Washington Update

RISE Negotiated Rulemaking Committee Convenes This Week 
The Reimagining and Improving Student Education (RISE) negotiated rulemaking committee is convening this week for its second and final meeting. The committee, whose work focuses on the student loan provisions of the One Big Beautiful Bill Act, met during the week of September 29. Though the materials have begun circulating, the U.S. Department of Education (ED) has not made available discussion drafts for this week’s session due to the government shutdown. 

In the first session, the committee spent significant time discussing how to delineate between graduate and professional programs, which are eligible for different annual and aggregate loan limits under the law. The intention of ED was to retain the narrow definition of professional programs as found in current regulation. Prorating new loan limits for students enrolled less than full time is also a discussion point this week, among other topics.   

APLU is closely tracking the progression of the committee. Typically, under the Department’s “master calendar,” a rule must be published by November 1 in order to be effective July 1 of the following year. ED appears unlikely to meet this deadline as publication of a final rule is expected to come in the spring.  

APLU understands the challenges institutions will face in receiving loan limits for the coming academic year only months in advance. As a final rule is promulgated, APLU will seek detailed impact statements from institutions to inform our actions on timelines. 

U.S. Department of Education Publishes Final Rule on PSLF 
On Friday, October 31, the U.S. Department of Education (ED) published its final regulations on Public Service Loan Forgiveness (PSLF), which adds and clarifies provisions to limit employer eligibility based on their engagement in “unlawful activities.” The final regulations clarify provisions to “exclude employers that engage in specific enumerated illegal activities such that they have a substantial illegal purpose, including defining obligations and processes tied to making such a determination of an employer, clarifying that borrowers will receive full credit for work performed, until the effective date of the Secretary’s determination that an employer is no longer a qualifying employer under the rule; and establishing methods for an employer to regain eligibility following a determination of ineligibility by the Secretary.” 
 
The regulations were promulgated in response to a March 7 Executive Order, Restoring Public Service Loan Forgiveness, which directed the U.S. Department of Education to change PSLF criteria to prevent using federal funds to subsidize illegal activities and to ensure the definition of “public service” excludes “organizations that engage in activities that have a substantial illegal purpose.” 

APLU Joins Community Letter on $100,000 H-1B Fee 
APLU joined more than 30 higher education organizations in a letter seeking an exemption for higher education institutions from the new $100,000 H-1B fee. The letter details outstanding questions regarding the fee’s implementation, including how USCIS will process the fee and if it will be refunded if the petition is denied. The letter also seeks clarification on how exemptions will be determined and confirmation that change of status petitions are not subject to the fee.  

The letter was transmitted after USCIS published detailed guidance on the fee. The guidance suggests visa holders transitioning from active F-1 to H-1B visas are not subject to the fee, and that exemptions to the fee will be made on an individual basis. APLU seeks clarification on these points, and others, in the letter.  

APLU Submits Comments on H-1B Lottery 
In mid-October, APLU submitted comments on the Trump administration’s proposed H-1B lottery rule. The comments focus on the rule’s impact on recent graduates, a welcoming environment for prospective international students, and impacts on public research universities.  

The proposed rule implements a weighted lottery system for H-1B visas that prioritizes higher paid petitioners. While the rule does not apply to cap-exempt entities like public research universities as employers, it would have substantial impact on graduates of APLU member institutions. 
 
APLU also joined ACE and 20 associations in submitting community comments on the proposed rule, as well as a multi-sector letter featuring education, industry, and legal associations. Additionally, Compete America, an industry-higher education coalition of which APLU is a member, submitted comments.

APLU Responds to Senate HELP RFI 
In October, APLU responded to the Senate HELP Committee’s request for information on increasing college cost and value transparency. The RFI asks 12 questions on price transparency, value transparency, financial aid offers, and informed borrowers. APLU’s comment provides four key recommendations for how the committee can advance our mutual goals of increasing cost and value transparency: 

•  Consider data available to institutions at various stages of the admissions process when calculating prices for students and families
• Pass the College Transparency Act (S. 2511/H.R. 4806) to fix flaws in existing federal outcomes data 
• Support a system that allows states and institutions to develop their own financial aid communications 
• Avoid a one-size-fits-all approach to informing borrowers 

APLU Joins Community Letter on VA NPRM on State Approving Agency Jurisdiction 
Last week, APLU joined in submitting higher education community comments on a U.S. Department of Veterans’ Affairs (VA) proposed rule that would expand GI Bill access to unaccredited online, non-college degree programs and the scope of programs under State Approval Agency jurisdiction. The proposed rule amends the definitions of distance learning and independent study in ways that do not align with the Department of Education’s definitions and frames other definitions without differentiating between teaching modalities and curriculum.  
 
The letter recommends the VA withdraw the proposed rule and instead work with Congress in partnership with the higher education community to modernize definitions while preserving program guardrails.  

Golden Goose Award Seeks Nominations 
The Golden Goose Award is accepting nominations for the 2025 award cycle through Friday, December 12, 2025. The award celebrates silly-sounding or serendipitous research that has led to significant societal impact. It is intended to demonstrate that scientific outcomes build upon each other and celebrate projects that contributed to scientific advances which could not have easily been predicted at the outset of the research project. 

This year’s awardees were honored at the Library of Congress for their NIH- and NSF-funded research that led to improved disease diagnostics techniques and insights on aging, and a testicular cancer drug that increased survival rates from 10% to 90%.  

APLU encourages members to share this opportunity with those on campus who may wish to nominate colleagues.