate cap across all federal student loans. Parent PLUS loans are excluded from that lifetime number. Grad PLUS loans count toward it.
The Grad PLUS program itself is closed to new borrowers. An interim exception preserves access for students already enrolled in a program before July 1, 2026 who have already received a loan for that program. Those borrowers may keep the prior limits for the lesser of three years or their expected time to credential, provided they remain continuously enrolled. Withdrawing or breaking enrollment forfeits the exception.
Institutions also gain new authority to set lower loan limit caps. Schools may set loan caps below the federal limits, as long as those caps apply consistently to every student in the program. The Department also requires schools to apply a schedule of reductions for students enrolled less than full-time.
Professional vs. Graduate Student
The higher $50,000 annual cap applies only to programs that meet the rule’s stricter professional-student definition. Eleven core fields qualify automatically:
- Law (LLB or JD)
- Medicine (MD or DO)
- Pharmacy (PharmD)
- Dentistry (DDS or DMD)
- Veterinary Medicine (DVM)
- Optometry (OD)
- Podiatric Medicine (DPM, DP, or Pod.D.)
- Clinical Psychology (Psy.D.)
- Chiropractic (DC or DCM)
- Theology or Divinity (MDiv or MHL)
Other programs must satisfy a four-part test:
- Completion of academic requirements for beginning practice plus skill beyond a bachelor’s degree
- Generally doctoral-level coursework spanning at least six academic years (with at least two post-baccalaureate)
- A general professional licensure requirement
- Placement within the same four-digit Classification of Instructional Programs intermediate group as one of the eleven core fields.
The Department spent significant space in the final rule rejecting comments asking it to include physical therapy, occupational therapy, physician assistant, social work, nursing (including MSN, DNP, and nurse practitioner programs), marriage and family therapy, counseling, and art therapy.
Those programs fall under the graduate-level caps. The Department was explicit that exclusion is solely for loan-limit administration and does not reflect a judgment about program rigor or professional standing.
However, there’s already a new bill in Congress looking to expand this definition.
New Repayment Plans: RAP and Tiered Standard
For loans made on or after July 1, 2026, borrowers must choose between two plans. The Tiered Standard plan provides fixed monthly payments over 10, 15, 20, or 25 years based on balance. The minimum monthly payment is $50.
The Repayment Assistance Plan is the new income-driven option. Payments range from 1% to 10% of adjusted gross income on a sliding scale, with a $10 monthly minimum. Married borrowers’ payments are prorated by loan balance rather than calculated against combined income, addressing a longstanding complaint about IDR penalizing two-earner households.
RAP also features two benefits not available under prior plans. Unpaid interest is waived in any month the borrower’s on-time payment does not fully cover accruing interest, eliminating negative amortization. The Department also matches each on-time payment with up to $50 of additional principal reduction.
RAP grants forgiveness after 360 qualifying monthly payments (30 years) and qualifies for Public Service Loan Forgiveness.
Closed Loophole: RAP-to-IBR Strategy
While you are able to enroll in RAP, and then switch to IBR at a later time if eligible, it’s important to note that the Department clarified that payments made under RAP do not count for IBR/ICR/PAYE forgiveness.
A planning idea circulating in financial-aid circles assumed borrowers could enroll in RAP for low monthly payments, then switch to IBR later to capture IBR’s shorter 20- or 25-year loan forgiveness clock. The final rule shuts that down.
The Department amended 34 CFR § 685.209(k)(4)(i)(A) to read: “Notwithstanding paragraph (k)(4)(i)(B) of this section, making a payment under an IDR plan except the Repayment Assistance Plan or having a monthly payment obligation of $0.” In its discussion, the Department stated that “Congress was intentional about excluding payments made under the Repayment Assistance Plan to count towards IBR forgiveness.”
Translation: a borrower can switch back from RAP to IBR, but RAP months do not count toward the IBR forgiveness clock. However, time in IBR, ICR, or PAYE do count towards RAP’s forgiveness clock.
What This Means For Americans With Student Loans
Families pricing out graduate school will see real impacts immediately. A two-year MBA, MSW, or master’s program will effectively only have $41,000 in borrowing federally ($20,500 per year for the two year program). This will likely push more borrowers to private student loans.
Doctoral students in clinical psychology, dentistry, or medicine retain access to the higher $50,000-per-year track, but anyone outside the eleven core fields will need to verify their program qualifies under the four-part test before enrolling.
Parent borrowers face the biggest change. Many families who relied on Parent PLUS to cover the full cost of attendance gap will need to plan more carefully, look harder at need- and merit-based aid, or choose less expensive schools.
For current borrowers, the practical question is whether to switch from a legacy IDR plan into RAP. Some lower-income borrowers with large balances will see meaningfully lower monthly payments under RAP, especially given the principal-match feature and full unpaid-interest waiver. Higher-earning borrowers near the end of an existing 20- or 25-year IBR clock generally should not switch.
See our full RAP vs. IBR comparison for details.
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Editor: Colin Graves
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